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ISO 45001:201X – Occupational Health and Safety Management

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Safety-BlogsThe development of ISO 45001 for Occupational Health and Safety Management Systems had a significant setback early this year.  By a narrow margin the international committee voted to refer it for additional review and comment.   ISO 45001 is being developed to replace OHSAS 18001:2007.

The effect of the no vote was discussed at the June 2016 international meeting held in Toronto.  Also discussed in Toronto were the 3000 comments that had been made internationally on the draft standard.  The development process is proceeding slowly because many of the participants are still  learning  how ISO management systems work.  These include traditional OH&S professionals and those representing organized labor.

Traditional OH&S Professionals

Traditional OH&S professionals make up a large portion of the members of the US TAG and the international committee.  Most of these members are new to management systems and do not understand how management systems work.  OH&S professionals are quite familiar with “compliance” to OSHA laws.  However, they sometimes struggle to understand that the purpose of a management system is to improve performance over time.  As a result the proposed Standard has become prescriptive including:

  • Requirements to use a Hierarchy of Controls when addressing OH&S hazards
  • Requiring more documentation than necessary
  • Inserting requirements that do not add value

Organized Labor

Organized Labor s a participant in the development of ISO 45001 and represent over 1 million members nationally.  One of the roles of organized labor has  been to help workers negotiate contracts between labor and management on compensation, benefits and workplace safety.   Labor has adopted the position that ISO 45001 should be a “workers’ rights” standard. Their approach to providing input to the ISO 45001 development process is like a contract negotiation.

This has created tension at both the national and the international levels.  Labor views the rest of the TAG as representing “management”.   When others on the TAG propose language that is not aligned with labors’ position, they voice strong  opposition. More then once labor representatives have accused other TAG members of wanting to “kill workers”.

What’s Next for ISO 45001

A committee was formed in Toronto to create the second draft international standard ISO/DIS2 45001:201X which is expected to be issued in the late fall to early winter.  We remain cautiously optimistic that both traditional OH&S and those representing labor will become more informed about the purpose of management systems and how they help organizations improve OH&S performance.  This in turn will help them participate more effectively in the consensus process.  If all goes well, a final international standard could be expected in mid-2017.

ISO 14001:2015 – What is a “Life Cycle Perspective”?

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The term” life cycle” is not new to most, but the use of the term “Life Cycle Perspective” (LCP) in ISO 14001:2015 (2015) is one of the bigger changes in the most recent revision.  Organizations transitioning to the revision must think carefully about how to use a life cycle perspective when planning the transition to the 2015 revision.  2015 requires the use of a life cycle perspective when it states:

Perspective

6.1.2 Environmental aspects
Within the defined scope of the environmental management system, the organization shall determine the environmental aspects of its activities, products and services that it can control and those that it can influence, and their associated environmental impacts, considering a life cycle perspective.

The previous version of 14001 (2004) only mentioned the term life cycle once in the Annex:

The identification of environmental aspects does not require a detailed life-cycle assessment. Information already developed for regulatory or other purposes may be used in this process

In 2015, the term life cycle appears 18 times, 7 of which are associated with the concept of perspective.  2015 does not explicitly define LCP stopping short and providing only a definition of term “life cycle”:

3.3.3
life cycle

consecutive and interlinked stages of a product (or service) system, from raw material acquisition or generation from natural resources to final disposal

Note 1 to entry: The life cycle stages include acquisition of raw materials, design, production, transportation/delivery, use, end-of-life treatment and final disposal.

[SOURCE: ISO 14044:2006, 3.1, modified ? The words “(or service)” have been added to the definition and Note 1 to entry has been added.]

So the major questions are:

  1. How should organizations use a life cycle perspective when planning its EMS?
  2. What sort of evidence will auditors expect to see to confirm a life cycle perspective was used in planning an EMS?

Using a life cycle perspective when planning an EMS.

