Professional Documents
Culture Documents
Safety Management
Safety Management
ANSI/AIHA
Z10-2005
The new benchmark for safety management systems
By Fred A. Manuele
programs success is employment possibilities for its tive employee participation are crucial for the success
graduates, professors responsible for those programs of an occupational health and safety management
will likely ensure that core courses properly equip system (OHSMS) (AIHA). The standard says:
students to meet employer needs. In many cases, that Top management shall direct the organization to
will require substantive curricula modifications. establish, implement and maintain an OHSMS.
Content of the examinations for the CSP designa-
tion is reviewed about every five years to ensure that The organizations top management shall establish
the exams are current with respect to the work SH&E a documented occupational health and safety policy.
professionals actually perform. As the substance of Top management shall provide leadership and
SH&E practice changes in light of the impact of Z10, assume overall responsibility.
what those professionals who participate in the
examination review process say about the content of The organization shall establish and implement
their work at that time will influence the content of processes to ensure effective participation in the
the CSP examinations. OHSMS by its employees at all levels (AIHA).
Annexes A, B and C provide supporting data on
The Continuous Improvement Process these areas.
In accord with the Plan-Do-Check-Act concept,
the major sections of the standard are: 4.0: Planning
3.0: Management Leadership and Employee This section sets forth the planning process to
Participation; implement the standard and to establish plans for
4.0: Planning; improvement. The planning process goal is to iden-
5.0: Implementation and Operation; tify and prioritize OHSMS issues (defined as haz-
6.0: Evaluation and Corrective Action; ards, risks, management system deficiencies and
7.0: Management Review. opportunities for improvement) (AIHA).
Brief comments on 3.0 and
7.0 follow; more extensive re-
marks are made on select sec-
tions in 4.0, 5.0 and 6.0. When Hazard Analysis &
reviewing these excerpts, keep
in mind the intent of the terms Risk Assessment Guide
shall and should. As is 1) Select a manageable task, system or process to be analyzed.
common in ANSI standards, 2) Identify the hazards. Ask the question, What characteristics
requirements in the left column of things or actions [or inactions] of people present a potential
are identified by the word for harm?
shall. An organization that 3) Define possible failure modes that result in exposure to hazards
chooses to conform to the stan- and the realization of the potential harm. Ask, How could an unde-
dard is expected to fulfill these sirable event happen for a task and each associated hazard?
requirements. The text in the 4) Estimate the frequency and duration of exposure to the hazard.
right-hand column uses the 5) Assess the severity of injury/illness. Based on experience and
word should to describe rec- knowledge, make an estimate of the worst credible injury or illness
ommended practices or to ex- consequence(s), should an incident occur.
plain the requirements on the 6) Determine the likelihood of the occurrence of a hazardous
left. Comments in the right- event. This is usually subjective. For complex hazard exposure sce-
hand column are not require- narios, brainstorming with knowledgeable people is advantageous.
ments and are prefaced with an The likelihood of occurrence is normally related to an interval of time
E. The reader should note (several times a day, weekly, monthly, yearly, etc.).
that the material printed in ital- 7) Define the level of risk using a risk assessment matrix, risk rank-
ics is taken verbatim from the ing or scoring system. [An example of a risk assessment matrix can be
standard. found in Figure 1 of this article.] The level of risk is determined by
plotting the likelihood of an occurrence or exposure and the potential
3.0: Management Leadership severity of the injury or illness. The organization must then determine
& Employee Participation if the level of risk is acceptable or unacceptable.
Literature commenting on 8) Hazard risks can then be listed and ranked. Risks, system defi-
safety management, leadership ciencies and opportunities for system improvement make up the
and employee participation is OHSMS issues for a particular organization. All OHSMS issues are
abundant. Thus, this section of then prioritized by considering the level of risk, potential for system
the standard is dealt with improvements, compliance with standards and regulations, feasibility
briefly here. However, the read- and business consequences.
er should understand that this 9) The organization selects prioritized OHSMS issues and devel-
is the standards most impor- ops documented objectives and implementation plans.
tant section. SH&E practitioners
will surely agree that top man- Source: ANSI/AIHA Z10-2005. Reproduced with permission.
