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Manuele Feature Feb 2006.

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Safety Management
Safety Management

The new benchmark for safety management systems
By Fred A. Manuele

FFOR THE FIRST TIME IN THE U.S., a national con-
sensus standard for a safety and health management
system—applicable to organizations of all sizes and
types—has been issued. On July 25, 2005, ANSI
approved ANSI/AIHA Z10-2005, Occupational
dard that incorporates what has been learned in the
past several years concerning the best practices in
occupational safety and health management. In
effect, they have stated that no matter how effective
an existing safety management system has been if it
Health and Safety Management Systems. is lacking with respect to some of the provisions in
This is a major development. The standard pro- the standard, risks can be further reduced by adop-
vides senior managements with a well-conceived, tion of those provisions.
state-of-the-art concept and action outline to improve Employers who have a sincere interest in
safety and health management systems. However, employee safety will welcome discussions on how
few organizations have management systems in place their safety management systems can be improved.
that meet all of the standard’s provisions. As employ- Many companies have issued safety policy state-
ers make improvements in their safety and health ments that say the organization will comply with or
management systems to meet the standard’s provi- exceed all relative laws and standards. Those em-
sions, the frequency and severity of occupational ployers in particular will want to implement provi-
injuries and illnesses will likely be reduced. The soci- sions in the standard that are not part of their current
etal implications of this standard are substantial. A safety management systems.
few of those implications are addressed in this article. Furthermore, ANSI/AIHA Z10 places an obliga-
This standard will have a significant and favor- tion on SH&E professionals who give counsel on
able impact on the content of the practice of safety— what safety management systems should encom-
and on the knowledge and skill requirements for pass to become current with the standard’s provi-
SH&E practitioners. This article reviews select pro- sions. Having occupational safety and health
visions of the standard to which SH&E practitioners management systems that comply with the standard
should pay particular attention. Those provisions is the right thing to do.
pertain to risk assessment and prioritization; apply- One reason the Z10 Committee succeeded was its
ing a prescribed hierarchy of controls to achieve strict adherence to the due diligence
acceptable risk levels; design reviews; management requirements mandated by the ANSI Fred A. Manuele, P.E., CSP, is
of change systems; having safety specifications in process. A balance of stakeholders provid- president of Hazards Limited,
procurement systems; and safety audits. ed input and open discussion, which which he formed after retiring
resulted in vetting to a conclusion each from Marsh & McLennan, where
ANSI/AIHA Z10-2005: Background issue raised. In the early stages of the he was managing director and
American Industrial Hygiene Assn. (AIHA) ob- group’s work, safety and health, quality, manager of M&M Protection
tained approval as the ANSI Accredited Standards and environmental standards and guide- Consultants. Manuele is an ASSE
Committee (ASC) for this standard in March 1999. The lines from around the world were collect- Fellow, an inductee into the Safety
first full meeting of the committee was held in ed, examined and considered. In crafting and Health Hall of Fame Interna-
February 2001. Over the past six years, as many as Z10, the intent was not only to achieve sig- tional and a recipient of National
80 SH&E practitioners have been involved as commit- nificant safety and health benefits through Safety Council’s (NSC) Distinguish-
tee members, alternates, resources and interested its application, but also to impact favorably ed Service to Safety Award. He is
commenters. They represented industry, labor, gov- on productivity, financial performance, also a former board member of
ernment, business organizations, professional organi- quality and other business goals. ASSE, Board of Certified Safety
zations, academe and persons of general interest. The standard is built on the well- Professionals and NSC, and a
Through this, broad participation in the develop- known Plan-Do-Check-Act process for former member of ASSE’s Editorial
ment of and acceptance of the standard was achieved. continuous improvement, for which there Review Board. Manuele is a
The breadth of that participation is significant. A large is abundant reference material. Briefly professional member of ASSE’s
number of SH&E professionals have written a stan- stated, the purpose of the standard is to Northeastern Illinois Chapter. FEBRUARY 2006 PROFESSIONAL SAFETY 25

