Workshop II

Valuable Guidance in the Implementation of the New

Safety Standard—ISO 45001

Wednesday, March 28, 2018 11:15 a.m. to 12:30 p.m.

Biographical Information

Cory Justice, HS&E Specialist, MUBEA North America 8200 Dixie Highway, Florence, Kentucky 41042 USA

859.746.5315 x7062 Mobile: 513.760.3388 Cory.Justice@Mubea.com

Cory Justice is a Health, Safety, and Environmental Specialist with Mubea North America in Florence, Kentucky. Cory holds a Bachelor of Science in Occupational Safety and Health and a minor in Fire & Safety Engineering Technology from Eastern Kentucky University. Cory is responsible for managing and implementing Environmental, Health, & Safety compliance for 3 Business Units. Prior to joining Mubea North America, Cory worked as a Safety Specialist and Coordinator implementing various safety programs and conducting Environmental, Health, and Safety trainings.

Eric D. Harper, CSP, CHMM, Manager – Process Safety, EHS Technology Group, LLC

2912 Springboro Road West, Suite 101, Dayton, Ohio 45439 (937) 510-6523 eharper@ehstech.com

Eric is the Manager of Process Safety for EHS Technology Group LLC located in Miamisburg, Ohio. Eric has over 21 years of experience in the field of environmental health and safety. Prior to joining EHS Technology, Eric was responsible for managing the environmental health and safety program for two manufacturing facilities in the automotive industry. In this capacity, Eric was responsible for managing the regulatory compliance, worker’s compensation, and various risk management activities for his company. During his time in private industry, he developed and implemented numerous safety programs and injury reduction initiatives. In addition, he developed and conducted various safety training classes on a wide range of safety topics such as confined space, lockout/tagout. Since joining EHS Technology, Eric has been focused on providing safety, health, and environmental consulting services to clients in a wide variety of industries. Specifically, Eric has focused on helping clients with struggling safety and environmental programs achieve improved metrics while providing safer workplaces to their employees. Eric is a graduate of Ohio University with a B.S. in Industrial Hygiene. Eric has been a Certified Safety Professional (CSP) since 2001 and has been a Certified Hazardous Materials Manager (CHMM) since 2014. Eric is a member of the American Society of Safety Engineers.

March 28, 2018

What if the man or woman in the picture fails to come home tonight because he or she is killed at work?

2.3 MILLION TIMESGlobal Estimates of Occupational Accidents & Fatal

Work Related Diseases in 2014Tampere University of Technology

263 PEOPLEWill Die at Work in the Next Hour

Recognition globally that we need to do something different

First, understand the purpose of organization & intended outcome of the OHSMS

o What do you want OHSMS to help you accomplish?

Next, identify positive and negative issues impacting organization’s ability to achieve OHSMS success

o Internal issueso External issues

Context should be reviewed periodically to ensure it is up to date

Positive or negative issues outside of organization that can affect the OHSMS

o Political climateo Changes in legal requirements (i.e. walking-working surfaces)o Social or cultural issues (i.e. language barriers)o Industry trendso Technological changeso Market competitiono Economic conditionso Recent research findings detailing health effects of raw materialo Facility location & availability of emergency medical serviceso OSHA Local Emphasis Programs

Identify risks & opportunities associated with the external issueso Risk – Research on vital raw material component shows increased cancer risk

for those exposed to the materialo Opportunity – Increased sales presents opportunity to fund capital project to

improve machine guarding plantwide

Positive or negative issues inside of organization that can affect the OHSMS

o Corporate governanceo Organizational structureo Employee turnovero Work shifts & overtimeo Aging workforceo Workforce demographics (i.e. high number of temporary employees)o Culture of the organizationo Safety training programso Organizational relationship with union(s)

Identify risks & opportunities associated with the internal issueso Risk – High turnover in high hazard job could significantly increase risk

of severe injuryo Opportunity – Modification in shift times could reduce amount of

overtime and fatigue of employees

Identify who has interest in the success or failure of your safety programo Employees are given

Some interested parties are readily identifiableo Employee families (i.e. small children)o Unionso Regulatory agencyo Parent companieso Contractors & customers

Dive deep – some interested parties may not be so identifiableo Investment communityo Worker’s compensation insurerso ISO 45001 registrarso Media

What relevant needs or expectations do these interested parties have?o Mandatory or voluntarily accepted needs & expectations become compliance obligations

