The number of companies and consultants using generic auditing systems and software could face some challenges in the next 12 to 18 months as OHS practice will be forced to implement a risk-based approach to OHS management.
The current “system required” compliance measurement will no longer be relevant as the practice will move away from a pure “system” and embark on a risk based approach to OHS management.
Risk-based compliance measurement is not a fit-all-sizes auditing approach and one cannot you a standard auditing program or template if an objective audit result is important.
What are the key components of a risk-based auditing program?
In short, every element of the OHS management system must be risk driven. This starts with the statutory obligations of the company. Legal requirements imposed by the multitude of OHS related laws must be addressed on the legal risks each requirement poses. For instance, the risk for a strict liability is much higher than a vicarious liability or even a consequential liability.
The entire OHS inspection program must be risk-driven. This requires more than just an understanding of the OHS laws and the elements of management systems like ISO 45001. It also requires a technical understanding of machinery and machine systems. In particular, risk based inspections on driven and electrical machinery would require the involvement of plant and maintenance engineers.
Likewise, the hierarchy of controls would shift its focus from administrative controls like SOP’s, SWP’s and Training, to the more effective Engineering controls, like machine design, material design and selection and reliability centered safety management.
Another aspect of a risk-based approach to OHS management is the involvement of management in the actual “management” of the employer’s compliance program. Generic assignments of duties are inadequate to address this properly. Appointment of role players will have to be risk specific. A typical example is the appointment of employees vs a service provider to check items like fire extinguishers. Generic systems dictates monthly inspections, for no valid reason other than the inherited practice from pre-OHS act auditing systems like NOSA’s MBO system from back in the 1950’s. The only reason why inspections are done monthly today, is because it has always been done like that. A one size fits all.
But an office environment has less risk of fire related incidents than a factory working with flammable, high density chemicals in Class 1 explosive atmospheres. It is thus not necessary to send each and every employee on a Fire Fighting course. For the latter however, it would be viable to do so.
In the end, an RBB OHS management system will not only be effective, but also “cost effective” as resources will not be wasted on “system” requirements but on risk-driven requirements.
The Risk Assessment Guessing Game
Unlike generic risk assessments, where a number of people sits in a room, and guess high, medium or low and finally the dominant or most senior person vetos the vote, a Risk-based Hazard Identification is a complete flip-over of the HIRA.
The baseline risk is calculated from known information of a particular hazard instead of calculating the risk value after the hazard is identified as one. Common HIRA practice is designed to analise obvious hazards without looking at primary and secondary hazards. One typical example is the use of harnesses on scaffolds. The obvious hazard is fall from heights. But the primary hazard is ignored. (The actual unsafe scaffold). Likewise, the secondary hazards are ignored as well, like suspension trauma and the availability of rescue teams and the response time of emergency services like an ambulance.
These are only a few examples to show the OSFA (One-size-fits-All) is ineffective and it will not last very much longer. Companies will have to take a different look at their strategies when it comes to OHS management. Change is coming…
The Dead Give-away
A company’s current approach to OSH management is illustrated very easily in its employment practices when sourcing a management team for the company, and the most obvious job role to look at, is the person in charge of the OHS function itself.
The OHS specialist vs the SHREQ
It is obvious that the job role of the OHS specialist (the real one) is focused on the management of an OHS program. And while the global belief that the H and S parts are married, many upholds a distinct differentiation between health as a medical discipline and safety as an engineering discipline.
The SHREQ on the other hand is a jack of all trades and a master of none. The company seeks a person to perform 5 seperate functions a single salary. This approach is then obviously spilled over to how SHREQ is managed. With a shoe-string budget!
The GMR 2 Competent Person
Safety Engineers are very seldom advertised, where plant engineers with a GCC are well advertised. This tells us that maintenance and supervision is crucial, while improvement, R&D and other safety related aspects are left to the plant engineer.
The good news is that SHREQ is dead. Or will be soon, we hope. The bad news is that this should have happened 20 years ago.
As to why we believe that change is coming, we will discuss a bit later in the year.