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The DIRECTIVES and STANDARDS listed here may have been subsequently REVISED . You must refer to the CURRENT REVISION and AMENDMENTS if any.

Tuesday, March 31, 2009

OHSAS Expert

What is Hierarchy of Controls?

March 23, 2009

I recently had the following question e-mailed to me – “What is the “Hierarchy of Controls” [referenced in section 4.3.1 of OHSAS 18001:2007] and how do I address it in the hazard control & risk assessment procedure?”
 
The “hierarchy of controls” is a protocol that you use when deciding what kind of control measures you are going to use to address a particular OH&S hazard.  The rationale underlying the “hierarchy of controls” is that an organization should use more reliable control measures rather than measures that are more likely to fail. 

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A NEW blog about Management Systems

March 11, 2009

I am pleased to announce that ENLAR has launched a new blog -www.managementsystemexpert.com. 

The purpose of this blog is to provide real-world practical advice to assist you in establishing, documenting, implementing and maintaining an integrated management system.

This website provides information and resources to help you understand the requirements of the various management system standards - ISO 9001, ISO 14001, OHSAS 18001, etc.  In addition, it provides an opportunity for you to post your questions and comments on a variety of management system topics.

An integral part of this blog is the monthly FREE teleseminar that ENLAR will be hosting.  These monthly ”conversations with experts” will provide a unique opportunity for you to BOTH listen to experts on a variety of management system topics AND ask questions for them to answer in their calls.

Click here to check out this new blog.  While you are there, check out the upcoming teleseminars on -

  • Revision of ISO 19011 - The Challenge of Drafting a Generic Auditing Standard
  • Five Steps for Achieving Employee Engagement

 Thanks!  I hope you like this new site.

© ENLAR® Compliance Services, Inc. (2009)

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Thinking Outside the Bus…No, I Mean Box

March 5, 2009

One of the requirements of OHSAS 18001 is to identify all of your workplace hazards, including those that may cause “ill health”.  This includes illnesses that are made worse by a work activity.  This analysis also needs to be extended to individuals beyond the borders of the traditional workplace. 

ABC News reported on just such a situation last night.  It included a segment on the health implications of driving a school bus and the steps Broward County, Florida has taken to address them.

What did the Broward County School Board do? Read the rest of this entry »

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What are you going to STOP doing?

February 25, 2009

Many OHS management systems and programs have a major problem – they are bloated with paperwork, inefficient in their operation and filled with busywork.  These programs are often focused on the achievement of arbitrary metrics rather than improved OH&S performance. As a result, the managers of these programs are often fed-up, burned out and overwhelmed.  They are also increasingly being told – “Given the current economy, you need to do more with less.”

That is the wrong message and the wrong goal. 

To quote Peter Drucker – “There is nothing so useless as doing efficiently what should not be done at all.” 

The goal should not be to do more with less – it should be to do less.

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Developing an OHSMS Risk Management Strategy

November 6, 2008

In a previous post, I discussed that there is no single, fill-in-the-blank, process for conducting an OHS hazard identification and risk assessment.  Instead, what is needed is an assembly of individual processes that, when taken together, result in a comprehensive OHSMS risk management strategy. 

It is equivalent to assembling a meal from an a la carte menu.

So what are your a la carte choices?

They are numerous and varied and include –

  • Checklists and questionnaires
  • Consequence / likelihood matrices
  • Failure modes and effects analysis (FMEA)
  • Hazard and operability studies (HAZOP)
  • Exposure assessment strategies
  • Bayesian analysis
  • Ergonomic evaluations
  • Computer modeling programs

Just as the key to healthy eating is making wise menu choices, the key to a sound OH&S risk management strategy is choosing the hazard identification and risk assessment tools that are appropriate for your organization.

© ENLAR® Compliance Services, Inc. (2008)

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“It’s The System, Stupid.”

October 8, 2008

What does the current meltdown of the global financial markets teach us?

To paraphrase a line from the last presidential election - “It’s the System, Stupid.”

Right now, there is a lot of finger-pointing and plenty of blame to spread around.  This mess is not, however, the fault of a single individual, a single institution or, even, a single political party.  Instead, it is the system that is flawed. 

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ANAB Seeks Comments on OHSMS Accreditation Rule

August 29, 2008

The ANSI-ASQ National Accreditation Board (ANAB) is seeking public comment on its Draft Accreditation Rule A on OHSMS Program.  ANAB is the U.S. accreditation body for a number of different management system standards, including ISO 9001, ISO 14001 and ANSI/AIHA Z10.  ANAB has posted a link on its web site (under Public Ballots) that provides access to this draft rule.

