Data takes many forms: numbers, resources, time; for many reasons: analysis, tracking, allocation. Your OHSAS 18001 management system includes data management for most of these forms and reasons:

Hazard Identification-Risk Assessment [OHSAS 18001 Standard, Clause 4.3.1]. Identify workplace hazards and assess their risk … on an ongoing basis.

Legal and Other Requirements [OHSAS 18001 Standard, Clause 4.3.2]. Identify applicable legal and other requirements … on an ongoing basis.

Objectives and Programs [OHSAS 18001 Standard, Clause 4.3.3]. Monitor and evaluate performance for objectives and programs that are designed to continually improve my OH&S performance … on an ongoing basis.

Competence and Training [OHSAS 18001 Standard, Clause 4.4.2]. Establish competency and training requirements and monitoring training competency-training status for all workers … on an ongoing basis.

Performance Measuring and Monitoring [OHSAS 18001 Standard, Clause 4.5.1]. Measure and monitor OH&S performance, including equipment calibrations … on an ongoing basis.

Evaluate Compliance [OHSAS 18001 Standard, Clause 4.5.2]. Evaluate compliance with legal and other requirements … on an ongoing basis.

Incident Investigation, Nonconformity, Corrective-Preventive Acton [OHSAS 18001 Standard, Clause 4.5.3]. Investigate noncomformity and implement corrective and preventive action … on an ongoing basis.

Internal Audit [OHSAS 18001 Standard, Clause 4.5.5]. Conduct internal audits (and inspections), respond to nonconformity, and analyze findings … on an ongoing basis.

Management Review [OHSAS 18001 Standard, Clause 4.6]. Evaluate OH&S performance, determine changes to the system, establish new objectives … on an ongoing basis.

When first developing and implementing your OHSAS 18001 management system, much of the just-cited data are being established fully for the first time. For reasons of expediency and user friendliness, spreadsheets are frequently chosen as the tool-of-choice to initially amass and manage data. However, because of the need to management the data “… on an ongoing basis,” databases are the better tool over the long haul. Let’s discuss why.

Spreadsheets. Spreadsheets are used by most of us. Some of us are pretty good at inserting dropdown windows, linking worksheets, and using pivot tables. Spreadsheets are for the most part two-dimensional: flat sheets with data spread in rows and columns. As soon as we exceed a couple of dozen rows and more than a half dozen or so columns, the data is beyond the view of our pc monitor. Here are some big pros and big cons of spreadsheets.

Pros. We all know how to use them. Every corporate computer generally has a spreadsheet application installed. Spreadsheets allow data management – albeit awkward – for an initially established OHSAS 18001 management system. An example of a spreadsheet set up as an OSHA Compliance Register is illustrated. This same spreadsheet can be used as the basis for an OSHA Compliance Audit.

Cons. Spreadsheets become unwieldy as the amount of data increases. Inquiry is awkward and frequently limited. Reports are limited.

Databases. Those of us that use databases choose seamlessly between spreadsheets and databases depending upon our purpose. Databases offer almost unlimited possibilities for managing large amounts of data over time and changing inputs. Databases allow freestyle inquiry and provide reports with varying format. Here are some big pros and big cons of spreadsheets.

Pros. Databases allow virtually unlimited data management. This accommodates data amassment and changes over time. Inquiry is freestyle and can change based upon the question-of-the-moment. Reports can be easily configured to provide a wide range of data in a wide range of formats. Data can be exported into spreadsheets.

Database applications are commercially available for the specific purpose of managing OHSAS 18001 management systems. Some such applications are designed for managing OH&S and OSHA compliance data generally, but can be adapted to manage OHSAS 18001 data.

Cons. A lot of folks do not know how to setup databases. Database programs are frequently not installed on corporate computers.

I recommend that you ponder earlyon the best data management strategy for your new OHSAS 18001 management system. Consider the size of your organization and the frequency of changes. Consider the computer competency of your key OHSAS 18001 personnel. Consider short term expediency versus serving long term interest.

