OHSMS: Monitoring, Evaluation, & Correcting

Evaluating and Correcting an OHSMS
It’s time for another article in our ongoing series about occupational health and safety management systems (OHSMS).

In this article, we’re going to explain what to do once you’re implemented your OHSMS, it’s in operation, and you want to monitor it, evaluate the performance, and make any corrections necessary to improve results.

In doing so, we’ll look at monitoring, measuring, and assessing your OHSMS; performing incident investigations; performing audits of the various phases of your OHSMS; taking any corrective actions necessary; and including any corrective actions in your OHSMS’s planning process and in its management review.

If you’re new to the series, or if you’d like to review, here’s what we’ve covered so far:

As a reminder, this entire series is based on ANSI Z10 (2012), the ANSI/ASSE standard on occupational health and safety management systems. We encourage you to buy a copy, which you can do here.

And with that, let’s get started.

 

Evaluating and Correcting an OHSMS

We’ll break this article down into 5 parts:

  1. Monitoring, Measuring, and Assessing an OHSMS
  2. Performing Incident Investigations
  3. Auditing the OHSMS
  4. Performing Corrective Actions
  5. Updating OHSMS Planning Process and Management Review

To help with terminology, the following definitions are drawn directly from Appendix F of the ANSI Z10 standard:

  • Hazard: A condition, set of circumstances, or inherent property that can cause injury, illness, or death.
  • Exposure: Contact with or proximity to a hazard, taking into account duration and intensity.
  • Risk; An estimate of the combination of the likelihood of an occurrence of a hazardous event or exposure(s), and the severity of injury or illness that may be caused by the event or exposures.
  • Probability: The likelihood of a hazard causing an incident or exposure that could result in harm or damage—for a selected unit of time, events, population, items or activity being considered.
  • Severity: The extent of harm or damage that could result from a hazard-related incident or exposures.
  • Risk assessment: Process(es) used to evaluate the level of risk associated with hazards and system issues.

Monitoring, Measuring, and Assessing an OHSMS

Your company should monitor and measure hazards, risks, and controls at the workplace.

There are two primary purposes of monitoring and measuring. The first is to see if the OHSMS is working as intended. The second is to make sure any safety and health problems are identified and then fed back into the OHSMS planning process with the goal of eliminating them.

Identify and track leading indicators that predict risk as well as lagging indicators such as injuries and illnesses. Leading indicators may include things like near-misses and more. Read more about EHS leading indicators here.

Monitoring and measuring may include some or all the following, plus possibly others:

  • Workplace inspections
  • Workplace testing
  • Exposure assessments
  • Injury, illness, and incident tracking
  • Safety suggestions from employees
  • Occupational health assessments

Always perform these monitoring and measuring tasks in a manner that matches or exceeds recognized industry standards or best practices, and always communicate findings to relevant parties.

We’ve included some additional, more specific information below.

Exposure Assessments

These measure, calculate, or estimate a worker’s contact with or proximity to a specific hazard. They may take note of things such as duration, frequency, intensity, or severity.

Examples include things like:

  • Air monitoring
  • Noise monitoring
  • Measuring distance from dangerous heights
  • Ergonomic risk exposures
  • Radiation exposure

Injury, Illness, and Incident Tracking

Track these and compare them over time to consider their frequency and severity. Don’t rely on these as your only measure, however. Because these numbers by definition are the errors the OHSMS is trying to prevent, relying on just tracking injuries, illnesses, and incidents may tempt companies to falsify or otherwise manipulate these figures to show improvement or hide evidence of failure.

Employee Suggestions

There are a number of ways to get employee suggestions. The key is to actively keep lines of communication open, solicit opinions, and let employees know their input is valued. It may be especially important to get employee input on tasks that are not performed frequently, as the safety aspects of these may not be as familiar.

Occupational Health Assessments

These man include medical examinations, biological monitoring, reviews of health records, and more.

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Performing Incident Investigations

Establish a process so that all incidents, including major/severe incidents, minor incidents, and near-misses will be reported. Then, be sure to investigate all incidents to determine a root cause and control hazards or correct system problems that allowed the incident to occur–so it won’t happen again.

Begin the incident investigation as soon as possible after the incident occurs. The incident investigation process should:

  • Define what is being investigated
  • Establish timeframes for the investigation
  • Define who should participate in the investigation
  • Explain how recommendations from the investigation will be created, distributed, and communicated to prevent similar incidents from occurring again.

For more information, please check out extended article on Performing an Incident Investigation.

In addition, the ANSI Z10 standard’s Appendix K includes a lot more helpful information on incident investigations and includes an incident investigation template.

Auditing the OHSMS

It’s also important to audit the OHSMS periodically to make sure each part of the system is working as intended.

Note that this is an audit of the occupational safety and health management system (OHSMS) and not a compliance audit. The purpose of the audit is to make sure the OHSMS is in conformance with the Z10 standard, other OHSMS standard, and/or the organization’s overall vision of their OHSMS.

Auditors should be:

  • Competent persons (the level of competence should be appropriate for the scope and complexity of the audit)
  • Not the person who’s responsible for performing the part of the OHSMS that’s being audited (it’s not necessary that they be external to the organization, however)

It’s important to encourage employee participation in the audit process as well.