• Complying with applicable OSHA regulations• Submitting required OHS data to corporate monthly or completing customer OHS surveys

o Compliance obligations accounted for when planning & executing the OHSMS

Understand & consider the following prior to determining scope of OHSMS:

o Internal & external issues identified in contexto Legal & other requirements associated with interested partieso Work related activities conducted

Include activities, products, & services within control or influence of the organization which can impact OHS performance

o Travelo Transportation of productso Contracted janitorial services

Scope will establish boundary & applicability of OHSMSo Do not exclude things which can impact OHS performanceo Do not exclude things to avoid legal or other requirements

Scope must be available as documented information

Section 5.1 outlines thirteen (13) different ways leadership & commitment should be displayed by top management

Objective evidence should be gathered as processes are audited & interviews are conducted

Fingerprints of top management should be all over the OHSMS system & documentation

o Meeting minuteso Communicationso Participation in safety activitieso Leading by example (PPE)

Top management must:o Take:

• Responsibility & accountability for injury prevention & safe working conditionso Ensure:

• Integration of OHS into other business processes• OHS policy & objectives are established & compatible with strategic direction of organization• Resources are available for OHSMS• OHSMS achieves intended outcomes• Continual improvement• Development of process for consultation & participation of workers

o Support:• Other managers to take leadership as it applies to the OHSMS for their areas• Establishment & functioning of health & safety committees

o Communicate:• Importance of OHSMS & conforming to OHSMS requirements

o Direct & support: • Contribution to the OHSMS

o Develop, Lead, & Promote:• A culture within the organization that supports the OHSMS & its intended outcomes

o Protect:• Workers from reprisal when reporting incidents, hazards, risks & opportunities

Evidence of leadership & commitment may include:o Participation in & decisions made at management reviewo Participation in safety committeeso Key communications addressing safety o Allowing time for safety committee members to attend meetingso Including safety metrics in performance reviewso Providing resources for safety (i.e. money, additional staff, etc.)o Establishing & monitoring safety hazard reporting processeso Participating in safety auditso Establishment of safety suggestion systemo Inclusion of safety in MOC processo Interviews with top management & their knowledge of what is

happening in safety at their facility

Requires normal OHSAS commitments:o Compliance with applicable legal & other

requirementso Continual improvement

Also requires commitments to the following:o Provide safe & healthy working conditions

to prevent injury & ill healtho Eliminate hazards & reduce OH&S riskso Consultation & participation of workers

and/or their representatives

Prevention of injury & ill healtho Also in OHSAS 18001o 45001 commitment draws focus back to

conditions that can cause injury or ill health• Fall hazard that never leads to fall

Employee consultation & participation required throughout all stages of OHSMS processo Developmento Planningo Implementationo Performance evaluationo Continual improvement

Non-managerial employees emphasized which means employees carrying out work activitieso Managers impacted by the work activities should not be excluded

Time, training, & resources must be provided to allow for participation

Timely access to clear, understandable, & relevant OHSMS informationo Can be obstacle or barrier to participation

Remove and/or minimize obstacles or barriers to participationo Threat of reprisalo Lack of response to suggestionso Language barriers

Employee consultation & participation required at all stages of OHSMS process

Non-managerial employees emphasizedo Managers impacted by work carried out by non-managerial employees should

not be excluded

Time, training, & resources must be provided to allow for participation

Timely access to clear, understandable, & relevant OHSMS necessary to allow for participation & consultation

o Can be obstacle or barrier to participation

Remove and/or minimize obstacles or barriers to participationo Threat of reprisalo Lack of response to suggestionso Language barriers

Consultation – Seeking views before making a decisiono Two-way communication where information is shared with employees &

informed feedback is provided from them prior to a decision being made

Non-managerial employees consultation should be emphasized when:o Determining needs & expectations of interested partieso Establishing OHS policyo Assigning roles, responsibilities, and authoritieso Determining how to fulfill legal & other requirementso Establishing O&T and planning to achieve themo Determining controls for procurement including contractors & outsourcingo Determining monitoring & measuremento Developing internal audit programo Ensuring continual improvement

Not a system that management develops & drives down employee throats

Participation – Involvement in decision-makingo Allows employees to contribute to decision-making process