not a specification standard (see As to breadth of coverage. the required management system audits related to column). and and the use of PPE. Every SH&E practi. since Z10 represents cur- B) Ensure through appropriate education. the standard is compatible and harmonized with risks are to be assessed and prioritized. “This standard is applica.qxd 1/13/2006 3:10 PM Page 26 provide organizations with an effective tool for con. one can envision international require- If Z10 were written as a specification standard.S. a “shall” provision in ANSI/AIHA Z10. Specification Standards 2000—ISO voted on developing a stan- In a management system standard. formance standard. which is essentially a performance standard. caused by the event or exposures (AIHA). ISO is the world’s largest management system manual. Awareness and Competence. the standard is a brief safety and health Standardization (ISO). is represented at ISO by ANSI. nongovernmental developer of standards. Similarities between the guideline and Z10 are tioner who has responsibilities for occupational notable. set of cir- and Safety Management Systems (ILO-OSH 2001) as cumstances or inherent property that can a resource. working with a network of the national stan- dards institutes of 148 countries. safety management systems (OHSMS)” mented and the records shall be retained for a minimum of five years. Comments are made in management system. The ISO membership is worldwide and a consensus for such a standard has not yet Section 5.2-B in the “shall” column (that is. posal was approved. The guideline is an additional reference cause injury. is used to vote against carried by a narrow margin. Training. Intentionally. good safety practices standard.2-B. could be easily integrated into any management sys- A major theme apparent throughout the standard tems an organization has in place. Available Risk is defined as an estimate of the com- for purchase through ILO. to be followed annually with a mini- mum of six hours of refresher materials.Manuele Feature Feb 2006. incident investigation. establish processes to: However. but those comments are not part of the standard. The U. As to structure. the document can also be bination of the likelihood of an occurrence of read (but not printed) online (www.htm). However. Z10 adopts from and is in harmony One must understand these definitions to suc. as would be the case in a spec. ments for occupational health and d) All training activities conducted as a part of this provision shall be docu. training or other methods that employ- rent best practices and since ISO will ees and contractors are aware of applicable OHSMS requirements and are competent likely again consider the development to carry out their responsibilities as defined in the OHSMS (AIHA).org . a) A minimum of 12 hours of training shall be given initially to engineers and safety practitioners in safety through design. The drafters set out to ensure that it ble to organizations of all sizes and types” (AIHA). Management System Standards which is the approval body for Z10. cessfully apply the standard. Continue the speculation. and it may very well be considered as dard and be familiar with its provisions. the provisions of ANSI/AIHA Z10. Even though the standard sets forth minimum requirements. According Of particular note is the recognition given in the to the standard: Z10 introduction to the International Labor Organi- zation’s (ILO) Guidelines on Occupational Health A hazard is defined as a condition. (AIHA). ILO is an inter- severity of injury or illness that may be national organization of considerable influence. Compatibility. one can speculate the “should” column—the advisory column—on certain subjects such as training that Z10 will become the model for that for safety design. in the latter case. With its a model by the International Organization for annexes. Long-Term Influence: b) All employees shall be given a minimum of three hours training annually in Societal Implications hazard identification. illustrate the difference.ilo. is that hazards are to be identified and evaluated. requirements comparable to the ments for accredited safety and health following might be extensions of 5.some respects.asse. taken to achieve an acceptable risk level. hazard identification. for a safety and health management system. reduction or control measures are to be standards (ISO 9000 and ISO 14000 series). dard for an occupational safety and general process and system guidelines are given for a provision without specifying health management system. Harmonization tinuous improvement in their occupational health & Possible International Implications and safety management systems and to reduce the Z10 is a management system standard—a per- risk of occupational injuries.with ILO-OSH 2001. illnesses and fatalities. sidebar below). The organization shall emerged among its membership. the ification standard. Z10 goes beyond the guideline in safety and health should have a copy of this stan. illness or a hazardous event or exposure(s) and the english/support/publ/xtextoh. On two occasions—in 1996 and vs. and risk quality and environmental management system elimination. This is the standard’s scope: “This c) All employees shall be given a minimum of four hours training annually in standard defines the minimum require- the use of PPE.2: Education.2-B. Section 5. Neither pro- the details on how the provision is to be carried out. only a small segment of employment locations 26 PROFESSIONAL SAFETY FEBRUARY 2006 www. of an international safety and health That is the extent of the requirements for Section 5.

