The Integration Dr Blog

Organizations that are implementing 3 management systems – Quality (Q), Environmental (E), and Occupational Health and Safety (OHS) – are doing it for a variety of reasons:

• they want to manage all of their requirements under one system;
• they are incorporating, combining, or reducing headcount;
• they are looking for additional savings and efficiencies;
• they are interested in providing information to their employees that are incorporated into one document

What does that one employee document look like?  It may look something like this:

Employees are to manufacture the widget to meet quality and customer specifications (see attached); using safe practice for handling chemicals including applicable PPE (personal protective equipment) – chemical resistant gloves and safety glasses; and if there is any chemical spill, appropriate steps shall be taken including containment and clean-up.

So, we’ve told the employee to make a high quality part (Q), using PPE (OHS), and what to do if there is an accidental environmental impact via spill (E).  The employee shouldn’t look at this and say, “Hey – is this a Q, E, or OHS instruction?”  They should look at it and say, “Hey, this is what I have to do to meet the requirements of my job.”  It should be seamless to them which standard they are meeting; they should meet all requirements, regardless of which standard the requirement originates from.

How to do the integration?  We know from previous posts on integrating Q and E and integrating E and OHS that there are overlapping requirements among the standards.  When implementing the trilogy of standards that are the subject of this post, it is important to remember that, while there are several areas of alignment, including management reviews, internal audits, document and records control, and corrective and preventive actions, there are also several requirements that are unique to one or two of the standards (but not the other(s)).  Therefore, it is important to identify and address the unique requirements, and ensure that they don’t get overlooked in our ecstasy of implementing an integrated system.  What are some of these requirements?  We need to address customer requirements for quality; the environmental aspects/impacts for environmental and health/safety aspects/impacts for OHS; risk management and management of change for OHS; to name a few.

I’d love to hear your comments on your integration – what worked and what didn’t?  Any tips or advice for others?  Please share!

Depending on your industry, you may be asked to integrate an Environmental (E) system with an Occupational Health and Safety (OHS) system to make your system more robust; to save time and effort; or to comply with customer requirements (to name a few of the many reasons cited for integration of E and OHS).

With the latest revisions of ISO 14001 and OHSAS 18001, integration is very easy to implement.  [A joke within the consulting field is that one standard is identical to the other with the exception of the “global replace” – and it’s not too far from wrong].  Since there is virtual identical redundancy in requirements in most cases, integration is the way to get a bigger ‘bang for the buck’.  However, there are important differences between these two standards, and you want to ensure that you are not overlooking the differences between the two standards while doing the implementation.

Unique areas of the standard: for OHS, the organization must consider acceptable risk and risk management; management of change; participation of workers; and incident investigation. For EMS, the focus is on environmental impact rather than impact to workers/safety.

Areas that are similar include a Policy (4.2); hazard (OHS) or Environmental (E) identification (4.3.1); legal and other requirements, and compliance (4.3.2 / 4.5.2); objectives and programs (4.3.3); roles and responsibility (4.4.1); competence, training, and awareness (4.4.2); communication (4.4.3); documentation (4.4.4); control of documents (4.4.5); operational control (4.4.6); emergency preparedness/response (4.4.7); measurement and monitoring (4.5.1);  nonconformity, corrective and preventive actions (4.5.3); control of records(4.5.4); internal audits (4.5.5); and management review (4.6)

Let’s presume that you are working a problem in your facility – the problem is a rather thorny one, and is affecting multiple management standards.  How should you handle the root cause determination, and the corrective action resulting from it?  For reporting purposes, how do you report it for metrics – as a problem in all three metrics?  Do you pick one and let the other standard metrics alone?  What’s the best way to handle this?

