Safety Management Systems (SMS): a Comparison

Tim Neubauer, CSPPresident

Evolution Safety Resourcest.neubauer@evolutionsafetyresources.com

919-650-9172

Objectives

• Review the historical perspective

• Explore the common elements and contrast

their differences

• Identify the best SMS for your employer

• Discuss ways to implement an SMS

OHSMS Evolution

ISO

9001

OSHA

VPP

Program

ISO

14001

BS

8800

OHSAS

18001

ILO

OSH/2001ANSI

Z10

1979 1987 1996 1996 1999 2001 2005

1976 International

Safety Rating System

(ISRS) Frank Bird, et

al.

OSHA’s Voluntary

S&H Mgmt Program

Guidelines 1989

Occupational health

and safety

management

systems-Guide

National Standards

U.S. ANSI Z10

(2005)

OHSMS Evolution

ISO

31000

OHSAS

18001ISO MMSFramework

ISO

22301ANSIZ10

ISO

45001

2007 2009 2010 2012 2012 2016

Risk Management

Standard

Aligns 9000 & 14000

framework

Business community

Mgmt. System

OSHA SHPMG draft

• Reduce risk

• Reduce in incidents, downtime and associated costs

• Better management of S&H risks, now and in the future

• Gain competitive advantage Increased access to customers, business partners

• Demonstrate S&H commitment to stakeholders

• Conform to regulatory compliance

• Improve overall organizational performance

• Accentuate commitment to an innovative and forward thinking approach (CIP)

Why Have an SMS?

Examples of SMS’s

• OSHA Voluntary Protection

Program ( VPP)

• Injury and Illness Prevention

Plans (I2P2)

• OSHA Safety and Health

Program Management

Guidelines (SHPMG) draft

• ANSI/AIHA/ASSE Z10

• OHSAS 18001

• ISO 45001 draft

• MIL-STD-882E 2012 (DoD)

• ACC – Responsible Care

• SOCMA - ChemStewards

• National Safety Council – 9

Elements

• Well developed internal system

Turn and Talk

• Do you have a Safety Management System?

– If yes….

• Which one?

• What benefits have you seen?

– If no…• Are you considering a Safety Management System?

• Why?

OSHA SHPMG

• Management Leadership

• Worker Participation

• Hazard Identification and Assessment

• Hazard Prevention and Control

• Education and Training

• Program Evaluation and Improvement

• Coordination and Communication on Multiemployer Worksites**

+ tools & appendices

OSHA SHPMG

Management Leadership

1. Communicate your commitment to a S&H program

2. Define program goals & expectations

3. Allocate resources

4. Expect performance

OSHA SHPMG

Worker Participation

1. Encourage workers to report S&H concerns

2. Encourage workers to participate in the programs

3. Involve workers in all aspects of the program

4. Give workers access to S&H info

5. Remove barriers to participation

OSHA SHPMG

Hazard Identification & Assessment

1. Collect existing info about workplace hazards

2. Inspect the workplace

3. Conduct incident investigations

4. Identify hazards associated w/ emergency & non-routine situations

5. Characterize the nature of identified hazards, determine controls to be implemented, prioritize hazards for control

OSHA SHPMGHazard Prevention & Control

1. Identify control options

2. Select controls

3. Develop & update a hazard control program

4. Select controls to protect workers during non-routine operations & emergencies

5. Implement selected controls in the workplace

6. Follow up to confirm controls are effective

OSHA SHPMG

Education & Training

1. Provide program awareness training

2. Train workers on their specific roles & responsibilities in the S&H program

3. Train workers on hazard identification & controls

OSHA SHPMG

Program Evaluation & Improvement

1. Monitor performance & progress

2. Verify program is implemented & operating

3. Correct program deficiencies & identify opportunities to improve

OSHA SHPMG

Coordination & Communication of Multiemployer Worksites

1. Management leadership

2. Worker participation

3. Hazard identification & assessment

4. Hazard prevention & control

5. Education & training

6. Program evaluation & improvement

Coordination & Communication on Multiemployer Worksites

• Ers occasionally have other employers’ workers present in their workplace: janitorial staff, temporary clerical support, specialized workers – electricians, mechanics

• These workers (like those you employ) can be exposed to safety/health hazards present in your workplace

• E.g.: maintenance contractors enter mechanical rooms where asbestos-containing material is present; access roofs where skylights can pose fall hazard

• Contractor Ers might create hazards in your facility due to work they perform: welding fire hazard; wet-mopping floors slip/fall hazard

