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MANAGING BEST PRACTICES: OSHA compliance alone doesn't cut it

July 8, 2009
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Figure 1: Containers – Flammable Materials

If you really want to control injuries and illness, you must persuade management to implement a health and safety management system and integrate the health and safety management system into other business objectives such as quality. Injury and illness prevention cannot be simply an OSHA compliance issue or be accomplished by varied standalone tasks.

For example, how do you ensure that the bonding and grounding straps in Figure 1 (below) remain properly attached? If you don’t do it right, it’s an OSHA violation because a static spark may occur and cause a fire, explosion or other problem.

I asked a plant manager this question many years ago and his response was typical of someone who did not see the big picture of safety. He felt that all that was necessary was to ensure that employees working in the area knew that the straps must remain properly affixed.

The answer seems simple enough; management set the objective. If the objective is not met, it’s mostly a behavioral safety issue. If a bonding/grounding strap is not attached, it’s the employee’s fault. Is this correct, or is there more that must be considered?

Diagram 1 – Example: H&S Management System

The big picture

To solve the problem of potentially missing/broken bonding/ground strap in Figure 1, all of the activities in Diagram 1 (below), and possibly more, must be active.

Consider some of the points in the diagram. Employees may know they have some obligation to keep bonding and grounding straps properly attached; but what if the strap is broken? Who reports that the strap is broken?

Who gets a new strap? What if budget is tight and a proper strap is hard to obtain?

Who installs the new strap? How do we know the new strap was installed properly? How soon does a new strap have to be installed? Do we stop work without the strap? And how important is it that the bonding/ grounding straps remain affixed?

Management system

Diagram 1 show some of the elements found in every health and safety management system including OSHA VPP, OHSAS 18001, ILO-OSH, and ANSI/ AIHA Z10. The diagram contains the key concepts of: 1) management leadership and employee involvement; 2) planning; 3) implementation and operation; 4) checking and corrective action; and 5) management review. These key concepts are represented in a continual improvement cycle based on the quality concept of “Plan-Do-Check-Act.”

Diagram 2 – Example of Gears in an Integrated Management System

Integrated systems

As business becomes more globally competitive, management must continually consider new or improved best practices to stay viable. Diagram 2 (below) shows how best practices in the form of consensus standards or management specifications may mesh together in an integrated mechanism where one program or system helps to drive and support another system. As good as they are, stand-alone systems, such as ANSI Z10, may not be enough today.

More gears?

Diagram 2 may contain more gears, depending on need. For example, ANSI/ ASSE Z490.1-2009 “Criteria for Accepted Practices in Safety, Health, and Environmental Training” was issued as a final standard in May 2009. To improve the mechanism, ANSI Z490.1 may need to engage with the other systems. And if management really doesn’t understand what your job does, installing and engaging the gear ANSI/ASSE Z590.2 “Criteria for Establishing the Scope and Functions of the Professional Safety Position” may be warranted.

Lead gear

Regardless of what gears mesh into an integrated system, it now seems prudent to have ISO 31000 “Risk Management — Principles and Guidelines on Implementation” as the lead gear, particularly where health and safety concerns are present. Here’s why: Handling nanomaterials, exposure to the H1N1 flu virus, developmental health risks, electromagnetic energies, and mental stress are examples where OSHA compliance is absent or inadequate. A health and safety management system could overlook new and emerging risks and ISO 31000 would help bring these risks into consideration.

The bigger picture

You need to help management see the big picture of safety — almost every safety or health hazard can be placed into the middle of Diagram 1 and the surrounding elements are necessary to fully resolve the concern. Help management appreciate the bigger picture why all necessary gears in the overall management mechanism need to mesh together to achieve health and safety as well as other business objectives.

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Recent Articles by Dan Markiewicz, MS, CIH, CSP, CHMM

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