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Systems in focus Guidance on occupational safety and health management systems IOSH publishes a range of free technical guidance. Our guidance literature is designed to support and inform members and motivate
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Systems in focus Guidance on occupational safety and health management systems IOSH publishes a range of free technical guidance. Our guidance literature is designed to support and inform members and motivate and influence health and safety stakeholders. Systems in focus guidance on occupational safety and health management systems The aim of this guide is to provide occupational safety and health (OSH) practitioners, managers, educators and others with a basic understanding of the role and development of OSH management systems. Starting with a brief introduction to the subject, the guide contains: - general structure main components, history, links with international regulatory regimes and integrated systems - detailed structure key elements of effective systems - discussion advantages and disadvantages, certification and getting started. The guide also has reference and further reading sections. If you have any comments or questions about this guide please contact Research and Information Services at IOSH: - t +44 (0) PDF versions of this and other guides are available at freeguides. Our materials are reviewed at least once every three years. This document was last reviewed and revised in May 2015. Contents 1 Introduction 02 2 The main components of OSH management systems 03 3 Typical systems an overview 05 4 Regulatory and industry standards some global perspectives 08 5 Should management systems be integrated? 09 6 The key features of an effective OSHMS 10 7 Advantages and disadvantages of OSHMSs 18 8 OSHMS certification 21 9 How to get started 22 References 24 Further reading 25 Appendix: List of abbreviations 27 Acknowledgments 28 List of figures 1 Plan Do Check Act diagram 03 2 Flowchart based on HSG Flowchart based on OHSAS Flowchart based on ILO guidelines 07 5 OSHMS stakeholders 13 6 Process for developing an OSHMS 23 List of tables 1 Typical changes faced by an organisation 10 2 Advantages and disadvantages of internal audit 16 3 Advantages and disadvantages of external audit 16 4 OSHMS comparison table 22 1 Introduction Guidance context Changes in work Developed countries are experiencing a shift of balance from manufacturing to service industries, new technologies, globalisation, flexible work practices and an ageing workforce. Meanwhile, many developing countries are shifting from rural to industrial and service activities. Both scenarios present changing work patterns and associated hazards. The multitude of workrelated risks requires a systematic approach to occupational safety and health (OSH) management, and some of the principal management tools are occupational safety and health management systems (OSHMSs). Management system developments Organisations are being encouraged to adopt formal management systems through their supply chains, and to a lesser extent through legal pressures. Current systems include both generic approaches and sector-specific arrangements developed by trade bodies. The continued development and wider use of formal systems seems to be inevitable, particularly where corporate governance issues have a high priority. Common features Formal systems have at their core the elements of plan, do, check and act (PDCA) embodying the principle of continual improvement. Although there are potential disadvantages to formal systems, such as increased paperwork, the benefits of developing arrangements that fully meet your organisation s needs make them worthwhile when they re properly implemented. IOSH s position IOSH recognises that work-related accidents and ill health can be prevented and wellbeing at work can be improved if organisations manage health and safety competently and apply the same or better standards as they do to other core business activities. We believe that the formal OSHMSs mentioned in this guidance, and others based on similar principles, provide a useful approach to achieving these goals. Guidance This document helps professional health and safety advisers to explore what OSHMSs can offer their own organisations and those that they advise. It has three specific aims: - to support improvements in effective health and safety management - to help organisations that want to introduce formal OSHMSs - to encourage IOSH members to play a full part in these developments and in continually improving existing systems. Structure of guidance Adopting and implementing an OSHMS, and integrating it with other management systems, requires careful planning and management. This guidance outlines the basis of these systems, discusses some of their benefits and pitfalls, offers practical suggestions and explains how to implement and develop an effective OSHMS. OSHMSs an overview The main components of an OSHMS include both policy a mission statement for health and safety that provides a mechanism for management control and accountability and arrangements for implementation, monitoring (including audit) and continual improvement. Formalising these arrangements removes the potential arbitrariness of processes developed by a few individuals and helps to support a management culture that can involve the whole workforce. OSHMSs have developed through national and international co-operation. Some were boosted by legal developments such as the European Union (EU) Framework Directive, 1 while others were created in response to industrial sector needs (eg Responsible care 2 in the chemical industry). With the publication of International Labour Organization (ILO) guidelines 3 in 2001, the international dimension came fully into focus. Today, the leading international standard is OHSAS This guidance is divided into three broad parts. Sections 2 5 cover the general structure of OSHMSs, including their history, links with international regulatory regimes and the issues involved in integrating them with other management systems and with business risk management. The detailed structure of an OSHMS and the key issues involved in implementing it are covered in section 6. Sections 7 9 provide information on the advantages and disadvantages of OSHMSs, the issue of third-party certification, and how to get started. The appendix contains a list of the main abbreviations used in this guidance. 