The audit should be documented and audit results should be communicated to:

  • The people responsible for any corrections and preventive actions necessary
  • Supervisors of work areas
  • Others, including employees, employee representatives, and contractors

If the audit uncovers any situation that might lead to a fatality and/or a serious injury or illness in the near-term future, make sure prompt corrective action is taken to control the hazard.

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Performing Corrective Actions

The OHSMS should identify any uncontrolled hazards and system deficiencies in order to control and/or correct them and reduce risk to an acceptable level. The most severe hazards should be corrected first and in an expedited manner. Others should be addressed after. The goal is not necessarily to remove all hazards and/or risks, but to reduce risk to an acceptable level.

For more about these concepts of risk, safety, hazards, and acceptable levels of risk, read our extensive article on Risk Management and Safety. You can also check Appendix F of the ANSI Z10 OHSMS standard.

Remember to use the hierarchy of controls to control hazards and lower risks. For more on this, read our extensive article on The Hierarchy of Controls or watch the eLearning course on the Hierarchy of Controls below (you can also download a free copy of the Hierarchy of Controls eLearning course here).

HIERARCHY-OF-CONTROLS-screenshot

Appendix G of the ANSI Z10 standard also has helpful information about the hierarchy of controls.

In cases when it will take an extended amount of time to fully implement the control for an identified hazard to get risk down to acceptable levels, be sure to apply immediate short-term/temporary corrective actions.

No single technique for hazard analysis and/or risk assessment will work for every company in every situation. Instead, you’ll want to pick and choose from a variety of different methods to find the one that best fits the need for the task, hazard, equipment, or process you must assess.

To help with performing hazard analyses and risk assessments, the ANSI Z10 standard includes the following list of methods to consider using in its Appendix F:

  • Brainstorming—a free-flowing conversation that includes employees that frequently perform the task being analyzed; helps to identify hazards, risks, and appropriate controls
  • Checklists—a checklist created by a supervisor to create a safety plan and periodically assess the work site while work is being performed. Typically based on more complete risk assessments created by experienced experts in the field. Z10 states that checklists are most effective if they (1) explain “why?”; (2) explain “how?”; (3) encourage open communication and employee communication; and (4) are part of a continuous improvement process to constantly make sure they cover all risks and hazards.
  • Consequence/probability matrix—This involves doing a task safety analysis and then creating a table, with each hazard listed in a row and the columns used to identify the likelihood of injury, the possible severity of the injury, and the resulting risk. Used for assessing multiple hazards.
  • Risk assessment matrix—The “classic” risk assessment technique used for assessing risk; involves creating a table with likelihood or occurrence frequency making up the rows (measured as frequent and/or likely to occur repeatedly; probable and/or likely to occur several times; occasional or likely to occur sometime; remote or not likely to occur; and improbable or very unlikely), severity and/or consequence making the columns (negligible and/or first aid or minor medical treatment; marginal and/or minor injury, lost workday accident; critical and/or disability in excess of three months; and catastrophic and/or death or permanent total disability); and risk level making the “boxes” at the intersections of likelihood/frequency and severity/consequences (low and/or risk acceptable, remedial action discretionary; medium and/or take remedial action at appropriate time; serious and/or high priority remedial action; high and/or operation not permissible). See our Risk Management and Safety article for more details on this.

For more information on risk assessment techniques, the ANSI Z10 standard suggests you check out ANSI/ASSE Z690.3-2011, Risk Assessment Techniques.

Updating OHSMS Planning Process and Management Review

The organization must establish processes to make sure the results of the monitoring, measuring, incident investigations, OHSMS audits, corrective actions, and preventive actions are all included in the continuing OHSMS planning process (as described in Section 4.2 of the standard and in our Planning an OHSMS article) and in the OHSMS management review process (as explained in section 7 of the standard and in our upcoming Management Review article).

This feedback loop is an essential aspect of the continuous improvement process for the OHSMS.

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Review: Evaluating and Correcting an OHSMS

You can use the tips, methods, and techniques listed and explained above to evaluate the performance of your OHSMS and, if necessary, to correct it as part of your continuous improvement efforts.

Remember that this is just one articles in a larger series of articles about occupational health and safety management systems (OHSMS). We’ve got at least one more article in the series to come–how to perform a management review of your OHSMS. We MAY also write a blog post that summarizes the materials in the Appendices of Z10, which we’ve begun to notice is full of helpful stuff (hats off to ANSI/ASSE for that).

If you’d like to review the earlier posts in the series, here they are:

As a reminder, this entire series is based on ANSI Z10 (2012), the ANSI/ASSE standard on occupational health and safety management systems. You can buy a copy here here.

Let us know if you have any questions. Otherwise, hang tight until we’ve got the next article in this series ready for you,  check out other articles here at the Convergence Training blog, and feel free to download the free guide below.

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Effective EHS Training: A Step-by-Step Guide

Learn how to design, create, deliver, and evaluate effective EHS training by following these best practices with our free step-by-step guide.

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Jeffrey Dalto

Jeffrey Dalto

Jeffrey Dalto is an Instructional Designer and the Senior Learning & Development Specialist at Convergence Training. Jeff has worked in education/training for more than twenty years and in safety training for more than ten. You can follow Jeff at LinkedIn as well.

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