Non-managerial employee participation should be emphasized in:o Determining mechanisms for their consultation & participationo Identifying & assessing risks & opportunitieso Determining actions to eliminate hazards & reduce riskso Determining competence requirements, training needs, training, &

training evaluationo Determining what and how to communicateo Determining control measures & how to effectively implemento Investigating incidents & nonconformities & determining corrective

action

Non-managerial employee fingerprints should be all over the OHSMS

Risks & opportunities (associated with OHSMS planning) must be identified considering:

o Context issueso Interested party requirementso Scope of OHSMS

Risks & opportunities (associated with OHSMS intended outcomes) must be identified considering:

o Hazardso OHS riskso OHS opportunitieso Legal & other requirements

Risks & opportunities will be documented information

Processes & actions necessary to determine & address risks & opportunities will become documented information

o To level required to ensure they are carried out as intended

Hazard identification process must be proactive & ongoing

Hazards can be masked in a variety of ways

At a minimum, the following items should be considered when identifying hazards:

o Organizational culture, social factors, & human factors (ergonomics)o Routine and non-routine taskso Internal & external relevant incidentso Potential emergency situationso Peopleo Changes in organization, processes, equipment, etc.o Changes in knowledge or information about hazardso Other issues

Process should be robust to identify the hazards associated with all of the operations & activities included in the scopeo Lone workerso Service personnel traveling between sites not controlled by

employero Occasional welding inside a machineo Active shootero Parking lot traffic

All hands on deck! - One person cannot make this process work

Risks associated with identified hazards must be assessedo Many ways to conduct risk assessments

OHS Risk - Combination of the likelihood of occurrence of a work-related hazardous event or exposure(s) and the severity of injury and ill health that can be caused by the event or exposure(s)

Risk assessments must be proactive NOT reactive

Risk assessment should take into account effectiveness of existing controls

Other risks related to the OHSMS must be identified & assessedo Review context for riskso Changes in legal or other requirementso Economic changeso Turnover in OHS administrative personnelo Seasonality of work

Risk assessment methodologies & criteria is documented information

Organization must evaluate opportunities to improve OHS performanceo Ergonomic conditions

o Eliminate hazards & reduce risks• Hierarchy of controls• Corrective action after near miss

o Other opportunities associated with OHSMS• Review context for opportunities • Employee suggestions

Must have a process for determining & accessing up-to-date legal & other requirements associated with risks & OHSMS

o Do you have a sawmill? Do you have a helicopter?

Determine application to organization & what needs to be communicated

o Hexavalent Chromium requirements based on exposure levelso Communication of corporate OHS requirements

Consider legal & other requirements in all aspects of OHSMS

Documented information required on legal & other requirementso Update as changes occur

LEGAL REQUIREMENTS OSHA regulations

OSHA settlement agreements

Court judgments

Permits or licenses

Collective bargaining agreements

OTHER REQUIREMENTS Corporate requirements

Contracts

Consensus standards

Voluntary codes of ethics

ISO 45001

Organization must plan actions to address:o Risks & opportunities

• Considering hierarchy of controlso Legal & other requirementso Prepare for & respond to emergencies

Actions should focus on achieving purpose or desired outcome associated with OHSMSo Protect employees o Compliance

Organization must plan:o Integration of actions into OHS & other business processes

• BBS observations & JHA completion – production levelo Evaluation of the effectiveness of actions taken

• Ensure actions are moving toward achieving purpose of OHSMS

Purpose – Maintain & improve OHSMS & OHS performance

Objectives must:o Be consistent with OHS policy

• Does objectives achieve or help achieve one of its commitments?o Be measurable (if practicable) or capable of performance evaluation

• Can you measure or evaluate its achievement?o Be monitored

• Are you monitoring its achievement?o Be communicated

• Is your objective(s) known throughout organization?o Account for:

• Applicable requirements, • Risk & opportunity assessments, & • Worker consultations

• Were risks & opportunities, employee input, & applicable requirements considered? o Updated as appropriate

• Is the status or progress toward achievement up to date?

Plan for achievement is roadmap for achieving objectiveo What activities or steps will you take to achieve the target?

Understand what resources are necessary for OHSMS

Resources could include:o Peopleo Moneyo Equipmento Timeo Infrastructureo Technology

Top management must provide the necessary resources for the OHSMS

• Clause 5.1(d)

Must determine necessary competence of employeeso Requirements expected to differ throughout organization

• Maintenance technician vs. Accountant vs. Production operator• Machine specific training vs. departmental specific training

Ensure competence through training, education, or experienceo Competence includes hazard identification associated with job

• Identifying a process needs to be shut down due to safety issues

Take action to acquire & maintain competence & evaluate the actions taken

o How do you evaluate actions?• Training quizzes or evaluations• BBS observations• LOTO periodic reviews• Review of cancelled confined space entry permits• Audit