and the Audit provision in The annexes contain explanatory comments.1 OHSMS Operation F Objectives/Implementation will become the benchmark against which the ade- Elements Plans (Sections 4.1.2) FEBRUARY 2006 PROFESSIONAL SAFETY 27 . Since one measure of a technical degree www.3 Audits Technologists. it 5.2) As awareness of the standard’s provisions 5.2 Education. Implementation and Operations (5.4 Corrective and Preventive a “bible” which provides guidance for the dis.1 Management Review Only in the [U.asse. As Barnett 4. for which knowledge of risk assessment methods Furthermore.2 Ongoing Review B Roles and Responsibilities Consultants who give counsel on safety manage- 4. provisions. 3.1 Hierarchy of Controls G Hierarchy of Control (Section be measured.1.2 Policy 7. that a management of change system be put in place •avoid bringing hazards into the workplace by through which hazards and risks are identified and incorporating design and material specifications evaluated in the change process. into procurement contracts for facilities. Over time. Training and (Sections 7.5 Feedback to the Planning the world.3 Application 6.1 Occupational Health Actions charge of their professional duties.0 Management Review ing whether or not safety has been achieved. treat a standard as 3. equipment •assess the level of risk for identified hazards— and materials. degree programs will be affected as employers will •use a prescribed hierarchy of controls in dealing seek candidates who understand the standard’s with hazards to achieve acceptable risk levels—for requirements. examples of forms Checking and Corrective Action (6. treat a standard Allocation of Resources (Section 4. 3. While information in the annexes is not part of the they state that employers “shall” establish and standard. those provisions are in Planning (4.S. and otherwise eliminate the hazard.S.4 Contractors I Audit (Section 6.2) ANSI standards acquire a quasi-official status. following management systems that are compatible with those is the table of contents from Z10.0 Scope. Reproduced with permission.1.3 and 4.1 Scope 6. 3.3 Objectives (Section 3. In that respect.1.1.3) ment systems to employers other than their own Prioritization C Employee Participation should recognize the status that ANSI standards 4. as this standard attains that stature. its impact on what employers and socie- ty believe to be an effective safety management sys. the term] minimum standard is an oxy. In summary.1 and 7.qxd 1/13/2006 3:10 PM Page 27 have safety management systems in place that include all of its elements.2 Design Review and 5. Societal expectations of employers 5.0 Evaluation and Corrective may not be enough.2 Assessment and (Section 3. while complying with a standard is nec.1 Monitoring and and aerospace engineering at Illinois Institute of 2.2 Management Review sufficient condition for precluding liability.1. by and large.4 Implementation Plans and D Initial/Ongoing Review says. 1.3 Procurement Guidelines (Section 6.1 Initial and Ongoing Annexes moron (Barnett).1.] is compliance with an appro. According to Ralph L. 4. and references.3) spreads.4) quacy of safety and health management systems will 5. “Technologists. Purpose and 5. 4. which in the U. Authority Process priate standard treated as a necessary but not 3.” Operation (Section 4.0). Barnett.2 Incident Investigation essary.2) acquire from a legal liability viewpoint. and Employee Participation 6. Throughout and Safety Manage. implement processes to: •identify and control hazards in the design Source: ANSI/AIHA Z10-2005.1) with respect to their safety and health management Management of Change H Incident Investigation systems will be defined by the standard’s provisions.1.0 Planning Outcomes and Follow-Up [Thus.3 Communication tem will be extensive.2 Employee Participation 7.1 Management Leadership 6.0 Implementation and E Assessment and Prioritization charge of their professional duties. and professor of mechanical 1.1.1. 3. Review A Policy Statements (Section 4.2) Over time. as the provi- sions of this ANSI standard are brought to the atten- Z10 Table of Contents To provide a base for review and comparison with safety manage- tion of employers and they strive to have safety ment systems with which SH&E practitioners are familiar. by and large. 1. certain provisions are of Awareness K Bibliography and References particular importance to safety practitioners.1) as a ‘bible’ which provides guidance for the dis- 5.1 Initial Review 3. employers will likely seek SH&E practi- 5.1.4 Documentation and The reader should understand that the standard Application Record Control Process sets forth minimum requirements. doing so may not be sufficient.3 Responsibility and 7. 5.0 Definitions Measurement Technology.5 Emergency Preparedness J Management Review Process tioners able to give counsel on meeting its require- Purpose Action chair of Triodyne Inc. Foreword 5. the content of college-level safety will be necessary. 4. 6. it will be helpful to those charged with its implementation.Manuele Feature Feb 2006. 1.0). process and when changes are made in operations— which requires that safety design reviews be made which the first step is to attempt to design out or for new and altered facilities and equipment. compliance or noncompliance with ment System Process a safety standard is the criterion for determin.0 Management Leadership 6.

