Environmental

EVALUATION. AND CORRECTIVE ACTION: SECTION 6.0 OF 210

In applying the Plan-Do-Check-Act concept for an occupational health and safety management system, the last two steps are to evaluate performance (6.0A) and take corrective action when nonconformance is found (6.0B). The following is a depiction of the applied POCA concept and how it relates to the processes required in Section 6.0, "Evaluation and Corrective Action."

Plan: Identify the problem(s) (hazards, risks, management system deficiencies, and opportunities for improvement, as in the planning section, 4.0).

Plan: Analyze the problem(s). Plan: Develop solutions. Do: Implement solutions. Check: Evaluate the results to determine that:

1. The problems were resolved, only partially resolved, or not resolved. 2. The actions taken did or did not create new hazards. 3. Acceptable risk levels were or were not achieved. Accept the results, or tak~ additional corrective action, as needed.

<) . • • ' , I

Act:

ev 1 1t s~ys in Section 6.0C that processes are to be in place to "include results of a uation act· · · · (6 5) " 1v1ties as part of the planqing process apd management review. . .

~ --.. · . Seconct Editio ty :anagement: Focusing on ZJO and Serious lnJury Prevention, © 2014 John ;.

1 red A. Manuele. .

1 ey & Sons, Inc. Published 2014 by John Wiley & Sons, Inc.

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438 EVALUATION AND CORREC TIVE ACTION: SECTION 6.0 OF 210

dback processes in place to communicate . tions have iee h . The intent is that orgamza learned about system s ortcollllngs, so that ding lesson~ back to manage~ent regar . l d d ·n the planning process. • · · an be me u e 1 appropriate acuv1ues c

NG MEASUREMENT, AND ASSESSMENT SECTION 6.1: MONITORI '

nt and assessment include workplace inspec. thod fi itoring measureme ' . . ~• s or mon ' incident tracking, employee mput, occupat1ona) health uons, exposure assessme;ts, ro ance relative to applicable legal and other require- assessment, assessment

O pe orm . ti' and other methods as required by the

ments as determined by the organiza on, · · . . • al h alth and safety management system. Fmdings denvmg employer's occupation e . ted arti s

from those processes are to be communicated to _mteres . p . e . . Li · b dant on workp· lace inspections. That subJect 1s not addressed terature 1s a un . .

here further. Measurements of effectiveness 'with respect to. exposure a_s~essments and occupational health assessments are to determine ho~ well the requrrements in the assessment and prioritization processes set forth Section 4.2 h~ve been ~l~lled. They require that organizations have processes in place to assess nsks perta.irung to health and safety exposures.

Although establishing p(?rformani;:e measures , is not one of the subjects listed in the "shall" provi~ions in Section 6.0, the advisory comments say in E~.lC that "organizations should devel(?p ~easures of performan~.e that enable them to see how they are doing in preventing injuries and illnes.s,e~.''.

To have statistical validity, the performance mea,sures adopted should consider the extent of the exposures (perhaps hours worked) as well as evaluations of the effec. tiveness of safety and health management systems. Although the advisory information in E6.1 C refers to occupational injury and illness rates as performance measures, a precaution is given indicating that such rates shQuld not be the sole or primary measurement tool. A dissertation that speaks of performance measures suitable for organizations of various sizes may be found in the chapter "Measurement of Safety Performance" in On the Practice of Safety, 4th edition.

The effectiveness of the processes outlined in Section 3.0, "Management Leadership and Empl~yee Participation:• would be the basis of performance measurements on empl~y~ mput. The p~isions !• Section 3 .2, "l;mployee Participation," state: 'The ~8amzation shall establish and implement Processes to ensure effective participation :::: 07"upation~ h~°'. and ~afety management system by its employees at all

the orgamzat10n, mcludmg those working closest to the hazard(s)."

SECTION 6.2: INCIDENT lt.lVESTIGATION

Since I now give 8reater emphasis t h . . . the spectrum of safety and h alth

O t e importance of incident investigation within

subject appears here-.chapt e 22 ;a~age1?ent systems, a separate chapter on the er · ncident tnvestigations, well made, can be a good

SECTION 6.5: FEEDBACK TO THE PLANNING PROCESS 439

to identify cultural, operational, and technical .b . sourc! r incidents that result in serious injury or dam contn uting factors, particu- JarlY 10 . age.

s1:cr10N 6.3: AUDITS

11 vt"ng audits made of safety and health management ~ystem.s t d ' . . ria d ·ct ·t . . . o etermme their

~ectiveness an to 1 entI y opportumt1es for improvement 1· s the b. f S . eu• £ di . . su ~ect o ectmn 6.3, The goal of a sa ety au . t is to provide management with an assessment of the --nlity of the safety culture m place and to provide recommendation h, th IW1-' • ed Thi · s on ow e culture can be improv . s important measurement process is also the subject of a separate chapter, Chapter 23.

SECTION 6.4: CORRECTIVE AND PREVENTIVE ACTION

Although the requirements for corrective and preventive action are set forth briefly, the importance of this section should not be minimized. To fulfill its requirements, organizations are to have processes in place so that corrective actions are taken expeditiously: on the deficiencies in occupational safety and health management systems, inadequately controlled hazards, and newly identified hazards that are discovered in the monitoring process.

This section also requires that processes be in place to "review and ensure the effectiveness of corrective and preventive actions taken." Item E6.4, an advisory, says that an effective occupational health and safety management system would "identify system deficiencies and control hazards in any part of the system to an acceptable level of risk." Item E6.4B offers a precaution-zero risk is not attainable and should not be sought. It says that "risk cannot typically be elimi- nated entirely, although it can be substantially reduced through application of the hierarchy of controls. Residual risk is the remaining risk after controls have been implemented."

SECTION 6.5: FEEDBACK TO THE PLANNING PROCESS

The Purpose of this section is to assure that hazards, risks, and safety and he~~ rnanag th ru· toring measurement, au , • . ement system deficiencies observed in e mo ' . . . mmuni-1nc1dent . ti action act1v1t1es are co cated IDvestigation, and corrective and pr~ven ve. h oing planning and lllan to the appropriate parties and considered m t_ e ,;°:g objectives are to be rev· agement review process. As a result of that commun~ca to achieve a more ef£ 18~ and modifications are to be made in implementauon P

ective health and safety management syStem.

440 EVALUATION AND CORRECTIVE ACTION: SECTION 6.0 OF 210

CONCLUSION

When applying the Plan-Do-Check-Act continual improvement_process, an important element is to determine whether the management systems put m place achieve what is intended. That is the purpose of Section 6.0, to provide an ~valuation mechanism so that system deficiencies can be identified and acted upon. This is an important continual improvement function.

REFERENCE

Manuele, Fred A. On the Practice of Safety,' 4th ed. Hoboken, NJ: Wiley, 2013.

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