HSE, Quality and Risk Management Blog

An OSH management system is a tool combining people, policies and resources. It aims at improving a business’ occupational health and safety performance, making for better organisation and continual improvement within the company by ensuring that OSH matters are integrated across the organisation.

Adopting this kind of system is a signal that the company is taking an integrated approach to the prevention of occupational risks. It is a choice that specifically sets out to:

Anticipate change, Improve business responsiveness and performance in OSH Reduce OSH failures Ensure overall consistency with other management policies.

It contributes to improving the organisation’s image.

OSH management systems form a framework for integrated, structured risk management, in particular as regards small and medium-sized enterprises (SMEs). They frequently enable OSH to take on strategic importance, giving the area of safety authority and legitimacy, and can make it possible for the company to learn useful lessons in every field. To this extent, businesses should be encouraged to implement such systems, as long as certain conditions are met. They can however also have detrimental effects if implemented without taking into account certain essential values or ensuring the right conditions. Such effects could include over-standardisation of management methods, breakdown of social dialogue, compliance with the system without achieving genuine progress or excessive behavioural control.
An OSH management system can be an integral part of sustainable development, which must give consideration to workers’ health and safety.

OSH management system guidelines help the company to implement a policy, i.e. to make the organisational and management decisions needed to comply with the needs of occupational safety and health and to work towards continual improvement in this field.

The guidelines are sometimes imposed by a company’s client. It can be very tempting to view these guidelines as an end in themselves. If this happens, there is the risk of generating excessive formalism and rigidity, leading to the application of methods that are unsuitable or too numerous, or can even be in contradiction with the organisation’s business goals.

Experience has shown that it is in the company’s best interests to adapt existing guidelines to its OSH targets to form its own standard according to its size, its area of business, its safety culture or the existence of other similar systems (e.g. for quality or the environment).

There is no need to choose existing guidelines. The company can select the combination of its choice from different systems, whether they can be used as a basis for certification or not.

SMEs often decide on a stepped approach, with the first step being a low-level, customised standard system allowing them to embark upon a process of continual improvement.

There are roughly speaking four categories of existing OSH guidelines or standard systems:

General good practice guidelines, such as ILO-OSH 2001 (produced by the International Labour Organisation) and the British standard BS8800. Certifiable OSH specifications such as OHSAS 18001 (produced by national standardisation bodies and private bodies, but not having the status of an international standard). Guidelines focusing on relations with outside/user companies, such as the Guide for the improvement of safety in companies, the French Chemical Industry Association (UIC). Specific guidelines produced by and for a company or business sector.

One interesting feature of the ILO-OSH 2001 guidelines is that they have been adopted by the social partners. They stress the importance of worker involvement and consultation with worker representative bodies.

The success of an OSH management system depends not on the guidelines or standard system selected but more on the way they are used, in particular on the way the safety policy is implemented.

To avoid having an elaborate system that does not deliver results (especially when it has been imposed or is applied through a solely top-down approach), leadership and support are required. If this is not done, the management system will be perceived as just “another layer” of rules and regulations, more often than not unconnected with actual working practices. Making it a “living” system, and integrating it into a genuine process of improvement, are the most difficult targets to achieve.
The introduction of such a management system means setting up a project for change in the organisation. Even if the objectives of the system have been agreed and its adoption seems easy and natural, this type of management scheme needs to be approached as a project and resources need to be allocated to support the change in order to achieve genuine results.

This approach is based on innovation theories describing the most successful and sustainable changes, which are achieved through a process of three steps referred to as incitation, laisser-faire and institutionalisation.

Incitation is the period when the project is launched Laisser-faire is the period during which certain individuals or groups will take ownership of the project, perhaps making some changes but also creating favourable conditions for its introduction and effectiveness. Institutionalisation is the period when management takes back control of the project once adapted to then introduce it on a broader basis.

This being so, an OSH management system can be viewed more as a project than a tool, and must be approached as such (identification of those involved, specific responsibilities and tasks, schedule, etc.).

