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Occupational Health and Safety Management Systems

Review and Analysis of International, National, and Regional Systemsand

Proposals for a New International Document

Prepared for: The International Labour Office,Geneva, Switzerland

Prepared by: The International Occupational Hygiene Association

Principal Contributors: Hugh Dalrymple, ICLCharles Redinger, Redinger & AssociatesDavid Dyjack, Loma Linda UniversitySteven Levine, The University of MichiganZack Mansdorf, Arthur D. Little, Inc.

Report Issued: August 31, 1998

Please note thatthis report is a working paper, does not claim to be complete and has not been up-dated since its publication;

●

the analysed documents listed in Appendix A in some cases may not have been the most recent ones for the indicatedcountry or region;

●

some documents listed in Appendix A may have been revised and amended after the publication of the report;

●

it is advisable for getting the most recent information for a country/region to contact directly the respective originatinginstitution.

●

The National Occupational Safety Association of South Africa (NOSA) referred to as No. 16 in Appendix A indicated that thedocument analysed in Appendix C/16 has been replaced by a more recent one. Further information can be obtained on the NOSAwebsite.

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Table of Contents

I. Executive Summary

II. Report Genesis, Scope, and Findings

A. BackgroundB. Authorisation and Project GenesisC. OHSMS Use and ValueD. Common OHSMS VariablesE. Analysis Summary and FindingsF. Discussion

III. Recommendations & Outline for a New International OHSMS

Appendix A: Standards, Guidance Documents, and Codes of Practice Analyzed

Appendix B: Methods and Definitions

Appendix C: Analysis

Appendix D: List of External Reviewers

Appendix E: Biographical Sketches of Report Contributors

Appendix F: Bibliography

Appendix G: About the International Occupational Hygiene Association

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IOHA Report to ILO on an International OHSMS - Chapter I.[Title page] [Table of Contents] Chapters: I II III Appendices: A B C D E F G [Bottom]

I.

Executive Summary

This report has been prepared by the International Occupational Hygiene Association(IOHA) at the request of the Occupational Safety and Health Branch of the InternationalLabour Office (ILO).

IOHA's brief from the ILO was to:

prepare a review of existing and proposed standards and documents ofoccupational health and safety(OHS) management systems which analyzes andsummarizes key elements (scope, coverage, practicability, similarities, differences,etc.);

.

based on this review and analysis, prepare recommendations of how to avoiddifferences and to harmonize the provisions of such standards/documents; and,

b.

prepare an extensive draft outline * of a new international document on OHSmanagement, following the structure of ILO Codes of practice.

c.

* The term "extensive draft outline" refers to titles of chapters to be considered in a futuredocument and short references to the key elements to be dealt with in each of them.

This report analyzes the nature and content of 24 Occupational Health and SafetyManagement System (OHSMS) Standards, Codes of Practice and Guidance Documentsfrom 15 countries, and for the purpose of comparison, the International Standards ISO14001:1996 on Environmental Management Systems, and a draft ISO Standard on Health,Safety and Environmental Management in the Petroleum and Natural Gas Industries, onwhich work was suspended in 1996.

The publishers of the documents are mainly national governments, state/provincialgovernments, national standards organisations and professional health and/or safetyorganisations. The documents themselves are either auditable standards, non-auditablestandards, guidance documents or national/state/provincial legislation that containOHSMS components.

The documents analyzed were generally strong in addressing traditional occupationalhealth and safety management issues such as risk assessment, hazard evaluation andcontrol, and training. However, there was a general weakness in areas often consideredcentral to management-system approaches, such as management commitment, allocationof resources, continual improvement, integration with other systems and managementprocesses of organisation, and management review. In addition, the coverage ofhealth/medical surveillance and employee health programmes, and the manner in whichemployee participation is addressed, are also variable.

There is concern in IOHA, that the present situation where national, provincial/state,

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industry and consultancy developed OHSMS standards and guidance documents arebeing developed in many different parts of the world, is causing confusion andmisunderstanding. Employers are often faced with competing systems, but are beingdenied the opportunity to have their OHS performance verified to an internationallyrecognised standard by an accredited conformance-assessment process.

Similarly, employees and other workers are being denied the opportunity of benefiting fromthe improvements in safety and health that are likely to result from such recognition, andthe increased organisational focus on health and safety management necessary toachieve it.

The report concludes that an initiative by ILO in the area of OHSMS would be a significantcontribution to this important and developing area of occupational health and safety. Ifsuccessful, such an initiative could lead to widespread improvements in worker health,safety, and risk management. It would also accelerate the development of preventive,rather than reactive, measures to secure safe and healthy working conditions.

To have maximum effect, it is recommended that an ILO OHSMS document should:

be developed in consultation with the International Organisation for Standardization(ISO);

1.

be expressed in terms of a "standard" against which employers can assess theirown performance; and,

2.

offer the opportunity to employers who implement the OHSMS, to obtaininternationally recognised independent verification of their achievements.

3.

The report also recommends an outline for such a document. The suggestion is made thatthis should be a two-tier approach to permit smaller, less complex organisations with lowerhealth and safety risks, or those organisations introducing an OHSMS for the first time, toapproach the subject in stages.

IOHA Report to ILO on an International OHSMS - Chapter I.[Title page] [Table of Contents] Chapters: I II III Appendices: A B C D E F G [Top]

Updated by AS. Approved by JT. Last update: June 1999.





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IOHA Report to ILO on an International OHSMS - Chapter II.[Title page] [Table of Contents] Chapters: I II III Appendices: A B C D E F G [Bottom]

II.

Report Genesis, Scope, and Findings

A. BackgroundB. Authorisation and Project GenesisC. OHSMS Use and ValueD. Common OHSMS VariablesE. Analysis Summary and FindingsF. Discussion

A. Background

With the goal of reducing occupational injury, illness, fatalities and their associated costs, strategies for augmenting traditional command-and-control regulatory and managementapproaches 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. Thecurrent attention being given to OHS management systems (OHSMS) stems from developments in the International Organization for Standardization (ISO), nation-states, professionalsocieties, 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 in1996; 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.

• Australia, Province of Victoria SafetyMap

• British Standards Institute BS 8800

• United States - OSHA Voluntary Protection Programs

• UK - Chemical Industries’ Association Responsible Care

• US - Chemical Manufactures’ Association Responsible Care

• American Industrial Hygiene Assoc. OHSMS Guidance Document

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. Inthis 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 Branchof 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 prominenttopic 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 discussioncentered 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 andthose 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 underdevelopment, 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, andpossibly 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 aplateau over the last decade. Many novel approaches have been tried to further improve performance such as behavior-based-safety techniques, improved health and safety auditingconcepts, 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 isthe 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, coupledwith 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 burdenon 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 frominjuries, 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 $171billion (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 thebenefits 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 theindustrially developed world are multinational and favour a standardized approach to safety and health. Japan, for example, has been manufacturing products and dealing with safetyconcerns 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 tomeet 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 measuredand 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 ofISO’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 inmost companies.

