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II.Report Genesis, Scope, and Findings
A. Background With the goal of reducing occupational injury, illness, fatalities and their associated costs, strategies for augmenting traditional command-and-control regulatory and management approaches have been explored, notably over the past few years. One such approach is the application of systems models to occupational health and safety (OHS) management. The current attention being given to OHS management systems (OHSMS) stems from developments in the International Organization for Standardization (ISO), nation-states, professional societies, industry bodies; and, health, safety and environmental consultancies.
Key events within ISO include: 1) the publication of a quality-assurance management system (ISO 9000) in 1986; 2) an environmental management system (ISO 14000) published in 1996; and, 3) the decision not to develop an ISO OHSMS in 1997.
Nation-state, professional-society, and industry activities in the early to mid-1990s included the development and publication of the following OHSMSs.
The proliferation of OHSMS models and approaches to OHS management increased in the mid to late 1990s leading to concerns about the arising of a potentially confusing situation. In this report 24 of those OHSMSs published or under development by nation-states, standards-development organizations, or professional societies are analyzed and compared.
B. Authorisation and Project Genesis This project was first discussed between members of the International Occupational Hygiene Association (IOHA) Executive Board and representatives of the Safety and Health Branch of the International Labour Office (ILO) at IOHA’s 3rd International Scientific Conference held in Crans Montana, Switzerland in September 1997. The OHSMS issue was a prominent topic at the conference. It was the subject of several keynote presentations and an entire platform session was devoted to various aspects of OHS management. Much discussion centered around ISO’s decision to not pursue an international OHSMS standard, and of alternative mechanisms to meet this need.
Provisional agreement was reached between IOHA and the ILO to work together to draft a document on OHSMS. A necessary first step was to survey existing OHSMS documents and those under development to obtain a better overview of OHSMS activities throughout the world. With this knowledge of the OHSMS models and approaches in use, or under development, it would be possible to embark on the development of an international OHSMS that would build on the work already done, minimize conflict with other OHSMSs, and possibly provide a model whereby good OHS management principles are strengthened.
C. OHSMS Use and Value Many of the industrially developed countries of the world have seen injury and illness rates decline drastically over the last 50 years. However, these rates have generally reached a plateau over the last decade. Many novel approaches have been tried to further improve performance such as behavior-based-safety techniques, improved health and safety auditing concepts, and management systems schemes. There is no doubt that many other approaches will also be tried in the future. Nevertheless, as mentioned, one of the newer techniques is the use of a management-systems approach.
For example, in the United States, since the passage of the Occupational Safety and Health Act of 1970, the incidence rate of occupational fatalities has been reduced by 76 percent, and total injury/illness case-rates by 27 percent. Even with these positive changes, the frequencies of occupational health and safety (OHS) fatality and injury/illness incidents, coupled with a stubbornly high and unchanging total lost-work-day case rate, continue to affect adversely the lives of millions of workers and their dependents, and present a substantial burden on the cost of health care in the United States. This was recently confirmed in a comprehensive study which, among other things, found that approximately 6,500 job-related deaths from injuries, 60,300 deaths from disease, and 862,200 illnesses are estimated to occur annually in the American work force. The total direct and indirect costs are estimated to be $171 billion (Leigh, 1997). A similar problem is found in many other developed countries.
Interest in OHSMSs grew as the need for a global approach to OHS management was recognised as a logical and necessary response to the growth of the "global economy", as the benefits of "systems" management approaches become apparent, and a result of the impact of ISO standards for quality and the environment. First, most major companies in the industrially developed world are multinational and favour a standardized approach to safety and health. Japan, for example, has been manufacturing products and dealing with safety concerns around the world for a considerable period of time. Most companies recognize the need and benefits of meeting world standards or best practices for OHS while striving to meet local requirements of the host country. Second, current management science theories suggest that performance is better in all areas of business, including OHS, if it is measured and continuous improvement sought in an organized fashion. Third, central to the ISO approach is to harmonize existing standards or create new ones that promote free trade. Two of ISO’s recent standards, ISO 9000 and 14000, developed by the world community, address areas analogous to OHS. Both standards integrate these functions within a business (management) framework.
One of the advantages to an OHSMS approach is resolution of the common criticism that OHS is rarely integrated into business systems but rather is typically a stand alone adjunct in most companies.
Additional value realized through the use of OHSMSs include: Some would argue that there are an equal number of disadvantages as well. Those most commonly cited include no need for change from present approaches and practices, social and legal barriers internationally that cannot be overcome by a standardized approach, bureaucracy and cost.
