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Workshop II
Valuable Guidance in the Implementation of the New
Safety Standard—ISO 45001
Wednesday, March 28, 2018 11:15 a.m. to 12:30 p.m.
Biographical Information
Cory Justice, HS&E Specialist, MUBEA North America 8200 Dixie Highway, Florence, Kentucky 41042 USA
859.746.5315 x7062 Mobile: 513.760.3388 [email protected]
Cory Justice is a Health, Safety, and Environmental Specialist with Mubea North America in Florence, Kentucky. Cory holds a Bachelor of Science in Occupational Safety and Health and a minor in Fire & Safety Engineering Technology from Eastern Kentucky University. Cory is responsible for managing and implementing Environmental, Health, & Safety compliance for 3 Business Units. Prior to joining Mubea North America, Cory worked as a Safety Specialist and Coordinator implementing various safety programs and conducting Environmental, Health, and Safety trainings.
Eric D. Harper, CSP, CHMM, Manager – Process Safety, EHS Technology Group, LLC
2912 Springboro Road West, Suite 101, Dayton, Ohio 45439 (937) 510-6523 [email protected]
Eric is the Manager of Process Safety for EHS Technology Group LLC located in Miamisburg, Ohio. Eric has over 21 years of experience in the field of environmental health and safety. Prior to joining EHS Technology, Eric was responsible for managing the environmental health and safety program for two manufacturing facilities in the automotive industry. In this capacity, Eric was responsible for managing the regulatory compliance, worker’s compensation, and various risk management activities for his company. During his time in private industry, he developed and implemented numerous safety programs and injury reduction initiatives. In addition, he developed and conducted various safety training classes on a wide range of safety topics such as confined space, lockout/tagout. Since joining EHS Technology, Eric has been focused on providing safety, health, and environmental consulting services to clients in a wide variety of industries. Specifically, Eric has focused on helping clients with struggling safety and environmental programs achieve improved metrics while providing safer workplaces to their employees. Eric is a graduate of Ohio University with a B.S. in Industrial Hygiene. Eric has been a Certified Safety Professional (CSP) since 2001 and has been a Certified Hazardous Materials Manager (CHMM) since 2014. Eric is a member of the American Society of Safety Engineers.
March 28, 2018
What if the man or woman in the picture fails to come home tonight because he or she is killed at work?
2.3 MILLION TIMESGlobal Estimates of Occupational Accidents & Fatal
Work Related Diseases in 2014Tampere University of Technology
263 PEOPLEWill Die at Work in the Next Hour
Recognition globally that we need to do something different
First, understand the purpose of organization & intended outcome of the OHSMS
o What do you want OHSMS to help you accomplish?
Next, identify positive and negative issues impacting organization’s ability to achieve OHSMS success
o Internal issueso External issues
Context should be reviewed periodically to ensure it is up to date
Positive or negative issues outside of organization that can affect the OHSMS
o Political climateo Changes in legal requirements (i.e. walking-working surfaces)o Social or cultural issues (i.e. language barriers)o Industry trendso Technological changeso Market competitiono Economic conditionso Recent research findings detailing health effects of raw materialo Facility location & availability of emergency medical serviceso OSHA Local Emphasis Programs
Identify risks & opportunities associated with the external issueso Risk – Research on vital raw material component shows increased cancer risk
for those exposed to the materialo Opportunity – Increased sales presents opportunity to fund capital project to
improve machine guarding plantwide
Positive or negative issues inside of organization that can affect the OHSMS
o Corporate governanceo Organizational structureo Employee turnovero Work shifts & overtimeo Aging workforceo Workforce demographics (i.e. high number of temporary employees)o Culture of the organizationo Safety training programso Organizational relationship with union(s)
Identify risks & opportunities associated with the internal issueso Risk – High turnover in high hazard job could significantly increase risk
of severe injuryo Opportunity – Modification in shift times could reduce amount of
overtime and fatigue of employees
Identify who has interest in the success or failure of your safety programo Employees are given
Some interested parties are readily identifiableo Employee families (i.e. small children)o Unionso Regulatory agencyo Parent companieso Contractors & customers
Dive deep – some interested parties may not be so identifiableo Investment communityo Worker’s compensation insurerso ISO 45001 registrarso Media
What relevant needs or expectations do these interested parties have?o Mandatory or voluntarily accepted needs & expectations become compliance obligations