Additional value realized through the use of OHSMSs include:

alignment of OHS objectives with business objectives;●

integration of OHS programs/systems into business systems;●

establishment of a logical framework upon which to establish an OHS program;●

establishment of a universal set of more effectively communicated, policies, procedures, programs, and goals;●

applicability to, and inclusive of cultural and country differences;●

establishment of a continuous improvement framework; and,●

provide an auditable baseline for performance worldwide.●

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 andlegal barriers internationally that cannot be overcome by a standardized approach, bureaucracy and cost.

The Systems Approach

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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 theoriesare: 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 --- exchanginginformation with and gaining energy --- from its external environment. This phenomenon is readily observed in biological systems. Conversely, closed systems do not have suchpathways, 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 ofthe 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 traditionalprogrammatic approaches and the newer systems approaches to OHS management. In the paradigm shift suggested by the development and implementation of OHSMSs, a programoperates 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 whichthe 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 OHSimprovement, not exclusively on programmatic regulatory compliance. A key distinction of a systems approach is that there are clear feed-back and evaluation mechanisms whereby thesystem 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. Asystems 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, thesystems 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 OHSmanagement approaches do not reflect or embrace systems concepts. Furthermore, such systems approaches potentially offer previously unrealized opportunities for advancement inOHS.

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). Inorder 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 theuniversal OHSMS are presented in Appendix B of this report.

The UAI structure can be described as containing:

5 Organizing Categories;●

27 Sections (16 primary and 11 secondary);●

118 OHSMS Principles; and,●

486 Measurement Criteria.●

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.

Table No. 1 - OHSMS Variables

Initiation (OHS Inputs)

1.0 Management Commitment and Resources

1.1 Regulatory Compliance and System Conformance

1.2 Accountability, Responsibility, and Authority

2.0 Employee Participation

Formulation (OHS Process)

3.0 Occupational Health and Safety Policy

4.0 Goals and Objectives

5.0 Performance Measures

6.0 System Planning and Development

6.1 Baseline Evaluation and Hazard/Risk Assessment

7.0 OHSMS Manual and Procedures&

Implementation/Operations (OHS Process)

8.0 Training System

8.1 Technical Expertise and Personnel Qualifications

9.0 Hazard Control System

9.1 Process Design

9.2 Emergency Preparedness and Response System

9.3 Hazardous Agent Management System

10.0 Preventive and Corrective Action System

11.0 Procurement and Contracting

Evaluation (Feedback)

12.0 Communication System

12.1 Document and Record Management System

13.0 Evaluation System

13.1 Auditing and Self-Inspection

13.2 Incident Investigation and Root Cause Analysis

13.3 Health/Medical Program and Surveillance

Improvement/Integration (Open System Elements)

14.0 Continual Improvement

15.0 Integration

16.0 Management Review



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. Asummary 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.

Country/Region Publisher

1. Australia/New Zealand Standards Australia

Standards New Zealand

2. Australia, Victoria Health and Safety Organisation (HSO),Victoria

3. Brazil Ministry of Labor

4. European Union The Council of the European Communities

5. India Ministry of Labour

6. International Oil Industry International Exploration andProduction Forum (E&P Forum)

7. International - ISO ISO 14001

8. International - ISO ISO OHSMS (suspended)

9. Ireland The National Standards Authority of Ireland

10. Jamaica Jamaica Bureau of Standards

11. Japan Japan Industrial Safety & Health Association

12. Korea Ministry of Labor, Republic of Korea

13. The Netherlands Nederlands Normalisatie-Instituut

14. Norway Norwegian Standards Inst.

15. Poland Polish National Labour Inspectorate

16. South Africa National Occupational Safety Association

17. Spain Asociacion Espanola de Normalizacion yCertificacion

18. United Kingdom British Standards Institute

19. United Kingdom Chemical Industries Association

20. United States American Industrial Hygiene Association

21. United States Chemical Manufacturers Association

22. United States Occupational Safety and HealthAdministration; Voluntary Protection Prog.

23. United States Occupational Safety and HealthAdministration; Proposed OHS Prog. Stand.

24. United States, California Department of Labor and Industrial Relations- Cal OSHA

Included in the 24 documents analyzed are:

18 published and final models and approaches;●

5 models and approaches that are under development; and,●

1 ISO OHSMS (TC 67) that has been suspended.●

The publishers of these documents include national governments; state/provincial governments; national standards organizations; and professional health/safety associations. The typesof OHSMS models and approaches published by these organizations included: auditable standards; non-auditable standards; guidance documents; and, national/state/provincialregulations 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; TheNetherlands OHSMS; South Africa NOSA; United Kingdom BS8800, Chemical Industries Association, E&P Forum; United States, AIHA OHSMS, CMA Responsible Care, OSHAVPP, 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 ispresented 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 bystandards-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;



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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-auditablestandards, 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 guidancedocument for auditing, and definitions. The Australian/New Zealand, British, Irish and Jamaican OHSMSs, while not auditable (using "should" statements") were very informative. Inaddition 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:

Australia SafetyMap;●

Spain’s draft OHSMS standard;●

Norway’s draft integrated management system;●

Chemical Industries Association, Responsible Care;●

Chemical Manufactures’ Association, Responsible Care; and,●

American Industrial Hygiene Association’s OHSMS guidance document.●

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 atemplate for OHSMS development. Two key OHSMS variables that are missing in ISO 14001-based OHSMSs are 1) employee participation, and 2) health/medical programs andsurveillance, which need to be included in any international OHSMS document.

The following models and approaches are considered strong non-auditable standards or guidance documents:

Australia/ New Zealand OHSMS guidance OHSMS, AS/NZS 4804;●

British guidance OHSMS, BS 8800;●

Ireland’s draft OHSMS standard; and,●

Jamaica’s draft OHSMS standard.●

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 generallystrong in addressing traditional occupational health and safety (OHS) management issues, such as, hazard control, training, evaluation, and risk/hazard assessment. Conversely, thereis a general weakness throughout the models and approaches in areas often considered central to management system approaches. These include management commitment, resourceallocation, 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 preventivehealth 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 OHSMSdevelopments 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-approachesfrom 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 samegeneral 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 ofmanagement systems approaches is the manner in which employee participation is addressed. This issue is perhaps the single most important issue to labor representatives. Forinstance, 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/feedback channels;1.

System evaluation, specially the development/measurement of auditing/self-inspection, and root-cause analysis;2.

Continual improvement;3.

Integration; and,4.

Management review.5.

