In this article, we’re going to look at some best practices for ensuring management leadership and employee participation in your workplace occupational health and safety management system.
This is the third in a series of articles discussing health and safety management systems. If you’ve missed the two earlier articles, the first was an introduction to various health and safety management system standards and guidelines, and the second was a look at the difference between a H&S management “system” and H&S management “programs” (and more specifically, the difference between the system-approach advocated by ANSI and the ASSE in their ANSI Z10 standard and OSHA’s program approach advocated in their upcoming H&S management guideline).
The entire series of articles is based on information from ANSI Z10, Occupational Health and Safety Management Systems. As we’ve said in the earlier articles, we highly recommend that you buy a copy of the Z10 standard for yourself. There’s a ton of useful information in it, including a large collection of helpful appendices at the end. It never hurts to take some guidance and get some helpful resources from the experts at ANSI and ASSE. The cost is $105.
Also, if you’re a big fan of ANSI standards created by the ASSE, you may want to check out our previous series of articles on ANSI Z490.1, Criteria for Accepted Practices in Safety, Health, and Environmental Training, and/or download our free guide which summarizes those articles.
With the scene now set, let’s get on to the focus of this article: management leadership and employee participation in your health and safety management system.
Management Leadership of the Occupational Health and Safety Management System
Section 3 of ANSI Z10 “defines the requirements for management leadership and employee participation” in your health and safety management system.
Management leadership should direct the organization to establish, implement, and maintain an occupational health and safety management system (OHSMS).
The OHSMS should conform to the requirements of ANSI Z10 that are appropriate to the nature and size of the organization and the health and safety risks.
Z10 notes that “Top management involvement and commitment can be measured by inclusion of the OHSMS as an element of the organization’s business plan, time spent on OHS, visible personal participation in OHS, and the number of OHSMS tasks performed” (by management).
Further, Z10 notes that “leadership by top management includes communicating not only what needs to be done by why it should be done.”
Establishing the Occupational Health and Safety Policy
One of top management’s responsibilities is to establish a documented health and safety policy. This policy acts as the foundation for the occupational health and safety management system.
The occupational health and safety (OHS) policy should include provisions detailing the organization’s commitment to each of the four principles below:
- Protection of employee health and safety and continual improvement of employee health and safety
- Effective employee participation in the occupational health and safety management system
- Conformance with the organization’s health and safety requirements
- Compliance with all applicable occupational health and safety regulations and laws
There’s no single correct way to write the OSH policy. Instead, the OHS policy should be expressed in whatever manner best reflects the organization’s culture and occupational health and safety values. It should then be:
- Signed or otherwise officially authorized and endorsed by top management
- Communicated to all employees
- Made available to interested relevant external parties as appropriate (this could include various stakeholders, including suppliers, customers, contractors, local communities, and other interested or affected parties)
Management Responsibilities for Implementing, Maintaining, and Monitoring Performance of the OHSMS
Management must provide leadership for, and assume ultimate responsibility, for implementing, maintaining, and monitoring the performance of the OHSMS. Doing so includes allocation:
- Providing appropriate resources
- Establishing roles, responsibilities, accountability, and authority
- Integrating OHSMS into the organization’s other business systems and processes
Let’s look at these in more detail.
Management Responsibilities for Allocating Resources
Management must provide appropriate human, organizational, and financial resources to plan, implement, operate, check, correct, and review the OHSMS.
Management Responsibilities for Establishing/Delegating Roles, Responsibilities, Accountability, and Authority
Management must define roles; assign responsibilities; establish accountabilities; and delegate authority to implement the OHSMS.
Roles and responsibilities should be documented.
In addition, Z10 notes that while authority is delegated, “Top management should not simply delegate implementation of the OHSMS to other members” and that “visible leadership by management sets the tone for the entire organization which is much more effective than if driven by health and safety staff.” So, in short, stay active.
Integration of OHSMS into Organization’s Systems and Processes
Management must integrate the OHSMS into the organization’s other business systems and processes. This includes ensuring that the organization’s systems for performance reviews, compensation, rewards, and recognition are aligned with the OHS policy and the objectives of the OHSMS.
