Should there be an occupational health and safety management system standard?
Looking at both sides of this question are Charles F. Redinger, who argues in the affirmative on this issue, and Joel B. Charm, who’s against a new comprehensive standard. Dr. Redinger is a Certified Industrial Hygienist and has a masters degree in public policy. He has been at the forefront of domestic and international OHS performance measurement, conformity assessment, and management systems development since the early 1990s. Mr. Charm is president of Charm HS&E International, a consulting firm specializing in environmental, product safety, and occupational health management. He’s the chairman of U.S. SubTAG 1 and U.S. Delegation to ISO Technical Committee 207 SubCommittee 1, Environmental Management Standards
Occupational health and safety
management systems—the train has left the
by Charles F. Redinger, Ph.D., CIH
For better or worse, the management systems genie was let out of the bottle with the development of the ISO 9000 quality assurance management system (QAMS) series of standards. As many of you know, the ISO 9000 momentum soon carried over into the development of the environmental management system (EMS) ISO 14000 series of standards in the early 1990s. Given the ubiquitous organizational/institutional trend of integrating environmental management with occupational health and safety (OHS) management soon after the ISO 14000 series development began, it was inevitable that the management system approach would be applied to OHS directly. Current discussions revolve around both stand-alone OHSMSs and integrated EHSMSs.
At the ANSI-sponsored meeting in Rosemont, Illinois, in May 1996, the American position on the development of an ISO OHSMS standard was considered. The metaphor of a "train leaving the station" was commonly used by presenters and participants. Many suggested that the train had not left the station and, for that matter, should not leave—the point being that ISO should not consider the development of an international OHSMS standard or guidance document.
Four years later, it’s clear that the train not only had left the station four years ago, but is now well down the tracks. The development of OHSMS standards and guidelines by nations throughout the world is well documented in a report prepared by the International Occupational Hygiene Association (IOHA) for the International Labor Office (ILO) and by ISO itself. ILO has initiated the development of its own international standard or guidance. And now the issue is once again being considered by ISO. All indications are that the pressure on ISO to move forward with this issue will not let up. If ISO elects once again not to act, it may lose its opportunity to have a say in how such a standard or guidance document will be structured, as other international standards development organizations move forward with such development.
People from around the world are waiting with great anticipation for an OHSMS or an integrated EHSMS. In my view, the compelling case for an OHSMS or a system that’s integrated with an organization’s quality management system has been made in many books, papers, presentations, and in professional practice on a worldwide scale. This idea is no longer new or radical; but those companies that believe the approach is novel should study, institute, and evaluate such policies and practices like the "benchmark" companies have done.
OHSMSs and EHSMSs are effective and efficient. Even if we ignore the compelling ethical arguments in favor of using all available effective tools in our arsenal to protect workers domestically and globally, we cannot be blind to mounting evidence that this approach, adapted by so many forward-looking organizations, represents good business.
Applying ISO 14001 as a pure environmental management system without regard to OHS aspects is simply illogical. This was already a moot point even in past national and international meetings, during which "an international ISO standard for OHS was turned down by the overwhelming consensus of representatives from industry, labor, and various governments from both developed and developing countries." During the time of this debate, an article was published in the technical press entitled "IBM spells SAFETY I-S-O." Indeed, a representative of one of the largest companies in the world stood up in one of these debates and said, "Whom do we think we’re kidding? We’re either already doing this [EHSMS], or we’re planning to do it because it makes sense!"
I’m asked on a regular basis to speak and write on OHS performance measurement and management system issues. Over the past decade since I’ve been conducting research and working in this area, I continue to be disappointed when I hear the arguments put forth by those who want to stop or impede efforts to develop OHSMS standards or guidelines. There is ample evidence that this approach to OHS management has the potential to achieve something where command-and-control approaches and regulations have failed, namely, to eliminate occupational injury and illness incidence rates while increasing organizational performance. It’s that simple. Based on my research, work with large organizations, and observations as an occupational health professional, there’s no doubt that applying management system theories and practices to OHS management improves safety and the bottom line.
I have two concerns when I hear colleagues say that there’s no need to develop OHS management system standards or guidelines since many approaches or models already exist that can be used. In these conversations, ISO 14001 is often mentioned as a robust means to develop either a stand-alone OHSMS or an integrated EHSMS. While I agree in principle, I am concerned that the application of ISO 14001 to OHS will not be well done, leading to weaker worker health and safety protection.
The second concern is that within the "standards marketplace," there has been a proliferation of both OHSMS and EHSMS standards and guidelines developed by private consultants (e.g., DNV, ILCI), private professional organizations (e.g., AIHA, JISHA), and nations (e.g., Britain, Australia, Spain). A group in the U.K. recently published OHSAS 18001 through the British Standards Institute. I have even developed a universal OHSMS as part of a performance measurement instrument I created.
Some would say that it’s good that the standards marketplace has so many approaches available. My concern is that these standards are not equally good. Following my analysis of well over 30 OHSMS, EMS, and EHSMS standards and guidelines, it’s my opinion that some of the weaker approaches could be detrimental to worker health and safety. Another concern is that transaction costs associated with the different approaches may vary widely.