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 abasic 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 eachother 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 thatthe communication system variables can function. However, in its most basic form, a viable communication system should identify how, and to whom, information for the properfunctioning 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 inthe 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 theindicators 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 leadingindicators 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 inthe 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 formany 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 inthe 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 numericrating 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 unplannedincident, 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, effectiveOHS 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 topolicy, 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 throughcontinuing 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 "betterthan 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 operationallydefine continual improvement. However, the ultimate goal of continual improvement should be to reduce the potential for worker injury and illness, with the ultimate goal, howevertheoretical, 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 areconnected 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 beconnected, 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 afundamental 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 externalto the organization. This involves evaluating the OHSMS’s ability to meet the overall needs of the organization, its stakeholders, its employees, and regulating agencies. Managementreview 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 monitoringof the fuel level, engine temperature, and general performance of the automobile corresponds with the functions performed during OHSMS system evaluation. Management review, onthe 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 theprogram/system dichotomy discussed, earlier, it can be said that, checking the tire pressure would correspond with program evaluation and overall trip planning and vehicle performancewould 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 orcontinual 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:

the existing, and sometimes comprehensive, legislative framework which many countries have for OHS, and which it has been argued are sufficient in themselves to bring aboutimprovements in health and safety if properly enforced; and,

●

a "backlash" against certifiable specification standards, following introduction of the ISO 9001 and ISO 14001 certifiable standards.●

This is arguably due mainly to the over-bureaucratic way in which they have been implemented in organizations, and the overzealousness with which paperwork and recordshave been examined by external assessors, to the detriment of assessment of how 'real-life' health and safety issues are managed.

●

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 environmentand 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 isa substantial and growing demand for independent verification and recognition of achievement in OHS. The absence of any "officially accredited" certification scheme for those whoimplement 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 managementis 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 BSquality 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 certificationpurposes. 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 andperformance 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 certificationmarketplace 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 competitiveadvantage. 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 andother arguments were discussed in detail at the session on "International Standard of Occupational Hygiene Management" at the IOHA 3rd International Scientific Conference inSeptember 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, environmentand 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 internationalstandard, 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 anOHSMS 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 ISOTechnical 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 hasrekindled 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 bediscussing 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 membercountries, 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 118aof 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 beadvantageous.

In addition to the above, the importance of the effectiveness of, and the senior management commitment to, the management system behind occupational health and safetyprogrammes is gaining recognition among health and safety professionals. A recent meeting of the WHO PACE programme on controlling hazards from dust, the need for anoverarching management system, that ensures all the technical and administrative tasks necessary are actually being carried out, was recognised, as was the importance of havingmeasurable 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 ofpractice 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 alteredthinking 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 requirementfor 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, suchas 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 constructionindustries.

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 psychologicalissues such as trauma and stress, and rehabilitation from occupational injuries and illnesses are addressed.

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III.

Recommendations & Outline for a New International OHSMS

As the ILO moves forward with the consideration of an international OHSMS standard,there are several important issues that must be addressed. These are:

1. What type of document will be developed? Fundamentally, the options include:

• an auditable standard that uses "shall" statements;

• a non-auditable standard or code-of-practice that uses "should" statements;or,

• a guidance document.

2. Will the standard be compatible or aligned with ISO 14001 or other standards?

3. Will auditor guidance be provided as an adjunct to the document?

4. How will conformity assessment and recognition of achievement be addressed?

Recommendations

Based on the analysis conducted and observations of IOHA, the followingrecommendations are provided to the ILO for consideration in the development of aninternational OHSMS.

1. It is recommended that the document is auditable; that is, it uses "shall"statements.

Experience to date indicates that where nationally recognised non-auditablestandards or guidance documents are published, "unofficial" auditing andcertification schemes proliferate because of the demand from employers. Inaddition, any international document which does not facilitate audit and certificationwill inevitably take second place to one which does.

2. Develop an OHSMS document that contains a two-tiered approach.

Many organisations who are inexperienced at management systems approachesfind the prospect of implementing a system rather forbidding, especially if they are asmall or medium sized enterprise (SME). Organisations with low risk activities mayfind that some of the requirements necessary for others with high risk activities. Thefirst tier would be more general, and not as detailed as the first tier. This structurewould facilitate a phased introduction of an OHSMS.

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3. Use the 27 OHSMS variable identified in this report as the basis for thedevelopment of both a general and comprehensive OHSMS.

4. Ensure that employee participation and health surveillance are strongcomponents of the OHSMS.

5. Base the standard on ISO 14001 and include implementation guidelines.

Published ISO management-system standards have received worldwideacceptance. Many organisations who have implemented OHSMS's, even inaccordance with schemes developed by others, have followed the principles set outby ISO. To maximise acceptability of the ILO OHSMS document, alignment withISO 14000 and ISO 9000 series standards is important. ISO 14004 and ISO 9004are good examples for implementation guidelines.

6. Consult ISO.

For example, representatives of Technical Committees 207 and 176, which areresponsible respectively for ISO 14000 and 9000. Each of these internationalstandards are currently in various stages of revision. There is momentum in thesetechnical committees to publish more closely aligned or compatible standards, orpossibly even an integrated quality and environmental management system. Thereare also discussions about the need to integrate occupational health and safety insuch a standard as it becomes more widely accepted that managementcommitment and resources for OHS suffer in the presence of certifiableenvironmental and quality standards.

7. Address conformity assessment.

Ensure that conformity-assessment mechanisms that meet the needs of potentialusers are thought through, and guidance given, by the time the ILO OHSMSdocuments are published.

8. OHSMS structure

In addition to the general layout below, if the OHSMS parallels the ISO 14000 andISO 9000 series of documents, it could contain the following six sections, either in asingle document or as a multi-part series.

1. Occupational Health and Safety Management System-Specification

2. Occupational Health and Safety Management System-Guidelines andPrinciples

3. Guidelines for OHSMS Auditing - General Principles

4. Guidelines for OHSMS Auditing - Audit Procedures

5. Guidelines for OHSMS Auditing - Auditor Qualifications

6. Occupational Health and Safety Management Systems-Definitions

IOHA recommends that the following key elements should be included in an ILOInternational OHSMS document. This is based on the 27 sections described inTable No. 1 and Appendix B. It is recommended that the items under 3 to 18 below,are covered by the suggested (two tier) approach.