Z10 Elements

1. Scope, Purpose and Application

2. Definitions

3. Management Leadership and Employee

Participation

4. Planning

5. Implementation and Operation

6. Evaluation and Corrective Action

7. Management Review

8. Appendices

ANSI/AIHA/ASSE Z10 – 2012

3.0 Management Leadership and

Employee Participation

4.0 Planning

ANSI/AIHA/ASSE Z10 – 2012

5.0 Implementation and Operation5.1 OHSMS Operation Elements

5.1.1 Hierarchy of Controls5.1.2 Design Review and Management of Change5.1.3 Procurement5.1.4 Contractors5.1.5 Emergency Preparedness

5.2 Education, Training and Awareness5.3 Communication5.4 Documentation and Record Control Process

ANSI/AIHA Z10 – 2012

6.0 Evaluation and Corrective Action

7.0 Management Review

OHSAS18001Clause OHSAS 18001

1 Scope

2 Reference publications

3 Terms and definitions

4 OH&S management system elements

4.1 General requirements

4.2 OH&S policy

4.3 Planning

4.3.1 Planning for hazard identification, risk assessment and risk

control

4.3.2 Legal and other requirements

4.3.3 Objectives

4.3.4 OH&S management programme(s)

4.4 Implementation and operation

4.4.1 Structure and responsibility

4.4.2 Training, awareness and competence

4.4.3 Consultation and communication

4.4.4 Documentation

4.4.5 Document and data control

4.4.6 Operational control

4.4.7 Emergency preparedness and response

4.5 Checking and corrective action

4.5.1 Performance measurement and monitoring

4.5.2 Accidents, incidents, non-conformances and corrective and

preventive action

4.5.3 Records and record management

4.5.4 Audit

4.6 Management review

Annex A Correspondence to ISO 14001, ISO 9001

Bibliography

BS OHSAS 18001 – 2007

4.0 OH&S management system elements

4.1 General requirements

4.2 OH&S policy

4.3 Planning

4.3.1 Hazard identification, risk assessment &

determining controls

4.3.2 Legal and other requirements

4.3.3 Objectives and programs

BS OHSAS 18001 – 2007

4.4 Implementation and operation4.4.1 Resources, roles, responsibility,

accountability and authority4.4.2 Competency, training and awareness4.4.3 Communication, participation and

consultation4.4.4 Documentation4.4.5 Control of documents4.4.6 Operational controls4.4.7 Emergency preparedness and response

BS OHSAS 18001 – 2007

4.5 Checking4.5.1 Performance measurement and monitoring4.5.2 Evaluation of compliance4.5.3 Incident investigation, nonconformity,

corrective action and preventative action4.5.3.1 Incident investigation4.5.3.2 Nonconformity, corrective and

preventative action4.5.4 Control of records4.5.5 Internal audit4.6 Management review

ISO 45001Clause ISO 45001

0 Introduction

1 Scope

2 Normative references

3 Terms and definitions

4 Context of Organization

4.1 Understanding the organization and its context

4.2 Understanding the needs and expectations of interested parties

4.3 Determining the scope of OH&S Management system

4.4 OH&S management system

5 Leadership

5.1 Leadership and commitment

5.2 OH&S Policy

5.3 Organization roles, responsibilities and authorities

6 Planning

6.1 Action to address risks and opportunities

6.2 OH&S Objectives and planning to address these

7 Support

7.1 Resources

7.2 Competence

7.3 Awareness

7.4 Communication

7.5 Documentation

7.5.1 General

7.5.2 Creating and updating

7.5.3 Control of updated information

8 Operation

8.1 Operational planning and control

9 Performance Evaluation

9.1 Monitoring, measuring, analysis and evaluation.

9.2 Internal audit

9.3 Management Review

10 Improvement

10.1 Non Conformity and corrective actions

10.2 Continuous improvement

Annex A Normative reference control objectives and controls

4 Context of the organization 4.1 Understanding the organization and its context 4.2 Understanding the needs and expectations

workers and other interested parties4.3 Determining the scope of OH&S management

system4.4 OH&S management system

5 Leadership, worker participation and consultation5.1 Leadership and commitment 5.2 OH&S Policy5.3 Organizational roles, responsibilities and

