Insights Into Results-oriented Human Resources Solutions

Canada

October 2004

Aon Consulting

Canada

Occupational Health and Safety Management Systems: Defined Management Solutions to Manage Risk and Demonstrate Due Diligence
Business governance must include an occupational health and safety strategy to ensure compliance with regulatory responsibilities or face the new legal consequences.

Whats Inside
Occupational Health and Safety Management Systems: Defined Management Solutions to Manage Risk and Demonstrate Due Diligence International Standards A Canadian Standard

Bill C-45, An Act to amend the Criminal Code (criminal liability of organizations), received Royal Assent in November 2003, and came into force as of March 31, 2004. This federal legislation holds organizations and individuals criminally liable when they fail to take reasonable steps to prevent workplace accidents affecting workers and the public. It applies not only to corporations, but also to every one who undertakes, or has the authority, to direct how another person does work or performs a task. A legal duty is imposed not only on directors, officers, managers and supervisors, but also on lead hands and coworkers. The term organization has a far-reaching application as it includes trade unions. Occupational Health and Safety (OH&S) has progressively gained greater importance, with employers of choice performing due diligence to ensure the safety of their workforce and the public in general. The implementation of Bill C-45 has increased the profile of OH&S through unprecedented criminal and financial penalties. Provincial regulators have availed themselves of this opportunity to increase their profile in the workplace. The Ministry of Labour in Ontario has announced the doubling of the number of worksite inspectors to allow for the aggressive review of 6,000 employers with poor safety records. A similar approach has been adopted in Alberta where companies with questionable safety histories will be targeted for review by newly hired auditors.
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Proactive Approach

International Standards While Bill C-45 has raised the profile of OH&S in Canada, international efforts have been underway to establish a standardized model. The International Organization for Standardization (ISO) has had success in establishing such standards with its ISO 9000 (quality control) and ISO 14000 (environmental management) series. Unfortunately, its attempt to introduce a health and safety series did not achieve the requisite 2/3 approval in a vote held in 2000. While it is anticipated that there will be further attempts by ISO, there are two specifications currently used at the international level.
Occupational Health and Safety Assessment Series 18001 (OHSAS 18001)
Management Review Checking & Corrective Action

Continued Improvement

OH&S
Implementation & Operation

OH&S Policy

Planning

Figure 1. The Elements of the OHSAS 18001 Management System

International Labour Organization Occupational Safety and Health 2001 System (ILO-OSH 2001)

The International Labour Organization, a United Nations Agency, has developed and published, under the ILO-OSH 2001 system, guidelines for implementing an OH&S management system. These management guidelines were designed to help organizations and competent institutions develop and implement a practical vision for OH&S performance and continual improvement. Formulated as recommendations, these principles do not require any standardized certification.
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In 1999, the British Standards Institution developed and published the OHSAS 18001. This series incorporates certifiable specifications and is being adopted throughout the European Union. This fervour, fuelled by the needs of a global economy, has now spread to North America and, more specifically, to Canada. Indeed, many Canadian organizations have already undertaken or will soon undertake integration of the OHSAS 18001 specification as a standard for the implementation of their OH&S management systems.
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Organizing

Action for Improvement

AUDIT
Planning & Implementation Evaluation

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Figure 2. The Main Elements of the ILO-OSH 2001 Management System

OHSAS 18001 and ILO-OSH 2001 A Comparison

It is important to note that the OHSAS 18001 and ILO-OSH 2001 systems were inspired by the Deming Wheel principle that, like quality management, applies the notion of continual improvement to OH&S. The two systems are based on the OH&S vision of performance. In both cases, managements commitment and leadership, coupled with strict OH&S management, are prominent features.

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1. Plan:

1. 4.
Corrective or Preventive

2. 3.