1. General Provisions



1.1 Objectives

1.2 Scope

1.3 Definitions

2. OHSMS Policy and Principles

2.1 At International Level

2.2 At National Level

2.3 At Enterprise/organisation Level

3. Management Commitment and Resources

3.1 Recognition of OHS performance as integral to Organisation BusinessPerformance

3.2 Commitment to a high level of performance

3.3 Allocation of Resources

3.4 Establishment of Supporting Structures

3.5 Senior Management Accountability, Responsibility and Authority


4. Employee Participation

4.1 Accountability, Responsibility and Authority of Employees

4.2 Employee consultation

4.3 Management/Employee communication

5. Occupational Health and Safety Policy

5.1 At Enterprise/Division/Facility Level

5.2 Formulation and Periodic Review

5.3 Authority

5.4 Documentation Mechanisms

5.5 Understanding at all levels

6. Goals and Objectives

6.1 At Enterprise/Division/Facility/Local Level

6.2 Objectives/Goal Setting process

7. Performance Measures

7.1 Leading Indicators

7.2 Trailing Indicators



8. System Planning and Development

8.1 Initial Planning

8.2 Overall Structure/Form of OHSMS

8.3 Implementation Processes

8.4 Review and Modification Processes

8.5 Baseline Evaluation and Hazard/Risk Review

8.6 Regulatory Compliance Review

8.7 OHS Management Practice/Procedure Review

8.8 Hazard/Risk Assessment of Activities

9. OHSMS Manual/Procedures

9.1 Nature and Form of Manual

9.2 Updating Procedures

9.3 Accessibility by Employees and others

10. Training System/Skills

10.1 Senior Management Training

10.2 Management/Supervisor Training

10.3 Employee Training

10.4 Induction and Refresher Training

10.5 Training for Hazardous Work

10.6 Competence, Expertise and Qualifications

10.7 Competent OHS Advice

11. Hazard Control System

11.1 Hierarchy of Controls

11.2 Effectiveness of Controls

11.3 Modification and Adaptation of Controls

11.4 Process Design

11.5 Safe Working Procedures/Permits etc.

11.6 Assessment of Risks/Hazards

11.7 Accordance/Minimization of Risk

11.8 Emergency Preparedness/Response

11.9 Hazardous Agent Management



11.10 Co-ordination of Departments

11.11 Health Screening

12. Preventive and Corrective Action System

12.1 Anticipation of Events

12.2 Preventive Maintenance

12.3 Routine Inspections/Surveys

13. Procurement and Contracting

13.1 Safety Assessment of Procured Products

13.2 Assessment of Contractors

13.3 Control/Supervision of Contractors

13.4 Rules for Contractors

14. Communication System

14.1 Between the Enterprise and Employees

14.2 External Communication

14.3 Document/Record Management System

14.4 Specialist Advice/Information

15. Evaluation System

15.1 Auditing and Self Inspection

15.2 OHSMS response to changes in circumstances

15.3 Incident Investigation and Risk Cause Analysis

15.4 Health Surveillance

16. Continual Improvement

16.1 Senior Management Commitment

16.2 Mechanisms for Achievement

17. Integration

17.1 Integration of OHS processes into organizational processes

17.2 Common goals for the OHSMS and the organization

18. Management Review

18.1 Performance Evaluation

18.2 Feedback into OHSMS



18.3 Information to Stakeholders

19. External Certification and Accreditation

20. Bibliography

Annexes: OHSMS Auditing General Principles/Procedures/Qualifications

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IOHA Report to ILO on an International OHSMS - Appendix A[Title page] [Table of Contents] Chapters: I II III Appendices: A B C D E F G [Bottom]

Appendix A

Standards, Guidance Documents, and Codes of Practice Analyzed

Country/Region Publisher Reference No. Title

1. Australia/NewZealand

Standards AustraliaStandards NewZealand

AS/NZS4804:1997

Occupationalhealth and safetymanagementsystems - Generalguidelines onprinciples, systemsand supportingtechniques

2. Australia,Victoria

Health and SafetyOrganisation (HSO),Victoria

SafetyMap SafetyManagementAchievementProgram(SafetyMAP)

3. Brazil Ministry of Labor NR-9 (PPRA) EnvironmentalRisk PreventionProgram

4. European Union The Council of theEuropeanCommunities

CouncilRegulationNo. 1836/93

CommunityEco-Managementand Audit Scheme(EMAS)

5. India Ministry of Labour Section 41F ofthe FactoriesAct, 1948,revised 1988

Various

6. International Oil IndustryInternationalExploration andProduction Forum(E&P Forum)

Report No.6.36/210

Guidelines for theDevelopment andApplication ofHealth, Safety andEnvironmentalManagementSystems

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7. International InternationalOrganisation forStandardization -Technical Committee67, Subcommittee 6,Workgroup 1

ISO/WD 14690, N46 rev.2

Petroleum andnatural gasindustries -HEALTH, SAFETYANDENVIRONMENTALMANAGEMENTSYSTEMS

8. International InternationalOrganisation forStandardization -Technical Committee207

ISO14001:1996

Environmentalmanagementsystems -specification withguidance for use

9. Ireland The NationalStandards Authority ofIreland

OH and S Draft Standard forCode of Practicefor anOccupationalHealth and Safety(OH and S)ManagementSystem

10. Jamaica Jamaica Bureau ofStandards

Draft OH&S1/2

Draft JamaicanStandardGuidelines forOccupationalHealth and SafetyManagementSystems - GeneralGuidelines onPrinciples,Systems andSupportingTechniques

11. Japan Japan Industrial Safety& Health Association

March 1997 OccupationalHealth and SafetyManagementSystem (OHS-MS):JISHA Guidelines

12. Korea Ministry of Labor,Republic of Korea

1998 Labor Laws ofKorea, IndustrialSafety and HealthAct, Chapter II -Safety and HealthManagementSystems.

13. The Netherlands NederlandsNormalisatie-Instituut

NPR 5001 Dutch TechnicalReport: Guide toan occupationalhealth and safetymanagementsystem



14. Norway NorgesStandardisengsforbund

96/402803August 27,1996

NorwegianProposal:ManagementPrinciples forEnhancing Qualityof Products andServices,OccupationalHealth & Safety,and theEnvironment

15. Poland Phare Programme tothe Polish State,Labour Inspector

WorkerProtectionProgrammePL 9407November1996

Safety and HealthManagement inSME’s: Best EUPracticesRegarding Safetyand HealthManagement inSmall and Mediumenterprises(SME’s), How CanLabour InspectionSupport LabourPrevention

16. South Africa National OccupationalSafety Association

Reg. No.51/0001/08;HB 0.0050E

The NOSA 5 StarSafety & HealthManagementSystem

17. Spain Asociacion Espanolade Normalizacion yCertificacion

UNE 81900December1996

Prevention ofoccupational risks:General rules forimplementation ofan occupationalsafety and healthmanagementsystem

18. United Kingdom British StandardsInstitution

BS 8800:1996 Occupationalhealth and safetymanagementsystems

19. United Kingdom Chemical IndustriesAssociation

Third Edition,1998

Responsible CareManagementSystem

20. United States American IndustrialHygiene Association

AIHA OHSMS96/3/26

OccupationalHealth and SafetyManagementSystem: An AIHAGuidanceDocument



21. United States ChemicalManufacturersAssociation

EmployeeHealth andSafety Code

Responsible Care:A Resource Guidefor the Employeehealth and SafetyCode ofManagementPractice

22. United States Occupational Safetyand HealthAdministration

FederalRegister,4/12/88

VoluntaryProtectionPrograms

23. United States Occupational Safetyand HealthAdministration

None yet1910.700

Draft ProposedSafety and HealthProgram Standard

24. United States,California

Department of Laborand IndustrialRelations - Cal OSHA

Title 12,Subtitle 8, Part2, Chapter60-2

General Safetyand HealthRequirements:Safety and HealthPrograms

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Appendix B

Methods and Definitions

Each standard received was compared against the Review Questions (see next page) to identify itscurrency, status and intended use, and the 27 variables set out in Table No. 1. A brief description ofeach of these variables is given in this Appendix.