agement leadership and effec-
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Manuele Feature Feb 2006.qxd 1/13/2006 3:10 PM Page 29
Z10 will have contains a brief outline titled Hazard Analysis guards and ventilation systems should be consid-
and Risk Assessment Guide which presents an ered. This process continues down the hierarchy
a significant easily understood and applied thought-and-action until the highest level feasible control is found.
process on how to conduct a hazard analysis and a Often a combination of controls is most effec-
and favorable risk assessment. The sidebar on pg. 28 presents tive. In cases where the higher order controls
this outline. (elimination, substitution and implementation of
impact on the Annex E also gives an example of a risk assess- engineering controls) do not reduce risk to an
ment matrix for illustrative purposes (Figure 1). acceptable level, lower order controls may be nec-
content of the This matrix gives incident probability categories, essary (e.g., warnings, administrative controls or
severity categories and risk levels, which is typical, personal protective equipment).
practice of but it also incorporates recommended manage- For example, if an equipment modification or
ment action levels within the matrix. Such a matrix noise enclosure (engineering control) is insuffi-
safety can serve as a valuable instrument in working with cient to reduce noise levels, then limiting exposure
decision makers to set risk levels and prioritize cor- through job rotation and using hearing protection
and on the rective actions. Published risk assessment matrixes would be an acceptable supplemental means of
vary widely, so SH&E practitioners should develop control (AIHA).
knowledge models that are suitable to the organizations they Note that Z10 prescribes a hierarchy of controls
serve. [See also Manuele(a) and (c).] which contains six elements, the first of which, in
and skill 5.0: Implementation & Operation priority order, is to design out or otherwise eliminate
According to the standard, This section defines the hazard. If the hazard is eliminated, the risk is
needs of the operational elements that are required for eliminated. Also note that the substitution element is
implementation of an effective OHSMS (AIHA). separate from the elimination element.
SH&E The comments here focus on only four provisions The number of elements and the separation of sub-
hierarchy of controls, design review, management stitution from elimination are important. Other
practitioners. of change and procurement. Only a few safety man- published hierarchies of control are not quite as
agement systems have comparable provisions. descriptive and complete. Some have as few as three
elements. Over time, the hierarchy of controls set
5.1.1: Hierarchy of Controls forth in Z10 will become the accepted norm. Annex G
Z10 outlines provisions for the use of a specifical- provides a pictorial and verbal display of the hierar-
ly defined hierarchy of controls. The organization chy of controls listed in 5.1.1 with application exam-
shall apply the methods of risk reduction in the ples for each element.
order prescribed. The standard and the explanatory In an occupational setting, these outcomes are to
comments state: be achieved through the application of the hierarchy
The organization shall implement and maintain a of controls:
process for achieving feasible risk reduction based 1) an acceptable risk level;
upon the following preferred order of controls: 2) work methods and processes in which the
A) Elimination; probability of a) errors by supervisors and workers
B) Substitution of less hazardous materials, because of design inadequacy is at a practical mini-
processes, operations or equipment; mum; and b) supervisors and workers defeating the
C) Engineering controls; system is at a practical minimum.
D) Warnings; Similar outcomes should be expected when
E) Administrative control; and applying the hierarchy of controls to other hazards
F) Personal protective equipment. and risks, such as for the design and use of industri-
al and consumer products, and environmental man-
Feasible application of this hierarchy of controls agement systems. [See also Manuele(c).]
shall take into account:
a) the nature and extent of the risks being 5.1.2: Design Review & Management of Change
controlled; The following excerpts indicate what the stan-
b) the degree of risk reduction desired; dard requires for design reviews and management
c) the requirements of applicable local, federal of change, and replicate the explanatory information
and state statutes, standards and regulations; given in its right-hand column. Again, these are
d) recognized best practices in industry; shall provisions.
e) available technology;
f) cost-effectiveness; and The organization shall establish and implement
g) internal organization standards. processes to identify, and take appropriate steps to
prevent or otherwise control hazards and reduce
E5.1.1: The hierarchy provides a systematic way to potential risks associated with:
determine the most effective feasible method to A) New processes or operations at the design
reduce the risk associated with a hazard. When stage; and
controlling a hazard, the organization should first B) Changes to its existing operations, products,
consider methods to eliminate the hazard or substi- services or suppliers.
