How to Design and Implement a Safety and Health Management System Pam (Ferrante) Walaski, CSP, CHMM JC Safety & Environmental, Inc. Pittsburgh, PA www.jcsafety.com Essential Questions  Why Safety Management Systems? • Paradigms • History  What Standards Can Guide Me? • ANSI/ASSE Z10-2005 (Occupational Safety & Health Management Systems) • ANSI/ASSE Z590.3 (Prevention through Design)  How Can I Implement an SMS at My Organization 2 Polling Question #1 How would you rate your knowledge of Safety Management Systems? 1. I have heard the term but don’t really understand what it means. 2. I have a remedial understanding of what SMSs are and how they work. 3. I have a fairly strong understanding of SMSs but my organization doesn’t really implement one very well. 4. I think that my organization both understands and implements a robust SMS. 3 Rethinking the Paradigms Was Heinrich wrong with the injury pyramid?  The ratios apply to the same person  Ratio not concurrence  Mistaken assumption that frequency reduction leads to severity reduction 4 Rethinking the Paradigms Was Heinrich also wrong with the “domino theory”  “first, direct, and proximate cause of why persons commit unsafe acts”  Often leads to “operator error” as only cause  Limits incident investigations and root cause analysis 5 Rethinking the Paradigms How about the Pareto Principle? The law of the “trivial many and the critical few” Also known as the 80/20 Rule 20% of the units represent 80% of the financial impact and source of improvements Too much time on the 80% gives minimal ROI 6 Rethinking the Paradigms How about Deming’s Rule?  85% of the problems in any operation are within the system and are the responsibility of management, while only 15% lie with the worker 7 Rethinking the Paradigms “Currently, management works under the assumption that people and not the systems they work in are responsible for safety. We therefore reward and punish people, but the system they work in remains unchanged.” W.E. Deming Copyright 2011 - JC Safety & Environmental, Inc. Rethinking the Paradigms  Do we have it backwards?  In reducing frequency, have we neglected severity?  Did we think severity would “take care of itself”?  Major reductions in the past 40 years at reducing injuries/illnesses  Then why are serious injuries on the rise?  And what can we do about it? 9 Rethinking the Paradigms Safety by Hazard  Looks at the system from a case-by-case basis  Hazards-based approach to minimizing workplace injuries  Procedures and processes that rely almost exclusively on worker behavior 10 Rethinking the Paradigms “Common Sense is not so common.” Voltaire My common sense is based upon my life experiences, my values, my perceptions. And it’s not the same as yours. Is that really what you want to base your safety program on? Copyright 2011 - JC Safety & Environmental, Inc. Rethinking the Paradigms Safety by Design  Risk assessment approach to managing workplace incidents  Assessing risks and designing systems to reduce them to an acceptable level.  Emphasis on preventing incidents through designing them out 12 Polling Question #2 How would you rate your knowledge of ANSI/ASSE Z10-2005 (Occupational Safety and Health Management Systems)? 1. I have never heard of it. 2. I have heard of it, but have never seen/read/reviewed a copy. 3. I have a copy and have skimmed it but don’t really have a strong working knowledge of it. 4. I have a copy and understand the Standard, but have never implemented it in my organization to an great degree. 5. We implement some, if not all, of the Standard in our organization. 13 ANSI Z10 Brief History  AIHA obtains approval to be Secretariat in March 1999  Approved by ANSI on July 25, 2005  Currently under regular revision process 14 ANSI Z10 Key Issues  Originally planned to be a resource for smaller businesses  Is a Guidance Document not a Certification Standard  Is a Performance Standard not a Specification Standard  Follows standard “Plan, Do, Check, Act” process for continuous improvement 15 Summary of Standard 1.0 – Scope, Purpose, and Application 2.0 – Definitions 3.0 - Management Leadership and Employee Participation 4.0 - Planning 5.0 – Implementation and Operation 6.0 – Evaluation and Corrective Action 7.0 – Management Review Appendices A-K 16 OHSMS Model 17 ANSI Z10 – How’s It Working?  