The Systems Approach
The OHSMS approach to OHS management is based on systems theories developed primarily in the natural and social sciences. Four elements common to general system theories are: input; process; output; and, feedback.
Systems are further characterized as either open or closed systems. In the case of open systems, there are identifiable pathways whereby the system interacts --- exchanging information with and gaining energy --- from its external environment. This phenomenon is readily observed in biological systems. Conversely, closed systems do not have such pathways, and thus limit their ability to adapt or respond to changing external conditions.
In traditional OHS management approaches, the focus has been on trailing indicators (outcomes or outputs), such as illness, injury, and fatality statistics. In a systems approach, regulatory compliance and trailing indicators are not neglected; however, there is a shift in focus towards performance variables and metrics from the input and process components of the system. These components can be thought of as being "upstream" from the system output.
Programs vs. Systems
An important distinction to make in an OHSMS approach is that between what are customarily referred to as "programs" and "systems". The distinction is made here between traditional programmatic approaches and the newer systems approaches to OHS management. In the paradigm shift suggested by the development and implementation of OHSMSs, a program operates as singular, vertical, and based on traditional command-control regulations. The focus is on compliance with the program standard/regulation, not the broader impact on OHS. Programs traditionally do not have strong, if any, feedback or evaluation mechanisms whereby the program is adjusted or modified to accommodate changing circumstances.
Conversely, a systems approach --- while not losing sight of programmatic requirements and opportunities for improvement --- broadens in perspective to address the manner in which the program affects other programs, and the extent to which the program may or may not improve worker health and safety. Furthermore, a systems approach focuses on OHS improvement, not exclusively on programmatic regulatory compliance. A key distinction of a systems approach is that there are clear feed-back and evaluation mechanisms whereby the system responds to both internal and external events.
In this context, an example of program compliance would be with a single standard, such as a lock-out-tag-out standard for construction or an asbestos standard for general industry. A systems approach integrates individual programs within the business operations and the external environment, and is thus more comprehensive than any single program.
One could argue that this program/system dichotomy is a potentially weak distinction. That is, the programmatic approaches do in fact contain systems qualities and conversely, the systems approaches do in fact contain programmatic qualities. This observation is valid. However, the point of presenting the dichotomy is to elucidate the fact that programmatic OHS management approaches do not reflect or embrace systems concepts. Furthermore, such systems approaches potentially offer previously unrealized opportunities for advancement in OHS.
D. Common OHSMS Variables In 1997 researchers in the Michigan Occupational Health and Safety (OHS) Policy Group at the University of Michigan developed a universal OHSMS assessment instrument (UAI). In order to develop the UAI, it was first necessary to identify and define the scope of OHSMSs, and to develop a universal OHSMS that could be used as the foundation for the instrument. Because of its comprehensive nature, the universal OHSMS developed at the University of Michigan was used in the analysis conducted in this project. The development steps in the universal OHSMS are presented in Appendix B of this report.
The UAI structure can be described as containing: The 27 section titles were used in this analysis are referred to in this report as "OHSMS variables." These variables are listed in Table No. 1.
A brief description of each of these variables is given in Appendix B.
E. Analysis Summary and Findings The search for publicly available OHSMS models and approaches yielded 31 standards, guidance documents, and codes of practice; 24 of which were included this analysis. A summary of the 24 documents is listed below. A more detailed list, giving biographical details can be found in Appendix A. An in-depth analysis of the standards, guidance documents, and codes of practice is presented in Appendix C.