Here’s a hypothetical problem:  you’ve noticed that a chemical used in your facility has been used up  prematurely, so there is insufficient quantities to maintain production; you investigate further and discover that an employee was trying to attach a hose without the correct safety equipment and process equipment in place, and he was injured; before he could turn off the valve, the chemical poured out onto the tank farm floor, resulting in a chemical spill.  The resulting problem affects the product quality, employee safety and health, and requires a chemical spill cleanup – so we’ve got an impact from a QMS, OHS, and EMS standpoint.  What’s the best way to handle the root cause determination, and the interim and final corrective action(CA) ?

Our first step is the put an interim CA in place to ’stop the bleeding’.  Our first concern is the employee   – let’s make sure that they’re safe and getting the attention they need.  Ensure that all safety precautions are in place, then institute chemical spill cleanup per your environmental procedures and following manufacturer and MSDS recommendation, paying particular attention to containment and prevention of chemical down drains that lead to water supplies, or out the door and to the soil.  Now that we’ve got the basics covered in the short term, we want to focus on a) understanding why this happened, and b) ensuring that this won’t happen again.  In order to do that ’smartly’, we want to assemble a small team from the major groups affected, to step through a formal corrective action process — determine the root cause — in this case, determine how the spill happened in the first place.  The team should also determine what permanent CA will be implemented, and take steps to put the permanent CA in motion (ordering new supplies, reviewing spill procedures, safety procedures, etc. and determining what will ensure that this problem won’t happen again, for this reason).  Finally, the org should determine what steps need to be taken to prevent this in the future (preventing this from happening for other reasons), and what this impact may have to product quality.  Do customers need to be notified that shipments may be delayed?  Can an expedited shipment of the chemical be ordered and delivered?

Now let’s take a minute to go back and review:

- Quality is affected – shortfall of one of the raw materials

Fix:  investigate expedited delivery

- improper handling resulted in a chemical spill – both environmental and occupational health and safety implications

Fix:  review the existing environmental and safety procedures; update as required;

- Preventive action:  how could a spill have happened if not this way?  How could an employee have been injured if not this way?  How could our product quality have been affected if not this way?

Is there anything we’ve forgotten?  Anything you’d do differently?  Let me know – I’d love to hear your comments!

Occupational Health and Safety has long been legislated in many parts of the world.  In other areas, OHS control is virtually non-existent, and the impact in these areas (Africa, China, etc. come to mind) is significant.

Let’s talk first about what OHS is, then we can dive into why this standard varies so widely across the globe.

In developed countries, OHSMS is probably in place because it is also mandated / regulated by law.  These countries have had  laws in place much longer than the OHS standard 18001 has been in existence; so complying with OHSAS 18001 has not been difficult.  However, there is little impetus for companies to implement OHSAS 18001:2007 compared with other standards in these countries, since they are often not implementing significant new processes (and therefore reaping significant new benefits).

In developing countries, OHS systems may not be the norm; nor are these countries emphasizing OHS legislatively.  At a recent NOSHCON conference, several speakers presented data on the impact of poor nutrition, dehydration, and substandard working conditions on the accident/incident rate in South Africa.  Not surprisingly, the more compromised a worker is due to ill health (25% of the population is HIV compromised), poor nutrition (employees in the field are fed ‘pap’ – something akin to grits – with hot sauce as their meal); or dehydration (water stations are spaced too far apart to allow workers to get a drink, despite the heat and humidity, without loss of productivity; so workers who are paid by the piece do not hydrate except at lunch, which leads to chronic dehydration).

What is a OHSMS?

it has very similar elements to the QMS and EMS system we’ve discussed in previous blog posts – and this is by design.  Therefore, it has a policy, supported by planning, objectives, and targets; it asks the organization to identify health and safety significant aspects and impacts; and it monitors OHS performance, and provides for continual improvement of that performance.

What are the benefits of a OHSMS?

- it allows the organization to perform a formal assessment of their system.  This is one of the indicators that every company has mentioned in their exit survey as a key benefit.

- it provides the organization with a framework to implement OHSMS as described above.  This gap analysis road map provides a clear action item list, to provide continual improvement project sources.

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