Prerequisites and values The chances of an OSH management system being successful are increased if the following conditions are met:   Strong and sustained commitment by management, reflected in the provision of resources (availability of people, budgets, training programme, communication, etc.) The existence of a regulatory compliance target (if this requirement is not met at the outset); The existence of an occupational safety culture as shown for example by knowledge of OSH principles or a policy of post-accident analysis; The determination to take on board a certain number of essential values and good practices, in particular those suggested by the French occupational risk prevention institution (CNAMTS, CRAMs, CGSSes, Eurogip, INRS) and adopted by the French Occupational Accidents and Diseases Commission (CATMP) of the CNAMTS: people, transparency and social dialogue. The values can form a genuine management tool. This involves:   Identifying the values endorsed by debate; Explaining and publicising these values; Applying these values through principles, good practices and commitments on a daily basis; Assessing the implementation of these values in order to adjust and breathe life into them; Facilitating and encouraging discussion so as to highlight non-compliant situations and ensure consistency between values and practices. Knowledge of similar management approaches, based on continual improvement, can be an advantage when implementing an OSH management system. Prior assessment of company situation Before developing and introducing an OSH management system tailored to the organisation’s requirements, it can be worthwhile to perform an initial assessment. How good is the existing occupational health and safety management system? What are its strong and weak points? How does the workforce feel about the way it is organised? INRS, CNAMTS and the CRAMs can provide you with a tool to help with your assessment. It is a matrix known as the GPS SST. Applicable across 20 different domains, it can be used by any organisation to score its existing practices against 4 standard situations and identify possible areas for progress. The tool can also offer the company support in setting up an occupational safety and health management system.

OSH policy
Defining an OSH policy sets a framework for the management system. It must be driven by a genuine desire of the most senior executive to commit to the process and to taking the organisation continually forward.

It requires the gradual introduction of the following elements:

An effective policy is one that results in OSH being integrated across the organisation. All departments are involved and have to manage this issue just like any other factor affecting their unit.

The organisation’s OSH policy should be set out in a policy statement that should be communicated and made readily accessible to staff.

Organising
The role of those with OSH responsibilities in the company must be specified: their assignments, responsibilities, obligations, powers and connections etc. Employees and their representatives must be consulted, informed and trained so that they take ownership of the process. This requires documentation, a training programme and internal communication procedures to be set up.

Planning OSH actions
One of the essential drivers of continual improvement in occupational health and safety is the assessment of occupational risks. How relevant the analysis of real working situations is will largely determine how successful this process will be. Risk assessment findings must be recorded in a single document (art. R.230-1 of the French labour code). In addition to being a legal requirement, this document should give rise to an action plan defining the appropriate preventive measures for the risks identified. Multidisciplinary approaches (technical, human or organisational) are necessary both for the company as a whole and for the detailed study of workstations. Regulatory developments must also be monitored.

Implementation
The action plan must be implemented in a way that is compatible with professional rules and practices as well as with existing procedures. This presupposes close co-operation with all the workers concerned, participatory schemes based on an analysis of the activities and workers’ freedom to seek innovative solutions. This in turn requires a training programme, social dialogue, communication, documentation and anticipating emergencies.

A system for regular status reporting must also be introduced.

Audits, analyses and corrective actions
The effectiveness of the system implemented must be checked, and if a new risk or hazard factor is identified there must be a response. Audits must be systematically carried out and analysed in order to select corrective actions. A set of quantitative and qualitative OSH indicators should be used: risk indicators, resource indicators and outcome indicators. The indicators traditionally used (i.e. frequency and severity rate of occupational accidents, contribution rate to the occupational accidents and diseases insurance scheme) are lagging indicators and are of limited use.

Audits include an analysis of occupational accidents and diseases that have occurred, without restriction to immediate and directly perceivable causes. A more comprehensive approach will seek to identify root causes to ensure greater effectiveness of preventive measures. This analysis must address not only accidents at the workplace, travelling between work and home and during business-related trips, but also near misses. Similarly, it is a mistake to wait until an occupational disease has been recognised before studying exposure levels to a dangerous emission.

Each organisation can and must innovate in this field. Superficial compliance with guidelines or standard systems without genuine progress over time is to be avoided.

Improving the management system
Management reviews help to improve the system, adjust policies and devise new programmes of action on the basis of observed indicator performance. Policy assessments allow for investigation into failure due to the general design and organisation of the system, i.e. into the effectiveness of the strategies for action.

A national study has been launched by the French occupational risk prevention institution (CNAMTS, CRAMs, CGSSes, Eurogip, INRS) to describe and assess business practices in the field of development and implementation of OSH management systems. An initial, questionnaire-based stage has identified the main features of such actions in 165 organisations. The second stage currently in progress is based on in-depth diagnoses to analyse in situ the application of these actions in around a dozen different companies (see box below).