Retain documented information required to show competence

Employees (including temporaries) must be aware of the following:

o OHS policy & objectiveso Their contribution to OHSMS effectiveness, including benefits of

improved performanceo Consequences of not conforming to OHSMS requirementso Incidents & outcomes of investigations relevant to themo Hazards, risks, & actions relevant to themo Ability to remove themselves from work situations they believe presents

imminent & serious risk to their safety & healtho Arrangements in place which allows them to remove themselves from

hazardous situations without reprisal

Contractors & visitors should also be aware of the relevant OHS hazards & risks

o Emergency response communications addressed in Clause 8.2

Communication process must define:o What will be communicatedo When to communicateo With whom to communicateo How to communicate

Must account for diversity & be reliableo Languageo Literacy o Disability

Consider views of interested partieso OSHA injury reporting requirementso Corporate requirementso Customer requirements (surveys)

Same documented information requirements as ISO 14001 except for OHSo Standard ISO language used

Documented information must include what is required by standard & determined by organization to show system performance

External origin documentation must be identified & controlledo Safety data sheetso Industrial hygiene lab results or reportso Medical surveillance documentation

Focus on establishing criteria & implementing controls for processes to eliminate hazards & reduce risks while considering hierarchy of controls

o Work procedureso Employee trainingo Inspection & PM procedures & programs

New requirement for adapting work to employeeso Requires ergonomics to be considered in work layout, equipment design,

induction of new employees, process changes, etc.

Multi-employer work places requires coordination between employers to maintain safe & healthy work environment

Documented information still required as necessary to ensure controls are adequate & being followed

MOC, procurement, contractors, & outsourcing broken out into separate clauses

Hierarchy of Controls Must be Used Potential Issue is Corrective Action After Accidents or Near Misses

Alluded to many different times in OHSAS standard

Goal = minimize new hazards & risks in the workplace

Planned changes impacting OHS performance must be controlled

o Replacing light curtains with laser safety scanners

o Relocating equipment within facilityo Employee turnover in high hazard job(s)o Changes in Beryllium & Silica standards

Consequences of unintended changes must be reviewed & actions taken (if necessary) to reduce risk

o Unforeseen hazard development from change

Process must include OHS considerations when procuring equipment, raw materials, services, etc.

o Equipment specification guide controlling equipment purchaseso Guidelines for chemical purchaseso Contractor qualifications

Focus should be on elimination of hazards & reduction of OHS riskso Establish guarding requirements for new equipmento Prevent purchase of chemical mixtures containing carcinogens

Verification of equipment, materials, & services must be part of the processo Equipment acceptance processo Material SDS reviewso Contract employee training verification

Communication & participation needs should be addressed in processo Process for special approval for chemical that may not exactly meet all chemical

purchasing guidelines

Contractor control addressed in OHSAS Clause 4.4.6(c) but ISO 45001 becomes more specific in Clause 8.1.4.2

Low Bid is now Low Bid with Qualificationso Procurement process must define & apply OHS criteria to contractor selection

• EMR• Incident rates• OHS program evaluations

Risk control is two way streeto Risks created by contractor impacting organization or other interested parties

must be controlled• Visitors, other contractors onsite, its own employees

o Risks created by organization impacting contractor must be controlled

Contractor management must ensure work is conducted in a safe manner

Outsource - Make an arrangement where an external organization performs part of an organization’s function or process

o Organization outside scope of OHSMS but process performed is not

Examples could include:o Janitorial serviceso Building maintenanceo Industrial hygiene testing

Cannot outsource a process & then ignore how process is being implemented & controlledo Janitorial service changing cleanerso Industrial hygiene testing not being performed in accordance with established protocols

OHSMS must define controls considering process risk & external organization’s own controlso Company vetting processo Contractual languageo Periodic auditing of process controls

Processes must cross reference & correspond to actual emergencies or potentialemergencies identified during hazard identification (6.1.2.1)

o Active shooter

Response plans to identified emergencies must consider needs & capabilities of relevant interested parties

o First aid consideration• Rural area EMS may not respond to medical calls fast enough

Interested parties should be involved, as appropriate, in plan developmento Confined space rescueso Potential Ammonia or Chlorine releases

Communications extended beyond your property boundaryo LEPC communications, SARA 312 filings, community evacuation information after release, etc.

Periodic testing & exercising of planned response capabilities o Evaluation of planned response actions

• Haz Mat team drillso Not just annual fire drills

“What gets measured gets done.”