authorities5.4 Participation and consultation

ISO 45001 draft

6 Planning

6.1 Actions to address risks and opportunities

6.2 OH&S objectives and planning to achieve them

7 Support 7.1 Resources 7.2 Competence 7.3 Awareness 7.4 Information and communication 7.5 Documented information

7.5.1 General7.5.2 Creating and updating7.5.3 Control of documented information

ISO 45001 draft

8 Operation 8.1 Operational planning and control

8.1.1 General8.1.2 Hierarchy of controls

8.2 Management of change8.3 Outsourcing8.4 Procurement8.5 Contractors8.6 Emergency preparedness and response

ISO 45001 draft

9 Performance evaluation

9.1Monitoring, measurement, analysis and evaluation

9.1.1 General

9.1.2 Evaluation of compliance with legal requirements and other requirements

9.2Internal audit

9.2.1 Internal audit objectives

9.2.2 Internal audit process

9.3Management review

ISO 45001 draft

10 Improvement

10.1 Incident, non-conformity and corrective action

10.2 Continual improvement

10.2.1 Continual improvement objectives

10.2.2 Continual improvement process

ISO 45001 draft

ISO 45001 draft

• Heavily derived from OHSAS 18001

• Integrate better with other ISO

Management System Standards, e.g., ISO

9001, ISO 14001

• Promote the management of risk, and the

required risk management processes

• “Context” of organization: consider

contractors, stakeholders, customers

ISO 45001 draft

• The basis of the OH&S management system

approach applied is founded on the concept of

“Plan, Do, Check and Act” (PDCA)

ISO 45001 draft

• Risk, identification of risks, and actions to

address the identified risks

• Greater emphasis on assessing the

opportunities, especially the use of safe design -

this allows management systems to be more

flexible, but could be more difficult to audit

• Firm commitments on health and safety

performance, and social responsibility

Challenges

• Accident vs. Incident vs. Non-conformance

• Risk and risk matrix

• Corrective actions and preventative actions

• “Continual improvement” vs. continuous improvement

• Hierarchy of controls

ISO 45001 Project Committee (PC) No. 283

• ISO/PC 283 is responsible for the development of ISO 45001

• ISO/PC 283’s membership currently includes:

– 65 participating countries, (increase of 6 since Sept 2015)

– 13 observer countries (decrease of 2)

– 19 liaison members

Result of Ballot ISO 45001

• The ballot closed on 12th May 2016

• 71% voted in favor but this was insufficient to secure the necessary vote to proceed to FDIS

• There were nearly 3000 comments

3000 Comments!

• The “fulfillment of” or “compliance with”, etc., legal requirements

• Editing Notes to avoid the inclusion of requirements

• Editing of the term “consultation” due to its definition

• Alignment with ISO 14001 and deviation from Annex SL

• The term “worker” and its definition

• Clause 5.4 on Participation and Consultation

• Structure of Clause 6 • Training versus competence • The definition of “hazard” • A bullet in 7.3 to add

requirement for workers to be allowed to remove themselves from imminent danger

Timetable ISO- 45001 proposed

2013

Working

Draft

Draft Int

StandardCommittee

Draft

Final

Draft Int

Standard

Final

Standard

2014 2015 2016

Summer OctoberDecember2017

Expected

Transition

2 – 3 years

Summer Spring

Timetable ISO- 45001 actual

2013

Working

Draft

Draft Int

StandardCommittee

Draft

Final

Draft Int

Standard

Final

Standard2014 2015 2016 2018

Expected

Transition

2 – 3 years

2017

Draft Int

Standard 2

Common Elements

• S&H policy statement• Management leadership• Worker participation• Responsibility and

accountability• Planning, objectives• Measurement• Management review• Management of change (MOC)• Hazard recognition, evaluation

and control• Risk assessment

• Control of contracted activities• Incident investigation• Competency and training• Communication, promotion• Audits• Compliance• Corrective, preventative action• Documentation, control of records• Continuous improvement• Definitions, glossary

HOW DO WE MOVE

FORWARD?

Common SMS Mistake

Many safety professionals fail to speak

in terms of the benefits to the listener.

Sell Benefits to Stakeholders

• Benefits to company or location/site/plant?

• Benefits to management/leadership?

• Benefits to supervisor?

• Benefits to employee?

Reactive vs. Proactive

• TRADITIONAL PROGRAM

Random

Compliance focus

Program of the month

Minimum performance level

Task oriented

Safety person dependent

Tied to incentives

Continually reinventing

Managed by a dept.

• SAFETY MGNT SYSTEM

Systematic

Focus on significant risk

Sustaining process

Best practices

Continuous improvement

System reliant

Repeatable & measurable

Knowledge capture

Entire organization involved

Common SMS Mistake

Many safety professionals fail to guide leadership on the selection of a safety

management system.