The introduction of 2015 provides some insight into what the standard means by Life Cycle Perspective when it states:

A systematic approach to environmental management can provide top management with information to build success over the long term and create options for contributing to sustainable development by controlling or influencing the way the organization’s products and services are designed, manufactured, distributed, consumed and disposed by using a life cycle perspective that can prevent environmental impacts from being unintentionally shifted elsewhere within the life cycle.

This statement suggests the purpose of using a life cycle perspective is to prevent the unintentional transfer of environmental impacts.  In order to do this, organizations need to expand their view of the impacts derived from their product and services beyond the property fence line.  Organizations need to look up their supply chain to understand the environmental impacts caused by their suppliers and those supplying their suppliers.   In doing so, the organization may be able to identify environmental impacts of which they had been previously unaware.  Armed with this new information the organization can then consider what, if any, control or influence they have over these supply chain environmental impacts.

Similarly, organizations will need to look down supply chains to identify environmental impacts that derive from the use of their products or services by their customers and end users. Also, they need to  evaluate their ability to control or influence these impacts..

Once these up chain and down chain impacts have been identified, 2015 expects that organizations endeavor to address the environmental aspects that are causing these impacts where practical.  How the organizations choose to address these life cycle aspects depends on several factors including:

  • the level of risk the aspect presents to the organizations
  • the level of risk the aspect presents to the environment
  • the degree of influence or control the organization has over the aspect

The amount of control or influence organizations have over life cycle aspects depends on:

  • how far up or down the supply chain is the aspect
  • how a design change will affect the performance or cost of the product
  • Who controls the design of the product or service

Organizations should also use a life cycle perspective when they are reviewing the potential environmental impacts and aspects from outsourced processes that are performed by other organizations on its behalf.

Evidence of a Life Cycle Perspective During Audits

Proving to an auditor that a life cycle perspective was used to identify the environmental aspects may be more difficult than actually using a life cycle perspective.  Based on early experience with 2015 certifications it is apparent that the certification community has not yet reached consensus on what and how much evidence is required to show conformance with the life cycle perspective requirements.  At minimum we recommend some discussion of how a Life Cycle Perspective was used perhaps in the high level documentation like an EMS Manual or in the documented procedure how the organizations addressed the requirements of Clause 6 Planning.

A graphic such as the one here describing the various life cycle stages may also be helpful in satisfying auditors need for evidence.Life Cycle Perspective ECSI copyright 2016

Unfortunately, and in the short term there is likely to be much variation between certification bodies and individual auditors regarding what is acceptable evidence of conformance the LCP requirements.  We encourage organizations to have a discussion up front with the auditors before the Stage 1 or transition audit about what the Certification Body (CB) and auditor will be looking for when collecting evidence that a LCP has been used in the EMS.

ISO 45001 – Other Risks and Other Opportunities

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risk_management_supply_chain_1320_892_60ISO/DIS 45001 is the new ISO Standard for Occupational Health and Safety Management Systems.  The public comment period for the draft international standard is open until April 2, 2016.  One of the important issues debated at the recent meeting of the US TAG in Dallas. TX,  Feb 22-25, 2016 was a requirement unique to ISO 45001 that  organizations are required  to assess “other risks” to the OHSMS.  Neither ISO 9001:2015,14001:2015 or OHSAS 18001 have such a requirement.  Here is what is required:

6.1.2.2 Assessment of OH&S risks and other risks to the OH& S management system

The organization shall establish, implement and maintain a process(es) to:

b) identify and assess the risks related to the establishment, implementation, operation and maintenance of the OH&S management system that can occur from the issues identified in 4.1 and the needs and expectations identified in 4.2.

To better understand what is expected one needs to go to the Annex of the standard where there is a list of examples in A.6.1.2.2 of what needs to be considered as follows:

“The organization should also give consideration to those risks which are not directly related to the health and safety of people and address factors affecting the OH&S management system, its performance and intended outcomes. These risks should be assessed using an appropriate method”.