• Complying with applicable OSHA regulations• Submitting required OHS data to corporate monthly or completing customer OHS surveys
o Compliance obligations accounted for when planning & executing the OHSMS
Understand & consider the following prior to determining scope of OHSMS:
o Internal & external issues identified in contexto Legal & other requirements associated with interested partieso Work related activities conducted
Include activities, products, & services within control or influence of the organization which can impact OHS performance
o Travelo Transportation of productso Contracted janitorial services
Scope will establish boundary & applicability of OHSMSo Do not exclude things which can impact OHS performanceo Do not exclude things to avoid legal or other requirements
Scope must be available as documented information
Section 5.1 outlines thirteen (13) different ways leadership & commitment should be displayed by top management
Objective evidence should be gathered as processes are audited & interviews are conducted
Fingerprints of top management should be all over the OHSMS system & documentation
o Meeting minuteso Communicationso Participation in safety activitieso Leading by example (PPE)
Top management must:o Take:
• Responsibility & accountability for injury prevention & safe working conditionso Ensure:
• Integration of OHS into other business processes• OHS policy & objectives are established & compatible with strategic direction of organization• Resources are available for OHSMS• OHSMS achieves intended outcomes• Continual improvement• Development of process for consultation & participation of workers
o Support:• Other managers to take leadership as it applies to the OHSMS for their areas• Establishment & functioning of health & safety committees
o Communicate:• Importance of OHSMS & conforming to OHSMS requirements
o Direct & support: • Contribution to the OHSMS
o Develop, Lead, & Promote:• A culture within the organization that supports the OHSMS & its intended outcomes
o Protect:• Workers from reprisal when reporting incidents, hazards, risks & opportunities
Evidence of leadership & commitment may include:o Participation in & decisions made at management reviewo Participation in safety committeeso Key communications addressing safety o Allowing time for safety committee members to attend meetingso Including safety metrics in performance reviewso Providing resources for safety (i.e. money, additional staff, etc.)o Establishing & monitoring safety hazard reporting processeso Participating in safety auditso Establishment of safety suggestion systemo Inclusion of safety in MOC processo Interviews with top management & their knowledge of what is
happening in safety at their facility
Requires normal OHSAS commitments:o Compliance with applicable legal & other
requirementso Continual improvement
Also requires commitments to the following:o Provide safe & healthy working conditions
to prevent injury & ill healtho Eliminate hazards & reduce OH&S riskso Consultation & participation of workers
and/or their representatives
Prevention of injury & ill healtho Also in OHSAS 18001o 45001 commitment draws focus back to
conditions that can cause injury or ill health• Fall hazard that never leads to fall
Employee consultation & participation required throughout all stages of OHSMS processo Developmento Planningo Implementationo Performance evaluationo Continual improvement
Non-managerial employees emphasized which means employees carrying out work activitieso Managers impacted by the work activities should not be excluded
Time, training, & resources must be provided to allow for participation
Timely access to clear, understandable, & relevant OHSMS informationo Can be obstacle or barrier to participation
Remove and/or minimize obstacles or barriers to participationo Threat of reprisalo Lack of response to suggestionso Language barriers
Employee consultation & participation required at all stages of OHSMS process
Non-managerial employees emphasizedo Managers impacted by work carried out by non-managerial employees should
not be excluded
Time, training, & resources must be provided to allow for participation
Timely access to clear, understandable, & relevant OHSMS necessary to allow for participation & consultation
o Can be obstacle or barrier to participation
Remove and/or minimize obstacles or barriers to participationo Threat of reprisalo Lack of response to suggestionso Language barriers
Consultation – Seeking views before making a decisiono Two-way communication where information is shared with employees &
informed feedback is provided from them prior to a decision being made
Non-managerial employees consultation should be emphasized when:o Determining needs & expectations of interested partieso Establishing OHS policyo Assigning roles, responsibilities, and authoritieso Determining how to fulfill legal & other requirementso Establishing O&T and planning to achieve themo Determining controls for procurement including contractors & outsourcingo Determining monitoring & measuremento Developing internal audit programo Ensuring continual improvement
