Continuous Improvement and Compliance

Week 10 – Continuous Improvement and Compliance

Overview of Topics and Concepts

Traditional safety and health programs tend to be compliance driven, reactive, and focus on injuries and illnesses after they occurred. These programs tend to be reactive with polices based on what has happened in the past rather than looking ahead, proactively to prevent workplace injuries and illnesses.

Over the past ten weeks, we examined the core elements needed for establishing an effective occupational safety and health management practices in within your organization. These OSHA recommended practices acknowledge that finding and fixing hazards before an injury or illness occurs is a more effective approach. We also examined performance-oriented standards such as the ANSI/AIHA/ASSE Z10 guidelines.

Regardless of the method selected, a company needs to select a method that employs a continuous improvement strategy. Continuous improvement by design requires a company to constantly examine its practices and make improvements as needed. The occupational safety and health approach must have provisions to continuously evaluate and examine how effectively the system is functioning. Furthermore, developing solutions for improvement is essential.

Unfortunately, when there is no one-size fits all strategy. The key component is adopting an approach that assures integrating occupational safety and health policies and practices within the existing organizational structure.

Required Readings

  • OSHA. n.d. “Program Evaluation and Improvement.” OSHA Recommended Safety and Health Programs. https://www.osha.gov/shpguidelines/program-evaluation.html
    • This OSHA Webpage provides information on the methods to monitor progress and performance of a health and safety program.
  • OSHA. n.d. “Safety and Health Management Systems: A Road Map for Hospitals.” Accessed May 27, 2018. https://www.ors.od.nih.gov/sr/dohs/Documents/DLib_2.4_SHMS_roadmap_508.pdf
    • Provides information, guidance, and best practice examples of healthcare organizations employing continuous improvement practices as part of their occupational safety and health process.
  • Haight, J. Patrick Yorio, Kristen Rost, and Dana Willmer. 2014. “Safety Management Systems: Comparing Content & Impact.” Professional Safety 59, no. 5 (2014): 44-51.
    • The authors discuss occupational safety and health systems and the challenges to implementing the process.

Recommended Readings

  • Chapter 17, Guiding Light: OSHA Compliance

Chapter 18, Golden Rules: OSHA Regulations

Chapter 20, All around Workplace – Environmental Issues (Reese 2016)