02 2 The main components of OSH management systems Whatever management model you use, it s likely to be based on the principle of plan, do, check and act (PDCA also known as the Deming cycle ). Numerous types of management system are based upon this principle, notably health and safety (OHSAS 18001), quality management (the ISO 9000 series) and environmental management (the ISO series). You can gain significant benefits by integrating your organisation s approach to these areas in other words, by adopting a holistic approach (see page 09). Effective OSHMSs include the following elements: - Policy a statement of commitment and vision by the organisation, which creates a framework for accountability that is adopted and led by senior management. - Planning a plan for identifying hazards, assessing and controlling risks, and preparing for and responding to emergencies, as well as identifying legal and other standards that apply. The organisation should set long term OSH objectives and plan targets and actions to achieve them. - Organising a definition of the organisational structure, allocation of OSH responsibilities to employees linked to operational controls, and ways of ensuring competence, training and consultation. - Workers representatives* a crucial resource that can make a valuable contribution to the organisation s overall response to risk and opportunities. - Communicating from basic information and work procedures to the details of the system itself, from managers to workers and vice versa. - Consulting whatever the flow of information, you need an effective way of tapping into the fund of knowledge and expertise held by your workforce, clients, suppliers and other stakeholders (eg regulators, trade unions and neighbours). Involving all these groups will also help you to shape your risk management programme. - Implementing and operating putting management processes and plans in place and carrying out the activities from risk assessment to audit in other words, putting the OSHMS into practice. - Measuring performance from reactive data on the rates of workrelated injuries, ill health, near misses (sometimes referred to as near hits ) and other incidents, to active data on routine inspections, health and safety committee activities, training, risk assessments and so on (see IOSH s guidance on reporting performance 5 ). Formal audits should evaluate the overall performance of the system. - Corrective and preventive actions a fundamental OSHMS component is a systematic approach to identifying opportunities for preventing accidents and ill health, including those that stem from investigating work-related injuries, ill health and incidents. Various techniques are used to identify and correct weaknesses in the system and to find ways of preventing failures and harm. Plan - Policy - Planning - Hazard identification and risk assessment Do - Implementation and operation Check - Performance assessment (active and reactive) Act - Review and continual improvement Figure 1: Plan Do Check Act diagram * We ve used workers representatives in this guidance to mean any workers safety representatives, regardless of whether they re appointed by a trade union or chosen in some other way. 03 - Management review an evaluation of how appropriate the overall design and resourcing of the system are, as well as its objectives in the light of the performance achieved. This includes making sure that compliance with relevant legal and other requirements is periodically checked. - Continual improvement at the heart of the system is a fundamental commitment to manage health and safety risks proactively, so that accidents and ill health are reduced (effectiveness) and/or the system achieves the desired aims by using fewer resources (efficiency). 04 3 Typical systems an overview Many OSHMSs have been published over the past 25 years. Some reflect the interests of the sponsoring bodies. For example, the American Industrial Hygiene Association system places the industrial (occupational) hygienist at centre stage as the crucial competent person. Others, such as the International Safety Rating System, were developed so that commercial organisations could offer third party certification. Three generic OSHMSs reflect this history and illustrate the different emphases of current systems. HSG65* The UK Health and Safety Executive (HSE) published Successful health and safety management (HS(G)65) in This was characterised by five key elements: - policy - organising - planning and implementation - measuring performance - audit and review. It s based on the traditional PDCA principle, where the organisation s plans reflect the policy document and the implementation phase is dominated by risk assessment and application of controls. Checking includes a mixture of performance monitoring, auditing and corrective action. The guidance intentionally reflected contemporary management processes and encouraged readers to harness them for health and safety programmes. However, at that time, the HSE was under pressure to restrict its activities to supporting and enforcing legal compliance. This led to a system in which legal compliance became embedded in organisational policy and, once achieved, the aim was largely to maintain the status quo. This compared unfavourably with systems that unambiguously focus on continual improvement, a fundamental weakness that was addressed in the second and current edition of HSG65. 6 This edition contains information on managing change and more advice on consultation, communication and continual improvement. HSG65 retains the special status of a management system developed by a regulatory agency, and it s familiar to many UK-based managers and OSH practitioners, particularly in larger organisations. OHSAS OHSAS grew from a desire to create a system capable of assessment and certification, as a follow-on from BS 8800 (now revised and reissued as BS 18004: ). HS(G)65 covered the implementation of an OSH policy, and implied that this would be quite straightforward once the policy had been adopted. OHSAS 18001, on the other hand, more fully reflects the problems of changing an organisation. Building on established Policy Control link Information link Organising Planning and implementation Measuring performance Auditing Reviewing performance Figure 2: Flowchart based on HSG65 * HSG65 is currently (May 2011) under revision see for more information. 