Following a comparison with the OHSMS variables, a short appraisal of the standard was prepared,together with a summary if its content. The question of whether it meets the criteria to beconsidered "a system" is discussed. Any significant items which were not captured by the ReviewQuestion form or the Checklist, are also highlighted in this Appendix.

The analysis was reviewed by members of the project team and a number of external reviewers, asindicated in Appendix D.

ILO/IOHA ProjectStandard/Guidance Document - Review Questions

Standard/Guidance Document Origin:

Name of Standard/GuidanceDocument:

Reference Number:

_________________________

_______________________________________

_______________________________________

_________________________

Questions

1. When was the standard/guidance document published?

(date)

2. Has it been officially published? Or is it a draft?

(yes/no)

3. Is it known whether there are pending revisions?

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(yes/no)

4. It is published by what type of organization?

(government, national standards org., professional association, other)

5. What kind of OHSMS is it?

(part of an original OHS law/act, a national regulation, voluntary consensus standard,professional association best-practice, other)

6. Is it used by regulatory agencies to accomplish agency mandates/goals?

(yes/no)

7. Is it considered an auditable standard?

(yes/no) As stated in the standard/guidance document.

8. Is it an auditable standard?

(yes/no) Answer after completing checklist. Are clauses stated as "shall" or "should." Is thisa guidance document (e.g. ISO 9004 or 14004) that is not meant to be an auditablestandard?

9. Is it a management system?

(the five general system elements are: input, process, output, feedback, and open-systemelements). All five elements of the general systems model must be present. The feedbackand open-system elements are considered most crucial to this definition. Use the checklist tomake determination.

10. Are there technical appendices? What do they cover?

(yes/no) Provide description if yes.

11. Is it known whether a companion evaluation/audit guidance document has beenprepared?

(yes/no)

12. Does the standard state limitations to its use?

(yes/no) Provide description if yes.

OHSMS Variables Definitions

1.0 Management Commitment and Resources

Management commitment to occupational health and safety may be operationally definedas: 1) the allocation of sufficient resources for the proper functioning of an OHS program ormanagement system; 2) the establishment of organizational structures whereby managersand employees are supported in their OHS duties; and, 3) a senior managementrepresentative, who is responsible for overseeing the proper functioning of the OHSMS, isdesignated.




Many governmental regulations and non-governmental standards impose requirements onoccupational health and safety management and, therefore, can affect the way an OHSMS isdesigned, implemented, and operated. Organizations need to understand incorporate thegovernmental regulations and non-governmental standards which apply to them, and toincorporate their requirements into the policies, procedures and goals of the OHSMS.

1.2 Accountability, Responsibility, and Authority

These variables address the manner in which an organization defines the roles of personnelwho are involved in OHSMS management, and the employees, supervisors, and managerswho are affected by it. Crucial to role definition is the manner in which occupational healthand safety and OHSMS accountability, responsibility, and authority are defined, supported,and enforced by senior management.

2.0 Employee Participation

Employee participation in OHS management may be operationally defined in any number ofways. The key requirement is that employees have input into OHS considerations, and thatthe input is meaningful, valued, and can affect policies and practices. Many OHSprofessionals have identified employee participation in occupational health and safetymanagement as the variable essential to successful OHS management and illness/injuryreduction, for example through joint employee/employer committees, steering/task/workinggroups, etc.

3.0 Occupational Health and Safety Policy

The OHS policy represents the foundation from which OHS goals and objectives,performance measures, and other system components are developed. The OHS policyshould be short, concise, easily understood, approved by the highest level of management,and known by all employees in the organization. It can be expressed in terms oforganizational mission or vision statements. It is a document that expresses theorganization’s OHS values.

4.0 Goals and Objectives

The development of OHS goals and objectives follows naturally from the OHS policydevelopment activities. With the OHS policy established, there is a foundation upon whichOHS goals and objectives can be built. The establishment of OHS goals and objectivesrepresents the beginning of a progression from the conceptual realm of the OHS policy to anoperational realm as expressed in the overall system structure/design and OHSMSmanual/documentation or information system. They should be measurable and appropriateto the size, nature, and complexity of the organization’s activities.

5.0 Performance Measures

The ability to measure OHS performance over time is essential to eliminating occupationalinjuries and illness, and to verify continuous improvement. To achieve this, the organizationshould develop performance measures that are consistent with the OHS variables expressedin the OHS policy and goals and objectives, and measure both preventive ("upstream") andtrailing performance indicators.

6.0 System Planning and Development

System planning and development activities address both initial OHSMS development andongoing revision and modification of the system. These variables address the manner inwhich the overall structure and form of the OHSMS will be developed, implemented, and



subsequently modified to achieve the required level of performance and continuousimprovement.

6.1 Baseline Evaluation and Hazard/Risk Assessment

A baseline evaluation or review of the organization’s existing OHS management practicesand OHS hazards is necessary before a robust OHSMS can be completely designed orimplemented. The baseline evaluation needs to identify OHS hazards and their associatedrisks clearly. This information is essential to the development of numerous OHSMScomponents, including the training system, hazard control system, and the emergencypreparedness and response system. Failure to properly identify hazardous and associatedrisks can lead to inadequate employee protection on one hand, or overzealous protectivemeasures, which are not cost effective, on the other.

7.0 OHSMS Manual and Procedures

The OHSMS manual or its electronic equivalent is the document where OHS and OHSMSpolicies and procedures are to be found. The manual should be easily accessible toemployees, taking into account levels of education and possible language barriers. It shouldbe written in clear language and should use graphic illustrations where possible tocommunicate the intended information.

8.0 Training System

The term training system is used broadly to reflect the importance of knowledgedissemination and skill development in a well functioning OHSMS. OHS training has beenan integral component of OHS management for many years. It is universally recognized asan essential element in maintaining a healthy and safe workplace.

8.1 Technical Expertise and Personnel Qualifications

Successful OHSMS operation requires qualified and competent personnel. This includespersonnel in the organization who have direct OHSMS responsibilities as well as externalconsultants who may provide OHS services to the organization.

9.0 Hazard Control System

The hazard control system is broadly defined to include the various methods used to reduceor eliminate occupational hazards, and the methods through which the control system ismodified as workplace conditions change. Control methods are typically defined in terms ofadministrative controls, personal protective equipment (PPE), or engineering controls.