I suggest that you consider starting your OHSAS 18001 process using spreadsheets; or, purchasing a commercially prepared database application. Once your OHSAS 18001 management system is established – and you know more clearly your data management needs – consider converting from reliance upon spreadsheet to using a database application.

For the purposes of our continuing discussion, I will address data management from the perspective of using spreadsheets.

Are you ready to develop your OHSAS 18001 management system?
Deciding how to manage data is critical!

Discuss how best to manage your OHSAS 18001 data with Banks Clark today!
Email: BClark@ESHpartnering.com; or, call: 864-517-2299.

Before discussing Risk and other OHSAS 18001 elements, the next few discussions address information management that is generated by Legal and other OHSAS 18001 elements.

OHSAS 18001 requires identification of legal requirements that apply to occupational health and safety (OH&S) aspects of your business. You must also identify other requirements (non-legal).

Legal OH&S requirements usually include OSHA, and perhaps no other legal requirement. Non-legal OH&S requirements can include agreements with customers, agreements with employees, voluntary commitments, and corporate requirements. An example of non-legal requirements are commitments associated with the OSHA Voluntary Protection Program (VPP). [OHSAS 18001 Standard, Clause 4.3.2 – Legal and Other Requirements]

Identifying legal and other requirements that are applicable is the first of a two-step process. The other step is evaluating compliance with these applicable requirements [OHSAS 18001 Standard Clause 4.5.2 – Evaluation of Compliance]. The following discussion includes both steps of this process.

Broad-base identification of applicable requirements and evaluation of compliance is usually performed upon initially establishing your OHSAS 18001 management system; and then monitoring compliance on an ongoing basis as part of maintaining your system.

A strategy for identifying applicable requirements and evaluation of compliance should consider the following tasks. Your strategy can be implemented using third-party experts, in-house specialists, or a combination of both. One approach is to use third-party experts (aka Banks Clark) for your initial and periodic (say, every one to three years) audits and in-house specialists on an ongoing basis. This provides the assurance with in-depth third-party expertise and develops expertise within your own organization.

1. Compliance Registry. This is a compilation of all legal and other requirements that apply to OH&S aspects of your business. If OSHA compliance were your primary – or perhaps only – legal requirement, your compliance registry would begin with the contents of OSHA requirements …

   OSHA Act – Employer’s General Duty.

   OSHA 29 CFR 1904 – Record Keeping.

   OSHA 29 CFR 1910 – General Industry. This assumes that you are not a construction business.

   OSHA Multi-Employer Workplace Doctrine. The OSHA multi-employer workplace doctrine extends compliance responsibility beyond the contracted employer to a facility employer – who creates, controls, or should correct a hazard. Through this doctrine, OSHA 29 CFR 1926 – Construction – can apply to facility employers who are not the construction businesses.

2. Applicability. Examine each element of the standards to determine whether or not the element applies to your business. Yes, this is tedious; but necessary. Due to the need for clear understanding of the standards, a third-party expert is often appropriate for your initial applicability determination. On an ongoing basis, this exercise must be re-visited whenever a regulation changes or your business undergoes change. Applicability determination – applicable; not applicable – should be recorded for each element of each standard considered.
3. Compliance. Evaluate compliance with applicable standards. Your initial compliance evaluation should include a wall-to-wall inspection. As stated previously for determining applicability, a third-party expert is often appropriate for your initial compliance evaluation. On an ongoing basis, compliance can be monitored with routine inspections and periodic audits using in-house specialists. Compliance – conformity; nonconformity – should be recorded for each element of each standard considered.
4. Corrective-Preventative Action. Yes, you guessed it! OSHAS 18001 expects you to determine the root cause for non-compliance and to initiate corrective and preventative action [OHSAS 18001 Standard, Clause 4.5.3.2 – Nonconformity, Corrective, and Preventative Action]. Your determinations of root cause and corrective and preventative action should be recorded for each incidence of nonconformity.