Progress/ Improvement

Predict, Specify, Define Execute Under Control

2. Do:

3. Check: Assess 4. Act: Correct to Improve

OH&S policies, requirements and national standards. In this respect, organizations that adopt one of the two systems may wish to consider assistance and support through national and standard OH&S management system policies. Another strength of the ILO-OSH 2001 framework lies in its recognition of and emphasis on the importance of the participation of workers and their organizations OH&S representatives. This vision of the dynamics of an OH&S management system is more in keeping with the OH&S culture that Canadian companies have been endorsing for many years. ILO-OSH 2001 principles are in line with those contained in most OH&S legislation. ILO-OSH 2001 is also more explicit than OHSAS 18001, requiring less interpretation. A Canadian Standard Over the past year, through its Technical Committee, the Canadian Standards Association (CSA) has developed a Canadian OH&S management system standard. The final version is expected to be available sometime in 2005. In its draft form, the CSA Z1000 does not reference any other standard. Nevertheless, a review of the draft document draws the reader to conclude that it is a hybrid of the two international standards discussed above.

Figure 3. Deming Wheel

The two systems are quite comparable when it comes to orientation, objectives and processes. Each reflects the need for sound OH&S management. An examination of the content of each framework shows no significant difference. The main difference lies in the fact that OHSAS 18001 imposes requirements (i.e., an organization must), while the ILO-OSH 2001 suggests principles (i.e., the employer should). The requirements or principles are neither constraining nor aimed at replacing accepted standards or applicable legislation and regulations.
OHSAS 18001

OHSAS 18001 appears more credible given the fact that it features obligatory requirements that are certifiable by an outside organization. This characteristic undeniably provides to the organization and all interested parties (i.e., managers and workers) assurance of performance and continual improvement. The participation of workers in the OH&S management system is not as clearly set out in OHSAS 18001 as it is in ILO-OSH 2001. An organization can nevertheless overcome this shortcoming by voluntarily including requirements that make worker participation an essential component of its OH&S management systems. The compatibility of the OHSAS 18001 framework with ISO 9000 and ISO 14000 standards facilitates the integration of OH&S into the management processes for organizations which have already committed to such management systems. This is an important advantage for ISO-certified organizations that are seeking an integrated management system for their Quality-Environment-OH&S components. The ILO-OSH 2001 may be applied at two levels: at the national level and at the organizational level. Chapter 2 of the ILO-OSH 2001 deals with the establishment of a national framework for OH&S management systems and presents a component not covered by OHSAS. This component deals more with competent institutions which are responsible for establishing, for a given territory, the
ILO-OSH 2001 Aon Consulting Forum October 2004

The draft standard is similar to the OHSAS 18001 in that there are imposed requirements by virtue of the term shall, but it also adopts the worker involvement principle of ILOOSH 2001. The CSA Z1000 is intended as a self-administered or externally verified standard for establishing and assessing OH&S management. However, it does not have a certification requirement. In keeping with the goal of developing a distinct Canadian standard, the draft document refers to actions appropriate to the size and nature of the organization. Whether this qualifier will be expanded, and how it will be interpreted and applied, remains to be seen.
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Since industry and regulatory bodies reference CSA guidelines, it is anticipated that the CSA Z1000 will be considered a best practice. Consequently, senior managers should give serious consideration to administering this management system upon its release. Proactive Approach The two established international systems contain processes and components that call for the leadership and commitment of management in OH&S matters. They are aimed at enhancing OH&S performance and continual improvement. In the regulatory climate faced by organizations, directors and officers, a recognized OH&S management

system is strongly recommended in order to demonstrate due diligence and manage legal risk. A Canadian standard is being developed which attempts to incorporate the strengths of both international systems. Regardless of the system adopted, it is in the best interests of an organization to adopt a managed OH&S system to deal with its legal risk and maintain economic competitiveness. It would be to an organizations advantage to voluntarily adopt requirements that call upon a real commitment from all interested parties with a view to obtaining better performance through the continual improvement of its OH&S management systems.

About Forum
This issue of Forum was published by Aon Consulting, a member of Aon Consulting Worldwide. For information about Forum: National Research Department, Aon Consulting Inc. 145 Wellington Street West Suite 500 Toronto, Ontario M5J 1H8 E-mail: national.research@aon.ca Service national de recherche, Groupe-conseil Aon inc. 1801 McGill College Avenue Suite 1100 Montreal, Quebec H3A 3P4 E-mail: recherche.nationale@aon.ca For information about Aon Consulting: 1 877 292-2714 or http://www.aon.ca

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