The "So What" Test

October 15, 2004
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Dear Subscriber,

Will the proposed ANSI Z10 health and safety management system standard pass the "so what" test?

You know the "so what" test. You can apply it to any new idea that comes along, any proposal. Say you want to roll out a behavior-based safety program. Your boss says, "So what's it going to get me?"

Some safety and health pros call the voluntary standard, released to the public in September, a benchmark or a blueprint for how to pull together and assess all the disparate parts of a worksite safety and health program.

Others aren't as optimistic.

"When all the dust settles, (the ANSI standard) will be just another great idea that never really met its potential," says consultant Dave Pierce.

In this issue of ISHN's e-newsletter, we assess the ANSI Z10 standard's chances of passing the "so what" test.

BEYOND COFFEE CUPS

Most all the pros we surveyed agree the potential exists for Z10 to make a difference.

Alan Leibowitz, co-chair of the large committee (40+ members) that has worked on the ANSI Z10 standard since 1999, says, "For me as a safety and health practitioner, this (standard) is something I would've liked to have starting out my career."

Many pros will tell you that OSHA should have spelled out the core necessities of a safety and health program back in 1970 as its very first standard. Several attempts at it fizzled out, to the detriment of workplace safety, according to some.

"Safety management efforts have wandered all over the map since 1970," says Ted Ingalls, president of Performance Management Consultants. "We've gone from an engineering to humanistic to something else in philosophy. All the while we've remained in the compliance-for-compliance-sake mode."

"Many of us in recent years have been successful in safety just because we finally started implementing management systems," says Kyle Dotson, vice president, corporate safety officer, Calpine Corp.

For pros like Dotson and Ingalls, the ANZI Z10 standard is a tool to take safety programs beyond machine guards, common sense and coffee cups, as Dotson puts it. "It actually assures you that you have an infrastructure in place to support all of those daily safety things that together make for a safe workplace," he says.

Judge for yourself. You can download the Z10 proposal at www.aiha.org. More than 500 requests for the standard have come in to the American Industrial Hygiene Association, which has coordinated the standards-setting.

It's 62-pages long, but the actual requirements run less than 20 pages. In very flexible language, Z10 covers all the essentials: management responsibility and authority, employee participation, making assessments and setting priorities, hazard controls, training, recordkeeping, audits and investigations, corrective and preventive actions, and management reviews.

"It's not proscriptive," says Leibowitz. "It gives guidance to existing programs and tells others how to build a management system."

BEWARE THE MAGIC BULLET

This being the safety and health community, you don't have to go far to find dissenting opinions about Z10's future.

"(ANSI Z10) is a good reference document but I don't see a lot of safety professionals using it," says a veteran safety standards watcher who requested anonymity.

"If you have a safety and health professional on staff, you're doing most of these things. If you don't, if you're not investing in safety and health, you wouldn't even know about it," he says.

Some see selling execs as a problem. "It's hard enough to get management to understand OSHA standards let alone ANSI standards," says Gary Higbee of Higbee and Associates.

Beware the magic bullet, says veteran safety pro Tom Lawrence. He says too many pros are "afflicted with the notion" that an OSHA reg or an ANSI standard on management systems — "something official" — will "magically provide the recognition we need to transform our profession into legitimacy."

To be sure, many safety and health pros we surveyed are quick to point out the limitations of management systems.

"A hypothetical company producing highly radioactive toxic waste and dumping it in the ocean as part of its core business could — if properly organized — get ISO 14000 certified," says Gary Rosenblum, who was taught that lesson during an ISO-auditor workshop.

"The point is, a management system specifies having processes to do safety management, not necessarily to be safe," he says.

COMMENCE SELLING

Even its supporters admit ANSI Z10 has a long way to go to reach its potential.

First, it must make it from a proposed draft to a final, approved standard. Barring unseen opposition, that should happen sometime in 2005, according to committee sources. One reason: the standard is a product of unusual compromise. "You haven't seen this kind of union-business group consensus in a decade," says one committee observer.

For example, the National Association of Manufacturers — a group not known for endorsing standards-setting — will probably sit this one out. "I'm about 95 percent sure NAM will be neutral," says Chris Tampio, director of employment policy. "We won't oppose it, and we definitely won't support it. Probably some of our small members wouldn't think it's the best thing, and probably some of our large members do a lot of this stuff already."

In others words, this isn't ergonomics.

What happens after Z10 is finalized and published as an ANSI-approved standard? That's when the selling commences.

