Safety and Health Management Systems and Programs: Comparing ANSI Z10 to OSHA’s Upcoming Safety and Health Management “Program” Guidelines

  This is the second article in a longer series of articles looking at Safety and Health Management in general and at ANSI Z10, the American national standard for Occupational Health and Safety Management Systems, in particular. If you want to start with the first article, which serves as an introduction to the various standards and guidelines for occupational health and safety management, click that link you just read past. But if you just want to dive into this article mid-stream, that's fine too. We're trying to present each article in the series as a logical, "bite-sized" bit of information that stands alone. And so this article is going to look at an interesting distinction: the difference between management "systems," such as the health and safety management system model detailed in ANSI Z10 (as well as similar guidelines for creating management systems in the upcoming ISO 45001 Occupational Health and Safety Management System standard, the ISO 9000 Quality Management System standard, and the ISO 14000 Environmental Management System standard), with OSHA's guideline for an occupational health and safety "program." Or, to put that in fewer words, we're going to look at the issue of management "systems" as opposed to management "programs" in the context of occupational health and safety. Of course, we acknowledge that the OSHA Safety and Health Management Program Guideline is not yet in final form. So it may look different when it's final. But we'll compare what we can compare today, and in doing so we'll get an interesting look at the distinction between "systems" and "programs." (NOTE: Since we first wrote this blog post, OSHA has released their revised safety and health management program guidelines in final form. Click here to read OSHA's Recommended Practices for Safety and Health Programs and/or download it as a PDF.)

ANSI Z10 Is about Creating (and Using) Occupational Health and Management SYSTEMS

ANSI Z10 sets up a model for companies or organizations who want to create an occupational health and management system. And the standard itself includes quite a bit of information about this "systems thinking" in the early parts of the standard. Let's look at some of that more closely. In the Foreword, ANSI Z10 says that "management systems" work and work well in EHS:

"There is widespread agreement that the use of management systems can improve organizational performance, including performance in the occupational health and safety arena." (source: 1)

As a result, the writers of ANSI Z10 set out to create a model for systems to manage occupational health and safety:

"The committee examined current national and international standards, guidelines and practices in the occupational, environmental, and quality systems arenas. Based on extensive deliberations, they adapted the principles most relevant from these approaches into a standard that is compatible with the principal international standards as well as with management system approaches currently in use in the U.S." (source: 2)

And in creating their standard, the creators of Z10 hoped management systems would take hold:

"The process of developing and issuing a national consensus standard is expected to encourage the use of management system principles and guidelines for occupational health and safety..." (source: 3)

[optin-monster slug="ti49m7rdg4wmrqfsyyoj"]

The Multiple Levels of a Management System

Because Z10 is focused on creating a model for a health and safety management system, it presents general information for setting up a system that individual companies can then apply differently to fit their specific circumstances and meet their specific needs. The writers of the standard did this by focusing on the more universally applicable levels of a multi-level system, with the expectation that once companies have the foundations in place, they can build in the details. According to ANSI Z10:

"Management systems typically include multiple levels of implementation..." (source: 4)

The standard includes a diagram that shows four levels of a management program. I've created my own diagram to simulate what's included in the standard. It's shown below. (source: 5) The writers of the Z10 standard note that the standard only sets out to model the creation of policy and processes:

"Z10 focuses primarily on the strategic levels of policy and the processes to ensure the policy is effectively carried out. The standard does not provide detailed procedures, job instructions, or documentation mechanisms. Each organization must design these according to their needs."

Z10 Models a System Based on the Familiar "Plan-Do-Check-Act" Concept

As noted above, Z10 is set up to help organizations establish policies and processes based on the standard's model, and then create job instructions and documents that are aligned with those policies and processes in the way that best suites the company. All this is done to help the organization create a perpetual cycle of continuous improvement, following the well-known plan-do-check-act (P-D-C-A) concept. That continuous improvement cycle is intended, in broad terms, to increase safety and health and to decrease hazards, risks, incidents, and other "negatives." The standard includes a somewhat-complicated graphic depiction of this. I've again tried to recreate that graphic below to give you the basic idea how the system is intended to work. (source: 6) Z10 further explains this use of the plan-do-check-act continuous improvement cycle in its model for health and safety management systems:

"The OHSMS cycle entails an initial planning process and implementation of the management system, followed by a process for checking the performance of these activities and taking appropriate corrective actions. The next step involves a management review of the system for suitability, adequacy, and effectiveness against its policy and this standard. The complete cycle is repeated, resulting in ongoing continual improvements in occoupational health and safety. Improvements result from reducing hazards and risks in a systematic manner--a goal traditionally pursued through independent programs that often are not coordinated through common management principles and processes." (source: 7)

Did you notice that section above that we put in bold font? If not, here's what it said: "Improvements result from reducing hazards and risks in a systematic manner--a goal traditionally pursued through independent programs that often are not coordinated through common management principles and processes." Here's where the writers of Z10 are explicitly showing their hand. In this statement, they:

• Create a distinction between management systems and independent programs
• Make a not-very-subtle, implicit statement that management systems are more effective than independent programs (because programs are "not coordinated through common management principles and processes")

Here's a further explanation, from Z10, of how the management system and the use of the P-D-C-A cycle of continuous improvement is supposed to work and be better than a series of independent safety programs:

"The management system approach is characterized by its emphasis on continual improvement and systematically eliminating the underlying or root cause of deficiencies. For example, in a systems approach, if an inspection finds an unguarded machine, not only would the unguarded machine be fixed, but there would also be a systematic process in place to discover and eliminate the underlying reason for the deficiency. This process might then lead to the goal of replacing the guards with a more effective design, or to replacement of the machines themselves so the hazard is eliminated. This systematic approach seeks a long-term solution rather than a one-time fix." (source: 8)

Additional Benefits of a Management System

Finally, at least in terms of this conversation and article, ANSI Z10 claims some additional benefits of using a management system for occupational health and safety. Here's what they say:

"The processes that drive implementation of the organization's management system also facilitate improved teamwork and operational performance. It places less reliance on single individuals and more emphasis on an organization's process and teamwork to maintain business functions even as personnel changes...occur. In addition to the direct benefits of improved employee health and safety, a management system can also yield positive business outcomes, including enhanced productivity, financial performance, and employee satisfaction." (source: 9)

OSHA Safety and Health Program Management Guideline: Not a Management System

As we mentioned above, OSHA is currently in the process of creating their own Safety and Health Program Management Guideline. It's not yet final, and even when it is, it will not have the full standing of an OSHA regulation or standard--it's just a guideline (that's not to say it won't be a helpful document, however). As part of their process, OSHA has already held a comment period, which closed in February, 2016, and a public meeting, which was held in March, 2016. At its website, OSHA makes available a lot of information about this new guideline, including:

• The OSHA Safety and Health Program Management Guideline (in non-final, draft form)
• Additional supporting documents
• The transcript from the public meeting

We invite you to read through as much of that OSHA guideline as you wish. We're going to cover it in more detail here on our blog when it's in final form. Until then, you might also want to read our previous blog post about the Safety and Health Management materials on OSHA's website (remember this is older material). But for our purposes, we're going to drill down into those public meeting transcripts, because a representative of the American Society of Safety Engineers (ASSE), which is now the organization responsible for Z10 along with ANSI, had some interesting comments to make. I'm going to cherry-pick comments that ASSE President Michael Belcher made during the public meeting. As a result, it may seem as if his comments are more negative than they really were. Remember I'm omitting a lot of stuff he said as well, and a lot of that was positive. In the public meeting, ASSE President Belcher addressed the "systems" v. "programs" issue that we're discussing in this article. Here's what he had to say:

"First of all, ASSE is concerned that OSHA has relied on a programs approach rather than a systems approach in the guidelines. A systems approach encourages a more holistic view of safety and the interdependent core elements of a plan. It's really the interactions between elements that ultimately foster or fail success, not the elements themselves. The systems approach is at the heart of the ANSI Z10 standard and the impending...ISO 45001 standard which we believe must be referenced in the final guidelines... In closing, I'd like to say that safety and health management systems are what our members do best. They encourage a risk-based approach to protecting workres. These guidelines, if written well, can help more employers better protect workers and organization bottom lines. ASSE looks forward to working with OSHA to spread that message far and wide." (source: 10)

So there's a definite difference of approach between the systems approach in Z10 and the OSHA guideline, at least in its final form. It will be interesting to see how this all works out over time. [optin-monster slug="tfb0ea1ze5dftije3pdk"]

Conclusion: ANSI Z10, Management Systems, and the ANSI Z10 Standard for Occupational Health and Safety Management Systems

Well, that's all we've got for you in this article. By our reckoning, we've explained a bit about what a management system is, have noted that ANSI Z10 is all about creating management systems for occupational safety and health (and for easily integrating with similar management systems for quality and environmental management), and have noted the distinction between a management system, called for by Z10, and OSHA's guideline for a management program. We hope you found all that interesting and helpful.   If you don't yet own a copy of Z10, we recommend you give some thought to purchasing a copy of your own.   And before you leave, why not download our free Guide to Risk-Based Safety Management, below? Notes:

1. ANSI Z10, Foreword, p. vii
2. ANSI Z10, Foreword, p. vii
3. ANSI Z10, Foreword, p. vii
4. ANSI Z10, Introduction, p. viii
5. Although I created this graphic, it's based on a graphic from ANSI Z10, Introduction, p. viii
6. Although I created this graphic, it's based on a graphic from ANSI Z10, Introduction, p. viii
7. ANSI Z10, Introduction, p. ix
8. ANSI Z10, Introduction, p. ix
9. ANSI Z10, Introduction, p. ix
10. OSHA Public Meeting Transcripts, pp. 37-38, access at https://www.regulations.gov/document?D=OSHA-2015-0018-0109 on 8/3/2016