Our next couple of discussions will address information management. This includes information generated by the identification of legal and other requirements, evaluation of compliance, hazard identification-risk assessment, training, controls … as well as monitoring and controlling certain aspects of your OHSAS 18001 management system.

Are you ready to develop your OHSAS 18001 management system?
Evaluating compliance with legal requirements is a critical first step!

Evaluate compliance with legal requirements with Banks Clark today!
Email: BClark@ESHpartnering.com; or, call: 864-517-2299.

Like roux, your OHSAS 18001 Policy is the foundation that makes your OHSAS 18001 management system right for your business and right for your organization. Let’s look at a recipe for OHSAS 18001 Policy [OHSAS Standard Clause 4.2 – OH&S Policy].

For perspective, establising Policy is one of two actions required of Top Management. The other required action is Management Review [OHSAS 18001 4.6 – Management Review]. In other words, Policy and Review require direct participation of Top Management … and cannot be delegated to others. The subject of this discussion is Policy; Management Review will be discussed later.

The recipe for an OHSAS 18001 Policy is simple …

Ingredients:

Size and Nature. Your Policy should reflect the size and nature of your business. Do not describe a workplace that is significantly smaller or larger than your own. Do not describe a business that is different than your own. Do not create a Policy that is inconsistent with the culture of your organization and its core values. In other words, realistically represent your business, your organization, and your core values.

Reduce Injuries. Express commitment to reducing injuries. After all … this is the purpose of OHSAS 18001. Do not promise zero injuries!

Obey Law. Express commitment to obeying the law. This ought to be easy … OSHA compliance is not discretionary!

Continually Improve. Describe periodic review of performance and commitment to continually improve health and safety performance. Like ISO 9001 and ISO 14001, OHSAS 18001 regards continual improvement as an essential outcome. Do not promise overnight improvement or leaps-and-bounds improvement; continual improvement is measurable improvement over time … great and small.

Integrate ingredients into a single Policy statement. Your Policy need not occupy more than a half page. Your Policy should be communicated throughout your organization as well as to other interested parties (examples: customers, vendors, subcontractors). Your Policy can be posted in your front lobby and on your website.

Your OHSAS 18001 Policy is a simple recipe; but it greatly affects your OHSAS 18001 management system. Objectives align with your Policy. Resource commitment (dollars, manpower) aligns with your Policy. Risk Assessment aligns with your Policy … acceptable risk versus unacceptable risk.

As Cajun cooking starts with a roux, your OHSAS 18001 management system starts with your Policy. Choose each ingredient of your Policy carefully … it will affect the flavor – and success – of your management system!

Are you ready to develop and implement your OHSAS 18001 management system?
Start with a well prepared Policy!

Discuss preparing your OHSAS 18001 Policy with Banks Clark today!
Email: BClark@ESHpartnering.com; or, call: 864-517-2299.

This article provides an overview of Policy, Legal, and Risk. Later articles will expand upon these cornerstone elements as well as discuss other elements that comprise a fully developed OHSAS 18001 management system. Throughout these discussions, reference is provided to specific clauses of the OSHA 18001 Standard.

Policy. Top Management must define a policy that is appropriate to the nature and scale of your business. The policy expresses your commitment to injury prevention, continual improvement, and obeying the law. A basis is provided for ensuring continual improvement. [OHSAS 18001 Standard Clause 4.2 – Policy]

The Policy is specific to your business and reflects your core health and safety values. It is incorporated directly or indirectly into all aspects of your OHSAS 18001 management system.