Seeing a shift from managing hazards to managing risks  Review and prioritize risks, develop measures to address, audit the process, revise (Plan, Do, Check, Act)  Less “zero accidents” - more “acceptable risk”  Compliance based activities are a given, not the driving force 18 ANSI Z10 – What Can You Do?  Safety through design • Lack of formal risk assessments • Hierarchy of controls  Management of change (MOC) • Use of contractors/Outage work/Unusual operations  Incident Investigation • Weak procedures not fully implemented • “Operator error” 19 MOC Processes  Disciplined approach to change  Manages deviations from normal operations – a significant predictor of serious incidents 20 Not implementing MOC? Why Not?  Changes in raw materials/feedstock  Changes in physical layout – affects exit routes  Installation of new equipment  Modification of new equipment  Changes in electrical service  Personnel changes in key positions 21 MOC Processes Identify unusual and non-routine work for formal MOC process:  Define the purpose  Establish accountability levels  Specify criteria that trigger process  Clear procedures for use of process  Criteria and responsibilities for reviews  Determine procedures to be followed  Establish process to evaluate results 22 Polling Question #3 On a scale of 1-5, how would you rate your organization’s Incident Investigation process? 1. Very poor/nonexistent; 2. We cover just the basics; 3. We do a good job of investigating most incidents, but our investigations are fairly limited ins cope and our corrective actions often don’t get done 4. We do an above-average job with investigating incidents, identifying causes, and developing a corrective action plan 5. We do an excellent job with not only investigating incidents, but also near misses and property damage incidents. 23 Incident Investigations  “The quality of incident investigation is one of the principal markers in evaluating an organization's safety culture.”*  “…incident investigations…a prime source of selecting leading indicators for improvements…”*  Remember Deming’s Rule? *Source: Manuele 24 Incident Investigations  Comprehensive with clear policies and procedures  User-friendly forms  Training for all levels of staff  Internal oversight of process  Investigate everything – near miss reporting system  Ongoing follow-up of corrective action plan 25 Polling Question #4 How would you rate your knowledge of ANSI/ASSE Z590.3-2011 (Prevention through Design)? 1. 2. 3. 4. 5. I have never heard of it. I have heard of it, but have never seen/read/reviewed a copy. I have a copy and have skimmed it but don’t really have a strong working knowledge of it. I have a copy and understand the Standard, but have never implemented it in my organization to an great degree. We implement some, if not all, of the Standard in our organization. 26 PtD A Brief History National Safety Council (late 1990s)  Benefits from integrating safety into design and redesign processes  Earliest recommendations on design initiatives NIOSH Stakeholders Meeting (2007)  “Create a sustainable national strategy for Prevention through Design”  Need to develop a standard or regulation to set forth principles and methodologies 27 NIOSH PtD Initiative 28 PtD A Brief History ASSE  Position Paper “Designing for Safety” (1994)  Manuele article – “Prevention Through Design: Addressing Occupational Risks in the Design and Redesign Process” (2008)  Technical Report Z790.001-2009 29 PtD A Brief History ASSE  Approved to become Secretariat in 2008  Approved for submittal to ANSI in February 2011  Approved for publication – September 1, 2011 30 What is PtD? “One of the best ways to prevent and control occupational injuries, illness, fatalities is to design out and minimize hazards and risk early in the design process.” NIOSH PtD Initiative 31 Z590.3 & Z10 Z10 is the what systems in place to control hazards and reduce risk at the design stage Z590 is the how risk assessments, acceptable risk, risk controls 32 Z590.3 & Z10  PtD efforts will be much less effective without an effective safety management system in place first – “This standard gives guidance on including prevention through design concepts within an occupational safety and health management system.” 