tute a less hazardous method or process. If this is The process for design reviews and management of
not feasible, engineering controls such as machine change shall include:
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Manuele Feature Feb 2006.qxd 1/13/2006 3:10 PM Page 31
a) identification of tasks and related health and tion and maintenance. He notes: Implementing an Employers
safety hazards; effective safety through design process often
b) consideration of hazards associated with requires challenging the culture within an engi- who have
human factors; neering organization (Adams) If a design safety
c) consideration of control measures (hierarchy of review management system is not in place in an a sincere
controls5.1.1); organization, SH&E practitioners should anticipate
d) review of applicable regulations, codes and a long-term effort to achieve the culture change interest in
standards; and necessary to meet the requirements of Z10. This
e) a determination of the appropriate scope and often means establishing a management system employee
degree of the design review and management that mobilizes engineering, purchasing, quality
of change. control and other departments which may not be safety will
accustomed to working collaboratively. (To assist
E5.1.2: The process for conducting design reviews in that accomplishment, Safety Through Design
and managing changes is designed to prevent includes a chapter titled Achieving the Necessary
welcome
injuries and illnesses before new hazards and risks Culture Change by Steven I. Simon.)
are introduced into the work environment. The discussions
design review should consider all aspects includ- Management of Change
ing design, construction, operation, maintenance Employers are to have processes in place to
on how
and decommissioning. identify and take the appropriate steps to prevent
The following are examples of conditions that or otherwise control hazards and reduce the poten-
their safety
should trigger a design review or management of tial risks associated with them when changes are
change process: made to existing operations, products, services or
management
new or modified technology (including soft- suppliers.
ware), equipment or facilities; With respect to drafting and implementing
systems can
new or revised procedures, work practices, management of change procedures, generalists can
design specifications or standards; learn from those in organizations that have met the
be improved.
different types and grades of raw materials; management of change requirements of OSHAs
significant changes to the sites organizational Process Safety Management of Highly Hazardous
structure and staffing, including use of con- Chemicals standard (1910.119), issued in 1992.
tractors; Briefly, 1910.119 requires that employers establish
modification of health and safety devices; and and implement written procedures to manage
new health and safety standards or regulations changes. Requirements of Z10 and 1910.119 have
(AIHA). similar purposes. Getting effective management of
change procedures in place and maintained is not
Design Review
easily done, however.
The author has long professed that the most effec- For all occupations, many incidents that result in
tive and economical way to minimize risks is to severe injury occur when out-of-the-ordinary situa-
address the hazards from which they derive during tions arise, particularly when unusual and nonrou-
the design process. That is what this standard tine work is being performed and when sources of
requiresand it is an extremely important element high energy are present. In support of that premise,
in this standard. Its impact can be immense. consider these excerpts from historical and explana-
To become qualified to give counsel on establish- tory data published with respect to 1910.119.
ing a management system to apply the design
review requirements of this standard, many SH&E Management of Change: OSHA believes that
practitioners will have to acquire new knowledge one of the most important and necessary
and skill. A chapter in Innovations in Safety Manage- aspects of a process safety management pro-
ment titled How to Avoid Bringing Hazards into the gram is appropriately managing changes to the
Workplace covers this topic [Manuele(a)]. It in- process. This is because many of the incidents
cludes a general industry guide to safe design and that the agency has reviewed resulted from
operational requirements; general design safety some type of change to the process. While the
checklist; and a section on design safety reviews. agency received some excellent suggestions
Another key reference in this area is Safety Through concerning minor changes to improve this pro-
Design, which contains these three major sections: posed provision, there was widespread support
Introducing Safety Through Design; Integrating for including a provision concerning the man-
[Safety Through Design] into Business Processes; and agement of change in the final rule (OSHA).
Safety Through Design in Industry. The latter section As noted, support for the management of change
contains six chapters pertaining to application of provisions was strong. However, about two years
safety through design concepts in general industry, after 1910.119 became effective, Thomas Seymour, a
the automotive industry, aircraft manufacturing, the director at OSHA as the standard was being devel-
chemical industry, construction and in the electronics oped, said that chemical plant operators had reported
industry (Christensen and Manuele). that the management of change requirement in the
In the chapter on application in general industry, standard was the most difficult to apply. Therefore, it
Adams discusses challenges to process implementa- is not surprising that courses have been developed to
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Manuele Feature Feb 2006.qxd 1/13/2006 3:10 PM Page 32
control risks. This is what the standard and the become the benchmark against which safety and
explanatory data state. health management systems will be measured. As
6.3 Audits the quality of safety and health management sys-
tems improves, it is logical to expect that the fre-
The organization shall establish and implement quency and severity of occupational injuries and
processes to: illnesses will be reduced.