Observation shows that there are severe restrictions on the implementation of OSH management systems, dictated by the context of the organisation itself and its goals. The OSH performance of the organisations researched, at first sight all exemplary, is variable. The benefits of an OSH management system depend less on the guidelines or standard systems than on the way they are implemented.

Description of OSH configurations

The study, covering organisations of every size, from all areas of business, and using the main standard systems in France, shows that there are four major categories of OSH management approaches according to different context variables: structure, size, industry, technology, etc.. These factors determine the approach and the outcomes. OSH management approaches therefore follow not a model but four organisational configurations that typify all companies to a greater or lesser extent. Though there are standard principles or baselines found in all guidelines, the outcome will depend on the approach implemented. Different approaches produce different results. While the guidelines in general offer a framework for a more comprehensive and co-ordinated approach to managing risks, they do not necessarily succeed in structuring and altering practices in the same way. The problems encountered are not typical of the guidelines or one of their elements, but are due to the characteristics of the approach. Effective OSH management therefore means first addressing the management of the approach. The outcomes show quite considerable differences: the four situations described summarise the main approaches found in organisations.   The four major categories of OSH management approaches The different types of approach to an OSH management system   MODALITIES TYPES OF APPROACH Cascade Innovative Applied Ideological Origin of decision Senior management Supervisory level management QHSE dept. (quality, health, safety, environment) Senior management Expected goal Integration of OSH into local policies Integration of OSH into practices Formalisation of OSH management Integration of OSH into people’s behaviour Leaders and partners National (or regional) management and safety line managers Supervisory level management and staff together with safety line managers Supervisory level management and safety line managers Senior and supervisory level management Method of dissemination Information and awareness-raising meetings Working groups with staff Supervisory level management meetings Human resources and individual assessments Resources provided Limited Negotiable Limited Extensive Employee involvement Low High to start with Limited High at the end Link with CHSCT* Information Participation and validation Consultation Information * French Health, Safety and Working Conditions Committee   “Cascade” configuration The “cascade” configuration is found in subsidiaries of large groups or clients with strong OSH policies imposing guidelines and often OSH certification, which it is up to the company to implement. A cascade-type process is initiated by top management for implementation across the organisation, involving a comprehensive approach to OSH, with local management responsible for application. Without appropriate local adjustments this type of approach produces standard measures for the most commonly found risks. It is perceived as a bureaucratic imposition, and is often implemented in a merely formal or superficial fashion. It delivers no benefits for the safety and health of workers. “Innovative” configuration The “innovative” configuration is found in companies that desire a well organised OSH structure, which certain employees (in particular supervisory level management) will take control over to produce their own version of the management system. An “innovative” model starts from what already exists, but analyses afresh the organisation of safety-related aspects. This process often goes hand in hand with a complete rethink of jobs and activities using rules that merge the demands of quality, environment and OSH systems within a genuinely integrated management system. Its only drawback is the risk of loss of momentum because of the investments required and the demands of the system, especially if management support declines. “Applied” configuration The “applied” configuration has been observed in organisations that have a safety line management structure and view OSH as an occupational necessity. The “applied” model is led by safety line managers that scrupulously apply the guidelines to their organisation, mostly drawing on an effective risk analysis. This approach requires the safety line managers to have a certain status and level of qualification in order to assert the strategic importance to the organisation of the process. If their status and/or skills are inadequate, there is the risk that this will remain a technical process (workstation design, hygiene rules, etc.) and have little impact on practices. The OSH outcomes are in any case often limited. “Ideological” configuration The “ideological” configuration is found in organisations whose awareness of OSH issuesis driven less by technical or management considerations than by the moral values involved. With the focus on staff empowerment, the OSH management system is seen as a way of changing employees’ attitudes and behaviour, or even of bringing them all together under a “common safety culture”. Mostly, an “ideological” model is overlaid on an existing set of strict general safety procedures (integration of new employees, accident analysis, wearing PPE, etc.). The technical know-how of the staff in charge of safety is indisputable and the overall OSH outcomes are positive. This normative approach works well in a stable environment but reaches its limits when things are reorganised and the targeted behaviour is no longer appropriate.