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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This entry was posted on Thursday, January 14th, 2010 at 10:45 am and is filed under Political Activity, Safety Culture. You can follow any responses to this entry through the RSS 2.0 feed. You can leave a response, or trackback from your own site.