Included in the 24 documents analyzed are:
The publishers of these documents include national governments; state/provincial governments; national standards organizations; and professional health/safety associations. The types of OHSMS models and approaches published by these organizations included: auditable standards; non-auditable standards; guidance documents; and, national/state/provincial regulations that contain some OHSMS components. Of the documents analyzed the following have been published and are final. Australia/New Zealand AS/NZS 4804; Australia SafetyMap; Brazil NR-9; European Union, EMAS; India Factories Act; ISO 14001; Japan OHSMS; Korea Labor Laws; The Netherlands OHSMS; South Africa NOSA; United Kingdom BS8800, Chemical Industries Association, E&P Forum; United States, AIHA OHSMS, CMA Responsible Care, OSHA VPP, and California Program Standard. The Polish document is final and was analyzed. However, strictly speaking, while it contains valuable information, it is not a management system. The following documents are still under development. Ireland OHSMS; Jamaica OHSMS; Norway OHSMS; Spain OHSMS; United States, OSHA OHS Program Standard. A central aspect of the analysis included an assessment of the presence or absence of 27 common OHSMS variables in the 24 models and approaches. A summary of this analysis is presented in Table No. 2. Not all the documents analyzed covered all aspects of occupational health and safety. The ones exhibiting the most comprehensive coverage were those developed by standards-development organizations and professional associations, namely: Australia/New Zealand AS/NZS 4804; Australia SafetyMap; United Kingdom BS8800; United States, AIHA OHSMS, ISO 14001, CMA Responsible Care; Ireland OHSMS; Jamaica OHSMS; Norway OHSMS; Spain OHSMS; the E&P Forum; EMAS; and, Chemical Industries Association OHSMS. It is recommended that the content of these 13 documents should be the basis of the content of an international OHSMS. They are is a mix of auditable standards, non-auditable standards, and guidance documents. Contained within them are all the variables commonly associated with comprehensive management systems. Of particular interest is the proposed Spanish OHSMS. This document was the only one reviewed that contained both an auditable standard (using "shall" statements), a guidance document for auditing, and definitions. The Australian/New Zealand, British, Irish and Jamaican OHSMSs, while not auditable (using "should" statements") were very informative. In addition to containing comprehensive recommendations on the OHSMS structure, they included helpful implementation and auditing guidance.
Based on the analysis conducted, and the extent to which OHSMS variables are present, the following models and approaches are considered strong auditable OHSMS standards:
ISO 14001 was included in the analysis and is considered a strong auditable standard. However, strictly speaking it is not an OHSMS, even though many organizations are using it as a template for OHSMS development. Two key OHSMS variables that are missing in ISO 14001-based OHSMSs are 1) employee participation, and 2) health/medical programs and surveillance, which need to be included in any international OHSMS document. The following models and approaches are considered strong non-auditable standards or guidance documents:
The only document that provided comprehensive auditing guidelines is the draft Spanish draft OHSMS. Using the 27 OHSMS variables identified in a comprehensive universal OHSMS model as the primary basis for analysis, it was found that the 19 models and approaches were generally strong in addressing traditional occupational health and safety (OHS) management issues, such as, hazard control, training, evaluation, and risk/hazard assessment. Conversely, there is a general weakness throughout the models and approaches in areas often considered central to management system approaches. These include management commitment, resource allocation, continual improvement, OHSMS integration with other organizational systems, and management review. A further weakness found throughout what are otherwise strong OHSMSs is the lack of medical surveillance and health programs. In view of the importance of this aspect of preventive health management, this is somewhat surprising. An additional weakness is the manner that employee participation is addressed. While 20 of the 24 models and approaches reviewed contain some level of employee participation language, there is wide variation in the strength of the language.
F. Discussion Introduction
This discussion is in two parts. The first, discussing a number of the key elements of occupational health and safety management systems, the second looking at global OHSMS developments in 1997-98, and the implications of these for the development of an ILO OHSMS document.
Key Distinguishing Features of Management Systems
An important outcome of recent OHSMS-related research conducted at the University of Michigan was the identification of key OHSMS variables that distinguish systems-approaches from programmatic-approaches.
Figure No. 1 presents the OHSMS variables described earlier and in Appendix B, within a universal systems model. That is, in terms of inputs, process, outputs, and feedback loops. Also depicted are variables associated with open systems, whereby the system interacts with the external environment. There are many such models, but they all contain the same general features.
As depicted in this model, the essential OHSMS inputs are 1) management commitment, 2) allocation of resources, and 3) employee participation. A weakness in a number of management systems approaches is the manner in which employee participation is addressed. This issue is perhaps the single most important issue to labor representatives. For instance, it is possible to have an otherwise strong OHSMS that has weak employee participation. This is observed in some ISO 14001-based OHSMSs.
The OHSMS variables that are central to a systems approach are:
Communication System
A well functioning communication system with defined feedback channels is essential for a successful OHSMS. As depicted in the systems model presented in Figure No. 1, this is a basic feature of a system, especially an open system. For the system to survive and develop, there must be mechanisms whereby the system components receive feedback from each other and from the external environment. The communication system provides the means by which all other parts of the system relate and interact. There are any number of ways that the communication system variables can function. However, in its most basic form, a viable communication system should identify how, and to whom, information for the proper functioning of the OHSMS will be transmitted. The communication system should have mechanisms in place to confirm that information has been received by the intended party and in the prescribed time-frame.