Risks.0: Management Leadership and Employee This section sets forth the planning process to Participation. This is usually subjective. leadership ciencies and opportunities for system improvement make up the and employee participation is OHSMS issues for a particular organization. Comments in the right. yearly. 7) Define the level of risk using a risk assessment matrix. ops documented objectives and implementation plans. common in ANSI standards. compliance with standards and regulations.0: Management Review. professors responsible for those programs of an occupational health and safety management will likely ensure that core courses properly equip system (OHSMS)” (AIHA). Ask. more extensive re- marks are made on select sec- tions in 4. “The planning process goal is to iden- •5. opportunities for improvement)” (AIHA). The standard says: students to meet employer needs. and business consequences.Manuele Feature Feb 2006. “What characteristics requirements in the left column of things or actions [or inactions] of people present a potential are identified by the word for harm?” “shall. should an incident occur. ments and are prefaced with an The likelihood of occurrence is normally related to an interval of time “E. Based on experience and word “should” to describe rec. assume overall responsibility. agement leadership and effec- 28 PROFESSIONAL SAFETY FEBRUARY 2006 www. potential for system the standard is dealt with improvements. Reproduced with permission.0: Evaluation and Corrective Action. implement and maintain an OHSMS. make an estimate of the worst credible injury or illness ommended practices or to ex.0. consequence(s). right-hand column uses the 5) Assess the severity of injury/illness. weekly.” An organization that 3) Define possible failure modes that result in exposure to hazards chooses to conform to the stan. As the substance of Top management shall provide leadership and SH&E practice changes in light of the impact of Z10.0: Implementation and Operation. B and C provide supporting data on The Continuous Improvement Process these areas. implement the standard and to establish plans for •4. “How could an unde- dard is expected to fulfill these sirable event happen for a task and each associated hazard?” requirements. system or process to be analyzed. Ask the question. Brief comments on 3. OHSMS by its employees at all levels (AIHA). etc.0 follow. this section of then prioritized by considering the level of risk. er should understand that this 9) The organization selects prioritized OHSMS issues and devel- is the standard’s most impor. In accord with the Plan-Do-Check-Act concept. improvement. professionals actually perform.0. event.qxd 1/13/2006 3:10 PM Page 28 program’s success is employment possibilities for its tive employee participation are crucial for the success graduates. risks. All OHSMS issues are abundant. tify and prioritize OHSMS issues (defined as haz- •6.” As is 1) Select a manageable task. system defi- safety management.). 5. 2) Identify the hazards.asse.0 and 7. In many cases. plain the requirements on the 6) Determine the likelihood of the occurrence of a hazardous left. Source: ANSI/AIHA Z10-2005.0: Planning. For complex hazard exposure sce- hand column are not require. feasibility briefly here. narios. monthly. Literature commenting on 8) Hazard risks can then be listed and ranked. When Hazard Analysis & reviewing these excerpts.0 and 6. brainstorming with knowledgeable people is advantageous. Thus. Content of the examinations for the CSP designa- tion is reviewed about every five years to ensure that The organization’s top management shall establish the exams are current with respect to the work SH&E a documented occupational health and safety policy.] The level of risk is determined by plotting the likelihood of an occurrence or exposure and the potential . The organization must then determine & Employee Participation if the level of risk is acceptable or unacceptable. establish. that the material printed in ital.” The reader should note (several times a day. The text in the 4) Estimate the frequency and duration of exposure to the hazard. SH&E practitioners will surely agree that “top man. tant section. [An example of a risk assessment matrix can be standard. However. the major sections of the standard are: 4. what those professionals who participate in the examination review process say about the content of The organization shall establish and implement their work at that time will influence the content of processes to ensure effective participation in the the CSP examinations. that Top management shall direct the organization to will require substantive curricula modifications. risk rank- ics is taken verbatim from the ing or scoring system. ards. found in Figure 1 of this article. the read.0: Planning •3. keep in mind the intent of the terms Risk Assessment Guide “shall” and “should. management system deficiencies and •7. knowledge. and the realization of the potential harm. Annexes A.0: Management Leadership severity of the injury or illness.

risk assessment methods.2 sets forth the requirements for assessment and prioritization. For example. failure modes and effects analysis. An ongoing review process (4. and potential business conse. feasibility. a list of publications that describe the many possible mathematical calculations will be limited. regula. employers are to have processes in place to niques and how they are applied will satisfy the identify and analyze hazards. and and easily applied risk assessment methods will be C) Identify underlying causes and other con. risks and management systems deficiencies. will achieve niques. ment: Addressing Career Knowledge Needs includes the These are the explanatory notes for 4. sales or profit analysis. standards. when acted on.Manuele Feature Feb 2006. and (AIHA). identified hazards. Assessment. There are many The chapter provides brief descriptions of eight methods of risk assessment. assessment and prioritization requirements. fault tree analysis.1. assessment can be daunting but it need not be. qualitative rather than quantitative judg- acceptable risk levels. potential The breadth of the field of knowledge in risk for system improvement.1) is to be main- tained for the same FEBRUARY 2006 PROFESSIONAL SAFETY 29 . practitioners who become familiar with several basic quences.needs and requirements of Z10. E4. measurement data. able to give counsel on and apply the standard’s risk tributing factors related to system deficiencies assessment provisions.” It is designed to counter the dread that tors such as identification of potential hazards. checklist analysis. used risk assessment techniques. qualitative (descriptive) methods. Reproduced with permission. in addition. Few current safety management systems contain similar provisions. Innovations in Safety Manage- that lead to hazards and risks (AIHA). “A Primer on Hazard Analysis and Risk E4.2A and 4.2 Assessment & Prioritization Subsection 4. (Note the emphasis on haz- ards. and establish priorities for noted that in the application of these eight tech- improvement that. and to give assur- ards and potential severity of hazards. chapter. The organization shall estab- lish and implement a process to assess and prioritize OHSMS issues identified in 4.2B.2A: The assessment of risks should include fac. what-if analysis. Assessing ance that acquiring such understanding will not be risks can be done using quantitative (numeric) or overly difficult [Manuele(a)].asse. It should also be ing from those hazards. sources and frequency about achieving an understanding of commonly of exposure. and documented risk reduction objectives are to be established for the issues selected. safety reviews/opera- tions analyses. SH&E practitioners may experience in thinking exposure. The process shall: A) Assess the impact on health and safety of OHSMS issues and assess the level of risk for Source: ANSI/AIHA Z10-2005.2B: Business consequences may include either what-if/checklist analysis.1). It also www. the System Annex E provides information on the standard’s Safety Analysis Handbook describes 101 such methods. ments will prevail since for all but the complex risks Annex K (Bibliography and References) provides qualitative judgments will be sufficient. assess the risks deriv. hazard and operability increased or decreased productivity. SH&E tions. Having knowledge of those tech- Thus. types of measures used to control haz.) 4. preliminary hazard analysis. Issues identified during the review are to be Example of a Risk Assessment Matrix assessed and priorities deter- mined.qxd 1/13/2006 3:10 PM Page 29 An initial review of the OHSMS is to be made for that Figure Figure 1 1 purpose (4. Examples are included hazard analysis and risk assessment techniques— in the Annexes and References. B) Establish priorities based on factors such as the level of risk.