Potential sources of risk to the OH&S management system can include:

  • inappropriate context analysis; outdated analysis;
  • inadequate consideration of OH&S management system requirements, change management and other health and safety issues in strategic planning and other business processes;
  • the absence of resources for the OH&S management system, whether financial, human or other;
  • an ineffective audit program;
  • poor succession planning for key OH&S management system roles;
  • poor top management engagement in the OH&S management system activities;
  • failure to address the needs and expectations of relevant interested parties;
  •  poor OH&S performance leading to reputational risks.

The standard also requires organizations to identify “Other Opportunities” in clause 6.1.2.3(b) when it says:

“The organization shall establish, implement and maintain processes to identify:

b) opportunities for improving the OH&S management system”.

Again the annex provides a bit more guidance regarding “other opportunities” in A 6.1.2.3.  Here is what it says:

Opportunities to improve the OH&S management system can include:

  • improving the visibility of top management’s support for the OH&S management system;
  • enhancing incident investigation processes;
  • improving the processes for worker participation;
  • benchmarking, including consideration of both the organization’s own past performance and that of other organizations;
  • collaborating in forums which focus on topics dealing with health and safety.

Some of the US TAG experts argue that without a requirement to address these other OH&S Risks and Other OH&S Opportunities the management system will be ineffective and will not lead to OH&S performance improvement.  Others on the US TAG maintain that by implementing and operating an ISO 45001 OHSMS the organizations will address these potential risks and requiring an additional step to look at these other risks is redundant and confusing to potential users.

What do you think?  Leave a comment here and… if you like… take the survey and express your opinion.

ISO 45001 – Hierarchy of Controls (HOC) – Should it be a Requirement?

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Section 8.1.2 of ISO/DIS 45001 requires that organizations “shall establish a process and determine controls for achieving reduction in OH&S risks using the following hierarchy:

  1. occupational_health_safetyeliminate the hazard
  2. substitute with less hazardous materials, processes, operations or equipment
  3. Use engineering controls
  4. use administrative controls
  5. provide and ensure use of adequate personnel protective equipment

The US Technical Advisory Group at its recent meeting in Dallas, TX Feb 22-26, 2016 had lengthy and at time heated discussion about requiring the use of the HOC.  The basic question is should the phrase “using the following hierarchy” be revised to soften it by saying “considering the following hierarchy”.

Many of the seasoned OH&S professionals in the group believe that the language should remain as “use” . They believe the HOC is well accepted in the industry and it is also required by law.  Others on the US TAG with experience in drafting and auditing ISO standards like ISO 14001 think the use of the HOC should be optional.  They maintain that it will be difficult during audits to prove that the HOC was used and that additional control is not possible or practical.

The standard also requires that the OH&S Policy “includes a commitment to control OH&S risks using the hierarchy of controls.

Give us your opinion and please take the survey.

Results of ISO 45001 US TAG Meets in Dallas, TX  – February 22-26, 2016

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We recently participated on the leadership team for the United States Technical Advisory Group (US TAG) for the Development of the  new ISO 45001 standard for Occupational Health and Safety management systems.  Group Photo at ISN

The purpose of the week long meeting held at the ISN headquarters in Dallas, TX was to disposition over 800 comments on ISO/DIS 45001.  The US TAG successfully dispositioned all of the major issues and many of the individual comments.  Our role at this meeting was as co-chair of a subcommittee with Vic Toy for Clause 6 – Planning.  Our section had 157 comments to review and decide how they would be addressed.

The meeting was attended by about 70 participants representing business, organized labor and government.  Major issues addressed during the meeting included questions and comments like:

  • Should organizations be required to use the hierarchy of controls when reducing risk?
  • Does redundancy add clarity or confusion (frequent references to workers and worker representatives)?
  • Should organizations be required to assess risk to the management system (other risks) or is this already addressed by the clauses of the standard?
  • When must workers be asked for an opinion (consultation) and when must workers have authority to influence decisions made by management about risk control and other management system issues (participation)?

We have posted some articles about the following on our website blog if you are interested in learning more about these important issues.