05 environmental management systems in particular, OHSAS recognises the importance of planning and managing the changes that are likely to be needed as an OSHMS is introduced. ILO OSHMS guidelines The ILO is a tripartite United Nations agency that influences the development of labour laws across the globe. Its publications and guidance are authoritative and its 2001 Guidelines on occupational safety and health management systems 3 established an international model, following a detailed review of over 20 management systems worldwide. It reflects the globalisation of organisations and the increase in outsourcing and partnering these changes demonstrate how systems need to evolve continually to reflect new business practices. Policy Planning Continual review Implementation and operation Checking and corrective action Management review Figure 3: Flowchart based on OHSAS Policy Continual improvement Organising Planning and implementation Audit Evaluation Action for improvement Figure 4: Flowchart based on ILO guidelines 07 4 Regulatory and industry standards some global perspectives A key factor in implementing a formal OSHMS is consideration of the legal framework that creates the operational context. In the EU, Australia and offshore regimes generally, regulation of major hazard industries via a safety case approach is accompanied by an emphasis on effective management systems to complement and reinforce required high standards of technical safety. Also, the International Maritime Organization (IMO) now requires most categories of international shipping to use the International Safety Management (ISM) Code, 8 an OSHMS for marine operations. Some countries, particularly in the Pacific Rim, require organisations to adopt OSHMSs with third-party auditing by government-approved auditors. In others, there have been moves to link internal OSHMS status with the enforcement inspection regime. For example, under the Voluntary Protection Program in the United States, organisations with systems approved through an extensive audit may be exempted from normal Occupational Safety and Health Administration (OSHA) inspections. Proponents of this system claim that it allows employers to concentrate on systems of work rather than individual deficiencies (hazards and risks), but there s considerable debate over the merits or shortcomings of this approach. There s also been a general worldwide movement away from prescriptive regulations which have the advantage that employers are told explicitly what they have to do to process requirements, with risk assessment as the key process (although many would argue that in the EU there s still a strong drive towards embedding detailed prescriptive requirements in Directives). Developing management systems is another step along the same road. The structure of a lot of national legislation reflects this. In the UK, for example, the Management of Health and Safety at Work Regulations require demonstrable management of OSH. In Canada, due diligence defences have been successfully used by defendants with a formal OSHMS. In Norway since 1991, it s been mandatory for organisations to establish internal control systems to make sure that health and safety activities, including internal and external audit, are legally compliant, and to document them. Similarly, Swedish law requires systematic internal control of OSH. In India, following the Bhopal disaster, legislation in 1988 prescribed systematic management to prevent such events. The Chinese government has adopted the ILO s OSHMS guidelines and has used them to develop a certification framework. Australia and New Zealand have a welldeveloped national OSHMS standard, 10 but no plans to make its adoption mandatory. These are all examples of the extension of self-regulation. Some management systems have been developed to meet the needs of specific sectors. For example: - the chemical industry has developed Responsible care - the shipping industry uses the IMO s ISM Code - oil and gas producers have published comprehensive, global guidelines for a health, safety and environmental system for exploration and production activities. 11 Looking ahead There is increasing international certification to OHSAS and an increasing trend towards integrating PDCA management systems. The OHSAS Project Group surveys have found that between 2003 and 2007, the number of countries where OSHMS certification occurs has grown from 70 to 102 and the number of reported OHSAS (or equivalent) certificates from 3,898 to 31,512. These trends are driven by factors such as the increasingly international nature of business and supply chain requirements in general, supported by increasing recognition by enforcers that management systems when run properly can help to deliver improved legal compliance and OSH performance. In addition, the designers of management systems themselves are paying increasing attention to supply chains and dealing with OSH issues associated with products, not just with operations. 08 5 Should management systems be integrated? IOSH s guidance, Joined-up working an introduction to integrated management systems 12 covers: - the case in favour of integrating management systems - arguments for retaining largely independent systems - organisational prerequisites for integration - factors that should be considered when introducing an integrated management system (IMS) - maintaining and developing an IMS. IOSH s view is that an effective IMS should be the preferred option for many, but not all. A well-planned IMS should be more efficient and capable of taking the best decisions in the face of various factors and uncertainties. An integrated approach is also expected in business risk management (BRM), which is defined in IOSH guidance 13 as the eradication or minimisation of the adverse effects of pure and speculative risks to which an organisation is exposed. Such risk includes health and safety, environmental and quality failures. The requirement for corporate accountability based on a BRM approach is highlighted both globally by the Organisation for Economic Co-operation and Development and in the so-called Turnbull Report, 14 which requires companies listed on the UK stock market to identify, assess, record and manage their significant risks in a suitable manner. There must be systems for regularly reviewing these risks and adjusting their controls, together with statements in company annual reports that confirm the effectiveness of these systems. Hence, the management of OSH, environmental or quality risks should not be treated in isolation, because of the impact that poor risk management can have on brand, reputation, business continuity and financial wellbeing. This is the fundamental reason why most organisations integrate their OSHMS with the systems used to manage environmental and/or quality risks. Integration allows risks to be prioritised overall, so that resources can be allocated to achieve maximum risk reduction and benefit. In non-integrated systems, on the other hand, resources are allocated to each risk area in isolation, and the resources allocated to each may not reflect that risk area s overall significance. The process of integration presents distinct challenges to organisations. Those that are most likely to integrate th
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