Environmental
ctfAPTER 24
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MANAGEMENT R.EV.IEW; SECTION 7.0 OF 210 .
section 7.0 opens with this statement: "This section defines the requirements fot the periodic review of the occupational health and safety management system .. " The importance of the management review requirements in ZlO is inverse to the ·length of this chapter. ,
In Chapter 1, "An Overview of ANSI/A/HA ZJ0-2005-the American National Standard for Occupational Health and Safety Management Systems" we stated that Section 3.0, Management Leadership and E!Ilployee,, Participation, is the most important section in ZlO. Top management leadership is vital because it se~s, the organization's safety culture and because continual improvement processes cannot be successful without effective top management direction. To achieve superior results, top management must repeatedly "walk the talk". · '
We also said that Section 7 .0, the management review section, was a close second importance. Maintaining superior management ·leadership · requires that evalua-
tions be made of the effectiveness of safety processes so that improvements can be made w_here necessary. J _ • •
Section 7 .1 requires that "the organizatioµ shall estabhs~ process for top management to review the occupational health and safety management system at least · · d · b'li ~nnually and to recommend improvements to ensure its continue suita 1 ty, adequacy, and effectiveness " This section lists inputs fo the management review Process t b . . .. • , 0 e considered, among which are:
~ -····· . Second ~fety' Management: Focusing on ZJO anti Serious Injury Preventwn,
2014 Jo on .. Fred A. Manuele. hn Wiley & Sons, Inc. Published 2014 by John Wiley & Sons, Inc.
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484 MANAGEMENT REVIEW: SECTION 7.0 OF 210
A. Progress in the reduction of risk
· G. Toe objectives to which objectives have been met
H. The performance of the occupat~on~l health_ and _safethy m~nag_ement systems relative to expectations, takin~ mto cons_ideration c angmg c_ircum- stances, resource needs, alignment with the busmess plan, and consistency with the occupational health and safety policy.
At the conclusion of the review (Section 7 .2), top management shall determine the:
A. Future direction of the OHSMS based on business strategies and condi- tions; and
' . ' B. Need for changes to the organization's · policy, priorities, - bbje~tives:
resources, or other OHSMS elements. · ·
Action items for improvement are to be drafted as the performance assessment is made and "Results and action items from the management reviews shall be docu- mented, communicated to affected individuals, and tracked to completion."
•As shown below, the management review process begins with the "check" step in the Plan-Do-Check Act model and provides input to , senior management so ,that processes put in place previously can be accepted as satisfactory or revised, as in the "act" step.
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: Evall,late th,e 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.
Act: Accept the resu;Iis, o~ _take additional' corrective action, as needed. J •
. 1:he writers of the ZlO ~t{lnqard may apprecifl~~ the recognitiop given to the significance of the s_tandard, particularly thi ~ 1}1.anagement revie'Y section. On March
23 , ~005, a senous workplace disaster occurred at the BP Texas City refinery.
It resulted m 15 deaths and more than 170 injuries. A blue ribbon panel, populated mostly by ~own experts, was created with financial support from the U.S. Chemical Safety Re:-iew Board to "make a ~orough, independent, and credible assessment of the effectivenes~ of BP'.s corporate oversight of safety management systems at its five U.S . refinenes and its corporate •culture."
MANAGEMENT REVIEW: SECTION 7.0 Of Z10 48~
e Report of the BP U.S. Refinerie,s Independe,nt Sq,fety Review Panel was Th . January 2007 as a document available to the public It h b d 1n & • 1 • as ecome jssuen in occupational saiety cir~ es fl~ The Baker Report. The panel's chair was
~ows A, Baker III, who served m sem~r go:vernment posjtions under tl)ree U.S. JaIJl~dents. Several references are made m th~ r~port to sectioqs in 210.as recom- pres ded practices. Those references, and by mf~rence the 210 standard, are file~ that they represent the state of the art in safety and health management 1esnmonY . . .. Ystems. . tak fr Th 5 h of the followmg, en om e Baker, Report, relates to the content of S::;: 3.o in ZlO, "Management Leadership and.Employee Participation."
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1n 2oos, theAmerican National ~tandards Institute (ANSI) approved "a voluntary nsensus standard on occupational health and ·safety management systems."
co dard. . ed d While the stan 1s onent towar occupational rather than process safety, the Panel believes that the standard provides a ' useful tool in analyzing safety , management systems generally. The ANSI 210 standard emphasizes "continual . unprovement and systematically eliminating the underlying or root causes of deficiencies." The standard indicates that an organization's management should provide leadership and assume overall responsibility for
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• implementing, maintaining, and monitoring performance of the safety system; , ·. ·
• providing appropriate financial, humah, and organizational resources to plan, implement, operate,· check, correct, and review the system;
I defining roles, assigning rei~onsioilities, e'stablishing '·accountability, and delegating authority to implement an effective system for continual • I ; • o i f , IIDprovement
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• integrating the system into the organiiation's other business syst~ms and processes. (p. 131)
' . ' Elsewhere in The Bake~ Report, ob~rvati.on.~ are on management revi~ws ·that
are close to a verbatim copy of wh,at appears in thy, advisory column for Seqtion 7. Whereas OHSMS is the term used in Section 7, .it has .been repl~ced by the safety management system in the B~er Report.