9.1 Process Design

Process design addresses the OHS actions associated with the installation of new processesor operations. Examples are: the installation of new office work stations; modificationsmade to an existing manufacturing process; or, development of a new hazardous wastedisposal operation.

9.2 Emergency Preparedness and Response System

Emergency preparedness and response refers to the manner in which the organizationprepares for and responds to OHS emergencies and accidents. Emergency preparedness andresponse system actions are initiated and conducted immediately when events occur that cancause illnesses, injuries, or fatalities. Emergency response covers many possible hazardscenarios including, for example, evacuation of an office building, spill of a flammableliquid, release of a toxic gas, incapacitation of workers by unknown agents, and health fromthe elements (flood, earthquake, excessive heat/cold, etc.).



9.3 Hazardous Agent Management System

The term hazardous agent refers to chemical, biological and physical agents, including suchthings as radioactive materials, noise, heat, cold, lasers, and hazardous wastes. Thehazardous agent management system is an important component of the more broadlydefined hazard control system. The key issues addressed here are the identification ofhazardous agents, understanding of their risks, elimination or control of the risks, andestablishment of mechanisms to ensure the actions of all those involved in the process areeffectively coordinated.

10.0 Preventive and Corrective Action System

Preventive and corrective action refers to actions taken in response to, or in anticipation of,system breakdowns or high hazard/risk events. Central to an effective system is that inwhich actions should be as anticipatory as possible. That is, actions should be taken inadvance to prevent an incident or other unplanned event that might adversely affect workerhealth, or that would require emergency or other response actions. Safe working proceduresand practices are key elements of this system.

11.0 Procurement and Contracting

Products and contractors can impact workplace health and safety. This OHSMS variableaddresses the need to be aware of such impacts and the need for mechanisms to controlthem. This can include minimum requirements for the behavior of contractors while on theorganization’s premises. In some cases, it may be appropriate for contractors to follow all ofthe organization’s safety rules. It can also include a mechanism to evaluate the manner inwhich all incoming products or items may affect workplace health and safety.

12.0 Communication System

The communication system can be defined and implemented in several ways. In its mostbasic form, a viable communication system should identify how, and to whom, informationfor the proper functioning of the OHSMS will be transmitted. A well-functioningcommunication system with defined feedback channels is essential for a successfulOHSMS. This system component provides the means by which all other system variablesrelate and interact.

12.1 Document and Record Management System

The document and record management system addresses the way the organization managesand organizes OHSMS documents and records; this can include both hard-copy andelectronically stored information. A well-functioning document and record managementsystem is an essential prerequisite for effective communication of policies, standards andprocedures, and for an organisation’s ability to be able to demonstrate that it is achievingwhat it said it would. It is of particular importance in organizations that are pursuingOHSMS registration or certification. The document and record management systemprovides one of the key indicators of whether the OHSMS is currently in conformance, andwhether the probability is good that conformance will be maintained over time.

13.0 Evaluation System

The evaluation system is broadly defined and includes baseline evaluations, auditing,self-inspection and self-correction, incident investigation, medical surveillance, andmanagement review activities. These activities are fundamental to the system’s ability tofunction and sustain itself over time, and ensure continuous improvement.

13.1 Auditing and Self-Inspection



OHS auditing and self-inspection are specific activities of the evaluation system whereinformation is gathered and assessed on individual OHS programs and systems. Theseactivities include an assessment of changes in OHS hazards and the ability of the OHSMS torespond properly to the changes. Auditing and self-inspection activities provide essentialinformation to other OHSMS components, including the training, hazard control, andpreventive and corrective action systems.

13.2 Incident Investigation and Root Cause Analysis

Incident investigation and root cause analysis refers to the activities conducted to determinethe origin and cause(s) of accidents, near miss accidents, injuries, fatalities, or breakdownsin the OHSMS. An important aspect of Incident Investigations is the performance of a rootcause analysis is to see at what point(s) the OHSMS failed, and how it can be modified topresent a reoccurrence.

13.3 Health/Medical Program and Surveillance

Health and/or medical programs and surveillance refers to the activities associated withproviding occupational health services within the organization, and the development andoperation of a health surveillance and promotion program. An occupational healthsurveillance program, when workplace hazards dictate, is a key component of an OHSsystems approach, and provides feedback on the effectiveness of the hazardous controlsystem.

14.0 Continual Improvement

Continual improvement may be operationally defined and implemented in any number ofways. The basic notion is that the organization should seek ways to achieve ongoingimprovement of occupational health and safety performance. The ultimate goal of continualimprovement activities is to eliminate worker injury and illness, and to move towards theultimate goal in a measured and consistent manner.

15.0 Integration

Integration refers to the actions the organization takes to integrate its occupational healthand safety functions and procedures with other management system and business processesin the organization and in the community. A successful OHSMS requires that the elementsof the OHSMS be connected, or related, to other key functions in the organization. Thismeans that OHS issues and aspects of the OHSMS will be part of the organizational culture,and that the goals and objectives become the organsational goals, and goals for managers inthe organisation.

16.0 Management Review

The overall performance of the OHSMS is evaluated through management reviews. It isthrough this activity that the OHSMS, the organization, and the environment external to theorganization are linked. This involves evaluating the OHSMS’s ability to meet the overallneeds of the organization, its stakeholders, its employees, and regulating agencies.

Basis for the Universal OHSMS model used in this analysis

The 27 OHSMS variables used in the analysis conducted were developed during the construction ofa Universal OHSMS Assessment Instrument (UAI) at the University of Michigan (Redinger, 1998).From the initial discussions in The Michigan Occupational Health and Safety (OHS) Policy Groupwhich led to the development of the UAI, an identified goal was to construct an instrument whichwould be able to measure the effectiveness of a wide range of OHSMSs. Even though it wasacknowledged by some in the group, and their colleagues, that this goal might be difficult to



achieve, it was clear that it would be a significant contribution to the OHS field if one singleinstrument could be constructed. In order to meet this goal of developing a universal assessmentinstrument, it was first necessary to identify and define the universe of OHSMSs and create auniversal OHSMS upon which the UAI would be based.

To define this universe, 13 publicly-available systems were reviewed, seven of which wereOHSMSs. The remaining six systems were quality assurance management systems (QAMS) orenvironmental management systems (EMS). Three OHSMS and one EMS models were selected foruse in the UAI development process. These four models were selected because they provided themost comprehensive management system approaches and contained the essential elements of all ofthe models reviewed. The four models are referred to herein as input models. These input modelsare:

The Occupational Safety and Health Administration’s (OSHA), Voluntary ProtectionProgram (VPP);

1.

The British Standards Institution’s OHSMS, BS 8800:1996;2.