products. Again.published hierarchies of control are not quite as agement systems have comparable provisions. given in its right-hand column.Manuele Feature Feb 2006. If the hazard is eliminated. and take appropriate steps to prevent or otherwise control hazards and reduce E5. tute a less hazardous method or process. the first of which. and controlling a hazard. system is at a practical minimum. is to design out or otherwise eliminate According to the standard. In cases where the higher order controls this outline. and The organization shall establish and implement g) internal organization standards. if an equipment modification or ment action levels within the matrix. the hierarchy of controls set 5. management stitution from elimination are important. Also note that the substitution element is implementation of an effective OHSMS” (AIHA). Other practitioners. and replicate the explanatory information and state statutes. the risk is needs of the operational elements that are required for eliminated. standards and regulations.provides a pictorial and verbal display of the hierar- ly defined hierarchy of controls. probability of a) errors by supervisors and workers B) Substitution of less hazardous materials. then limiting exposure decision makers to set risk levels and prioritize cor. This process continues down the hierarchy a significant easily understood and applied thought-and-action until the highest level feasible control is found. If this is The process for design reviews and management of not feasible. because of design inadequacy is at a practical mini- processes. federal of change. e) available technology.asse. Some have as few as three elements. and applying the hierarchy of controls to other hazards F) Personal protective equipment. The standard and the explanatory In an occupational setting. engineering controls) do not reduce risk to an ment matrix for illustrative purposes (Figure 1). mum. D) Warnings. Published risk assessment matrixes would be an acceptable supplemental means of vary widely. [See also Manuele(a) and (c).1.1. personal protective equipment). separate from the elimination element. SH&E The comments here focus on only four provisions— The number of elements and the separation of sub- hierarchy of controls. and risks. 28 presents tive. upon the following preferred order of controls: 2) work methods and processes in which the A) Elimination. lower order controls may be nec- content of the This matrix gives incident probability categories. (elimination. For example. the organization should first B) Changes to its existing operations.g. practice of but it also incorporates recommended manage. administrative controls or severity categories and risk levels.1. engineering controls such as machine change shall include: 30 PROFESSIONAL SAFETY FEBRUARY 2006 www. warnings. in and skill 5. and environmental man- Feasible application of this hierarchy of controls agement systems. Similar outcomes should be expected when E) Administrative control. consider methods to eliminate the hazard or substi.1. f) .] which contains six elements. services or suppliers. design review.1: Hierarchy of Controls forth in Z10 will become the accepted norm. of change and procurement. process on how to conduct a hazard analysis and a Often a combination of controls is most effec- and favorable risk assessment. The following excerpts indicate what the stan- b) the degree of risk reduction desired.2: Design Review & Management of Change controlled. [See also Manuele(c).1: The hierarchy provides a systematic way to potential risks associated with: determine the most effective feasible method to A) New processes or operations at the design reduce the risk associated with a hazard. which is typical. order prescribed. acceptable level. so SH&E practitioners should develop control (AIHA).] shall take into account: a) the nature and extent of the risks being 5.0: Implementation & Operation priority order. The organization chy of controls listed in 5. these outcomes are to comments state: be achieved through the application of the hierarchy The organization shall implement and maintain a of controls: process for achieving feasible risk reduction based 1) an acceptable risk level. these are d) recognized best practices in industry. such as for the design and use of industri- al and consumer products. Such a matrix noise enclosure (engineering control) is insuffi- safety— can serve as a valuable instrument in working with cient to reduce noise levels. Only a few safety man. and b) supervisors and workers defeating the C) Engineering controls. Annex G Z10 outlines provisions for the use of a specifical. Over time. operations or equipment. descriptive and complete. dard requires for design reviews and management c) the requirements of applicable local. through job rotation and using hearing protection and on the rective actions.. When stage. processes to identify. knowledge models that are suitable to the organizations they Note that Z10 prescribes a hierarchy of controls serve. essary (e. “shall” provisions. The sidebar on pg.qxd 1/13/2006 3:10 PM Page 30 Z10 will have contains a brief outline titled “Hazard Analysis guards and ventilation systems should be consid- and Risk Assessment Guide” which presents an ered. “This section defines the hazard.1 with application exam- “shall” apply the methods of risk reduction in the ples for each element. substitution and implementation of impact on the Annex E also gives an example of a risk assess.