Performance Measures and Root Cause Analysis
In order to make valid and reliable performance measurements, the indicators, variables, measurement units, and their logical relationships must be established. In terms of the indicators to measure, the distinction has been made in the OHS literature between leading and trailing indicators. As in many disciplines, efforts are underway to identify leading indicators upon which management can rely on as predictors of emerging problems. This is seen in the economics field with an emphasis placed on leading economic indicators and in the environmental field with efforts to identify leading environmental health indicators from which environmental management decisions can be made.
Central to the identification of leading OHS indicators are the root-cause-analysis activities required in many OHSMSs. The use of root-cause-analysis techniques have been in use for many years in the health and safety field. Root-cause analysis has been highlighted in OHSMSs because of its central importance in moving up the causal chain to the point of origin in the pursuit of leading OHS indicators.
Root-cause analysis may be considered a relatively minor component of an OHSMS, especially in entities in which full compliance is achieved with regulations and in which a numeric rating system is in place. However, compliance with regulations and high scores on a numeric system cannot replace the practice of following a line of inquiry from an unplanned incident, near miss, or regulatory contravention to objective evidence that answers the question why? This is central to the philosophy of planning and operating an efficient, effective OHS management system. The lack of procedures for, or documentation of, the use of root-cause analysis may be traceable to, for example, nonconformance in clauses related to policy, management commitment, or training.
Continual Improvement
Continual improvement is a key concept in the ISO-based OHSMSs and is the central concept reflected in the Deming/Shewhart Plan-Do-Check-Act cycle. In an OHSMS context, continual improvement can be defined as the process of improving the OHS management system to achieve enhancements in overall OHS Management performance through continuing reviews of appropriate OHS measures that are in line with the organization’s OHS policy.
Continual improvement does not mean or imply a requirement to attain "better than compliance" conditions as measured against specification regulations or standards. While "better than compliance" may be a goal of an organization, it is not a requirement of the definition of continual improvement. There are numerous ways that an organization may operationally define continual improvement. However, the ultimate goal of continual improvement should be to reduce the potential for worker injury and illness, with the ultimate goal, however theoretical, of eliminating injury and illness altogether.
Integration
A basic characteristic of OHSMSs is that they are integrated with other business functions and the external environment. As depicted in Figure No. 1, the OHSMS variables are connected through feedback channels. Also depicted in this figure is the manner in which the OHSMS is integrated with both the organization as a whole and the external environment. In order for an OHSMS to succeed, this open-system aspect must be understood and functioning. By definition, the implementation of an OHSMS requires that the OHSMS be connected, or related to other functions in the organization. This means that OHS issues and aspects of the OHSMS will be part of the organizational culture. Furthermore, at a fundamental level, this also means that worker health and safety will be an important value to which management and employees and stakeholders will be committed.
Management Review
Management review is the means whereby the overall performance of the OHSMS is evaluated. It provides the link between the OHSMS, the organization, and the environment external to the organization. This involves evaluating the OHSMS’s ability to meet the overall needs of the organization, its stakeholders, its employees, and regulating agencies. Management review is different from more specific system-evaluation efforts which address specific aspects of the OHSMS elements.
The distinction between management review and system evaluation can be viewed in terms of how one would plan a long automobile trip. Using this metaphor, the ongoing monitoring of the fuel level, engine temperature, and general performance of the automobile corresponds with the functions performed during OHSMS system evaluation. Management review, on the other hand, corresponds with the ongoing evaluation of whether the car is on the correct highway to reach the intended destination. Continuing with the metaphor in terms of the program/system dichotomy discussed, earlier, it can be said that, checking the tire pressure would correspond with program evaluation and overall trip planning and vehicle performance would correspond with system evaluation.
Management review is the hallmark of a successful system and is a key attribute of strong management commitment to OHS. Without feedback, there can be no strategic planning or continual improvement. Management resistance to participate actively in the OHSMS-review process would be a clear indicator of the lack of management commitment.
International and National OHSMS Developments
The Certification Debate
The majority of consensus-standards developed by the national-standards bodies of different countries are non-auditable standards or guidance. The main reasons for this are: However, the reservations of some about the merit of certifiable standards, has not dampened the demand for a certifiable standard to put OHS on an equal footing with environment and quality management systems.
The experience in the UK is a case in point. Over 7000 copies of BS8800, which is a guidance document, were sold within the first 12 months, and it has become apparent that there is a substantial and growing demand for independent verification and recognition of achievement in OHS. The absence of any "officially accredited" certification scheme for those who implement BS8800, has lead to a growth in non-accredited proprietary OHSMS and non-accredited certification schemes, which is seen as undesirable.
