Maybe you missed it, but on September 1 a "very significant event in the history of safety and health management" took place, in the words of a corporate vice president of safety.
Thatâ€™s the day "American National Standard â€“ Occupational Health and Safety Management Systems" was released for public comments. The 62-page document is the closest U.S. employers may ever come to receiving a set of requirements â€“ a blueprint â€“ for how to run a workplace safety and health program.
In this issue of ISHNâ€™s e-newsletter, we take a close look at the standard that could become the benchmark for U.S. industry. After all, OSHA has shied away from setting a safety and health program standard for 35 years, and shows no inclination to do so now.
YOU WONâ€™T BE FORCED
First, you can stop worrying. Thereâ€™s nothing that will force you to comply with this standard. A committee of the American National Standards Institute (the ANSI Z10 committee) drafted the requirements and recommendations â€“ and they are strictly voluntary.
Plus, the standard at this point is a proposal, not a final product. Public comments are being accepted until October 15. You can obtain a copy of the Z10 proposal by visiting www.aiha.org. AIHA â€“ the American Industrial Hygiene Association â€“ has shepherded the standards-setting work since it began in 1999, serving as the secretariat, organizing committee meetings, posting minutes, and providing resources.
Hereâ€™s the real value of the Z10 standard: requirements have been written by some of the sharpest thinkers in occupational safety and health from business, labor, trade groups, professional societies and government agencies. You can tap their experience and use the standard right now, in its proposed form, to see how your safety and health program measures up.
Keep in mind compliance with the Z10 standard doesnâ€™t guarantee success. But what the standard does is lend any safety and health program an organized structure. Many workplace programs are a patchwork quilt of efforts unrelated to each other â€“ hazard communication, lockout-tagout, machine guarding, etc. ANSI Z10 requirements tie together all the loose ends.
GRADE YOUR PROGRAM
Hereâ€™s how to use the ANSI Z10 standard as a checklist to grade your own safety and health program.
Use this grading system:
Give your program a grade for each of the following building blocks of a safety and health program described in the ANSI standard. To do this you must download the PDF of the standard. Read the requirements and recommendations for each category and compare to your program.
TO THE POINT
For each program element listed above, the ANSI Z10 standard requirements are briefly worded and very flexible.
For example, requirements for employee participation take no position â€“ for or against â€“ the use of safety committees, safety incentives, discipline or drug testing.
As far as employee participation goes, the standard simply states: Employees and employee representatives shall be provided with the time, resources and mechanisms to partake in safety and health program planning, implementation, evaluations and preventive and corrective actions.
The standard goes on to state that employees shall be provided with timely access to relevant safety and health information. And they shall be encouraged to identify and remove barriers that get in the way of their participation. Examples of obstacles include lack of response to employee suggestions, reprisals by supervisors or other forms of discrimination.
How all of this is done is left up to you.
The ANSI Z10 standard does offer more detailed recommendations for how to carry out its flexible requirements, but they are only suggestions, not mandates.
For example, the standard says effective employee participation "should" include roles in investigating incidents, developing procedures, audits, developing training, and job safety analyses.
Relevant safety and health info that "should" be provided to employees includes results of investigations, monitoring data, ergonomics evaluations, injury and illness data, risk assessments, and safety committee records â€“ if you have a committee.
Again, there is nothing in the standard forcing you to do these things. What is required is that you have a formal process or system covering employee participation that can be documented and evaluated.
The standard is formatted into two columns. Requirements are in the left column and are identified by the word "shall." Requirements for all elements of a program total only about nine pages. If you want to conform to the standard, youâ€™re expected to meet these requirements.
Text in the right column uses the word "should" to describe recommended practices. These descriptions are helpful in benchmarking your own program and assigning a score for your level of performance. But there is nothing mandatory about them.
Here are answers to some questions you might have about the ANSI Z10 standard:
Do I have to scrap my current safety and health program and rebuild it along the lines of the ANSI standard in order to conform?
The standard does not imply that existing programs need to be rebuilt. Any current programs that operate the required elements in a way that is effective and consistent with company policies and objectives should be integrated into the standard.
Who is qualified to oversee implementation of the standard?
This role can be filled by full or part-time in-house personnel or by outside resources. Competence is normally demonstrated through education, training, mentoring, experience, certification, licensing and performance assessment.
No specific certifications or licenses are referenced.
Does the standard specify what methods I should take to control hazards?
Feasible risk reduction is to be based on a preferred order of controls: eliminate the hazard; substitute less hazardous materials, equipment, etc.; use engineering controls; warnings; administrative controls; and finally use personal protective equipment. You continue down the order of controls until the highest-level feasible control is found.
Will consultants certify my compliance with this standard, as with ISO standards?
ANSI Z10 standards-writers steered clear of any ISO-like certification scheme. Still, a number of safety and health experts expect conformance to the standard will eventually be audited and certified by consultants â€“ if the standard progresses from the current proposal to a final, approved set of voluntary requirements.
Remember, an ANSI voluntary standard on ergonomics never made it past the proposal stage, killed by business opposition. Some safety experts predict a similar rough going for the Z10 management systems standard.
So what happens next?
Thatâ€™s what weâ€™ll cover in the next issue of ISHNâ€™s e-newsletter. Weâ€™ll look at the business communityâ€™s reaction to Z10, and prospects for the standard being used by OSHA and being adopted by ISO.
Dave Johnson is the ISHN E-News editor. He can be reached at firstname.lastname@example.org, (610) 666-0261; fax (610) 666-1906.
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Among the books you'll find:
Shakespeare need not apply, but ISHN is looking for authors to publish short articles (1,000 words) in our monthly issues.
Topics include: safety success stories, close calls and personal experiences, training tips, use of software, engineering controls (machine guards, lockout-tagout), gas detection and air monitoring, confined space safety, personal protective equipment, and OSHA compliance issues.
If any of these topics interest you â€” or if you have other ideas â€” e-mail editor Dave Johnson at email@example.com
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