  • ISO 45001 – Hierarchy of Controls
  • ISO 45001 – Other Risks and Other Opportunities

The public comment period in the USA is now open until April 1, 2016 so if you are in the USA and your organization would like to submit comments for consideration send me an email to tagosh@envcompsys.com and I can help you get the comments to the right place. Also please feel free to call or email with any questions about ISO/DIS 45001.

ISO 45001 Update – June 2015

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Goole Bikes

The famous Google Bikes!

We recently participated as voting members in a meeting of the United States Technical Advisory Group (TAG) for the new ISO 45001 (Occupational Health and Safety) standard.  The meeting was held at Google Headquarters in San Francisco.  Extensive discussion took place within the TAG regarding the United States TAG position on the proposed ISO 45001 Draft Standard (CD#2).  The consensus was strong that the United States TAG believes the standard is still not ready to move to the next stage of the standards development process (DIS).  To this end, a motion was made, seconded, and unanimously approved during the course of the meeting and at a follow-up conference call.

The motion and its result were communicated in a letter to the American National Standards Institute (ANSI) on June 3. The motion was as follows:

The United States votes “No with Comments” on the draft standard with the position that the proposed standard is not yet ready to move to the DIS stage of the standards development process.

The impact of this negative vote is uncertain because the US has only a single vote on the International ISO 45001 committee (PC283) and there could be enough votes by other nations to move the standard to DIS rather than to another Committee Draft.  The US is voting that the standard go through another cycle as a Committee Draft (CD3) to allow more time to iron out some sensitive and controversial issues.

METADATA-START

When at work Googlers are never more than 100 feet from good, healthy food

Initially many of the TAG and PC members familiar with government mandated safety requirements (OSHA) were of the belief that this standard was much like a new law or labor regulation.  The good news is that the understanding of the standards development process by memberships of the US TAG and members of the International Committee is maturing which in turn has resulted in more flexibility for users of ISO 45001.  Over the last 2 years many of the membership has come to understand that allowing flexibility in how organizations choose to implement their OHSMS is key to its acceptance by potential users.

During the meeting in San Francisco we were able to talk candidly with the US TAG leadership and the belief is that a final draft of the ISO 45001 standard may not be ready until early 2017.  This will require that the PC is granted a 9 month extension to the three year project timeline that was originally approved by ISO.

TC 207 – Survey request on Verification of Environmental Sustainability Reports

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652px-Logo-ISO[1]In 2011 the ISO/TC 207/SC 2 – Environmental auditing sub-committee established an ad hoc group to gather information on current developments on auditing/verification of publicly available environmental and sustainability reports. Status reports were given at the 2012 and 2013 meetings. In 2013 the ad hoc group decided to conduct a survey to gather further information on the market needs for a standard on the topic of verification of environmental sustainability reports for discussion at its upcoming meeting in Panama on May 27, 2014.

TC 207 is seeking your assistance in obtaining broad participation in this survey. The survey can be accessed via the following link:https://www.surveymonkey.com/s/RCBL6D5. The survey will be open until May 2, 2014. We understand that this is a short timeframe for capturing this information but the deadline was established by ISO to make sure responses were available in time for consideration at the Panama meeting.

To obtain a statistically diverse and representative sample we are requesting that you consider passing this survey to other experts and stakeholders that you are familiar with personally.  We are hoping to get responses from a variety of organizations, based upon their environmental risk, number of employees, size and type (small, medium, and large as well light, medium, and heavy manufacturing), as well as those in the public and/or private sector.

Day 4 – ISO 14001 EMS Lead Auditor Washington, DC, 4/10/14

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Day four of ISO 14001 Lead Auditor is going well.  A great group of folks in the class makes my job here in DC enjoyable.  From time to time I wonder if ISO 14001 is destined for jettison to the ash heap of sustainability irrelevance.  I sometimes question if others will continue to believe as I do that an ISO 14001 environmental management systems is a good way to manage the plant part of sustainability’s triple bottom line.14001_0414_dc

But teaching this class often restores my confidence that ISO 14001 will continue to be relevant for the foreseeable future.  Students continue to appreciate learning the fundamentals of environmental aspects, impacts, significance, auditing including the relationship between audit criteria, evidence, findings and conclusions.   I also believe that the current revision process is tracking well toward delivering an improved model for environmental management systems and I am looking forward to teach this course for the revised standard next year.

