ISO 14001 and OSHA Safety Programs

General Duty Clause

• OSHA's General Duty Clause applies when a specific written standard doesn't address a workplace hazard.
• Four conditions must be met:
  • A hazard exists in the workplace.
  • The hazard is recognized.
  • The hazard is causing, or likely to cause, serious physical harm to employees.
  • A feasible means exists to reduce the hazard.
• Examples of hazards covered: Ergonomics, heat/cold stress, combustible dust, lasers, workplace violence.

Workplace Injuries

• Ergonomics: 21-33% of injuries.
• Heat/cold stress: 789 hospitalizations and 54 deaths from 2018-2021.
• Combustible dust: 2021:163 fires, 53 explosions, 215 injuries, 69 deaths.
• Lasers: 26 incidents since 1999.
• Workplace violence: 2020: 705 deaths and 27,000 lost-time injuries.

Two Approaches

• Comprehensive Safety and Health Program
• Occupational Safety and Health Management Systems

OSHA Recommended Practices

• Compliance with OSHA standards is important but an effective program goes beyond specific requirements.
• Safety and health programs reduce injuries, lost workdays, and worker's compensation costs.

OSHA's Safety and Health System Model

• The model emphasizes a proactive approach.
• Key elements include:
  • Management leadership and employee involvement
  • Worksites analysis
  • Training
  • Hazard prevention and control

OSHA's Model

• Top management demonstrates commitment, sets expectations and responsibilities
• Managers create a culture of safety and health, provide resources and support.
• Workers and representatives involved in the program: setting goals, identifying hazards, investigating incidents, and monitoring progress.
• Barrier removal, allowing for open communication.
• Procedures to identify and evaluate hazards.
• Control measures (engineering controls first, followed by administrative and personal protective equipment).
• Training to understand the program and control measures.
• Program evaluation for effectiveness and continuous improvement.

Element 1 - Management Leadership

• Management should integrate safety and health into the company's mission.
• Set a good example, by wearing PPE and following safety procedures.
• Enforce safety rules promptly with clear expectations for response time to hazards.

Element 2 - Employee Involvement

• Workers should understand potential hazards effectively.
• Diverse input from employees helps in implementing effective safety programs.
• Increased employee support and use of the program.

Element 3 - Hazard Analysis

• Managers and employees should analyze all workplace conditions.
• Identify and eliminate existing or potential hazards.
• This includes looking at tasks, equipment, work practices and injury reports.

Hazard Analysis

• Covers all departments
• Reviews current tasks/proposed changes
• Reviews equipment condition
• Reviews work practices
• Reviews personal protective equipment (PPE)
• Reviews injury and illness reports

Element 4 - Hazard Prevention & Control

• Prioritize controls using a hierarchy: Elimination, Substitution, Engineering Controls, Administrative Controls, and Personal Protective Equipment (PPE).

Examples of Eliminating the Hazard

• Non-needle IV systems
• Placement of valves and controls at ground level.
• Prevention through design
• Mechanical mechanisms rather than manual

Examples of Engineering Controls

• Retracting and self-shielding needles.
• GFCI on electrical outlets.
• Machine guards.
• Local exhaust ventilation.
• Chemical fume hoods.

Examples of Administrative Controls

• Lock-out/tag-out energy sources before equipment maintenance.
• Prohibit recapping used needles.
• Job Rotation
• Housekeeping

Examples of PPE

• Gloves, Aprons, Goggles
• Respirators, Safety Glasses

Element 5 - Education & Training

• Is appropriate training conducted?
• Are employees learning what they should?
• Are unsafe work practices being used?

Element 6 - Program Evaluation & Review

• Performance monitored through:
  • Safety Committee
  • Employee feedback
  • Self-Inspection Program
  • Injury investigation and evaluation
  • Leading and lagging indicators

Element 7 - Host Employer/Contract Employees

• Host employers responsible for some contract/temporary employees' safety.
• Various websites contain information.

OSHA Safety and Health Programs

• Recommended Practices for Safety and Health Programs.
• Construction

OUHSC Comprehensive Safety and Health Policy and Program

• Policy on safety and health for OUHSC.

Management Systems

• Systems to establish policy and objectives to achieve objectives.
• Six common elements: Planning, Policy, Implementation & Operation, Performance Assessment, Improvement, and Management Review.

Occupational Health and Safety Management Systems

• A system organizations put into place for safety policies that includes continual improvement.
• Several formats are available: ANSI/ASSP Z10.0 standards and ISO 45001.

OHSMS

• Management expects processes to assure that management provides direction and leadership and workers are actively involved.
• Resources are adequate. Hazards are identified and evaluated. Risks are assessed and prioritized. Risk elimination, reduction, or control measures are taken. Injuries and illnesses are reduced. Management system deficiencies and opportunities are identified, and communication is ongoing about status.

ANSI/ASSP Z10.0-2019

• Occupational Safety and Health Management Systems
• Voluntary consensus standard
• ASSP video, https://www.youtube.com/watch?, (link removed)
• ASSP free resource. (link removed)

ANSI/ASSP Z10.0-2019 (Detailed Elements)

• Scope, Purpose, and Application; References; Definitions, Context of the Organization-Strategic Considerations: Management Leadership and Worker Participation, Planning; Support, Implementation and Operation; Evaluation and Corrective Action; Management Review

What's Different

• Setting SMART (Specific, Measurable, Achievable, Realistic/Relevant, and Timebound) goals.
• Continual improvement.
• Plan-Do-Check-Act model

Environmental Management Systems

• Establish comprehensive environmental compliance.
• Identify all regulations and requirements applicable to the company.
• Create organizational commitment to responsibility and accountability.