Not a system that management develops & drives down employee throats
Participation – Involvement in decision-makingo Allows employees to contribute to decision-making process
Non-managerial employee participation should be emphasized in:o Determining mechanisms for their consultation & participationo Identifying & assessing risks & opportunitieso Determining actions to eliminate hazards & reduce riskso Determining competence requirements, training needs, training, &
training evaluationo Determining what and how to communicateo Determining control measures & how to effectively implemento Investigating incidents & nonconformities & determining corrective
action
Non-managerial employee fingerprints should be all over the OHSMS
Risks & opportunities (associated with OHSMS planning) must be identified considering:
o Context issueso Interested party requirementso Scope of OHSMS
Risks & opportunities (associated with OHSMS intended outcomes) must be identified considering:
o Hazardso OHS riskso OHS opportunitieso Legal & other requirements
Risks & opportunities will be documented information
Processes & actions necessary to determine & address risks & opportunities will become documented information
o To level required to ensure they are carried out as intended
Hazard identification process must be proactive & ongoing
Hazards can be masked in a variety of ways
At a minimum, the following items should be considered when identifying hazards:
o Organizational culture, social factors, & human factors (ergonomics)o Routine and non-routine taskso Internal & external relevant incidentso Potential emergency situationso Peopleo Changes in organization, processes, equipment, etc.o Changes in knowledge or information about hazardso Other issues
Process should be robust to identify the hazards associated with all of the operations & activities included in the scopeo Lone workerso Service personnel traveling between sites not controlled by
employero Occasional welding inside a machineo Active shootero Parking lot traffic
All hands on deck! - One person cannot make this process work
Risks associated with identified hazards must be assessedo Many ways to conduct risk assessments
OHS Risk - Combination of the likelihood of occurrence of a work-related hazardous event or exposure(s) and the severity of injury and ill health that can be caused by the event or exposure(s)
Risk assessments must be proactive NOT reactive
Risk assessment should take into account effectiveness of existing controls
Other risks related to the OHSMS must be identified & assessedo Review context for riskso Changes in legal or other requirementso Economic changeso Turnover in OHS administrative personnelo Seasonality of work
Risk assessment methodologies & criteria is documented information
Organization must evaluate opportunities to improve OHS performanceo Ergonomic conditions
o Eliminate hazards & reduce risks• Hierarchy of controls• Corrective action after near miss
o Other opportunities associated with OHSMS• Review context for opportunities • Employee suggestions
Must have a process for determining & accessing up-to-date legal & other requirements associated with risks & OHSMS
o Do you have a sawmill? Do you have a helicopter?
Determine application to organization & what needs to be communicated
o Hexavalent Chromium requirements based on exposure levelso Communication of corporate OHS requirements
Consider legal & other requirements in all aspects of OHSMS
Documented information required on legal & other requirementso Update as changes occur
LEGAL REQUIREMENTS OSHA regulations
OSHA settlement agreements
Court judgments
Permits or licenses
Collective bargaining agreements
OTHER REQUIREMENTS Corporate requirements
Contracts
Consensus standards
Voluntary codes of ethics
ISO 45001
Organization must plan actions to address:o Risks & opportunities
• Considering hierarchy of controlso Legal & other requirementso Prepare for & respond to emergencies
Actions should focus on achieving purpose or desired outcome associated with OHSMSo Protect employees o Compliance
Organization must plan:o Integration of actions into OHS & other business processes
• BBS observations & JHA completion – production levelo Evaluation of the effectiveness of actions taken
• Ensure actions are moving toward achieving purpose of OHSMS
Purpose – Maintain & improve OHSMS & OHS performance
Objectives must:o Be consistent with OHS policy
• Does objectives achieve or help achieve one of its commitments?o Be measurable (if practicable) or capable of performance evaluation
• Can you measure or evaluate its achievement?o Be monitored
• Are you monitoring its achievement?o Be communicated
• Is your objective(s) known throughout organization?o Account for:
• Applicable requirements, • Risk & opportunity assessments, & • Worker consultations
• Were risks & opportunities, employee input, & applicable requirements considered? o Updated as appropriate
• Is the status or progress toward achievement up to date?
Plan for achievement is roadmap for achieving objectiveo What activities or steps will you take to achieve the target?