This draft accreditation rule sets out the requirements for certification bodies to obtain accreditation to their choice of -

  • ANSI/AIHA Z10, Occupational Health and Safety Management Systems (the US standard)
  • CSA Z1000, Occupational health and safety management (the Canadian standard)
  • BS OHSAS 18001, Occupational health and safety management systems – Requirements(the British standard, which is identical to the international OHSAS 18001:2007 standard)

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OH&S Risk Assessment is NOT a Single Process

August 29, 2008

One of the requests I commonly get from organizations seeking to integrate occupational health and safety into an existing environmental management system is –

“Can you provide a generic risk assessment process I can just plug into my aspect/impact procedure?”

The short answer to this request is “No.”

This is the fundamental difference between the OHSAS 18001 and the ISO 14001 standards.  To conform to ISO 14001, many organizations have a single aspect/impact evaluation process.  It may be complex and involve several factors and complicated calculations but it is typically one process.  This is not the case for OHSAS 18001 hazard identification and risk assessment.

To quote from the OHSAS 18002 guidance –

Hazard identification and risk assessment methodologies vary greatly across industries, ranging from simple assessment to complex quantitative analyses with extensive documentation.  Individual hazards may require that different methods be used, e.g. an assessment of long term exposure to chemicals may need a different method than that taken for equipment safety or for assessing an office workstation.  Each organization should choose approaches that are appropriate to its scope, nature and size, and which meet its needs in terms of detail, complexity, time, cost and availability of reliable data.  Taken together, the chosen approaches should result in a comprehensive methodology for the ongoing evaluation of the organization’s risk.

In other words – there is no simplistic answer or cookie-cutter methodology.  It is not one process but several that, when taken together, make up a comprehensive risk management strategy.

© ENLAR® Compliance Services, Inc. (2008)

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What is Competency? The Answer Seems Subject To Change.

August 25, 2008

In a previous blog, I discussed the difference between competency and awareness in an occupational health and safety management system (OHSMS).  In that blog, I used the ISO 9000:2000 definition of competence as “demonstrated ability to apply knowledge and skills” since OHSAS 18001:2007 does not include a definition. 

It seems that the appropriate definition of competence is now subject of some debate within ISO and may be subject to being “re-defined.”

Competency is a significant component of at least four standards currently under development within ISO –

  • ISO 10018 – Quality management: Guidelines on people involvement and competencies
  • ISO 14066 – Greenhouse Gases – Competency requirements for greenhouse gas validators and verifiers
  • ISO 17021 Part B – Conformity assessment – Requirements for third-party certification auditing of management systems
  • ISO 19011 (revision) – Guidelines for management system auditing

Interestingly, each of these standards has apparently rejected the dictionary definition, as well as the ISO 9000 definition, and each ISO Technical Committee appears to be in the process of developing its own concept of competence. 

ISO 10018 is apparently focusing on how “human factors” impact the effective functioning of management systems with the definition of competency being passed to a subcommittee.  ISO 14066 is structured to set out detailed lists of the skills and knowledge that must be possessed by GHG verification and validation teams – with the focus on team rather than individual competency.  The initial committee draft of ISO 17021 defined competence as “personal attributes and ability to apply knowledge and skills” with a heavy focus on personal attributes and generic audit skills but essentially no guidance as to the needed discipline-specific knowledge (e.g. quality, environmental, OH&S).  The revision of ISO 19011 has just begun; however, the issue of auditor competency has already been identified as one of the “hot-button issues” associated with revision of this standard.

A review of the various standards and other reference materials appear to set out three different, and distinct, attributes that underlie competency:

  • Attitude and personality traits –who you are
  • Knowledge – what you know
  • Skills – what you can do

Where the ISO standards seem to diverge is in the relative importance to be given to each attribute (personality vs. knowledge vs. skill) as well as in the specifics of what is actually required and how it should be demonstrated.

What do you think?  What is competency?

© ENLAR® Compliance Services, Inc. (2008)

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“Data Sprawl” - Not Just an IT Problem

July 21, 2008

An article in the 6/30/2008 issue of CRN Magazine reported on the problem of “sprawl proliferation” associated with the use of virtualization in IT datacenters. Because virtual machines are easy to deploy, they don’t get the same scrutiny as the purchase of physical machines. The result – virtual machines that are not doing any meaningful work and thousands of dollars of assets locked away in computer redundancy.

“Data sprawl” is also a significant concern for OH&S management systems. Read the rest of this entry »

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