Environmental Management Systems (Benefits)

• Not required by law.
• Competitive advantage.
• Improved public image.
• Minimized legal liabilities

Basic Process in an EMS

• Reviewing organizational environmental goals and impact/compliance, objectives and targets, establishing programs to meet targets.
• Monitoring and measuring progress, employee awareness and competence, and reviewing progress and improvement.

EMS ISO 14001

• The world's EMS standard.
• Various resources, including videos, are available.

ISO 14000/14001

• Global EMS standards for organizations demonstrating environmental responsibility.
• Controls environmental aspects, targets, and objectives.
• Improves compliance.
• Prevents pollution and reduces waste.

ISO 14001

• Environmental Management System
• Audit process to verify organizational actions.
• Continual improvement (Plan-do-check-adjust model).
• Not a checklist for compliance

ISO 14001 Standard

• Describes various key elements and procedures, including policy, environmental aspects, legal requirements, objectives and programs, roles and responsibility, awareness, documentation, control of documents, operational control, emergency preparedness, monitoring and measurement, evaluation of compliance, nonconformity corrective action, preventive actions, records, internal audit, management review, etc.

Environmental Policy

• Declares an organization's commitment to the environment.
• Provides a framework for planning and action.

Environmental Aspects

• Identifies activities, products, and services with potential environmental impact.

"Significant Environmental Aspects and Associated Impacts"

• ISO 14001 requires identifying environmental aspects, their potential impacts.
• Aspects interact with the environment.
• Impacts are the changes (positive or negative) in the environment resulting from the organization's activities.
• Full life-cycle of a product is considered.

ISO 14001

• Consistent with the life cycle perspective; organizations need to establish proper control of environmental requirements, including design processes, products and services and their life-cycle.
• Communicate environmental requirements to external contributors (contractors).
• Considering environmental impacts during transportation or disposal of products/services.

Product Stewardship

• Using a lifecycle perspective, companies need to manage health, safety, and environmental aspects of raw materials, intermediate materials, and consumer products that impact the value chain.
• Preventing or minimizing negative impacts, maximizing value.

Product Stewardship Sustainability

• Evaluation of product life cycle analysis for product sustainability
• Consideration of potential hazards in development, production, use and disposal.
• Practices such as substitution, waste minimization, recycling/reuse.

Procurement

• Supply chain accountability.
• Environmental polluters and child labor are addressed.
• Examples: Nike, Apple, Ikea, Walmart; examples of the negative impact that company purchasing has on the environment and on the lives of their workers.

Legal and Other Requirements

• Identify and ensure access to relevant laws and regulations.

Objectives, Targets, and Programs

• Establish environmental goals in accordance with policy, aspects, impacts and management viewpoints.
• Develop action plans for goals and targets.

Resources, Roles, Responsibility and Authority

• Establish responsibilities and provide resources to employees/departments with clear authority designations.

Competence, Training and Awareness

• Ensure employees are trained and capable of carrying out environmental responsibilities.

Communication

• Establish internal and external communication about environmental management issues.

Operational Control

• Identify, plan, and manage operations according to policy, objectives, and targets.

Emergency Preparedness and Response

• Identify potential emergencies, and establish preventative and response procedures.

Evaluation of Compliance

• Evaluate legal and other requirements periodically
• Record results.

Nonconformity, Corrective Action & Preventive Action

• Identify and correct problems; prevent future occurrences.

Documentation

• Keep thorough records of EMS performance.

Internal Audit

• Periodically review commitments and verify the EMS's operation as intended
• Report audit results to management.

Management Review

• Review EMS for continuous improvement.

EMS Supporting Documents (Details)

• Page lists environmental policy, aspects/requirements, objectives/targets, resources/roles/responsibility, communication, documentation, control of documents, operational control, emergency preparedness and response, monitoring, measuring, evaluation, nonconformity, corrective action, preventative action, records, internal audits, and management reviews.

Return on Investment

• Return on investment and various methods for demonstrating the return.
• Data showing how safety investments reduce costs.

The Tip of the Iceberg

• Detailed breakdown of direct and indirect costs associated with workplace injuries.

OUHSC Example

• Provides information about safety practices implementation and analysis of return on investment information from an actual OUHSC implementation.
• Specifics, including the difficulties in implementing effective safety training.

Training Lost Billable Costs

• Training costs may increase initially but show savings over time.

Injury Lost Billable Costs

• Show that injuries may decrease over time with the implementation of a safety program.

Total Financial Impact

• Summarizes the overall financial effects of the training program and the positive impact on injury-related costs.

Ways to Show Return on Investment

• Various methods for demonstrating return on investment (e.g., safety pays tools, white papers).
• Various organizations with safety resources are noted.

Other Resources

• Link for return on investment of safety.

Bottom Line

• Effective safety programs reduce injuries, illness, absenteeism, worker's compensation costs, and increase productivity/morale.
• Decrease potential for regulatory fines and fire hazards/insurance costs.

Homework 6

• Homework assignment.

Test your knowledge on ISO 14001 and OSHA safety practices. This quiz covers the core elements of ISO 14001, the General Duty Clause, and key recommendations from OSHA. Assess your understanding of environmental management and workplace safety regulations.