Legal. Applicable legal and other requirements must be identified. A prominent legal requirement is OSHA compliance. A typical other requirement is a process imposed by your corporation (example: worker pre-employment testing) or a client (example: worker documentation.). [OHSAS 18001 Standard Clause 4.3.2 – Legal & Other Requirements]

Having identified applicable legal and other requirements, a corollary element is to evaluate compliance. This is usually addressed with periodic compliance inspections and audits. [OHSAS 18001 Standard Clause 4.5.2 – Evaluation of Compliance]

Risk. Risk control is based upon a three-step process:

• Hazard Identification. Hazards must be identified throughout the workplace. This is usually accomplished with an initial wall-to-wall identification of the workplace hazards followed with ongoing re-consideration of existing and new hazards.

• Risk Assessment. Risk associated with identified hazards must be objectively evaluated and prioritized. Typically, risk is assigned numerical values that incorporate severity, frequency, and duration.

  OHSAS 18001 recognizes that your workplace does not represent zero risk. Your risk assessment process should distinguish between acceptable risk and unacceptable risk for your organization. Acceptable risk is not necessarily controlled. Unacceptable risk must be controlled.

  OHSAS 18001 emphasizes the importance of hazard identification and risk assessment as an ongoing process. This includes consideration of process and organizational changes (aka: management of change).

• Control. Control must be determined for unacceptable risk. Control usually follows the familiar hierarchy: elimination, substitution, engineering, administrative, and PPE.

  Having determined risk control, a corollary element is to establish and maintain control. This includes implementing engineering changes and establishing necessary procedures to control and mitigate risk. [OHSAS 18001 Standard Clause 4.4.6 – Operational Control]

Why are Policy, Legal, and Risk cornerstones for building your OHSAS 18001 management system? Because these critical elements affect – if not determine – nearly every other element of your management system. Failing to develop these three elements upfront is akin to planning a trip without establishing your destination!

Are you ready to develop your OHSAS 18001 management system?
Do you wish guidance in establishing a successful strategy?

Discuss your OHSAS 18001 strategy with Banks Clark today!
Email: BClark@ESHpartnering.com; or, call: 864-517-2299.

Question: In an egg and bacon breakfast, what’s the difference between the chicken and the pig?

Answer: The chicken is involved, but the pig is committed!

OHSAS 18001 is an occupational health and safety management system. The OHSAS 18001 management system is patterned after ISO 14001 environmental and ISO 9001 quality management systems. Like ISO 14001 and ISO 9001, a top-to-bottom commitment is essential. The organization is affected from top to bottom. System elements are part of the organization’s culture.

This means that Top Management must be like the pig, not the chicken … committed, not merely involved!

What is the difference between Top Management involvement versus commitment?

Involvement is Top Management’s delegating the responsibility for OHSAS 18001 success without supporting authority and resources (dollars, manpower). An example is a directive to the OH&S Manager to just-do-it without committing participation of the entire organization. The outcome is regarded as a discretionary cost of doing business.

Commitment is Top Management’s participating in OHSAS 18001 success with supporting authority and resources. An example is assigning the OH&S Manager as champion for developing, implementing, and maintaining an OHSAS 18001 management system that shares priority along with profitability. The outcome is regarded as part of the way of doing business.

If you are considering OHSAS 18001 Certification, remember the pig … be prepared to commit your entire organization including yourself!

OHSAS 18001 Certification has many rewards including reduced injuries, improved profits, and customer esteem. A key to success is embracing commitment from the get-go. Do not believe that casual involvement will succeed.

Do you wish OHSAS 18001 Certification?
Are you committed?

Discuss your OHSAS 18001 Certification strategy with Banks Clark today!
Email: BClark@ESHpartnering.com; or, call: 864-517-2299.

Injuries affect the Bottom Line … both directly and indirectly. However, Injury Rate simply measures how many workers are injured after-the-fact … it’s a lagging indicator. Used alone, Injury Rate is like counting horses escaping through an open barn door … reactively shutting the door won’t change what’s already happened.

Injuries are usually caused by hazardous workplace conditions. A Safety Program’s before-the-fact control of these conditions is a leading indicator … and is critical in reducing Injury Rate.