generalists can design specifications or standards. maintenance Employers are to have processes in place to on how and decommissioning. and a section on design safety reviews.119. after 1910. it Adams discusses challenges to process implementa. there was widespread support Introducing Safety Through Design. Management of Change ing design.119 have (AIHA).1. process.Manuele Feature Feb 2006. The latter section As noted. management of change requirements of OSHA’s •significant changes to the site’s organizational Process Safety Management of Highly Hazardous structure and staffing. aircraft manufacturing. agency received some excellent suggestions Another key reference in this area is Safety Through concerning minor changes to improve this pro- Design. This is because many of the incidents cludes a general industry guide to safe design and that the agency has reviewed resulted from operational requirements. Therefore. Simon. SH&E practitioners should anticipate d) review of applicable regulations. operation.1. That is what this standard tine work is being performed and when sources of requires—and it is an extremely important element high energy are present. ware). quality of change. who have human factors. support for the management of change contains six chapters pertaining to application of provisions was strong.asse. equipment or facilities. suppliers. codes and a long-term effort to achieve the culture change interest in standards. including use of con. about two years safety through design concepts in general industry. However. Chemicals standard (1910. general design safety some type of change to the process. It in. Safety Through Design and managing changes is designed to prevent includes a chapter titled “Achieving the Necessary welcome injuries and illnesses before new hazards and risks Culture Change” by Steven I. Requirements of Z10 and 1910. a the automotive industry. construction. however. aspects of a process safety management pro- ment titled “How to Avoid Bringing Hazards into the gram is appropriately managing changes to the Workplace” covers this topic [Manuele(a)]. consider these excerpts from historical and explana- To become qualified to give counsel on establish. ing a management system to apply the design review requirements of this standard. While the checklist.119). management of change procedures. particularly when unusual and nonrou- the design process. For all occupations. A chapter in Innovations in Safety Manage. identify and take the appropriate steps to prevent The following are examples of conditions that or otherwise control hazards and reduce the poten- their safety should trigger a design review or management of tial risks associated with them when changes are change process: made to existing operations. is not surprising that courses have been developed to www. •different types and grades of raw materials. Its impact can be immense. effective safety through design process often b) consideration of hazards associated with requires challenging the culture within an engi. Safety Through Design in Industry. in this standard. Integrating for including a provision concerning the man- [Safety Through Design] into Business FEBRUARY 2006 PROFESSIONAL SAFETY 31 . This e) a determination of the appropriate scope and often means establishing a management system employee degree of the design review and management that mobilizes engineering. said that chemical plant operators had reported industry (Christensen and Manuele). 1910. construction and in the electronics oped. that the management of change requirement in the In the chapter on application in general industry. products. issued in 1992.qxd 1/13/2006 3:10 PM Page 31 a) identification of tasks and related health and tion and maintenance.119 became effective. similar purposes. He notes: “Implementing an Employers safety hazards. In support of that premise. Thomas Seymour.1). which contains these three major sections: posed provision. Briefly. The author has long professed that the most effec. learn from those in organizations that have met the be improved. tory data published with respect to 1910.119 requires that employers establish •modification of health and safety devices. many SH&E Management of Change: OSHA believes that practitioners will have to acquire new knowledge one of the most important and necessary and skill. and necessary to meet the requirements of Z10. and agement of change in the final rule (OSHA). services or management •new or modified technology (including soft. (To assist E5. With respect to drafting and implementing systems can •new or revised procedures. organization.2: The process for conducting design reviews in that accomplishment. and and implement written procedures to manage •new health and safety standards or regulations changes. the director at OSHA as the standard was being devel- chemical industry. tractors. many incidents that result in tive and economical way to minimize risks is to severe injury occur when out-of-the-ordinary situa- address the hazards from which they derive during tions arise. The discussions design review should consider all aspects includ. standard was the most difficult to apply. neering organization” (Adams) If a design safety c) consideration of control measures (hierarchy of review management system is not in place in an a sincere controls—5. purchasing. control and other departments which may not be safety will accustomed to working collaboratively. Getting effective management of change procedures in place and maintained is not Design Review easily done. work practices.) are introduced into the work environment.