ISO High Level Structure and EH&S Management Systems

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ISO 14001 and OHSAS 18001 are undergoing significant change intended to improve these standards.  The new ISO High Level Structure will align all ISO standards along a common management systems structure and promote integration.   The recent US Technical Advisory Group meeting in Orlando, Florida was a particularly enlightening conference for us where US TAG members were able to share their ideas of the way the HLS applies to EHS management Systems.

ISO HLS & EHSMS

ISO HLS & EHSMS

An important part of the revision processes is being able to communicate to current and new users how the standards are changing and how these changes will affect an existing EHSMS.  This diagram represents how we at ECSI see the developing changes to ISO 14001 and ISO 45001 and the relationships between some of the important clauses of the revised standards.

We are interested in understanding how users of the EHSMS standards feel about the changes and what information they need to begin to plan for the changes to their EHSMS.  ECSI will be conducting a short, one hour webinar Tuesday, April 22, 2014 from 10am-11am Central Standard Time.  The purpose of the seminar is to provide the current state of the revision process and to discuss how we see the EHSMS standard revisions progressing.  If you are interested in participating in one of these webinars send us an email to webinar@envcompsys.com and we will reply with the logon instructions.

ISO 45001 Annex 6 – Response to Comments

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My draft was meant to be for the Annex only.  It was not intended to be included, or as a supplement to, the normative part of the standard.  I offered the draft of the Annex more to stimulate discussion than expecting it to be incorporated in its entirety.  As I have said from the beginning.  I believe that the HLS should remain largely intact without significant discipline specific additions.  Most discipline specific language for clarification of intent should be introduced in the Annex.

I like the idea of working the development process of this and other standards like ISO 14001 from back to front.  In other words, let’s work on the Annex (informative part of the standard) first, agree on what we want it to achieve and what the Annex should contain, and then decide what needs to be changed in the normative part of standard to meet the discipline specific outcome we want.

I also understand the desire to use much of Z10 to form the basis for ISO 45001.  However, I believe that we can improve upon the ideas presented in Z10 as we develop 45001, especially appendix F and the example risk matrix it contains.

Regarding the question of how opportunities should be addressed in the standard, I believe it matters little where opportunities are addresses.  It may be appropriate to address them in both 8 and 10 and maybe a little bit in 6.  I do however believe that we need to have a better idea about what we mean by opportunities before we add discipline specific language to the HLS in any or all of those clauses.

I believe there are at least two types of opportunities that can be identified, those being opportunities to reduce risk, and those opportunities that can result in other value enhancement.  Sometimes exploiting one type of opportunity comes at the expense of the other. ice3 Ice diving is a good example.  Personally I think you need to be out of your mind to do it, but some folks find great pleasure in scuba diving below the ice and take every opportunity they can to enjoy it.  One of the hazards of ice diving is getting lost under the ice and not being able to return to  the hole before your air supply is exhausted.  The bigger the hole, the easier it is to find when you want out of the water.  But cutting a big hole through 3 foot thick ice is hard and there comes a point where the discomfort in cutting the hole out weights the fun the divers expect to have on their adventure.  So the divers manage the likelihood of becoming trapped beneath the ice in other ways, like roping up and having folks at the surface holding the other end of the rope.  Managing the risks and enjoyment of an ice dive becomes an optimization problem.

The ISO 45001 standard Annex (either 6, 8 or 10) should include information to help users understand the relationship between risks and opportunities and that there are different types of opportunities they can exploit.  Once we have the right language in the annex, we can then think about what changes might be need in the standard itself to make the HLS work for the OH&S discipline.  Again this is the back to front approach to standard development I prefer.