The 4 “Danger Zones” of OSHA’s Revised Guidelines for Safety Programs

Thirty years ago, the Occupational Safety & Health Administration was leading industry and construction with the initial release of the Guidelines for Safety & Health Programs.  For most organizations, this was the initial step to implementing a proactive approach to health and safety in the workplace.

Thirty years ago.  A lot has changed in 30 years.

Fast forwarding to 2016, occupational health and safety management system standards have been common for almost two decades in forward-looking industry-leading firms and organizations.  These management systems standards use time-tested concepts and ideas that have been assembled from a consensus of senior industry professionals around the globe.  And some of these elements are very good.

So it should come as no surprise that the new guidelines have borrowed some of these concepts from ANSI/AIHA Z10, OHSAS 18001, VPP, and SHARP.  Worker Participation (employee engagement) and Communication for Coordination for Host Employers, Contractors, and Staffing Agencies (subcontractor management) are two great examples of elements that are included across the spectrum of occupational health and safety management system standards. 

All of this sounds like a good thing, right? 

It isn’t.

Why?  I’m glad you asked:

It omits important part(s) of the occupational health and safety management system standards.  For effective and proactive occupational health and safety management, the following elements should be in place in the health and safety program.

• Legal requirements and other requirements – an organization cannot claim safety & health compliance, unless they know and can prove which legal requirements (OSHA laws) and other requirements (customer health & safety standards) apply to them. Too many organizations are dependent on their clients to communicate these requirements to them.

• Control of Documented Information – lack of appropriate control over safety-related information and documentation introduces failure opportunities into the health and safety program. If a procedure isn’t current, the risk of failure increases, especially with changes and time.

• Management Review – the section on Program Evaluation and Improvement helps provide some inputs into a review process, but lacks a evaluative framework about how to approach and structure reviews, and how to feed back outputs from the review into the program for improvement.

• Management of Change – in order to have a proactive, forward-looking safety program or management system, it must be adaptable. Nothing in this world exists in a vacuum.  Change is constant.  If there’s no provision for the system to handle change, adaptations are ad hoc, potentially ineffective, and another opportunity for the introduction of latent risks and errors.

So as we can see, the elements that have been added and/or improved in the new RP for Safety & Health Program document are parts of existing specifications, but when they exist in isolation, they can sometimes cause more problems than they fix.  A safety management system is by nature complex, not complicated.  The implications of trying to reduce a complex system into its parts and cherry-picking elements will not achieve the same success as a systems approach.  This is akin to treating the symptom, versus treating the cause.

All that being said, if your organization is just beginning to focus attention on safety and health in your workplace, the framework is adequate.  But, if you’re a seasoned safety professional looking to advance your organization’s safety program to the next step, there are better opportunities to improve your health and safety program.

If you’re interested in speaking with us about a practical, pragmatic approach to implementing an occupational safety and health management system, we’d love to hear from you.