' ~e related comme~tary to the AN~I '210 s~ndard provides a usefol des~rip- tion of tpe r,ole of liJld purpose for managem~nt reviews: , 1 •
' Manag~IJl~nt reyiews are a. c.'r,itical part qf the ~ontinuFU improvement of the [safety management system]. . , • · ·
• The purpose of reviews is fo~ top management, with the participation ?f [safety management system] leaders and process o~ners, to do a strategic and critical evaluation of the performance of the [safety management system], and•to recommend improvements.
486 MANAGEMENT REVIEW: SECTION 7.0 OF 210
. • · · t J·ust a presentation or a non-critical review of the • This review is no . . . b h ld focus on results and opportumties for continual system, ut s ou . . . .
. t It is up to the organization to determine appropriate improvemen . • · Th h f [ afiety management system] effectiveness. ey s ould also measures o s ] . . ,
evaluate how well the [safety management system IS integrated with other business management systems, so it supports both health and safety goals and business needs and strategies.
Reviews by top management are required because they have the a~thority to make the necessary decisions about actions and resources, althou~h It may also be appropriate to include other employee and management levels m th~ proces~. "To be effective, the review process should ensur~ that the necessary mformatiQn is available for top management to evaluate the continuing suitability, adequacy, •and effectiveness of the [safety management system] .... Reviews should present results (for example, a scorecard) to focus top management on the [safety management system] elements mrn~t in need [of] their attention."
At the conclusions of the reviews, . top management should make decisions, give direction, and commit resources to implement the decisions. The management review should include an assessment of the current [safety management system] to address if the system is encompassing all of the risks to which the organization is exposed. This portion of the review should include a review of major risk exposures and, as~ the question, "Are there any holes" in the current [safety management system] that. could a\low a risk that might not be considered within the [safety management system]. (p. 225)
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Section 3 .0, ''Management Leadership and Employee Participation," and Section 7 .0, ''Management Review," are vital and integrated parts of a whole. An organization cannot achieve superior results if the'perfomiance in these two sections is not stellar.
A management review is to result in a documentation of the action items necessary to achieve continual improvement in occupational health and safety management systems, the as~ignment of responsibility for the actions to be taken, completion dates,_ an~ r:<Iurrements for ~eriodic reporting on progress made. One test of the ?rgamzation s safety culture 1s whether 'resources are made available to achieve the improvements decided upon.
A d' M ' ppen IX Is to help managements fulfill the Zl0 management review require-
men~. It con~ists principally of a scorecard, whose purpose is to focus "top manage- ment s attention on the part f h • t
s O t e occupat10nal health and safety managemen ~tyste~ thZaltOneed their attention and direction mostly." The scorecard lists the major I ems m on one page and 'd & • st tu f h f . . provi es 10r entering indicators of the implementation a s o eac o the prov1s1ons Wh · e to be entered t h th · . en usmg the scorecard example given, colors ar 0
s ow e followmg perfonnance levels.
• Blue: world-class OHS pe..l'onn · 111 ance ,
• Green: strong· confonni 1 ' ng complete, may have minor gaps with action plans
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REFERENCES 487
. 01oderate; sca~ered nonconformances need to be addressed, positive , fel1°W• ·or elements m place
nds/01aJ . . tre . nificant nonconformances exist, still needs focus \fiolet: s1g . d . . • . or effort requrre ; maJor systematic nonconformances exist
, Red: maJ ing color scheme is recorded here as an example of how performance
'1'he forego d Th . f A . 11•. ay be expresse . e wnters o ppend1x M properly recognized that a
gra~auo;; :Va1uation systems may be use_d-qualitative or quantitative. They also vanelY . partant statement when they said that management review reports should
ake an ID1 , " · ti' · rn_ anization s size, opera ons, services, or culture." A summary report will Ulttheorg ·1 'f. ti th . . , s ted more readi y 1 1t ts e organization s style and culture.
i,eacceP · • · 'fhis management rev!eV.: sect10_n _gives ~a1e_ty and health professionals a mean- in ful oppartunity to assist m providing obJect1ve summary reports on the status of g au·onal health and safety management systems and to present managements
occup . . 'th propasals to overcome shortcommgs. Such reports will have greater value if a WI tion addresses serious injury potential and risk reduction measures. sec In accord with the POCA concept, the overriding theme of the management review is to achieve continual improvement. Thus, having action items for improvement in the review process and follow-through are vital.
In many companies, a major management review process is conducted annually and a summary progress report carrying the signature of the chief executive officer is published. Such reports may be made available broadly, such as on the Internet. Publication of the reports serves the purposes of good community relations as well as good employee relations.
REFERENCES
ANSI/AIHA Zl0-2012. American National Standard, Occupational Health and Safety Management Systems. Fairfax, VA: American Industrial Hygiene Association, 2012. ASSE is now the secretariat. Available at https://www.asse.org/cartpage.php?link=z10_2005.
The Repon of the BP U.S. Refineries Independent Safety Review Panel, at http://us.yhs4. search.yahoo.com/yhs/search?p=The+Report+of+the+BP+U.S.+Refineries+Independent+ S~ety+Review+Panel&hspart=att&hsimp=yhs-att_OOl&type=att_lego_portal_home, Click on the Acrobat indicator.