WR: I agree, although these safety measures provide a much-needed emergency preparedness option in the event of incident, they are only ever as good as they are maintained and monitored. Too many times on assessment I have seen inadequately maintained and serviced equipment which either does not work, or rather has not been cleaned for such a long period that may present an issue on its own. Likewise, eyebaths and eyewash need to be maintained and replenished when expiry is near or has been used. ISO 45001 has clear requirements to ensure processes remain effective through testing and exercising of processes and taking appropriate action in the event that it is required in clause 8.2 Emergency Preparedness, and also in clause 9.1.1, as mentioned by Alberto, where the effectiveness of operational and other controls should be monitored and measured.
How should PPE factor into an organisation’s approach to managing dangerous substances?
WR: PPE sits at the bottom of the hierarchy of control, as found in both ISO 45001 (clause 8.1.2) and its predecessor OHSAS 18001 (clause 4.3.1), but it remains in many cases to be what is “reasonably practicable” for the protection of injury to workers.
It is vital that appropriate controls are put in place in relation to the selection and use of PPE. Often when visiting clients, I am told that I need safety shoes, eye protection and ear protection, but I’m rarely given a specification for the required PPE. This then tends to be further exacerbated by their lack of definition for their own processes. It takes the right standard to give the right level of protection. It is critical when thinking of implementing new control measures that a suitably sufficient risk assessment is conducted in relation to the changed controls before their introduction, in line with the requirements both in clauses 8.1.3, Management of Change, and 188.8.131.52, Assessment of OHS risks and other risks to the management system, and clause 10.2, Incident, non-conformity and corrective action, if the introduction of new control measures comes from a non-conformity.
“often when visiting clients, I am told that I need safety shoes, eye protection and ear protection, but I’m rarely given a specification for the required PPE”
What about human factors?
WR: The right human factors and behaviours are needed in the workplace to ensure that the appropriate actions are taken. During my delivery of lead auditor courses for both OHSAS 18001 and ISO 45001, I emphasise the importance of leadership demonstrating the appropriate behaviours by following the established safety processes such as the use of PPE.
One of my least favourite findings on an assessment relates to the lack of leading by example. While assessing a particularly hazardous working environment that required a comprehensive use of PPE despite fixed controls including steel toe capped boots, Kevlar arm sleeves, leather apron, Kevlar gloves, hard hat with integrated visor and a high level of ear protection, I observed two members of senior management use the workshop as a shortcut with none of the established PPE. What example does that set to the workforce?
People also need to feel confident that they can highlight to their colleagues the importance of the use of mandated PPE whatever their position in the organisational hierarchy. ISO 45001 places clear responsibility on top management to develop, lead and promote a culture in the organisation that supports the intended outcome of the management system in clause 5.1, but also then goes on to place an equal responsibility on workers to assume responsibility for those aspects of the OHS management system over which they control in clause 5.3. This matches the legal obligations found in the UK’s Health and Safety at Work Act 1974, but you would see similar levels of control in organisations worldwide.
On a positive note, I have seen many constructive interventions during my career, including where my own human factors have put me at risk. The inappropriate use of a mobile phone was pointed out to me by a security operative on a client’s site. No one is immune from those moments when we make poor choices. I commended the individual and passed on this very positive observation to the client, as for me this epitomises how we should all behave – watching each other’s backs!
You’ve mentioned the hierarchy of controls a couple of times, can you explain this for anyone not familiar with the concept?
PG: It all starts from how well we know the hazards and their impact. The risks associated with these hazards need to be thoroughly analysed and measured. Then controls need to be put in place to minimise the risks. The hierarchy of controls is a system to minimise or eliminate the hazard. For example, the most effective way is to eliminate the risk completely. If this is not possible, the organisation could substitute the substance to a less hazardous alternative or change the working environment. The next level of the hierarchy is to apply engineering controls, such as ventilation or isolating pipes and containers. Level four of the hierarchy is the use of administrative controls, including processes and procedures, safety checklists and permit systems. The fifth level is to use PPE as a last resort.
Controls four and five are always necessary to reduce risks. No matter how effective the other controls are, if the hazard still exists, a mechanical failure or a human error could lead to accidental hazards. As we mentioned earlier, this is where training, familiarisation with equipment and emergency preparedness drills are vital to ensure an effective emergency response and to minimise the consequences of any incident.
What examples of best practice have you seen during audits?
AM: Good planning and preparation is vital. Training helps everyone to know how to stay safe and what to do in the event of an incident. Scheduled maintenance and inspection, thorough housekeeping and cleaning procedures, and a well-practiced emergency plan are all best practices that seem obvious, but have a big impact.
SW: The best way to manage the risk is to look at why you need to use a dangerous substance. Can you eliminate its use by changing the way that a process is done? Is there a safer option that could be substituted into the process? Can you eliminate the interface between the workers and the substance to minimise exposure? This is what the organisations with good OHS practices routinely do.
WR: Definitely - the best practice I have seen is the elimination of chemicals through the re-engineering of processes, and clearly reflects the hierarchy of control that is evident in ISO 45001, as it was also in OHSAS 18001. However, in some cases the move towards the higher end of the hierarchy, using elimination or substitution is not always possible. I have seen innovative approaches to reduce the risk including sealed systems, but the best approach is always that of a proactive culture for health and safety – where each individual is clearly aware of the risks associated to the hazards they encounter, and follow safe practices without deviation, while watching their colleagues backs too.
What impact can a management system have on the OHS performance of an organisation?
SW: Having an OHS management system requires you to identify the risks associated with such substances and to put in place solutions to eliminate or reduce the risks. With ISO 45001 this means utilising the hierarchy of controls to look at ways to eliminate the use of the substance or substitute a safer alternative, before considering what else could be done to make workers safe.
PG: I cannot think of a better way to improve health and safety than by establishing an effective Management System that promotes H&S culture across the organisation, ensures that H&S hazards and risks are identified, and that measures and controls are implemented in a systematic way.
AM: Agreed! An OHS management system, based on ISO 45001, gives organisations a systematic approach to the management of hazardous substances from the identification of substances and related risks (clause 6.1.2), implementation of control measures (clause 8.1), and improvement (clause 10.1).
WR: Every client that I have ever worked with that has an occupational health and safety management system has told me how the plando- check-act approach has had nothing but a positive impact on their management of risk. This has been strengthened by the preventive approach found in ISO 45001 both from the context approach, and the proactive management of change. ISO 45001 (and OHSAS 18001) requires clients to understand the risks to the business and implement appropriate controls to manage the risk, while also continually improving the occupational health and safety performance. This can only help to support organisations to protect all the interested parties through having robust systems of internal control.