33 Summary of Standard I. Scope, Purpose, and Application II. Referenced and Related Standards III. Definitions IV. Roles and Responsibility V. Relationships with Suppliers VI. Safety Design Reviews VII. The Hazard Analysis and Risk Assessment Process VIII.Hazard Analysis and Risk Analysis Techniques IX. Hierarchy of Controls 34 PtD Flow Hazard Identification and Analysis Risk Assessment Acceptable Risk Design of controls hierarchy 35 Risk Assessment Tools  Matrices • Simple and complex  Preliminary Hazard Analysis • Initial design review for operations safety  What-if Analysis • Possible hazards, scenarios, how incidents occur and their outcomes  Failure Modes and Effects Analysis • Determines effects of failures 36 Risk Assessment Data gathering/Team gathering Identify tasks and hazards Determine frequency and duration Determine occurrence probability 37 Risk Assessment Assess severity of consequences Quantify risk with scoring system Rank risks in priority order Document controls and results 38 Risk Assessment Follow-up on actions Assess residual risk – acceptable? Complete process and schedule for review 39 Polling Question #5 How comfortable are you/your organization with the term “acceptable risk”? 1. 2. 3. 4. I don’t know the term very well or don’t really understand how it could apply to a safety program I think the term shouldn’t apply to SH&E because no risk can be acceptable I know and understand the term very well, but am having a hard time getting my organization to buy into it. Both my organization and I are on board with it and use it as an integral part of our SH&E program. 40 Acceptable Risk “Because nothing can be absolutely free from risk, nothing can be said to be absolutely safe. There are degrees of risk and, consequently, there are degrees of safety.” W. E. Lowrence (1976) 41 Hierarchy of Controls OSHA 1. Engineering controls 2. Administrative controls/safe work practices 3. Provide PPE CCOHS 1. Elimination 2. Engineering controls 3. Administrative controls/work practices 4. Provide PPE 42 Hierarchy of Controls - PtD Risk Avoidance Eliminate Substitution Engineering Controls Warning Systems Administrative Controls Personal Protective Equipment 43 Hierarchy of Controls PtD 1. Risk avoidance 2. Eliminate or reduce in design and redesign process 3. Reduce risk by substitution  Preventative actions  Rely least on performance of personnel  Difficult to defeat 44 Hierarchy of Controls PtD 4. 5. 6. 7. Incorporate safety devices Provide warning systems Apply administrative controls Provide PPE  Contingent actions  Rely substantially on personnel performance for effectiveness 45 Roles and Responsibilities  Calls for substantial and direct oversight by top management  Can designate internal staff to perform tasks, use external consultants or require suppliers and owners of facilities to perform the task 46 Relationships with Suppliers  Design specifications developed with internal procurement staff  Made available to potential suppliers, engineering firms and contractors  Include safety and health performance specifications so hazards aren’t brought into the workplace 47 Relationships with Suppliers  Must require that suppliers conduct risk assessment and assure that acceptable risk level has been achieved  Staff should visit suppliers to confirm  Do a test run at site when possible  Validation test after equipment is installed 48 For Further Review Manuele articles Prevention through Design (10/2008) http://www.asse.org/practicespecialties/academics/ docs/f1_manuele_1008.pdf Acceptable Risk (5/2010) http://a.gncdn.com/pfa/LnEw5PyDMYUH772Xatl1BM4G1qxYerHR3Xum-HfgLCnak6vEhM5zdp8gvpIkGuyA==/F1Manuel_0510.pdf Reviewing Heinrich: Dislodging the Myths (10/2011) https://www.asse.org/professionalsafety/pastissues/ 056/10/052_061_F2Manuele_1011Z.pdf 49 To Purchase the Standards Occupational Safety and Health Management Systems http://www.asse.org/shoponline/products/Z1 0_2005.php Prevention through Design https://www.asse.org/cartpage.php?link=sta ndards 50 How to Design and Implement a Safety and Health Management System Pam (Ferrante) Walaski, CSP, CHMM JC Safety & Environmental, Inc. Pittsburgh, PA www.jcsafety.com