The relationship between hazardous conditions and worker injury is illustrated below:


Counting the injury (Injury Rate) is after-the-fact … a lagging indicator.
Before-the-fact control of hazardous conditions and response to incidents can reduce injuries … leading indicator. Reflecting upon the above illustration, Injury Rate might be reduced by limiting driving speed and diligent incident investigation … especially near-miss investigations.

Leading indicators might generally include:
• Workplace inspections … Safety Program conformity
• Near-miss investigation … corrective and preventive actions
• Accident investigation … corrective and preventive actions
• Employee Training … implementation, effectiveness
• Employee involvement … safety meetings, safety teams

Injury Rate is rightfully a primary indicator for Safety Performance … after all reducing worker injury is our Mission. However, reducing Injury Rate relies upon controlling factors that cause injuries… leading indicators.

Safety Performance is best measured by both lagging (after-the-fact) and leading (before-the-fact) indicators!

OSHA recently published the Top 10 most frequently cited violations in 2010¹. OSHA sends a clear message of strong enforcement.

How many of the Top 10 apply to your business² …

1. Scaffolding [1926.451]. This standard covers general safety requirements for scaffolding at and above 10 feet. Total violations = 9,056.
2. Fall Protection [1926.501]. This standard prescribes fall protection systems and proper supervision for work above 6 feet. Total Violations = 8,224.
3. Hazard Communication [1910.1200]. This standard requires identification and communication of chemical hazards and worker protection. Total violations = 7,179.
4. Respiratory Protection [1910.134]. This standard prescribes proper selection, fitting, use, and care of respirators. Total violations = 4,224.
5. Ladders [1926.1053]. This standard prescribes the maintenance and use of ladders. Total violations = 4,132.
6. Lockout/Tagout [1910.147]. This standard provides requirements for the control of hazardous energy associated with machines and equipment. Total violations = 3,756.
7. Electrical – Wiring Methods [1910.305]. This standard addresses proper electrical grounding, wiring, and insulation. Total violations = 3,628.
8. Powered Industrial Trucks [1910.178]. This standard addresses maintenance and operation of forklifts and motorized hand trucks. Total violations = 3,453.
9. Electrical – General Requirements [1910.303]. This standard addresses general design of electrical systems. Total Violations = 2,977.
10. Machine Guarding – General Requirements [1910.212]. This standard addresses guarding of moving machinery. Total violations = 2,712.

Does your business comply with OSHA regulations? This question can be answered with an OSHA Baseline Compliance Audit.

An OSHA Baseline Compliance Audit compares your workplace and work practices to OSHA regulations.

An OSHA Baseline Compliance Audit provides a roadmap to achieve and maintain compliance in a manner that fits your business. Action items are prioritized to allow budgeting.

An OSHA Baseline Compliance Audit may be your best investment in this uncertain business climate.

Contact us now for an OSHA Baseline Compliance Audit!

[BClark@ESHpartnering.com]
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¹ OSHA’s 2010 is from October 1, 2009, through September 30, 2010.

² Sections from two parts of OSHA 29 CFR standards are cited: Part 1926 – Construction … generally applies to work for construction, alteration, and/or repair, including painting and decorating; Part 1910 – General Industry … generally applies to work for businesses that are static in nature and do not include agriculture, construction, and maritime industries.

This article addresses why you should not operate your air handler fan in the On mode while your air conditioner is operating in the Cool mode. Let’s see why.

What is wrong with the fan setting in the thermostat illustrated below? The answer is that the fan is set in the On mode when the air conditioner is set in the Cool mode. You may say, “I don’t do this.” But, we see this operation frequently … and, it nearly always causes humidity control problems! Allow me to explain.

Relative humidity reflects the amount of moisture in the air. If air is saturated, such as during a rainstorm, relative humidity is 100%. In the South, outdoor relative humidity usually ranges from 60% to 95%. Indoor relative humidity is usually ranges from 50% to 60%. If indoor relative humidity remains above 60% for long periods, mold growth usually results.