1. ASSE’s annual Professional Develop. measurement and assess- ment. The 13-page ry data state.Manuele Feature Feb 2006. incident investigation and audits.asse.extra.asse. provide an overview of the standard. equip.3A: For example. Thus. raw materials. visit the requirements will not be Although the require. the benefits of its implementation. not specification audits.system. they are brief in relation to the enormi. mer Service Dept. This is what the standard and the explanato.0 Evaluation & Corrective Action als. address only one provision in 6.3: The procurement process should be organization’s purchasing sys- implementation. raw systems audits. To cepts are to be applied in an change necessary for their learn more. tion provisions instituted by DaimlerChrysler ucts. SH&E practi. For. of hazardous incidents and ment of Change Systems. cal hazards and work methods. visit www.daimlerchrysler. or examine the design review of the requirements of this section. this one? Because audits “shall” be made. The audits cluded specifications in their purchasing agreements are to measure the organization’s effectiveness in and contracts that require suppliers to identify the implementing the OHSMS elements. it can be very expensive to buy https://gsp. To review the general acquisi- safety risks associated with purchased prod. and other goods and related services con. ment requirements. and C) Ensure that purchased products.” B) Establish requirements for supplies. et al’s A #657. This section of the standard outlines the require- form to the organization’s health and safety ments for processes to evaluate the performance of requirements.1. the ergonomic design criteria ty of what will be required to implement them. From a tion of a new chemical. and other goods and pertaining to “Tool and Equipment Follow-up. (AIHA). tive action when shortcomings are found. document covers ergonomics criteria only. help to avoid bringing hazards sive. 6. but the related services purchased by the organization benefits can be immense.4. to control potential health and safety risks. Provisions mented. Getting these procurement provisions in place ment.amedd/tooldesign/textsection15. An established by DaimlerChrysler for equipment sup- interpretation of the requirements could be: SH&E pliers and vendors and company engineers.qxd 1/13/2006 3:10 PM Page 32 help those responsible for director in a major company meeting the management of said recently. at (847) 699-2929. are to determine whether the management systems ment and materials being purchased. raw materi. Be of Benefit to You? The session will in the frequency and severity ting and Improving Manage. These criteria can be found at in the long term. is that OSHA standards and tioners should thoroughly from ASSE other legislative requirements study the management of be met. but recog- ments for procurement are nition slowly arises that they plainly stated and easily should be an integral part of a safety management understood.htm. related services before introduction into the Certification and Buy-Off Procedures. One example. As a safety in place do/do not effectively identify hazards and 32 PROFESSIONAL SAFETY FEBRUARY 2006 www.3: Procurement learn more about this session. change requirements of Z10 The Standard The Z10 standard implies to determine how they might ASSE is offering ANSI/AIHA Z10 to that safety through design con- help to achieve the culture its members for $58. One good reference on ment Conference will include Session into the workplace could pro- the process is Casada. you are assigned the responsibility to here to indicate how broad and complex procure- convince managements and purchasing agents that. www. discuss its key elements and review exposures. Z10 Resources specification in their contracts Given this. It sets The organization shall establish and implement forth specifications for suppliers and vendors to processes to: meet so as to avoid bringing ergonomics hazards A) Identify and evaluate the potential health and into the workplace. list price is $65.htm or contact ASSE’s Custo. Audit requirements are for safety management Only a small percentage of employers have in.0 (audits).com/mfg/ cheap.safety2006.” change the work environment. Adding an element to safety tunately. ANSI Z10: What Is It and Can It duce startling good reductions Manager’s Guide to Implemen. the literature on Safety 2006 Session management systems that will change management is exten. audits hazards and assess the potential risks in the equip. See section E5. is cited practitioners. the safety management system and to take correc- E5. “15” in the website address to “14. it seems specifications and operations manual for a new that many organizations may be making substantive piece of equipment being considered for purchase revisions in their audit systems. and other goods and will be a challenge for SH&E practitioners. ods will be necessary. organizations should evalu. To Procedures encompassing 5. Comments E5. pertain to monitoring. easy to implement. tem with respect to both physi- change management meth. Why only ate MSDS and other health and safety informa. Applying . the only safety change requirements.1.

