Is it Time to Revisit ANSI Z10 Occupational Health & Safety Management System?

Back in 2005, the American National Standards Institute published the ANSI/AIHA Z10-2005 health and safety management system standard that was developed through the American Industrial Hygiene Association.  ANSI Z10 was designed as a tool to provide companies with a standard for continuous improvement to minimize risk in the workplace.  It is currently a voluntary management system that can augment systems standards like ISO 9000 and 14000 and is flexible enough for integration with other management systems used in the workplace.  However, this document never seemed to gain much interest in the world of occupational safety.  Primarily because I suspect that OSHA has never embraced it or even encouraged employers to consider the program. 

Case in point: a few years ago I was working with a client assisting them through a settlement agreement with Kentucky OSHA.  The KYOSHA contact was strongly encouraging my client to utilize the Federal OSHA 1989 Safety and Health Program Management Guidelines.  I suggested the ANSI Z10 program, and the response I got was a pause, a look of bewilderment, and then a very direct “We don’t recognize that document.”

This individual apparently wasn’t aware that the ANSI Z10 standard does cover the basic components of OSHA’s 1989 draft Safety and Health Management Guidelines.  However, the Z10 standard goes well beyond the OSHA 1989 document requirements as it also contains provisions that address risk controls, audits, incident investigations, responsibilities, and authorities.

Enter 2010 and David Michaels, the new head of OSHA.  He has been an outspoken advocate of requiring all employers to establish a Comprehensive Workplace Safety and Health Program that features management leadership, worker participation, and structure for continual improvement.  I can’t help but think this will rejuvenate interest in ANSI Z10.  

The ANSI Z10 standard is based on the Peter Drucker quality principles of “Plan-Do-Study-Act.” Like many other safety, health, and environmental management systems, this standard provides you with a tool for continuous improvement.  The underlying goal of the standard is to reduce injuries, illnesses, and fatalities.  

The management system is designed with multiple levels of implementation. Z10 focuses primarily on the strategic levels of Policy and Processes.  It doesn’t provide detailed procedures, job instructions, or the like.  These are expected to be developed according to the user’s needs, thus providing flexibility.  If this document ever becomes an OSHA standard, it will allow for a significant amount of interpretation by OSHA as to what is or is not deemed compliant. 

The entire document is written in a left side/right side format where the left side is “Shall” (required) and the right side is “should” (recommended).

Here is a brief look at the seven different topics contained in the standard:

1. Scope, Purpose and Application:
The basic principles of the standard are covered in this section.  It clearly identifies that the standard can be integrated into other existing quality, safety, and environmental systems that an organization may already be using.

2. Definitions
Be sure to focus on the definitions. For instance, there is no definition of an “accident”; it actually falls under “incident”, which I personally was very excited to see.  I don’t agree with the term “accident” when describing the vast majority of workplace injuries.  Be sure to look at “hazard” and “risk”, which are what this standard focuses around. 

3. Management Leadership and Employee Participation
The standard places the responsibility for the Occupational Health and Safety Management Systems (OHSMS) directly on the shoulders of management. Top management must direct the development, implementation, and maintenance of the OHSMS.   While the standard does emphasize that there must be effective participation on all levels, the onus still falls on “top management” to accomplish this.
One of the benefits of this section is the opportunity to use the standard’s guidance in developing your occupational health and safety policy (OHSP). The OHSP must be made available, dated, and signed or otherwise officially endorsed by top management.

4. Planning
Planning by ANSI Z-10 is described as the process to “…identify and prioritize OHSMS issues.”   The “issues” are further defined as hazards, risks, OHSMS deficiencies, and improvement opportunities.  The emphasis is on determining the hazards and risks and prioritizing and making corrective measures to eliminate or at least reduce those risks. The process is as follows:

A. Review relevant information to identify issues related to safety and health performance
B. Prioritize issues
C. Develop objectives for the system and for risk control.  The program uses the SMART  process to outline the objectives:
• Specific
• Measurable
• Actionable
• Realistic
• Timely
D. Formulate implementation plans
This section will be a source of a lot of debate when looking at OSHA compliance vs. risk mitigation.

5.  Implementation and Operation
This section covers hierarchy of controls, design review, and management of change; procurement, contractors, emergency preparedness, training, communications, documentation, and record control process.  According to the standard, hierarchy of controls means that companies “shall” (required) employ the classic risk reduction steps through:

A. Elimination;
B. Substitution of less hazardous materials, operations, or equipment;
C. Engineering;
D. Warnings;
E. Administrative controls; and
F. Personal Protective Equipment.