And U.S. employers do need to be sold on management system standards. Consider that at the end of 2003, at least 500,125 certificates had been issued worldwide to the ISO 9001:2000 quality standard — but only 30,294 in the U.S., according to ISO.

At least 66,070 certificates had been issued to the ISO 14001 environmental standard — with the U.S. accounting for only five percent (3,553).

And more specifically, in terms of safety and health management systems, ISHN's most recent White Paper reader survey finds only 28 percent of readers using some type of systems-approach, such as ongoing audits. In workplaces that consider their safety performance as "average", usage drops to 19 percent.

WHITHER OSHA? ISO?

For the ANSI Z10 standard to be used by a significant number of U.S. workplaces, some combination of four "drivers" must take off:

1 — AIHA rolls out an aggressive campaign to promote, market and create demand for the standard. "AIHA wanted to do this, they were willing to budget for it and jumped on it," says one Washington source. "Now what are they going to do with it? That's the great unanswered question."

"AIHA has to seize the bully pulpit and sell it big," says another source close to the committee.

"We're looking forward to promoting the standard," says Margie Breida, AIHA's senior manager for committees and standards. The association is "cautiously optimistic" about the standard's chances of getting final approval, she says. A marketing campaign could include a teleweb event, articles placed in executive business magazines, working with peer organizations such as the American Society of Safety Engineers, and grassroots promotion through AIHA's local chapters, she says.

2 — A certification program is developed for the standard which consultants can rally around. "It was never our plan to develop this standard so consultants could push certification," says AIHA's Breida. "It wasn't self-serving."

Still, the newsletter Environmental Systems Update reports that if Z10 is approved in 2005, you can expect a formal accreditation program from the Registrar Accreditation Board to soon follow. RAB operates the National Accreditation Program for ISO 9000 and 14001 certification bodies jointly with ANSI.

In the certification game, the Z10 standard's main competition would come from OHSAS 18001, a management system standard published in the United Kingdom in 1999. And Z10 would have a lot of catching up to do.

"A lot of money has been thrown at 18001," says one committee source. "So is Z10 a little late? Maybe."

"18001 is gaining more mainstream momentum than would appear evident," says the corporate EHS director for a multinational. "Our European factories will adopt it and be certified to it."

How much momentum does 18001 have? It's being pushed by about a dozen global standards registrars, and midway through 2003 about 4,000 worksites had been registered worldwide, says Tom Shelley of BSI Americas. Half of those are in Asia and 1,500 in Europe, he says.

3 — ISO uses the Z10 standard as the basis for an ISO occupational health and safety standard. "At the moment, there is no pressure coming from anywhere to launch an ISO activity on occupational health and safety," says Roger Frost, an ISO spokesman. Instead, ISO is gearing up for a new international standard on social responsibility, to be led by the national standards institutes of Brazil and Sweden. ISO expects the social responsibility standard to be completed in 2007.

One possibility: the Z10 standard — or some safety and health standard — is folded into social responsibility requirements set by ISO. "It's logical to integrate it into corporate social responsibility to show what a company is doing to protect its employees' well-being," says one source.

But for now, any possibilities with ISO are years away.

4 — OSHA in some way bestows legitimacy on the Z10 standard. — making it part of the Voluntary Protection Program, referencing it in general duty clause enforcement cases, settling egregious penalty cases by having offenders put in place a Z10 program, or the longest of long shots, adopting it as the long-lost safety and health program rule.

OSHA has a seat at the Z10 table as a non-voting committee member, but co-chair Leibowitz says the agency has said it has no intention of using Z10 as a standard.

That could change as regulatory regimes change in Washington, he says. But for now, there are no prospects.

Bottom line: With U.S. industry's cultural bias against voluntary rules, it seems the ANSI Z10 rule will need a boost either from U.S. regulators or international standards-setters to pass the "so what" test.

Otherwise, it's going to be a hard sell. After all, "there is little evidence that any of the management standards actually improve performance," says one veteran safety and health pro.

Dave Johnson is the ISHN E-News editor. He can be reached at djsafe@bellatlantic.net, (610) 666-0261; fax (610) 666-1906.

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WE NEED YOU!

Are you a safety and health pro or a manufacturer or provider of occupational safety and health products or services who enjoys writing?

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 — or if you have other ideas — e-mail editor Dave Johnson at djsafe@bellatlantic.net

We will also consider articles you’ve already written but not submitted to any safety magazine.

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