  • These three chapters cover the regulatory and compliance issues for environmental safety issues.
  • ASSE Tech Brief. 2012. “ANSI Z10-2012 Now Available” American Society of Safety Engineers. https://letstalksafety.files.wordpress.com/2012/09/z10_tech_brief_2012_revised.pdf
    • This tech brief provides an introduction to the revised ANSI Z10 standard including a brief summary and review of the key provisions and changes to the guideline.
  • BSI Group. 2016. “Making the migration from BS OHSAS 18001 to ISO/DIS 45001” February 9, 2016. YouTube Video. 4:21.
    • This video provides a brief overview of the ISO 45001 guidelines including a comparison between OHSAS 18001 current guidelines.
  • Manuele, F. 2014. “ANSI / AIHA / ASSE An Overview of the Occupational Health& Safety Management Systems Standard.” Professional Safety. https://aeasseincludes.assp.org//professionalsafety/pastissues/059/04/F3_Manuele_0414.pdf
    • Manuele provides an up-to-date overview of the revised ANSI/AIHA/ASSE Z10 guidelines and latest revisions.
  • McNair, S. n.d. “Eight common misperceptions of management of change.” Reliable Planet. Accessed May 27, 2018. http://www.reliableplant.com/Read/25905/misperceptions-management-change.
    • The author focuses on common misconceptions about management of change.
  • Robson, L., Harry S. Shannon, Linda M. Goldenhar, and Andrew R. Hale. 2001. “Guide to Evaluating the Effectiveness of Strategies for Preventing Work Injuries: How to Show Whether a Safety Intervention Really Works.” USDHHS-CDC-NIOSH. https://www.cdc.gov/niosh/docs/2001-119/pdfs/2001-119.pdf
    • The stated purpose of this document is “to provide researchers and students with the tools and concepts required to conduct systematic evaluations of injury prevention initiatives and safety programs.”
  • EPA. n.d. “Risk Management Plan (RMP) Policies and Fact Sheets”. https://www.epa.gov/rmp/risk-management-plan-rmp-policies-and-fact-sheets
    • Occupational Safety and Health Management System Approaches
      • A brief explanation of the various occupational safety and health approaches that employ the specification and performance practices follows.
    • Occupational Safety and Health Administration (OSHA)
      • OSHA has adopted a systems approach to identify and evaluate hazardous operations for those companies that produce highly hazardous chemicals. These requirements are detailed in the Process Safety Management Standard, codified at 29 CFR1910.119. The USEPA also has requirements for these types of chemical manufacturers and users, this information can be found in the EPA Risk Rule.
  • OSHA. n.d. Health and Safety Program. Accessed July 13, 2018. https://www.osha.gov/dcsp/compliance_assistance/sampleprograms.html
    • OSHA Construction standard requirements contained in Subpart C of the 1926 regulations also required that an employer develop a health and safety program.
  • OSHA. n.d. General Industry Safety Orders. Accessed July 13, 2018. https://www.dir.ca.gov/title8/3203.html
    • Although it is not OSHA mandate yet (stay tuned to OSHA’s pursuit of the proposed IIPP standard and the possibility of its adoption), it still can be used to meet compliance requirements for state OSHA programs such as the Cal/OSHA IIPP standard.
  • OSHA. n.d. Voluntary Protection Program (VPP). Accessed July 13, 2018. https://www.osha.gov/dcsp/opr/index.html
    • OSHA’s Voluntary Protection Program (VPP)
      • VPP was created as a means to create a safe workplace that complies with OSHA, and acknowledges companies who adopt and implement the program. The near-term goal may be only meeting compliance and gaining a good working relationship with OSHA to avoid routine inspections. But the long-term goal may be for those companies or entities that achieve STAR status not only for the associated prestige, but an actual reduction in workplace injury and illness, and obviously any fatalities, but an overall performance improvement in the health and safety program that contributes to the company’s bottom line. Although more of a series of programs based on OSHA implementing standards, it does have a continual improvement step where once certified as a STAR status site (assuming the organization has surpassed the MERIT ranking/designation) through the audit process, it requires an annual review and report to the Regional VPP office, followed by initial recertification on the third year, and then every 5 years after assuming all continues to go well in the program or the organization wishes to maintain it.
  • Manuele, F. 2014. “ANSI / AIHA / ASSE An Overview of the Occupational Health& Safety Management Systems Standard.” Professional Safety. https://aeasseincludes.assp.org//professionalsafety/pastissues/059/04/F3_Manuele_0414.pdf.
    • The ANSI Z10, Occupational Health and Safety Management System (OHSMS) standard is the result of many hours and input from many dedicated health, safety, and environmental professionals. First published in 2005, and recently revised in 2012 by the as the American Industrial Hygiene Association (AIHA) as the Secretariat, the committee is comprised of stakeholders from industry, government, education, labor, interested parties, and numerous professional organizations. The result is a consensus based OHMS standard that follows recognized management systems principles of the Plan-Do-Check-Act model that is compatible with ISO 9001 (quality) and ISO 14001 (environmental) standards. As well, Z10 draws from the approaches described in the International Labor Organization (ILO) – OSH 2001 and the OHSAS 18001. Conforming to the Z10 implementation model (or a benchmark) provide those interested individuals/companies to develop or improve upon their existing programs, and as an effective tool for an organization to minimize workplace risks thus reducing the occurrence and cost of workplace injuries and illnesses, and ultimately continual improvement of the overall health and safety program performance.