      The documentation and record control processes are designed to fit in the ISO 9000 and 14001 quality systems. 

6. Evaluation and  Corrective Actions
This element requires the employer to evaluate performance of the process through:

• Monitoring
• Measurement
• Assessment
• Incident Investigation, and
• Audits

Corrective action is then taken when non-conformance is found and includes results as part of the planning process and review.  Remember that this standard is a management system standard and is designed to view things from a very high level.  For instance, the “audits” are for auditing the OHSMS to make sure it is in compliance with ANSI Z10.

7. Management Review
The last section requires management to continue to participate in the process by regularly addressing identified issues for improvement.  The standard requires that management review the OHSMS at least annually and take the appropriate action. 

Need help with establishing a safety program or any type of OSHA assistance please contact Advanced Safety & Health  toll free at 1-866-339-8040 and we’ll be glad to discuss your needs. 

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On December 16th David Michaels the new Director of OSHA gave a speech at the NIOSH “Going Green” workshop. His speech was titled “Making Green Jobs Safe: Integrating Occupational Safety & Health into Green and Sustainability” where he laid out his five principles for OSHA for the Going Green initiative. But clearly these principles are for OSHA as a whole and not just for the “Green” industry.

Briefly these Principles are:

To require that every employer establish a Comprehensive Workplace Safety and Health Program that features management leadership, worker participation, and structure for continual improvement. 

Significant movement in the area of chemical safety. Expect to hear a lot this year about REACH (Registration, Evaluation, and Authorization of Chemicals).

Prevention through design. He admitted in his speech he doesn’t really know what this will look like.

Step up OSHA rulemaking and streamline the process.

The last principle Michaels calls “Enhancing the worker’s voice”. However, the majority of the time he spent on this item he talked about inaccurate injury and illness recordkeeping and the Recordkeeping National Emphasis Program.

To read his entire speech you can click here.

If there is anything we here at Advanced Safety & Health can do to help you with your safety needs in 2010 please don’t hesitate to give us a call or send and email.

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By now most all of us are aware of the act of heroism by construction worker Jason Oglesbee as he plucked a woman out of the Des Moines River saving her from almost certain death. Many of my colleagues as well as I have been challenged philosophically about this event. Without regard for his own safety Mr. Oglesbee crawled into a set of grade 80 rigging chains and had the crane operator lower him into the water to save the women. I am sure you are aware the outcome was all good. However, it breaks all the rules of crane use and lifting personnel. Now this may sound stupid, but do Mr. Oglesbee and his employer, Cramer & Associates deserve an accommodation or an OSHA citation?

What if he fell from his makeshift chain sling and drowned? What if he and the woman both fell from the crane and died. What if for some reason the crane tipped over and more people would have been killed? Then would this event have been viewed in a different light? Should this employer receive citations from OSHA for doing the wrong thing? Look, I spent the first 15 years of my career in emergency services, I know some times you gotta do what you gotta do. I applaud Mr. Oglesbee for the outcome of his actions. I would be one of the first to cry “foul” if OSHA would now show up and cite Cramer & Associates. But on the flip side, if the crane had fallen, several workers killed then how many would be screaming “where is OSHA, and what are they going to do about this?”

Humor me for just a moment and let’s change this scenario up. Instead of it being water let’s say the lady was found clinging to life in the bottom of a pit that would be classified by OSHA as a “permit required confined space”. A worker throws all the PRCS rules and training out the window and enters the space to rescue the woman. He is overcome, then two of his co-workers go in after him and they all die. Now………….WWOD (What Would OSHA Do)?

What is OSHA going to do? I don’t know. What can they do?

Are they going to investigate and write a citation for what occurred? Wow, if they do can you imagine the backlash? Are they just going to ignore it and turn the other cheek? What message does that send?

So I ask, Citation or Accommodation?

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Ontario Canada’s Workplace Safety and Insurance Board (WSIB) which promotes workplace health and safety, and provides a workers compensation system for the employers and workers of Ontario has put together an impressive media campaign to promote safety in the workplace.   The campaign is called “Prevent-it”.  Here are just a few TV spots that we thought were pretty impressive. The one focus that I applaud them for is instilling the mindset that there is no such thing as an “accident”.  Also that is takes both the employer and employee to implement a functional safety effort.  The website also contains extensive information about prevention, health issues, return to work programs, and links to other health and safety organizations.