A) Conduct periodic audits to determine whether SH&E practitioners must not ignore the long-
the organization has appropriately applied and range impact Z10 will have on societal expectations
effectively implemented the OHSMS ele- concerning the quality of safety management sys-
ments, including identifying hazards and tems that employers have in place, and on the expec-
controlling risks; tations employers will have concerning the
B) Document and communicate audit results to: knowledge and capabilities of SH&E personnel.
a) Those responsible for corrective and pre- Prudent SH&E practitioners will study the require-
ventive action; ments of the standard to determine whether they
b) Area supervision; and need additional skills and capabilities, then will take
c) Other affected individuals, including action to acquire those skills. Having done so, they
employees and employee representatives. will be equipped to help managements put in place
C) Immediately communicate situations identi- safety management system elements that may not
fied in audits that could be expected to cause currently exist.
a fatality, serious injury, or illness in the The author also suggests that the leaders at pro-
immediate future, so that prompt corrective fessional organizations such as ASSE consider devel-
action under 6.4 is taken. oping seminars to instruct SH&E practitioners about
E6.3 Audits required by this section are system the content and application of ANSI/AIHA Z10-
oriented rather than compliance oriented. The 2005, particularly with respect to the requirements
audit should determine if the OHSMS meets the for risk assessments, the application of a hierarchy of
requirements of this standard. Audits should be controls, design reviews, management of change,
conducted by individuals independent of the activ- procurement and audits.
ities being examined. This does not mean that References
audits must be conducted by individuals external Adams, P.S. Application in General Industry. Chapter 13.
to the organization (AIHA). Safety Through Design, W.C. Christensen and F.A. Manuele, eds.
Itasca, IL: National Safety Council, 1999. 155-169.
Although many SH&E practitioners are familiar American Industrial Hygiene Assn. (AIHA). Occupational
with safety audit processes, they should review Health and Safety Management Systems. ANSI/AIHA Z10-2005.
what the standard requires and determine whether Fairfax, VA: AIHA, 2005.
it will be to their benefit to revise their audit systems. Barnett, R.L. Minimum Safety Standard: An Oxymoron.
Safety Bulletin. Vol. 5, No. 3. Niles, IL: Triodyne Inc.
Annex I is helpful in this respect; it contains an Casada, M.L., et al. A Managers Guide to Implementing and
example of an audit outline that matches the Plan- Improving Management of Change Systems. Washington, DC:
Do-Check-Act sections of Z10. Chemical Manufacturers Assn., 1993.
Christensen, W.C. and F.A. Manuele, eds. Safety Through
Design. Itasca, IL: National Safety Council, 1999.
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This section requires that OHSMS performance MI: DaimlerChrysler Corp. <https://gsp.extra.daimlerchrysler
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actions in response. It is an important part of the DaimlerChrysler. Tool and Equipment Follow-Up,
Certification and Buy-Off Procedures, Auburn Hills, MI:
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Occupational Health and Safety Management Systems. ILO-OSH
OHSMS at least annually, and to recommend 2001. Geneva, Switzerland: ILO, 2001. <http://www.ilo.org/pub
improvements to ensure its continued suitability, lic/english/support/publ/xtextoh.htm>.
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Geneva, Switzerland: ISO. <http://www.iso.org>.
E.7.1: Management reviews are a critical part of the Manuele, F.A.(a). Innovations in Safety Management: Addressing
continual improvement of the OHSMS (AIHA). Career Knowledge Needs. New York: John Wiley & Sons, 2001.
Manuele, F.A.(b). On the Practice of Safety. 3rd ed. New York:
These are a few of the subjects to be reviewed at John Wiley & Sons, 2003.
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of processes to identify, assess and prioritize risk and Control. Professional Safety. May 2005: 33-39.
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Manuele, eds. Itasca, IL: National Safety Council, 1999. 37-48.
ANSI/AIHA Z10-2005 represents an important Stephans, R.A. and W.W. Talso. System Safety Analysis Hand-
step in the evolution of the practice of safety. book. 2nd ed. Albuquerque, NM: System Safety Society, New Mex-
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www.asse.org FEBRUARY 2006 PROFESSIONAL SAFETY 33