The American Industrial Hygiene Association’s OHSMS; and,3.

The International Organization for Standardization’s EMS model, ISO 14001:1996.4.

The VPP was selected because it represents the most comprehensive OHS management systemapproach within OSHA and encompasses elements of other systems approaches in OSHA, such asthe 1989 Guidelines, Consultation’s SHARP/form 33, the Performance Evaluation Profile (PEP),and the draft OHS program standard. The British OHSMS contains two approaches. One is basedon ISO 14001 and the other is based on the British Health Safety Executive’s (HSE) OHSGuidelines HS(G) 65. Both of these approaches were considered during the development of theInstrument. The AIHA’s OHSMS is an ISO 9001-based OHSMS. Strictly speaking, ISO14001:1996 is not an OHSMS. It was selected based on its increasing visibility since itspromulgation in 1996. Initial indications are that many organizations have been organizing theirOHSM functions, along with environmental management functions, according to the ISO 14001model.

Input Model Partitioning

Following their selection, the four input models were partitioned into their respective individualvariables; these variables can also be called, auditable clauses.

The four input models were transferred from hard copy to electronic form. Once in electronic form,the models were reviewed and partitioned into individual auditable clauses. Care was taken toensure that the unique clause reference numbers were maintained during this process. In order toguide the model partitioning process, the following decision rules were developed and followed.

Input Model Partitioning Rules

Each auditable clause shall contain only one auditable issue. If more than one auditableissue is present in a given input clause, the clause shall be subdivided into multiple clausesuntil only a single auditable issue remains.

1.

In the case where the separation of a clause would adversely impact its meaning, the clausemay stay intact. However, it will be appropriately cross-referenced.

2.

When input-model clauses are sub-divided into single auditable clauses, language may beadded to make complete sentences or to restore any lost meaning which occurred throughthe separation process. Such added language must be clearly indicated and consistent withthe original intent of the input model from which the clause originated.

3.

Regrouping and Labeling

Following the partitioning of the input models into single auditable clauses, the clauses wereregrouped according to common issues. As with the model partitioning process, decision rules were



developed and followed to guide the clause regrouping process. These decision rules follow.

Regrouping and Arrangement Rules

Clauses shall be arranged by the primary issue (dimension) addressed in the clause.1.

In the case where more than one issue is included in a single clause, the secondary (ortertiary) issue shall be cross-referenced to the appropriate section of the instrument. Forinstance, a clause that states the need for the policy statement to contain a commitment tothe development of OHS goals and objectives, will be listed in Section 4.0 (Goals andObjectives) and will be cross-referenced with Section 3.0 (OHS Policy).

2.

From initial regrouping efforts to the final grouping, five iterations were conducted. Each iterationincluded the application of the decision rules to the clauses. The iterations were continued until thedecision rules were wholly satisfied. Additional iterations were necessary as to ensure that 1)elements truly contained only one auditable issue, and 2) that groupings were as precise as possible.

Following the final grouping, two quality-control exercises were performed. The first involved thereview of the groupings by a panel of 12 OHS or management-systems experts. Comments from thereviewers were incorporated. Second, once in its final form, hard-copies of the input models werechecked against each input element in electronic form to ensure that no input elements were omittedor deleted during the five iterations and panel review activities. Necessary corrections were made.

Labels for these groupings (referred to as UAI sections) were generated based on the major conceptor distinction represented in the groupings and knowledge of the labels that represented the inputelements from the original models. The labeling effort was also influenced by systems theory,policy analysis, and program evaluation nomenclature.

Overall Instrument Structure

Based on various systems, policy analysis, and program evaluation models, the UAI structure wascreated. The UAI sections were grouped into five categories as follows:

Initiation (OHS Inputs);1.

Formulation (OHS Process);2.

Implementation/Operations (OHS Process);3.

Evaluation (OHS Feedback); and,4.

Improvement/Integration (Open System Elements).5.

These categories are partially based on the policy analysis model developed by Brewer and deLeonand a simplified systems model.

The UAI sections, as arranged in the five categories listed above, were then arranged according to aconstruct which identified 1) occupational health and safety in the organization, 2) the organization,and, 3) the external environment (Figure No. 1). This construct is significant in that it reflects theopen system nature of OHSMSs and its need to interact with the organization as a whole, as well aswith the external environment. In this construct, the external environment is defined as stakeholdersand regulating agencies/units who have an interest in the organization’s performance.

IOHA Report to ILO on an International OHSMS - Appendix B[Title page] [Table of Contents] Chapters: I II III Appendices: A B C D E F G [Top]


For further information please contact the International Occupational Safety and Health Information Centre




at Tel: +41.22.799.6740, Fax: +41.22.799.8516 or E-mail: [email protected]





















IOHA Report to ILO on an International OHSMS - Appendix C[Title page] [Table of Contents] Chapters: I II III Appendices: A B C D E F G

Appendix C

Analysis

1. Australia/New Zealand 2. Australia, Victoria3. Brazil4. European Union5. India6. International7. International - ISO8. International - ISO

9. Ireland10. Jamaica11. Japan12. Korea13. The Netherlands 14. Norway15. Poland16. South Africa

17. Spain18. United Kingdom19. United Kingdom20. United States21. United States22. United States23. United States24. United States, California

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IOHA Report to ILO on an International OHSMS - Appendix D[Title page] [Table of Contents] Chapters: I II III Appendices: A B C D E F G [Bottom]

Appendix D

List of External Reviewers

Roger Alesbury Manager, Occupational & Environmental HealthBP International Ltd, Sudbury on ThamesUNITED KINGDOM

Lindsay Callard Health, Safety & Environment EngineerBP International Ltd, Sudbury on ThamesUNITED KINGDOM

Brian Davies IOHA Board Member andDirector of Australian Environmental HealthServices Pty Ltd., Figtree, NSWAUSTRALIA

Kurt Leichnitz IOHA Executive Board Member andHealth and Safety Consultant, Gross GroenauGERMANY

Vern Rose American Industrial Hygiene Association, Past-PresidentProfessorThe University of AlabamaUNITED STATES

Teuvo Uusitalo Assistant ProfessorInstitute of Occupational Safety Engineering,Tampere University of TechnologyFINLAND

James Vincent Professor and ChairDepartment of Environmental and Industrial HealthThe University of MichiganUNITED STATES

IOHA Report to ILO on an International OHSMS - Appendix D[Title page] [Table of Contents] Chapters: I II III Appendices: A B C D E F G [Top]


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IOHA Report to ILO on an International OHSMS - Appendix E[Title page] [Table of Contents] Chapters: I II III Appendices: A B C D E F G [Bottom]

Appendix E

Biographical Sketches of Report Contributors

Hugh L. DalrympleICLOld Windsor, BerksUNITED KINGDOM44 0 1753 604 [email protected]

Hugh Dalrymple has worked in the Occupational Health and Safety field for over 20 years,mainly in occupational hygiene. His career includes occupational hygiene appointmentswith British Airways, ITT and STC. He is currently Occupational Hygiene and SafetyManager for the computer software and services company ICL, part of the Fujitsu Group.