How do We Choose?

• Already ISO 9000 and/or 14000 18001/45001

• Dealt w/ OSHA in the past OSHA S&H Mgmt. Guidelines

• Global organization 18001/45001

• US oriented ANSI/AIHA Z10, OSHA SHMPG

• Just like it! Makes sense Z10, 45001, create your own

Creating a Proprietary SMS

• Pro’s

– Specific

– Customized

– Cost effective

– Self-certify

• Con’s

– Auditing criteria

– Develop metric(s) to determine implementation progress

– Consistency

– No third party certification or registration

Common SMS Mistake

Many safety professionals fail to

conduct a baseline assessment to

determine current status of safety

management system.

Task 1

Establish MS Objectives

Task 2

Define Scope and Structure

Task 3

Allocate Resources

(including roles and responsibilities)

Task 4

Determine Compliance Status

Task 5

Identify & Organize

Existing EH&S DocumentationTask 6

Gap Assessment

Task 7

Establish Implementation Plan

Task 8

Aspect and Hazards Identification

& Risk Assessment

Task 10

Refine EHSMS ObjectivesTask 9

Develop DocumentationTask 11

Training and Communication

Task 12

EHSMS Implementation

Task 13

Internal Audit

Task 14

Management Review

Baseline Assessment

• Helps prioritize needs

• Allows for budgeting and integration of safety

improvements into general operating plan

• Better defines S&H accountability for leadership and

front line supervision

• Gives management a method of judging program

effectiveness other than injury/illness rates

Common SMS Mistake

Many safety professionals fail to

develop an improvement plan(s) for the

following year(s).

Improvement Plans

• “Given all that needs to be accomplished, with

limited resources , what can we achieve?”

• Stops unrealistic expectations or projects

• S&H “plans” like other parts of the organization

• Keeps everyone motivated

• Allows for accountability

Common SMS Mistake

Many safety professionals fail to educate leadership on the length of time required to

change an existing safety culture.

Phase 1 Phase 2 Phase 3 Phase 4 Phase 5 Phase 6

I

N

J

U

R

Y

R

A

T

E

S

What is

safety?

Don’t shut

us down

Incidents

cost too

much

Safety

excellence

is a top

priority

Safety

excellence

is a value

Safety

excellence

is

instinctive

Culture Focus

Self Assessment–Data Focus

Discipline/Compliance Focus

TIME

Journey to Safety Excellence

Common SMS Mistake

Many safety professionals fail to

develop appropriate proactive leading

metrics.

Continual Improvement

Leading vs. Lagging Indicators

• Leading Indicators– JSA’s

– Observation program

– Safety contact program

– Inspections

– Safety meetings

– Safety training

– Corrective actions

– Scored assessments/audits

– Perception surveys

• Lagging Indicators– Near misses

– Property damage

– TRIR

– DART

– LWDC

– Fatalities

– Workers’ Compensation costs

– Liability/litigation costs

– Regulatory citations & penalties

Other Considerations

• In sync with Quality Management System

• Continued leadership commitment

• Compliance must be a given

• Implementation: stealth vs. competition find element champions

• Patience w/ sense of urgency

• Stay the course – it’s a long term strategy

• Develop, deploy, stabilize, then optimize

• Factor in human response to CHANGE

• Registration vs. Self Certification

Resources

• OHSAS 18001

– http://www.bsigroup.com/en-GB/ohsas-18001-occupational-health-and-safety/

• ISO 45001

• http://www.iso.org/iso/iso45001

Resources

• ANSI Z10

– http://www.asse.org/ansiaihaasse-z10-2012-occupational-health-safety-management-systems/ansi/aiha/asse-z10-2012-occupational-health-and-safety-management-systems/

• OSHA S&H Mgmt. Guidelines

– https://www.osha.gov/shpmguidelines/SHPM_

guidelines.pdf

Questions ??????Comments ??????

Concerns ?????

Tim Neubauer, CSP

President

Evolution Safety Resources

t.Neubauer@evolutionsafetyresources.com

919-650-9172

NSC 9 Elements of a SMS

Administrative and Management

• Management leadership and commitment

• Organizational communications and system documentation

• Assessments, audits, evaluations, and continuous improvement

Operational and Technical

• Hazard recognition, evaluation, and control

• Facility design and engineering

• Operational safety programs

Cultural and Behavioral

• Employee involvement

• Motivation, behavior, and attitude

• Training and orientation