Over the years, many a debate has been started on the impact of the OHS Practitioner. But a critical analysis of the impact of OHS interventions should reveal the fact that OHS has had minimal impact on the level of safety or health in any given system.
The safety of a person, or the risk of ill-health are commonly affected by Hazards. These hazards are controlled in a systematic process ranging in efficacy from high to low. It is called the “hierarchy of hazard control”
In analysing the elements within this process one would be able to assign the functionaries required to perform the various tasks to achieve the given objective. It is also understandable that the more effective a control element is, the less likely it is to be practicable. Regardless of the “reasonable practicability” of each component of the process, it requires a specific skill set to perform.
Eliminating a given hazard is obviously the best method. Preventing pedestrians being hit by cars can be eliminated by building a pedestrian bridge. If this component cannot be executed, we move down the list to the next best option.
Elimination means “not doing a particular action at all.” A simple example is replacing light fittings using scaffolding. In stead, we can eliminate the hazard by creating a system that lowers the light fittings to ground level, thus not requiring workers to work at height. This requires a fair amount of engineering design skills. And while the ”personal fall risk” is eliminated, a new hazard may be introduced, such as “falling objects”.
Substitution, the second most effective hazard control, involves replacing something that produces a hazard (similar to elimination) with something that does not produce a hazard—for example, replacing lead-based paint with titanium white. To be an effective control, the new product must not produce another hazard. Because airborne dust can be hazardous, if a product can be purchased with a larger particle size, the smaller product may effectively be substituted with the larger product.
In the above components, the focus is on the root source of the hazard itself, be it a moving part or object or materials used in a manufacturing process.
Both would however require a certain amount of research and development skills to find an alternative.
At best, substitution can produce an alternative that creates a hazard with less impact than the original. The risk is thus reduced, but will never be zero.
The third most effective means of controlling hazards is engineered controls. These do not eliminate hazards, but rather isolate people from hazards. Capital costs of engineered controls tend to be higher than less effective controls in the hierarchy, however they may reduce future costs. For example, a crew might build a work platform rather than purchase, replace, and maintain fall arrest equipment. “Enclosure and isolation” creates a physical barrier between personnel and hazards, such as using remotely controlled equipment. Fume hoods can remove airborne contaminants as a means of engineered control.
The three components above are therefore not concerned with Humans but with the plant, machinery, materials and equipment that people intend to use in the workplace.
Administrative controls are changes to the way people work. Examples of administrative controls include policies, procedure changes, employee training and competence, and installation of signs and warning labels. Administrative controls do not remove hazards, but limit or prevent people’s exposure to the hazards, through their own actions and decisions, such as completing road construction at night when fewer people are driving.
Personal protective equipment
Personal protective equipment (PPE) includes gloves, uniforms, respirators, hard hats, safety glasses, high-visibility clothing, and safety footwear. PPE is the least effective means of controlling hazards because of the high potential for damage to render PPE ineffective. Additionally, some PPE, such as respirators, increase physiological effort to complete a task and, therefore, may require medical examinations to ensure workers can use the PPE without risking their health.
The two components above focuses on “People” and how they behave toward and respond to hazards. It relies on the “human element” and is the least effective form of control.
Safety Management Programs
The latest addition to the various forms of Safety management programs, ISO 45001 is an administrative control to “oversee and evaluate” the effectiveness of the hierarchy of controls. An analysis of OHS Practice confirms that the 80/20 principle rings true when one look at the role of the H&S Practitioner. Generally, 80% of their work, involves 20% effectiveness in hazard control as they are not involved in the technical detail of “Prevention through design”.
If one has to assign a value on the effectiveness of each of the components, with “Zero impact” as the baseline, the pyramid will look like the graph below.
In the above graph, columns indicated in Blue is part of Safety Engineering, and those in Green is the impact of the OHS Administrative Practitioner. This can further be substantiated on the premise that OHS legal frameworks across the globe puts more emphasis on the Safety engineering components, and if all else fails, the administrative and personal controls.
Under the Organising Framework of Occupations (OFO, version 2017), the OHS and the Safety Engineer are therefore also separated into two or more specialised groups. The bulk of people practising Safety Management, therefore also lies within the “administrative” side of Hazard Control and while there may be individual crossing of the line, the majority of practitioners fail to meet or have no interest to achieve the competency requirements set by various Safety Engineering Professional Bodies and Societies.
With the minimal impact of the Safety Administrators, there is no need to invest in a proper technical qualification, and competency is mostly achieve within a two week period to understand the basic terminology and documentation requirements to provide an administrative support function to the Technical teams at the Engineering side of Safety Management.
It is therefore also not surprising that the bulk of Safety Management professionals are grouped into two factions. In South Africa for instance, the Institute of Safety Management has roughly 620 members, while the larger portion (10 000+) of OHS Practitioners opted for the less strenuous competency assessment criteria and broke away to form their own regime.