Understand what resources are necessary for OHSMS
Resources could include:o Peopleo Moneyo Equipmento Timeo Infrastructureo Technology
Top management must provide the necessary resources for the OHSMS
• Clause 5.1(d)
Must determine necessary competence of employeeso Requirements expected to differ throughout organization
• Maintenance technician vs. Accountant vs. Production operator• Machine specific training vs. departmental specific training
Ensure competence through training, education, or experienceo Competence includes hazard identification associated with job
• Identifying a process needs to be shut down due to safety issues
Take action to acquire & maintain competence & evaluate the actions taken
o How do you evaluate actions?• Training quizzes or evaluations• BBS observations• LOTO periodic reviews• Review of cancelled confined space entry permits• Audit
Retain documented information required to show competence
Employees (including temporaries) must be aware of the following:
o OHS policy & objectiveso Their contribution to OHSMS effectiveness, including benefits of
improved performanceo Consequences of not conforming to OHSMS requirementso Incidents & outcomes of investigations relevant to themo Hazards, risks, & actions relevant to themo Ability to remove themselves from work situations they believe presents
imminent & serious risk to their safety & healtho Arrangements in place which allows them to remove themselves from
hazardous situations without reprisal
Contractors & visitors should also be aware of the relevant OHS hazards & risks
o Emergency response communications addressed in Clause 8.2
Communication process must define:o What will be communicatedo When to communicateo With whom to communicateo How to communicate
Must account for diversity & be reliableo Languageo Literacy o Disability
Consider views of interested partieso OSHA injury reporting requirementso Corporate requirementso Customer requirements (surveys)
Same documented information requirements as ISO 14001 except for OHSo Standard ISO language used
Documented information must include what is required by standard & determined by organization to show system performance
External origin documentation must be identified & controlledo Safety data sheetso Industrial hygiene lab results or reportso Medical surveillance documentation
Focus on establishing criteria & implementing controls for processes to eliminate hazards & reduce risks while considering hierarchy of controls
o Work procedureso Employee trainingo Inspection & PM procedures & programs
New requirement for adapting work to employeeso Requires ergonomics to be considered in work layout, equipment design,
induction of new employees, process changes, etc.
Multi-employer work places requires coordination between employers to maintain safe & healthy work environment
Documented information still required as necessary to ensure controls are adequate & being followed
MOC, procurement, contractors, & outsourcing broken out into separate clauses
Hierarchy of Controls Must be Used Potential Issue is Corrective Action After Accidents or Near Misses
Alluded to many different times in OHSAS standard
Goal = minimize new hazards & risks in the workplace
Planned changes impacting OHS performance must be controlled
o Replacing light curtains with laser safety scanners
o Relocating equipment within facilityo Employee turnover in high hazard job(s)o Changes in Beryllium & Silica standards
Consequences of unintended changes must be reviewed & actions taken (if necessary) to reduce risk
o Unforeseen hazard development from change
Process must include OHS considerations when procuring equipment, raw materials, services, etc.
o Equipment specification guide controlling equipment purchaseso Guidelines for chemical purchaseso Contractor qualifications
Focus should be on elimination of hazards & reduction of OHS riskso Establish guarding requirements for new equipmento Prevent purchase of chemical mixtures containing carcinogens
Verification of equipment, materials, & services must be part of the processo Equipment acceptance processo Material SDS reviewso Contract employee training verification
Communication & participation needs should be addressed in processo Process for special approval for chemical that may not exactly meet all chemical
purchasing guidelines
Contractor control addressed in OHSAS Clause 4.4.6(c) but ISO 45001 becomes more specific in Clause 8.1.4.2
Low Bid is now Low Bid with Qualificationso Procurement process must define & apply OHS criteria to contractor selection
• EMR• Incident rates• OHS program evaluations
Risk control is two way streeto Risks created by contractor impacting organization or other interested parties
must be controlled• Visitors, other contractors onsite, its own employees
o Risks created by organization impacting contractor must be controlled
Contractor management must ensure work is conducted in a safe manner
Outsource - Make an arrangement where an external organization performs part of an organization’s function or process
o Organization outside scope of OHSMS but process performed is not
Examples could include:o Janitorial serviceso Building maintenanceo Industrial hygiene testing
Cannot outsource a process & then ignore how process is being implemented & controlledo Janitorial service changing cleanerso Industrial hygiene testing not being performed in accordance with established protocols
OHSMS must define controls considering process risk & external organization’s own controlso Company vetting processo Contractual languageo Periodic auditing of process controls
Processes must cross reference & correspond to actual emergencies or potentialemergencies identified during hazard identification (6.1.2.1)
o Active shooter
Response plans to identified emergencies must consider needs & capabilities of relevant interested parties
o First aid consideration• Rural area EMS may not respond to medical calls fast enough
Interested parties should be involved, as appropriate, in plan developmento Confined space rescueso Potential Ammonia or Chlorine releases
Communications extended beyond your property boundaryo LEPC communications, SARA 312 filings, community evacuation information after release, etc.
Periodic testing & exercising of planned response capabilities o Evaluation of planned response actions
• Haz Mat team drillso Not just annual fire drills
“What gets measured gets done.”
