Re: BS OHSAS 18001 is not an ISO standard...!
Please excuse my selective quoting but as your words were mixed in with mine I have to do some pruning.
Hi Paul !
I guess that you are especially a specialist in quality, but me of health safety to work. I propose several remarks in connection with your message:
You guess (partially) correct. My background is mechanical engineering that has to consider all aspects of a product - including safety. My first specialism was in quality and I am always interested in it. I have extended my areas of expertise into areas of environment and health & safety. Because I take H & S, in particular, so seriously I have taken additional qualifications in H & S.
1-I don’t agree with you when (as often in quality) you confuses “management system” and “system certification” (you said “If an organization chooses to go for certification they tend to…”). In Quality, Environment or Health and Safety domains, “to tend to…” organize my management and improve my (Q, E or H&S) results, it’s better I adopt a Management System… but I don’t need to be certified… The bases of our discussion are the real elements of our management standards. However I observe that certification is absolutely not a requirement of these standards! And I affirm that a SMS certification is absolutely not a H&S objective or an risks reduction objective…
I do not confuse the two terms. I merely offered the example of an organisation going for certification as this is probably the most common use of a management system standard. I accept that certification should not, in itself, be an objective but there are many who believe that the 'aim' of certification helps drive implementation.
2-I don’t agree either with you if you think “If an organization chooses to go for certification they tend to go through a systematic process to understand their (legal and other) obligations…”. It’s not the standard which brings the competence to the company for knowledge and comprehension of legal (and other) requirements which are applicable to him (more, the standard requires to identify these applicable legal requirements, but those are already obligatory even without this standard and the organization must understand the legal requirements before to think to adopt a OHSMS).
You have quoted selectively from my post. This is incorrect. There is a standard way to implement a management system starting with a gap analysis where an organisation looks at what its obligations are and then puts processes in place to make sure they have systems to meet requirements. I do not separate these two parts and nor should you when you are quoting my post back to me. You are, of course right the legal obligations existed long before the organisation went for certification but (as the examples in my post show - sometimes even good organisations are not aware of them).
3-I don’t agree with you to consider “the (OHSMS standards) controls at a level higher than the legal requirements and include a commitment to improve on areas of highest risk”. Short explanation (at least in the context of the European Union): the regulation imposes* a result (the essence), but the standards of management relate only to the organisational means (the form). The normative (volunteer) controls are not higher than the legal H&S requirements. The legal H&S prevention general principles comprise also the continuous improvement principle**. We cannot thus say that a OHSMS standard brings much more fundamental things than the “legal standards”, except if we don’t know the regulation in question as well as necessary.
Directive 89/391/EEC:
* Art 5 (point 1): The employer shall have a duty to ensure the safety and health of workers in every aspect related to the work.
** Art 6 (pont 2): The employer shall be alert to the need to adjust these measures to take account of changing circumstances and aim to improve existing situations.
You are talking to someone from a country who introduced the Health and Safety at Work etc. Act in 1974 based on an approach of an absolute duty of care for employees and others. Supported (amongst other things by our national body's management systems approach to a H & S management system - HS (G) 65 that came years before OHSAS 18001 and is IMHO a better document. I agree with the directives but you have to understand that OHSAS says your management system has to meet legal requirements 'as a minimum' - hence my post.
4-I agree with you, the true bottom of simple and practical step of prevention H&S is much better than a beautiful unutilised documentary system (a large sorter full with procedures).
We agree on something then.
5-I don’t believe that a independent* OHSMS auditor replaces a H&S regulator because they don’t have the same capacities and the same things to control (we find again the difference between the world of the standards and the world of the regulations).
* but this auditor is paid by the entity wich is audited.
I never said they replace a regulator. Most countries do not have the luxury of sending an employee from their regulator in to a company once or twice a year to check on them. Certification bodies do this.
As for who pays them ... if you use this argument then all H & S professionals cannot be trusted because they are paid by the company and will be scared to go against the company in case they lose their jobs.
Not all auditors are perfect - but most want to do a good job and have a conscience for the employees of organisations they certify.
But I understand our difference in vision: the context of the quality specialists are the standards (because the companies do not need laws to want to improve their production…), the context of specialists H&S it is the regulation (because the civil community imposes H&S “legal standards” on the companies…).
No, a quality specialist is interested in doing the right things. I believe and hope the same is true for H & S specialists.
A bientot. I hope you keep coming back to the cove. Your views are challenging - we are not that far apart but you have misunderstood in almost every way the things that I believe in.