He has also been a consultant to the International Labour Office (ILO) in Geneva, onSafety and Health in the Electronics Industry. He has served for many years as a CouncilMember and Treasurer of the British Occupational Hygiene Society, and was President ofthe Society in 1996 to 1997.

His interest in Standards for Health and Safety Management grew out of the profoundeffects that the quality standards BS5750 and ISO 9000 had on the attitudes of managersin industry, and on the culture of organisations. He was appointed representative of the(UK) Institute of Occupational Hygienists on the British Standards Institution Committeeresponsible for drafting BS8800, a 'Guide to Health and Safety Management Systems',published in 1996.

Charles F. Redinger, CIH, MPA, PhDErb Environmental Management Institute, University of Michigan, and Redinger & AssociatesSan Francisco, CaliforniaUNITED STATES415 575 [email protected]

Charles Redinger is an Occupational Health Fellow at The University of Michigan’s ErbEnvironmental Management Institute and a principal with Redinger & Associates.

The focus of Dr. Redinger’s work is international policy and standards development. Overthe past several years he has been at the forefront of the occupational health and safetymanagement system (OHSMS) arena.

He has a PhD in Environmental and Industrial Health from The University of Michigan, andan MPA in public policy from The University of Colorado. He is a member of the PublicPolicy honor society Phi Alpha Alpha; and, has been a Kemper Fellow in Public Health.

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David T. Dyjack, CIH, MSPH, DrPHLoma Linda UniversityLoma Linda, CaliforniaUNITED STATES909 478 [email protected]

David Dyjack is the Chairman of Loma Linda University School of Public Health'sDepartment of Environmental and Occupational Health.

He was the primary author of the American Industrial Hygiene Association's OccupationalHealth and Safety Management System guidance document and has published severalpapers on the benefits and challenges associated with the systems approach to healthand safety.

Dr. Dyjack received an MSPH in Industrial Hygiene from the University of Utah in 1992and a DrPH in Occupational Health from the University of Michigan in 1996.

Steven P. Levine, PhD, CIHUniversity of Michigan, School of Public Health, and Erb Environmental Management InstituteAnn Arbor, MichiganUNITED STATES734 995 [email protected]

Steven Levine began his career in industry where worked for eight years. He worked forStauffer Chemical Company, Ford Motor Company, and Oil and Hazardous Materials(OHM) Company. He has been at The University of Michigan for thirteen years andcurrently is Professor of Occupational and Environmental Health.

Professor Levine is the Director of the University of Michigan WHO Collaborating Centrefor Occupational Health. He has been a member of the ISO 9000 and 14000 AdvisoryCouncils of a non-profit company, NSFI; and, a member of the U.S. Technical AdvisoryGroup for ISO TC-207. He is certified by the ABIH in both Comprehensive and ChemicalPractice; and, by the IRCA against the ISO 10,011.2 requirements.

Over the past several years he has been a pioneer in the occupational health and safetymanagement system area. The research teams and mentoring have made significantcontributions to management system theory and practice.

S.Z. Mansdorf, MS, PhD, CIHA.D. Little Cambridge, MassachusettsUNITED STATES617 498 [email protected]

Zack Mansdorf is Director of Safety and Risk Management Consulting for Arthur D. Little.He is a past president of the American Industrial Hygiene Association and was the founderof Mansdorf & Associates, an industrial hygiene/occupational health consultancy based inAkron, Ohio.

Dr. Mansdorf has published numerous books and articles on a wide range of occupationalhealth topics. Over the past several years he has been active internationally in bothOHSMS policy and technical development.

Among other degrees and honors, Dr. Mansdorf has an MS in Environmental andIndustrial Health from the University of Michigan and a PhD in Environmental Science from






the University of Kansas.

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IOHA Report to ILO on an International OHSMS - Appendix F[Title page] [Table of Contents] Chapters: I II III Appendices: A B C D E F G [Bottom]

Appendix F

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Chen, Huey-tshy and Rossi, Peter, editors (1992); Using Theory to Improve Program and PolicyEvaluations, Greenwood Press, New York, New York.

Clayton, George D. and Clayton, Florence E., editors (1978); Patty's Industrial Hygiene andToxicology, Volume I, General Principles. John Wiley & Sons, New York, New York.

Corn, Jacqueline K. (1992); Response to Occupational Health Hazards: A Historical Perspective.Van Nostrand Reinhold, New York, New York.

Corn, Morton (1995); "Research & the Future of the Profession." Presentation given at theAmerican Industrial Hygiene Conference and Exhibition, Kansas City, Missouri, May 23, 1995.Forum no. 3 titled, Setting a National Research Agenda for Industrial Hygiene.

Davies, Kathleen (1994); "ISO 9000 Consistency and Control." Occupational Hazards, May 1994,pp. 121-124.

deVaus, D.A. (1986); Surveys in Social Research. George Allen & Unwin Publishers, Winchester,Massachusetts.

Dyjack, David and Levine, Steven (1995); "Development of an ISO 9000-Compatible OccupationalHealth Standard: Defining the Issues." American Industrial Hygiene Journal, Volume 56, number6, pp. 599-609.

Dyjack, David (1996); Development and Evaluation of an ISO 9000-Harmonized OccupationalHealth and Safety Management System. Doctoral Dissertation, University of Michigan, Ann Arbor,Michigan.

Levine, S.P. and Dyjack, D.T. (1997) "Critical Features of an Auditable Management System for anISO 9000-Compatible Occupational Health and Safety Standard." American Industrial HygieneJournal, 58:291-298.

Eccles, R.G. (1995); "The Performance Measurement Manifesto." In Performance Measurementand Evaluation, Sage Publications Inc., Thousand Oaks, California. Edited by Jacky Holloway andJenny Lewis.

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IOHA Report to ILO on an International OHSMS - Appendix G[Title page] [Table of Contents] Chapters: I II III Appendices: A B C D E F G [Bottom]

Appendix G

About the International Occupational Hygiene Association

At the present time IOHA includes 22 associations from 20 nations with a total membership ofabout 20,000 persons: Australia, Belgium, Canada, Denmark, Finland, France, Germany, HongKong, Ireland, Italy, Japan, The Netherlands, Norway, South Africa, Spain, Sweden, Switzerland,United Kingdom and the USA. IOHA is a Non-Governmental Organisation of the World HealthOrganisation.

Objectives of IOHA

The Association has several objectives. It seeks to spread the benefits of occupational hygieneworld-wide. It promotes the exchange of occupational hygiene information among interestedindividuals and organisations. It endeavours to promote the development of occupational hygieneand its practice according to the highest ethical standards.

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