    • While many global organizations use international standards as their benchmark guidelines, other companies opt to use U.S. ANSI/AIHA Z10 standards. These standards were developed to provide an integral approach to other management systems while providing a flexible platform that can be adapted to the organization’s needs (Manuele 2014). Manuele provides details on the in his article published in Professional Safety, ANSI/AIHA/ASSE Z10-2012 an overview of the occupational health & safety management systems standard. Links to this article are noted in the required reading section.
    • The ANSI Z10 “focuses primarily on the strategic levels of policy and the processes to ensure the policy is effectively carried out. The standard does not provide detailed procedures, job instructions or documentation mechanisms. Each organization must design these according to their needs.” With this statement in mind, this is why the Z10 model is desirable for an organization in the near term to initiate a management system approach to health and safety and taking gradient steps toward continual improvement. For the long term, strategically, it can lead an organization to more sophisticated health and safety program initiatives, and integrate the model with the quality and environmental systems. By doing this, an organization that also has an ISO 9001, ISO 14001, or OHSAS 18001 certification requirement can do so. As an example, think in terms of Bubbly Brews Beverage, a budding brewery, that may in its 5-year strategic plan want to export or license their products globally, thus the need for at least a conforming integrated management system approach if not the required certifications or registrations. ANSI Z10 does not have an accreditation organization that audits conformity to the system.
  • BSI Group. 2016. “Making the migration from BS OHSAS 18001 to ISO/DIS 45001” February 9, 2016. YouTube Video. 4:21. https://www.youtube.com/watch?v=F40Hu4kN54c
    • OHSAS 18001
      • OHSAS 18001 originated from the British Standards Institute (BSI) 8800:1996 Guide to Occupational Health and Safety Management Systems. According to the BSI, its basis is to “assist organizations in managing and controlling their health and safety risks and improving their OH&S performance.”  The OHSMS is based on the Plan-Do-Check-Act model to consistently and accurately, identify the associated risk and causal factors associated with injury and illnesses.
      • Once the risks are identified, the process develops, implements, and improves upon tools and processes to prevent occurrence or recurrence. When you dig into this OHSMS you will find it very prescriptive and analytical in its approach, which you would expect considering the U.K. Health and Safety Executive regulates health and safety by applying the OHSAS 18001 approach to manage the risks associated with an organization’s operation. Because of its approach and platform, as a near term goal this may be a good management system model to implement for an organization whose operations pose a high degree of risk, or have experienced severe injuries/illnesses or even fatalities, and want to take a more analytical approach toward preventing occurrence and recurrence of injuries, illnesses or fatalities. As a long-term goal, and possibly even a requirement as a supplier of goods or services globally, is to obtain OHSAS 18001 registration but for, “achieving sound health and safety performance, often while delivering cost savings and demonstrating Good Stewardship and Good Corporate Citizenship.” Green (2014) explains how the OHSAS regulation was designed as a fill a gap as there was not International standard. The BSI group provides a brief video offering that discusses the migration process.
      • As noted, the OHSAS is in the process of being phased out and its principals and focus are absorbed into the new ISO standard, ISO 45001, Occupational Health and Safety Management System.  Published in late 2017, this new guideline creates a worldwide standard for occupational safety and health management systems.
      • Throughout this course we have touched on the common aspects and processes of three OHSMS, primarily ANSI Z10, and the OSHA VPP, with some exposure to the OHSAS 18001 and PSM. The decision to use one OHSMS over will be unique to each organization’s needs. Although culture and employee empowerment play key roles in the process another consideration can be based on the company’s near and long-term goals for advancing the health and safety program and integrating it into the company’s operations.
  • Neubauer, T. 2017. Accessed July 13, 2018. http://www.isem.org.pe/portal/files/evento/sem-seg/2017/03/29/TIM-Neubauer.pdf
    • Neubauer 2017 provides an excellent summary of the 9 components common to several occupational safety and health approaches examined in this classroom. Neubauer suggest that there are three main components of safety systems approach, breaking it down into an administrative, operational and behavioral perspectives. These components can be broken down further into management commitment, employee involvement, commutation, adjusts and the need for continuous improvement.
    • Make sure to check out the detailed comparison charts provided in this presentation as it offers a quick overview of perceived strengths of each program.

Week 10 Discussion –OSHMS Models

Throughout the term we have discussed key components that form the foundation of an occupational safety and health management approach. Based on review of the OHSMS models examined, what would be a logical entrée into the management system world for Bubbly Brew?

Before responding, consider not only the initial near-term goal, but also the long-term goal for adopting a management system(s) and answer these questions in your post:

  1. What would be the three main drivers for selecting one particular OHSMS over the two others mentioned?
  2. Which OHSMS would be the least desirable, effective, or needed and why?
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