The OHSMS may be integrated with the following systems/processes (or more):
- Human resources recruitment
- Worker and incentive compensation systems
- Environmental waste systems
- Permit management systems
- External regulatory, community affairs, and sustainability communications teams
- Materials and/or facilities management, and safety data sheet (SDS/MSDS) information systems
- Risk management and insurance information systems
Employee Participation in the Occupational Health and Safety Management System
Now that we’ve detailed the role of management in the OHSMS, let’s look at the role of employees and the importance of employee participation.
The standard makes the following two key points about employee participation:
“Employees shall assume responsibility for aspects of health and safety over which they have control, including adherence to the organization’s health and safety rules and requirements.”
“The organization shall establish a process to ensure effective participation in the OHSMS by its employees at all levels of the organization, including those working closest to the hazards…”
As to that second point, the one about the organization ensuring effective participation by employees, Z10 recommends doing so by:
- Providing time, resources, and means necessary
- Giving timely access to relevant information
- Identifying and removing barriers to participation
Let’s look at each more closely.
Means, Time, and Resources Necessary to Participate
Employees can’t participate in the OHSMS if they don’t have the means, time, or resources to do so. And so employers should make sure employees do have these. This includes employee participation in:
- Planning the OHSMS
- Implementing the OHSMS
- Evaluating the OHSMS, including corrective action and protective action
The reasons to do including encouraging employees to:
- Be involved meaningfully in the structure, operation, and pursuit of the OHSMS’s objectives
- Identify tasks, hazards, and risks
- Identify possible control measures
- Participate in planning, evaluating, and implementing the OHSMS
According to Z10, effective employee participation in the OHSMS can include a role in:
- Health and safety meetings (check out our series of Toolbox Talk eLearning courses, created in combination with Caterpillar)
- Incident investigations (read our introduction to incident investigations or check out our Incident Investigations eLearning course)
- Development of procedures related to health and safety and to OHSMS
- Audits related to health and safety
- Health and safety training development (see our free Guide to Effective EHS Training based on ANSI Z490.1)
- Job safety analyses (read our explanation of the JHA/JSA or download our free Guide to Conducting a JHA)
- Use of occupational risk management processes (read our introduction to risk management and safety)
- All OHSMS planning processes
Timely Access to Information Relevant to OHSMS
It’s also important to give employees (or their representatives) timely access to information relevant to the OHSMS. As listed in Z10, this can include:
- Issues, objectives, and implementation plans of OHSMS
- Results of incident investigations
- Health and safety monitoring data (read our articles on EHS leading and lagging indicators and on EHS leading indicators for performance measurement)
- Exposure assessments
- Human factor evaluations
- Health and safety committee records
- Injury and illness data
- Risk assessments
- Control programs and activities
Z10 notes that in some cases, “incident investigations or audits performed under legal privilege may have limited distribution.”
Identifying and Removing Barriers to Employee Participation
Z10 lists the following as examples of barriers to participation:
- Lack of response to employee input or suggestions
- Any policy, practice, or program that penalizes or discourages participation
- Any other reprisal (act of retaliation) for participation
As part of this process, employees should always be encourage to report (and know how to report):
Z10 adds a final note that it’s important to design and implement the following carefully so that they don’t act to discourage employee participation in the OHSMS:
- Incentive programs
- Drug testing programs
- Disciplinary mechanisms
Conclusion: Management Leadership and Employee Participation in OHSMS
With that, we’ve concluded our look at the issues of management leadership and employee participation in an effective Occupational Health and Safety Management System (OHSMS).
If you have experience establishing, implementing, maintaining, evaluating, and/or improving an OHSMS at a workplace, we’d love to hear your experiences and thoughts in the comments section below.
Remember that this article is the third in a series looking at Z10 and at occupational health and safety management systems. As a reminder, earlier articles covered:
- An Introduction to Various Standards and Guidelines for Safety and Health Management (including Z10, natch)
- Comparing Safety and Health Management Systems (as described in Z10) with Safety and Health Management Programs (as described in OSHA’s upcoming guidance)
And, our next article will discuss section 4 of Z10, which is about planning the OHSMS.
If you made it this far-congratulations. Reward yourself by downloading the free Guide to Effective EHS Training (based on ANSI Z4901.) below.
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.