  Construction Worker      Factory Worker       Chef

Click here to view videos

For Immediate Release                                          Contact: Diane Hurns, 847-768-3413, dhurns@asse.org

Des Plaines, IL (December 18, 2008) — “Workplace safety processes must be in place at all times,” American Society of Safety Engineers’ (ASSE) President Warren K. Brown, CSP, ARM, CSHMM, of Fairborn, Ohio, said today. “They are even more critical during business downturns.”

Brown is referring to recent reports of some companies cutting safety processes hoping to reduce costs.

“If companies believe they will save money by reducing or ignoring safety for their workers, customers and communities they do business in, they are mistaken,” Brown said. “The ongoing positive results are in and have been for companies that have a strong safety culture and continually invest in and implement effective safety processes. Not only does their bottom line benefit positively, but their company reputation stays intact, employees stay safe and healthy reducing health care, workers comp, training and turnover costs not to mention keeping customers, the communities they do business in, vendors and employees happy. Safety is good business.”

Members of the 97-year-old ASSE — occupational safety, health and environmental professionals located worldwide — caution employers against cutting back on workplace safety in time of economic difficulty.President-Elect of the ASSE South Carolina Chapter Laura Comstock said, “Some safety related purchases and testing can be deferred, but other purchases, such as those for employee personal protective equipment (PPE) like hardhats, safety glasses and respirators, are critical to operations.”It is especially important for companies to show support for their employee safety during challenging economic times, she notes. “Employee morale may be low and employees may be carrying additional workloads, such as working additional hours or doing unfamiliar tasks due to cutbacks,” she notes. Comstock added, “In order to remain viable long-term, a company must maintain a solid safety process even through difficult times. The most successful companies in the long term also have the strongest safety performance.”“We realize these are tough times, but during economic down-turns, employers seeking to cut expenses may target variable operating costs such as travel, training and safety,” Brown said. “Money cut from safety processes now could have an enormous cost later; this can be from injury and health care costs, fines, lost production time, employee morale, or worst of all, employee injury or even death. There are better and smarter ways to protect the bottom line.”The South Carolina ASSE chapter suggests employees can also take measures to help companies save money such as by: following safe working procedures and practices to prevent injuries, related downtime and expenses such as costly fines; by properly using, cleaning and caring for protective equipment such as hardhats and respirators; reusing gloves whenever possible for as long as possible; and by keeping track of safety glasses and reusable hearing protection.

It Saves Dollars and Makes Good Business Sense

In the late 90’s and through 2000 a local business owner was lulled into believing that he did not have a safety problem within his company.  After all, his workers’ comp premium was not going up and in fact he even had a slight decrease in premium.  So he wasn’t concerned. In 2001 he was hit with a 240% price increase from the prior year.  Like any other business owner, he wanted to know how this could have happened to him, and what could be done about it.   While there were significant external factors with the hardening of the workers’ comp and insurance market as a whole, he also looked internally, and he didn’t like what he saw.

This business owner discovered that while his work comp premiums had been holding fairly steady for the past few years, his actual losses had been skyrocketing.  He was now paying the price for not watching his actual losses vs. his insurance premiums.He knew he could not control what the insurance market was doing as a whole, but he could control what was happening within the walls of his operation.  He knew he had to eliminate accidents.  He quickly went to work on the problem knowing the sustainability and profitability of his company depended upon his success.  In the first year he achieved over a 50% reduction in losses from the prior year.  By the third year he had reduced his work comp losses by over 94%.  The net results of his effort are that he is saving thousands of dollars over the next several years in work comp premiums and, on top of that, an untold amount of employee pain and suffering has been eliminated.The fundamental steps he took to achieve this type of success are what I call improving your “safety cultural climate“.  The steps are basic and can be implemented no matter what type of business you run.   

First – Take Responsibility:  Management must develop a belief (I call it a mindset) that all workplace injuries are avoidable, unacceptable, and predictable.  Simply put, you must throw away the notion that workplace injuries are just part of business. Stop putting the blame back on the injured employee.  You must believe that any injury within your organization is a breakdown in your business system and that somehow you, the employer, allowed this event to occur.   Some business owners find this mindset hard to embrace at first, but the ones who do will tell you of the success they have had.  

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