Based on my management system understanding and experience, I am confident that it’s possible to develop an OHSMS that will lead to reductions in occupational injury and illness, with minimal transaction costs, that also improves organizational performance. Both ISO and the ILO tripartite process provide a means for reaching consensus on the best system for achieving a standardized OHSMS.
I am suspicious when colleagues in large organizations vehemently oppose the development of standards, especially when their organizations have their own OHS management systems in place. In many cases, these systems are more stringent than any international standard or guidance document would be. This posture by large organizations ultimately hurts worker health and safety, especially in small to medium enterprises, where the largest improvements can be made.
The EHS community is at the threshold of a tremendous opportunity. With the knowledge gained from national and international QAMSs, and EMSs, the opportunity exists to develop a practical and effective OHS management system standard or guidance document that can lead to genuine reductions in occupational injury and illness while improving organizational performance. Many papers, guides, books, and experts are available to guide us in achieving these gains. Let us hope that practitioners and policymakers alike will embrace this idea. Indeed, there are many such efforts in progress.
The British Standards Institute has its BS 8800 and OHSAS 18001 products; the American Industrial Hygiene Association has its ISO 9001-based OHS MS and its new ANSI Z-10 Committee for Occupational Health and Safety Systems; and the ILO has its landmark report published in 1999 surveying and analyzing the world's OHS management system standards. These groups are leading the way. Those who suggest that the train did not leave the station and want to impede progress are ultimately hurting workers and are missing an opportunity to realize gains in organizational performance.
by Joel B. Charm, president of Charm HS&E International
Although I personally believe that a structured management system is an effective and efficient way to achieve an organization’s goals and policy objectives, there already exist models to use for such a system. These models include ISO 14001 and ISO 9001. Organizations have already successfully used ISO 14001, the Environmental Management System Specification Standard, for either integrating OHS into their EMS or formulating their own OHS-MS. Thus, I see no current need for a separate standard.
In 1996, ANSI convened a special conference of major stakeholders (industry, government, labor, insurance, and academia/professional associations) to debate this issue. The conference concluded overwhelmingly that there was no need for an international standard on OHS, but that if such activity were needed, it should be at the national level to reflect local values, culture, and requirements. This U.S. conference was followed by a similar international conference sponsored by ISO in Geneva, and the same result was overwhelmingly adopted. There has been no national or international consensus process to determine that the situation has changed—in fact, the U.S. Technical Advisory Group recently reaffirmed its view from 1996 that it sees no need for change, but that if such change were needed, it should be after using a clear consensus process to make that determination.
Organizations of all sizes and from all sectors have been expending great energy in structuring their quality and environmental management systems in accordance with ISO 9001 and ISO 14001. One should not minimize the effort it takes to conform to such standards. While many have found value and efficiency from such systems, these organizations have also expressed concern about more of the same until they have digested and reflected on what they have been doing thus far. Such standards have a way of becoming requirements for customer/supplier relationships and have also begun to find their way into the regulatory setting either as a "voluntary" program or as a regulatory/judicial requirement. Many organizations are now complaining that these standards may be diminishing in value as a result of the emphasis placed on "requirements" as opposed to "voluntary" initiatives.
The registration process for organizations that desire third-party certification for adopting such standards is complex and costly. While there is no prejudgment that an OHS-MS standard would be a "requirements" document, it is likely to be just that, for purposes of third-party registration.
OHS-MS standards already exist—the American Industrial Hygiene Association has already adopted an AIHA Guide on such a standard. The British Standards Association adopted its version of an OHS-MS a few years ago and, together with other registrars, has published OHS-AS 18001, which is not an ISO standard but seems like it. The Occupational Health and Safety Assessment Scheme 18001 is BSA’s own view of a system, largely based on ISO 14001, that organizations can use if they want to have their OHS system third-party registered as a marketing approach. Thus, if any organizations want guidance other than ISO 14001, such guidance exists already.
The International Labor Organization has been debating whether its 2000–2001 work program will include the development of a guide or recommendation on OHS-MS. At its most recent strategic planning session last month, ILO decided if it were to pursue doing that, it would not be a priority issue at this time.
And, finally, management systems are neither a guarantee of compliance with regulatory requirements nor a guarantee to prevent accidents, injuries, or illnesses. They do set in place a structure that can "help" assure compliance or can "help" identify significant risks and prevent those from materializing. Such models already exist. Another OHS-MS model will not increase compliance or prevent injury or illness. ISO 14001 already does a good job in that regard.
Thus, I do not see the pressing need for an OHS-MS at this time. Options already exist for those organizations that wish to develop an independent OHS-MS, including ISO 14001, ISO 9001, the AIHA Guide on OHS-MS, and the BSI (et al.) OHS-AS 18001. In the United States, the clear consensus in 1996 was that such a standard was not needed at that time, and the US TAG on Environmental Management reconfirmed that the 1996 position should still stand unless a national consensus process determines differently. While organizations do find efficiency and effectiveness in having a carefully structured management system such as ISO 14001 that reflects not only their culture but also external requirements, these organizations are also concerned about the proliferation of such standards and the impact such standards have on business and the marketplace.