Need to determine the following:o What needs to be monitored & measured to evaluate OHS performance;
• Fulfillment of legal & other requirements• Safety audits• Evaluation of compliance process
• Activities & operations related to hazards, risks, & opportunities• BBS observations• Training attendance
• Progress toward OHS objectives• Effectiveness of controls
• IH testing for employee chemical exposures• Periodic inspection required by LOTO
o How (methodology) you will monitor, measure, analyze, & evaluate it;o When monitoring & measurement will be performed; &o When results of M&M will be analyzed, evaluated, & communicated
Performance Metric
Monitoring Method
Criteria Monitoring Frequency
Analysis & Evaluation Frequency
Communication
Safety Training
Attendance
Sign In Sheets
100% Attendance
After Each Class
After Each Class
Monthly @ MR
BBS Observations
BBS Observation
Forms
3/Supervisor Monthly Monthly Monthly @ MR
Safety Audit Audit Forms 90% Score Monthly Monthly Quarterly @ MR
TRIR 300 Log Industry Ave. Monthly Monthly Quarterly @ MR
DART Rate 300 Log Industry Ave. Monthly Monthly Quarterly @ MR
Employee Safety
Suggestions
Suggestion Forms
1/Employee Monthly Quarterly Quarterly @ MR
Examples of possible calibrated or verified equipment:o 4 gas meters or other direct
read instrumentso SLM or dosimeterso Air sampling pumpso Ohm meterso Heat stress instrumentationo Meters for radiation detectiono Vibration detection
equipment (accelerometer)o Cranes (rated load test)o Chemical detection
equipment (NH3 system)
Organization must determine frequency & method(s) for evaluating complianceo Similar to 18001
Clause 9.1.2(c) requires “maintaining knowledge & understanding of compliance status”o Is evaluation frequency &
methodology sufficient?• Compliance evaluation every 3 years
Internal audit program should consider process importance & previous audit results
o Higher hazard/risk process (Maintenance) audited more frequently than lower hazard/risk process (Office)• 18001 required consideration of risk assessments & previous audits
Results of internal audits now reported to:o Relevant managerso Workers and/or representativeso Other relevant interested parties
• Corporate • Registrar
Documented information could include:o Audit schedule, auditor qualification documentation, audit
reports/results, communications associated with audit reports, corrective action documentation
Inputs of 45001 essentially unchanged from 18001 except:o Changes in needs &
expectations of interested parties
o Changes & trends in risks & opportunities
o Resources • Alluded to in 18001 since it
was an output
All inputs not required to be addressed all at onceo Can OHSMS really be
properly managed with one management review a year?
Outputs essentially the same as 18001 except:o Decision on continuing suitability, adequacy, & effectiveness of OHSMS
• Alluded to in 18001o Opportunities to improve OHSMS integration with other business processes
• Combining OHSMS management review with ISO 9001 management review• Extending OHSMS to newly acquired business location
o Implications for the strategic direction of the organization• Not being able to quote business because injury rate is too high• Poor injury record affecting employee recruitment while company trying to grow
Suitability – How OHSMS fits organization & its operations, culture, & business system
Adequacy – Is the OHSMS implemented appropriately Effectiveness – Is OHSMS achieving its intended outcome
45001 requires communication of outputs with workers or representatives while 18001 required outputs be made available for communication & consultation
Organization must identify opportunities for improvement & take necessary action to achieve OHSMS outcomes
Must continually improve OHSMS:o Suitability – How OHSMS fits organization &
its operations, culture, & business systemo Adequacy – Is the OHSMS implemented
appropriatelyo Effectiveness – Is OHSMS achieving its
intended outcome
Can be identified from:o Internal audits, Compliance evaluations,
Corrective actions, or Employee suggestions
Process must include three basic parts:o Reporting – Investigation - Action
Timely reaction necessary to deal with consequences, ensure control, & correction of issue
• First aid for severe laceration
Corrective action should be implemented in accordance with hierarchy of controls & be evaluated for effectiveness
Non-managerial employees should participate in investigation, root cause evaluation, & corrective action
Consult risk assessments after each incident or nonconformityo Was issue identified & was risk adequately considered (scored)o Does new hazard or risk need added or re-evaluated
OHSAS 18001:2007 considered “withdrawn” taking into account the migration period on date of 45001 publication
o Migration period starts on publication date
Migration period will be 3 years
OHSAS certifications issued during migration period will expire at the end of the migration period
o May be amended if local regulation requiring 18001 has not been amended to reference 45001
Migration can occur at any of the following times:o Surveillanceo Recertificationo Special audit
Migration during surveillance or recertification adds a minimum of 1 auditor man-day