Our air conditioners are normally set in Cool mode with the fan in Auto mode. This means that the fan operates when the air conditioner is cooling and does not operate when the air conditioner is not cooling. Humidity remains between 50% and 60% because moisture condenses on the chilled coils, drains into a pan, and flows to the outdoors. It works sort of like the cold beer can in the photograph below … where moisture is condensing on the side of the chilled can and runs onto your table.

If the fan is in the On mode, the fan operates like the cold beer can description and moisture is removed from the house … when the air conditioner is operating. But when the air conditioner stops operating, the fan continues to operate. Now, the fan blows over the wet coil and pan (illustrated in the photograph below) … and water re-evaporates and is re-distributed through the house.

It’s the latter scenario – fan On plus air conditioner Cool – that is the problem. Instead of removing moisture through the pan drain, moisture is re-evaporated and re-distributed throughout the house every time the air conditioner shuts off.

We have discovered houses operating fans continuously in the On mode and air conditioners in Cool mode. Indoor relative humidity was usually in the 60% to 70% range … and mold was usually a problem! Supply registers exhibited visible mold growth. Visible mold was established on the duct interior. These conditions resulted from operating the fan in On mode while the air conditioner operated in the Cool mode.

So, what have we learned …

If you live in a hot-humid climate, Do not operate your fan in On mode when your air conditioner is operating in Cool mode!

Contact me with questions or as I may assist.

Until about ten years ago, mold damage resulting from insurance-covered water intrusion was covered along with the water damage. Homeowners were even compensated for living off-site during restoration.

Nowadays, many homeowner insurance policies exclude coverage for mold damage (Mold Exclusion) or place a coverage limit (Mold Cap). Some insurance companies offer extended mold coverage for an additional fee.

What does Mold Exclusion or a Mold Cap mean to you? Let’s look at a claim process related to mold damage …

1. Claim. An insurance claim is initiated based upon a sudden water intrusion event. Mold damage has also resulted from the claim event.

   If your policy covers mold damage, the process related to mold continues. If your policy includes a Mold Exclusion, any aspect of your claim related to mold is probably denied.

1. Cause and Origin. Sometimes insurance companies initiate a cause and origin investigation (C&O) to determine the nature and extent of the damage.

   If the C&O determines damage is not caused by a sudden event, your coverage will probably be denied. If the C&O determines that damage is caused by a sudden event, provisions of your policy will probably apply … to the limit of your mold coverage (Mold Cap).

1. Initial Mold Assessment. A mold assessor performs an initial mold assessment (IA) to delineate damage, test air quality, and design a mold remediation protocol. An IA can cost about $1,900 … which is deducted from your mold coverage.

1. Remediation. A mold remediator removes damaged materials and cleans exposed surfaces. Remedication can cost from a few $thousand to many $thousand … which is deducted from your mold coverage.

1. Clearance Testing. A mold assessor performs clearance testing (CT) to verify that damaged material is removed and surfaces are cleaned. Air testing is performed to verify that air quality is normal with respect to mold contamination. CT can cost about $1,700 … which is deducted from your mold coverage.

1. Build Back. Once mold damage is removed and verified with a CT, removed materials must be replaced. Depending upon the extent of damage and nature of mold damaged materials, build back can cost from a few $thousand to many $thousand … which is deducted from your mold coverage.

You can see that a Mold Cap – typically $10,000 – may not cover mold-related costs. The IA and CT alone can cost $3,000+. The remediation and mold-related build back can easily exceed several $thousand, even for a relatively small loss such as a bathroom vanity or kitchen sink cabinet.

If mold-related damage is more extensive – say a ceiling, a couple of walls, and flooring – a Mold Cap will probably not cover the restoration cost.

Ask your insurance agent: Does your homeowner’s policy cover mold damage? If so, to what extent? Does your insurance company offer extended mold coverage?