It took me several years to realize that a traditional OSH program is NOT a “safety management system.” Like many workplaces, I always had a collection of written occupational safety and health programs placed into binders strategically located throughout the facility. Then, I had a separate PSM (and eventually an RMP) program that was a SEPERATE program. And yes, like many businesses, we claimed this collection of individually written programs as our “safety management system”. And nothing could be further from the truth; a collection of individually written safety programs is not a “safety management system” – they are simply a collection of individually written programs that are put into a single binder (or an electronic folder these days). The binder is literally the ONLY thing holding these programs together! Granted, these written programs are a BIG part of an SMS; however, without several other SMS elements, the typical OSH program is a far cry from a functioning management system.
But for those facilities that are not required to comply with OSHA’s PSM standard or EPA’s Risk Management Plan rule, they rarely have these necessary SMS elements; since they are not an OSHA or EPA requirement outside of PSM/RMP. And this is a significant miss for any business seeking to achieve world-class safety status, as these other supporting elements of the SMS bind all the other elements together.
But why would a business already neck deep into PSM/RMP need to spend the time, money and resources on a 3rd party SMS when the business already has the framework of an SMS within their PSM/RMP program? Why not just utilize the existing PSM/RMP SMS elements to manage the OSH side of the business? Once a business matures in its approach to process safety, the progress will look something like this…
Having lived in the Proces Safety arena my entire 30+ year career, I grew up with the expectations that MOC, PSSR, Root Cause, and Corrective Action Plans, and Auditing were just ways of managing safety (not necessarily reserved for process safety). And I was fortunate to have worked for organizations that used the PSM/RMP 14-element management system approach for our OSH management. In other words, we used the MOC, PSSR, Root Cause and Corrective Action Plans, and Auditing management elements outside of the PSM/RMP processes.
The value was huge once we realized that the MOC, PSSR, Root Cause and Corrective Actions, and Auditing activities were “tools of our trade” and not some government requirement that we had to check the box for compliance or some poisonous pill we had to swallow. Once we embraced these additional elements (which are NOT required by OSHA outside of PSM), we were much closer to having an actual SMS in place.
In my career, the logic was easy to follow.
We needed a MOC process for changes to our OSH programs and changes to the manufacturing/production process(s) that could increase risk by introducing new hazards or making current safety programs and training less effective. Having the ability to RECOGNIZE this BEFORE an incident is critical. A well-executed MOC tool will provide this ability in the traditional OSH setting. We have captured things like the need to
- revise the Fire Extinguisher layout, type, and size
- re-evaluate the hearing conservation program and the HP being used, only to find that some HP’s had too low of an NRR for the new work environment
- revise the egress paths due to changes in the workflow layout, which then led to a revision to the Emergency Action Plan (which is attached to the PSM/RMP programs)
- revise the PPS Hazard Assessment
- new PRCSs being added to the workplace
- new LOTO procedures needed for new equipment
We then would perform a Pre-Start Up Safety Review (PSSR) when the business was ready to implement its change. Just like in PSM/RMP, this PSSR intends to validate that the safety and health concerns IDENTIFIED in the MOC process were properly addressed BEFORE the change is allowed to be implemented. And I will also say that the MOC process prevented many changes that would have created a mountain of work for very little benefit. For example, a change that leads to a change in egress paths will have HUGE ripple effects on the organization. A change to the EAP, a change to posted Egress Maps, a change to signage, a change to floor markings if they are used, and all of the changes require TRAINING for the personnel impacted, including contractor training programs.
Of course, there will come a day when management begins to ask questions about “REPEAT” failures that lead to events. That is where we will need a formal Incident Investigation. A mature SMS will actually use the RCCA model to analyze the Audit findings, especially those REPEAT findings. From this formal analysis, using a recognized RC methodology will come with causes and corrective action plans (CAP). These CAPs are part of our CONTINOUS IMPROVEMENT efforts, another overarching need of any SMS approach, and should be viewed as OPPORTUNITIES to IMPROVE the SMS.
But auditing may be the most overlooked element needed to ensure that the OSH programs are well written, properly implemented, accurately measured, and being managed by the front-line leadership. Sadly, because OSHA does not have a requirement for OSH program audits, this vital element of a SMS is often not utilized by businesses. This painfully becomes clear after a significant event in the business. And although OSHA may not be able to cite the lack of any auditing, it will undoubtedly come up in the discussions. And typically, when we are asked to participate in the investigation of the events, we find significant/serious deficiencies in the OSH written programs, their implementation (which was usually decades earlier), and their management by front-line leadership. All things that a good audit at some frequency (as spelled out in the SMS) would have captured, allowing the business the OPPORTUNITY to address BEFORE the event.
So a business can make GREAT strides in improving their OSH efforts by implementing these four (4) supporting elements:
- MOC,
- PSSR,
- Root Cause/Corrective Action Plans, and
- Auditing
Even though they may not be mandated by some government standard/regulation/rule, they play a vital role in any effort to manage safety at the world-class level. Without them, an organization will NEVER recognize its full ability in safety performance or culture.
