We hear it all the time… “yes of course we have a safety management system.” Then we ask one simple question, “can we see your OSH auditing plan for the year/3-years/5-years?” The most common response we get is “OSHA does not require us to conduct overall workplace audits.” That is true and it is also evidence that the facility does NOT have a functioning SMS. Much like OSHA’s PSM standard, an SMS will have an auditing element. But for many facilities that have a PSM/RMP program, they refuse to adopt this practice outside of their efforts to comply with the PSM and RMP standards.
But imagine if OSHA had a standard that required “non-PSM” facilities to conduct wall-to-wall audits at some established frequencies. And with this audit requirement, also comes a requirement (exactly like we find in the PSM standard) to have a requirement to develop Corrective Action Plans (CAPs) for the audit and a formal means to track each corrective action to closure.
These audits could be done in-house, but not by someone associated with the program or within the facility being audited. This means 2nd Party Auditors or 3rd Party auditors. Of course, if we want a quality audit, we need quality auditors/SMEs.
This single OSHA requirement, should they ever be able to promulgate it, would be a game-changer for those businesses that truly want to become world-class. This leads me to say this… OSHA’s attempts at adopting the Injury and Illness Prevention Program (I2P2) approach to occupational safety and health would be a MASSIVE improvement from the old and worn-out compliance model approach to OSH.
Based on OSHA’s experience, the agency believes that an I2P2 rule would include the following elements:
- Management duties (including items such as establishing a policy, setting goals, planning and allocating resources, and assigning and communicating roles and responsibilities);
- Employee participation (including items such as involving employees in establishing, maintaining and evaluating the program, employee access to safety and health information, and employee role in incident investigations);
- Hazard identification and assessment (including items such as what hazards must be identified, information gathering, workplace inspections, incident investigations, hazards associated with changes in the workplace, emergency hazards, hazard assessment and prioritization, and hazard identification tools);
- Hazard prevention and control (including items such as what hazards must be controlled, hazard control priorities, and the effectiveness of the controls);
- Education and training (including items such as the content of training, relationship to other OSHA training requirements, and periodic training); and
- Program evaluation and improvement (including items such as monitoring performance, correcting program deficiencies, and improving program performance).