Need to determine the following:o What needs to be monitored & measured to evaluate OHS performance;

• Fulfillment of legal & other requirements• Safety audits• Evaluation of compliance process

• Activities & operations related to hazards, risks, & opportunities• BBS observations• Training attendance

• Progress toward OHS objectives• Effectiveness of controls

• IH testing for employee chemical exposures• Periodic inspection required by LOTO

o How (methodology) you will monitor, measure, analyze, & evaluate it;o When monitoring & measurement will be performed; &o When results of M&M will be analyzed, evaluated, & communicated

Performance Metric

Monitoring Method

Criteria Monitoring Frequency

Analysis & Evaluation Frequency

Communication

Safety Training

Attendance

Sign In Sheets

100% Attendance

After Each Class

After Each Class

Monthly @ MR

BBS Observations

BBS Observation

Forms

3/Supervisor Monthly Monthly Monthly @ MR

Safety Audit Audit Forms 90% Score Monthly Monthly Quarterly @ MR

TRIR 300 Log Industry Ave. Monthly Monthly Quarterly @ MR

DART Rate 300 Log Industry Ave. Monthly Monthly Quarterly @ MR

Employee Safety

Suggestions

Suggestion Forms

1/Employee Monthly Quarterly Quarterly @ MR

Examples of possible calibrated or verified equipment:o 4 gas meters or other direct

read instrumentso SLM or dosimeterso Air sampling pumpso Ohm meterso Heat stress instrumentationo Meters for radiation detectiono Vibration detection

equipment (accelerometer)o Cranes (rated load test)o Chemical detection

equipment (NH3 system)

Organization must determine frequency & method(s) for evaluating complianceo Similar to 18001

Clause 9.1.2(c) requires “maintaining knowledge & understanding of compliance status”o Is evaluation frequency &

methodology sufficient?• Compliance evaluation every 3 years

Internal audit program should consider process importance & previous audit results

o Higher hazard/risk process (Maintenance) audited more frequently than lower hazard/risk process (Office)• 18001 required consideration of risk assessments & previous audits

Results of internal audits now reported to:o Relevant managerso Workers and/or representativeso Other relevant interested parties

• Corporate • Registrar

Documented information could include:o Audit schedule, auditor qualification documentation, audit

reports/results, communications associated with audit reports, corrective action documentation

Inputs of 45001 essentially unchanged from 18001 except:o Changes in needs &

expectations of interested parties

o Changes & trends in risks & opportunities

o Resources • Alluded to in 18001 since it

was an output

All inputs not required to be addressed all at onceo Can OHSMS really be

properly managed with one management review a year?

Outputs essentially the same as 18001 except:o Decision on continuing suitability, adequacy, & effectiveness of OHSMS

• Alluded to in 18001o Opportunities to improve OHSMS integration with other business processes

• Combining OHSMS management review with ISO 9001 management review• Extending OHSMS to newly acquired business location

o Implications for the strategic direction of the organization• Not being able to quote business because injury rate is too high• Poor injury record affecting employee recruitment while company trying to grow

Suitability – How OHSMS fits organization & its operations, culture, & business system

Adequacy – Is the OHSMS implemented appropriately Effectiveness – Is OHSMS achieving its intended outcome

45001 requires communication of outputs with workers or representatives while 18001 required outputs be made available for communication & consultation

Organization must identify opportunities for improvement & take necessary action to achieve OHSMS outcomes

Must continually improve OHSMS:o Suitability – How OHSMS fits organization &

its operations, culture, & business systemo Adequacy – Is the OHSMS implemented

appropriatelyo Effectiveness – Is OHSMS achieving its

intended outcome

Can be identified from:o Internal audits, Compliance evaluations,

Corrective actions, or Employee suggestions

Process must include three basic parts:o Reporting – Investigation - Action

Timely reaction necessary to deal with consequences, ensure control, & correction of issue

• First aid for severe laceration

Corrective action should be implemented in accordance with hierarchy of controls & be evaluated for effectiveness

Non-managerial employees should participate in investigation, root cause evaluation, & corrective action

Consult risk assessments after each incident or nonconformityo Was issue identified & was risk adequately considered (scored)o Does new hazard or risk need added or re-evaluated

OHSAS 18001:2007 considered “withdrawn” taking into account the migration period on date of 45001 publication

o Migration period starts on publication date

Migration period will be 3 years

OHSAS certifications issued during migration period will expire at the end of the migration period

o May be amended if local regulation requiring 18001 has not been amended to reference 45001

Migration can occur at any of the following times:o Surveillanceo Recertificationo Special audit

Migration during surveillance or recertification adds a minimum of 1 auditor man-day