However, it is an entirely predictable response to a demand from employers which cannot be satisfied by the national standards organisation under the present constraints. Similarly, many commercial health and safety consultancies have responded to the demand from their clients by offering to review their OHSMS and issue a certificate if their OHS management is in accordance with BS8800.
In July 1998, the general level of concern about the situation lead to the British Standards Institution (BSI) publishing a draft "Product Assessment Specification" (PAS) against which BS quality assurance auditors will assess the conformity of organisations with the guidance given in BS8800, even though the latter makes it clear than it is not intended for certification purposes. This change in policy between April 1996 when BS8800 was published, and July 1998 is solely a result of the demand from organisations to have their OHS management and performance reviewed by an independent third party, and certificated if it conforms to the relevant standard. It is expected that this change in policy will be a catalyst in the certification marketplace in the UK, and result in many more organisations going for certification to BS8800.
This reflects the fact that certification to a standard is, in general something which organisations strive for, so as to have their achievements recognised and to gain competitive advantage. Attitudes to compliance with legal requirements are often different, and obeying the law is regarded as a duty for which one receives little recognition or credit. These and other arguments were discussed in detail at the session on "International Standard of Occupational Hygiene Management" at the IOHA 3rd International Scientific Conference in September 1997.
Ultimately, it is predicted that certification will be available for many OHSMS standards either through 'official channels' or through the entrepreneurial activities of quality, environment and health and safety auditors, as this is what many organisations want. There is concern about potential barriers to trade emerging if national standards proliferate. An international standard, which offers internationally recognised certification, is the single most effective way of avoiding this undesirable situation.
International Developments
Following the meeting of stakeholders by ISO in September 1996 and the decision of the ISO Technical Management Board early in 1997 not to proceed for the time being with an OHSMS standard, there have been a number of developments.
The widespread dissatisfaction about the current situation has manifested itself in many ways. The Dutch Standard NPR 5001 (see Appendix C) has been put forward to the ISO Technical Management Board (TMB) for adoption as an OHSMS guide, but not with certification or accreditation.
ISO are also working towards aligned (as opposed to integrated) standards for quality and environment in the revisions of ISO 9001 and ISO 14001 currently underway. This has rekindled the debate on the role of OHSMS, and there is growing feeling that OHSMS should be included in the current management systems standards revisions. The ISO TMB will be discussing what initiatives (if any) should be taken, over the next few months.
AFNOR, the Spanish national standardisation body proposed the Spanish standard UNE 81900 for adoption as a European (CEN) standard, though this was rejected by the member countries, mainly on the grounds that it was a "certifiable" standard which they did not want. In Germany, the "social partners" (Government at Federal and State Level, accident funds, employer and employee organisation) have developed a common position on OHSMS and are proposing that the European Commission should take action under Articles 117 and 118a of the Treaty of Rome, to make resources available to prepare on OHSMS "Guide." The EC Advisory Committee on OHSMS is also considering whether an OHSMS Guide would be advantageous.
In addition to the above, the importance of the effectiveness of, and the senior management commitment to, the management system behind occupational health and safety programmes is gaining recognition among health and safety professionals. A recent meeting of the WHO PACE programme on controlling hazards from dust, the need for an overarching management system, that ensures all the technical and administrative tasks necessary are actually being carried out, was recognised, as was the importance of having measurable performance indices and standards by which to assess its effectiveness.
Similarly, government labour inspectorates have recognised the importance of an effective management system and incorporated management elements in their legislation, codes of practice and guidance. A good example is the UK, where the Health and Safety Executive's Publication, HS(G)65, "successful Health and Safety Management" has significantly altered thinking on OHS management in many organisations. Other Governments are in the process of introducing measures, such as Hong Kong, who intend to bring into law a requirement for an OHSMS to be established by the end of 1998, in certain sectors of industry such as construction and ship building.
In addition to the comprehensive OHSMS, which are the main subject of this report, others aimed at particular industries or aspects of health and safety have also been produced, such as that by the Dutch Central Committee of Experts (CCE-SCC) who have produced a model for "certification of contractors" OHSMS systems in the engineering and construction industries.
Some of the OHSMS's reviewed also adopted a more 'holistic' approach, bringing in other aspects of OHS and employee welfare. A good example is Jamaica, where psychological issues such as trauma and stress, and rehabilitation from occupational injuries and illnesses are addressed.
Updated by AS. Approved by EC. Last update: 30.11.2004.
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