In relation to the Hierarchy of controls, the numbers are pretty much in line with the effectiveness of each of the two groups. With 90% of the success achieved by 10% of the qualified safety management professionals, it stands to reason that it would take more generalists to achieve the same result; 10 times more.
Holistic Safety Management = Safety Engineering + Safety Administration.
The general notion that Occupational Health and Safety is a profession practiced by a single individual has been in existence since the OHSA came about in the USA in 1974. Since then, the Safety Management profession have adopted a “calling all pockets” approach to what was once a specialised function.
But the role and purpose of Industrial Safety and the Safety Engineer is not dead. It is merely fractioned into a separate professional regime under the Engineering disciplines phrased in the OFO as Engineering Professionals.
The remainder of generalists sorted themselves under the banner of Business Services and Administration Managers. Accident statistics have shown a decline over the past 5 decades, but the impact of the advancement in safer machines, equipment and plant have not been attributed to the success of the safety engineering disciplines, but rather to the administrators of the programs that can demonstrate it visually.
The Engineering Council of South Africa regards a number of engineering fields as part of the Safety Management profession to be part of their “Specified Categories” which provides for the registration of persons who cannot register in the professional category, but who perform critically important work of an engineering nature which has a direct impact on public safety and health e.g. “Lift Inspectors”.
Under OHS Laws internationally, there are a myriad of regulations referring to mechanical, electrical, fire and civil engineering hazards and risks is a clear indication that “Safety Management” is not just a “paper-based” profession dealing with documents and forms, but requires a technical skill of a specialist nature.
A Safety Management professional is therefore not necessarily a “safety” professional, but would include for instance a Mechanical Engineer with a Safety management responsibility.
One such person can be found in the South African Occupational Health & Safety Act under General Machinery Regulation 2(1), commonly referred to as The Competent Person. While trading as an engineer, the office of appointment is solely responsible for ensuring that machinery and steam generation plant complies with Safety Requirements.
Under this function, the Responsible Engineer on a premises is in fact a Safety Management Professional.
In a recent article on Human & Organisational Performance (HOP), the role of the Safety Engineer came to the forefront once again. Whilst promoters of Behaviour Safety will remain firm on the human error approach to safety and accident prevention, Safety Engineering applying HOP addresses the removal of the effect of unsafe behaviour by design changes. The premise of Safety Engineering is to remove the risk at the source, and not to avoid the risk by changed behaviour, which relies on the absence of Human Error.
Under the banner of Safety Management, there are a number of technical specialists. The level of safety in an organisation is influenced by its processes, systems, machinery and energy sources.
The General Duty clause under the Occupational Health and Safety Act (SA), states that the provision and maintenance of Systems of Work, Plant and Machinery that is safe and free of health risks and places this at the top of the list of general duties of employers. Commonly also referred to as the hierarchy of controls, this is the Engineering controls which stands at the top of the hierarchy.
Safety Management is therefore, or should be concerned with the three aspects of “Systems”, “Plant” and “Machinery”.
Systems thinking is common phrase in Safety engineering, where a “system” is an interactive process comprising a number of elements performing a common action. For example: To write an article your “system” will comprise of four elements “Material (text), Machine (Laptop) and a Human (author) and Energy (Electricity). One can expand on this to include “knowledge”(knowing what to write about) and “Skills” (Knowing how to use a laptop) and then “experience” will be the last element.
Taking a system approach to safety will thus require foremost to identify the elements within a system and secondly, what impact each element as a single cause of failure will have on the system as a whole. The third part of Systems engineering will then look at the probability of the system as a whole failing as a result of a single element.
Another approach to Safety Management is Process engineering by designing a process to minimise ergonomic, environmental and physical stress factors. While process and industrial engineering are different fields, their overlaps are quite remarkable when it comes to Safety Management.
Information and Administrative Support
Under the auspices of the Safety Engineering team a group titled Environmental and Occupational Health and Hygiene Professionals (2263) are then engaged to provide informative support through physical measurement and analysis of the impact of the engineering controls, and who also provide input to the lower administrative functions of the OHS Administrators supported by a team of dedicated administrators and data capturers whose sole function it is to generate measurement and auditing mechanisms to evaluate and demonstrate the effectiveness of the engineering efforts within an organisation.
OHS Management Unity lacks validity in motive.
In an article published in 2012, and also recently during discussions between a voluntary association and the SA department of Labour, the question of a single umbrella body for Occupational Health and Safety once again emerged.
Given the vast difference between safety engineering, safety administration and the supporting functions provided by specialists such as Occupational Medicine & Health practitioners and Environmental and Occupational Hygienists, there would be no common purpose.
A single body will then in any case need to be sub-divided into the various disciplines, creating a “management body” for a vast array of professional chapters. A typical example of such a fragmented body is the Institute of Working at Heights, with a total of seven chapters or Chambers; each dealing with a specific aspect from which one can fall from height. Rope Access, Scaffolds, MEWP’s etc are all systems for working in an elevated position, each requiring a unique skill set.