procurement and audits. New Mex- Realistically. IL: National Safety Council. It is an important part of the DaimlerChrysler. Audits should be controls. A) Conduct periodic audits to determine whether SH&E practitioners must not ignore the long- the organization has appropriately applied and range impact Z10 will have on societal expectations effectively implemented the OHSMS ele.iso. oping seminars to instruct SH&E practitioners about E6. 7.A. serious injury.A. F.119.daimlerchrysler. least annually: progress in risk reduction. Vol. Itasca. 䡲 ities being concerning the quality of safety management sys- ments.0: Management Review DaimlerChrysler. “Minimum Safety Standard: An Oxymoron. F. W.C. 1992. Washington. Albuquerque. Occupational with safety audit processes.” Conclusion Chapter 4.(b).S. Itasca. R. On the Practice of Safety. effectiveness Manuele. Although many SH&E practitioners are familiar American Industrial Hygiene Assn. Manuele.htm>. what the standard requires and determine whether Fairfax. Ergonomic Design Criteria. Safety Through Design.I. 3rd ed. Auburn 7. F. mfg/amedd/tooldesign/textsection14. it can be expected that over time it will ico Chapter. of Labor. Itasca. eds.A. IL: National Safety Council. ments of the standard to determine whether they b) Area supervision. assess and prioritize risk and Control. and effectiveness.(c). Christensen. System Safety Analysis Hand- step in the evolution of the practice of safety. they employees and employee representatives. Geneva. IL: Triodyne Inc.3 Audits required by this section are “system” the content and application of ANSI/AIHA Z10- oriented rather than “compliance” oriented. VA: AIHA. Process Safety Management of Highly Hazardous Chemicals. E. <http://www. 2nd ed. 37-48. management of change. < improvements to ensure its continued suitability. Manuele.extra. conducted by individuals independent of the activ. New York: John Wiley & Sons. 1999. a) Those responsible for corrective and pre. P. 2001.” Professional Safety.W. Christensen and F. and need additional skills and capabilities.ilo. it contains an Casada. health management systems will be measured.C. it is logical to expect that the fre- The organization shall establish and implement quency and severity of occupational injuries and processes to: illnesses will be reduced. “Achieving the Necessary Culture Change. “Risk Assessment and Hierarchies of of processes to identify. they should review Health and Safety Management Systems. S. Career Knowledge Needs. A Manager’s Guide to Implementing and example of an audit outline that matches the Plan. Barnett. International Organization for Standardization (ISO). and on the expec- controlling risks. to the organization (AIHA). Geneva. including action to acquire those skills. www.extra. so that prompt corrective fessional organizations such as ASSE consider devel- action under 6. book. (AIHA).C.A. New York: These are a few of the subjects to be reviewed at John Wiley & Sons. and to recommend 2001. et al. DaimlerChrysler Corp. safety management system elements that may not fied in audits that could be expected to cause currently exist. tations employers will have concerning the B) Document and communicate audit results to: knowledge and capabilities of SH&E personnel.A. ANSI/AIHA Z10-2005. ILO-OSH OHSMS at least annually. Guidelines on Occupational Health and Safety Management Systems. Prudent SH&E practitioners will study the require- ventive action. OSHA. Innovations in Safety Management: Addressing continual improvement of the OHSMS (AIHA).org FEBRUARY 2006 PROFESSIONAL SAFETY 33 . M. a fatality. ANSI/AIHA Z10-2005 represents an important Stephans. 5. Certification and Buy-Off Procedures. system deficiencies. 2003. eds. Talso.7.A. Switzerland: ISO. Chemical Manufacturers Assn. <http://www. lic/english/support/publ/xtextoh. NM: System Safety Society. Niles. Auburn Hills. including identifying hazards and tems that employers have in place.asse. 2001. 29 CFR 1910. Safety Through Design. actions in response. Christensen and F. <https://gsp. IL: National Safety Council. design reviews. and W. W.” Chapter 13. As 6. underlying causes of risks and system deficiencies.1 The organization shall establish and imple. ment a process for top management to review the International Labor Organization (ILO). No.qxd 1/13/2006 3:10 PM Page 33 control risks. Manuele. Manuele.L. and effectiveness in addressing OSHA. or illness in the The author also suggests that the leaders at pro- immediate future.. the application of a hierarchy of requirements of this standard. This does not mean that References audits must be conducted by individuals external Adams. Safety Through Design.4 is taken. will be equipped to help managements put in place C) Immediately communicate situations identi. DC: Do-Check-Act sections of Z10.A. W. 1997. Dept. May 2005: 33-39. 1999. and F. 1993. 1999. then will take c) Other affected individuals.>. Switzerland: ILO. adequacy. DC: U.Manuele Feature Feb 2006.. This section requires that OHSMS performance MI: DaimlerChrysler Corp. “Application in General Industry.S. Simon.1: Management reviews are a critical part of the Manuele. This is what the standard and the become the benchmark against which safety and explanatory data state.daimlerchrysler be reviewed and that management take appropriate . 3. it will be to their benefit to revise their audit systems. R.(a).htm>. Having done so.” Safety Bulletin. Annex I is helpful in this respect.L. Improving Management of Change Systems. The 2005.htm>. particularly with respect to the requirements audit should determine if the OHSMS meets the for risk assessments.3 Audits the quality of safety and health management sys- tems improves. eds. Tool and Equipment Follow-Up. Washington. MI: Plan-Do-Check-Act process. 155-169.