example, OSHA may elect to give Merit status to a company with an overall good health and safety program but whose illness and injury rates have yet to drop below national averages. The third award is the Demonstration designation. Demonstration status may be awarded to companies that are not construction or general industry oriented, such as maritime or agriculture businesses. Merit and Demonstration sites receive annual onsite inspections (12).
The VPP criteria contain a number of best practices that can lead to superior safety and health performance. Certain elements are strong, such as employee involvement. Other elements that would make it a complete management system are weaker such as management review and continual improvement aspects. OSHA VPP gets employees involved in safety and health management unlike traditional OSHA approaches.
7 DEVELOPMENT AND IMPLEMENTATION
There are any number of ways to approach the development and implementation of an organizational MS, or for that matter, any new program or initiative. A seven‐step process follows, along with general project management tips. As well, a brief overview of a popular approach developed by John Kotter is presented.
Prior to the implementation of a new initiative, it first needs to be developed or created. The management system standards reviewed in this chapter provide guidance and requirements particularly if certification is sought; however, organization‐specific work needs to be done to apply them.
The seven development and implementation steps include the following:
1 Support, resources, scope, and selection;
2 Condition the culture;
3 Characterize existing systems and processes;
4 Gap analysis;
5 Development;
6 Rollout; and
7 Evaluation and continual improvement.
7.1 Support, Resources, Scope, and Selection
Important first steps in developing and implementing an OHSMS is to ensure there is top management and worker support, as well as sufficient resources. Initial thinking on scope and potential certification issues should be done early in this process. Selecting ISO 45001 is a popular choice. Consideration should also be given to OHSMS's that are specific to a particular country. As well, it is not uncommon for an organization to develop a hybrid OHSMS that integrates aspects of several approaches, such as ISO 45001, ANSI Z10, and OSHA's VPP.
Meetings should be held early in the implementation process with a wide range of stakeholders including senior executives, workers and their representatives, middle managers, and staff functions such as human resources. Prior to conducting any meeting, have clarity on the OHSMS or integrated system that is being implemented. Solicit and document support and concerns. Understand the basis for potential concerns, and hopefully address them. The goal of these meetings is to develop support and alignment with OSHMS implementation. Take these opportunities to recruit people to participate on the implementation team.
In addition to using these meetings to develop support, they also provide a good opportunity to begin collecting information on “context of the organization” and “risks and opportunities.”
It is important in all meetings to discuss and solicit ideas on OHSMS integration with the organization's business and operational processes.
Meet with the Senior Most Executives. Briefly review the OHSMS elements. Emphasize the following OHSMS elements: management leadership and commitment, OH&S policy, worker participation, responsibility and accountability, and management review. It is critical that executives understand the need for their initial and ongoing documented commitment to the management system. Discussing business and operational process integration is critical with the top executives. Affirming their support for this will valuable when working with middle managers and other personnel throughout the organization.
Meet with Workers and Their Representatives. The manner in which this is done is a function of the organizations size and culture. In small organizations, such meetings can be informal. In larger organizations or at those with union representation, meet with union representatives and/or other worker representatives first. Review the system's elements. Discuss how worker participation will be accomplished.
Meet with Middle Managers, Supervisors, and Line Managers. Review the system's elements. Discuss their anticipated role in the development, implementation, and ongoing improvement of the management system.
Meet with Human Resources. The human resource function is an important participant on the implementation team. Meet with a representative early to discuss the evolving implementation plan. Specifically discuss sections on responsibility and accountability, competence, training, and documentation.
Other Stakeholder Meetings. Depending upon organizational structures, consider meeting with personnel from– engineering or facility maintenance;– environmental management department, if integration with an existing environmental management system is to be done;– external stakeholders such as medical clinics and/or emergency responders.
With a good understanding of the management system recommendations, management system goals, and organizational dynamics, develop a detailed action plan that lays out the detailed steps you will take. Be prepared to alter your plan based on input from other stakeholders in your organization.
7.2 Condition the Culture
An often‐overlooked piece to be implementing an OHSMS is the extent to which organizational culture needs to be addressed prior to the development and formal rollout of the initiative. Examples of aspects of the culture that need to be addressed are;
establishing objectives and clarity about why the OHSMS is being implemented;
learning about problems or failures with past initiatives;
determining potential resistance and stakeholder concerns.
It is common that some degree of organizational enrollment or internal selling is needed for successful OHSMS implementation. Reasons for this range from general resistance to new things to concerns about more work from documentation, auditing and potential certification needs. In some cases, there are concerns from organized labor about diminished focus on regulatory compliance. Early in the implementation process, concerns should be identified and addressed by leadership and the implementation team.
7.3 Characterize Existing Systems and Processes
After commitments and resources have been secured, and culture‐conditioning efforts initiated, existing MS and approaches need to be characterized.
When considering the development and implementation of a formal OHSMS (e.g. ISO 45001 or ANSI Z10), it is not uncommon to find many aspects of the system already in place. Organizations have some degree of formal management system elements in place already even though they may not be well distinguished. Existing MS may include ISO 9001, ISO 14001, or organization's unique systems. Every organization has a system they use to manage OHS issues. Where no formal system exists, there are usually identified leaders and responsible parties.
Early in the development and implementation process, it is necessary to characterize the existing program/system elements (e.g. OH&S policies and procedures), as well the organization's business and operational processes, and begin identifying how the OHSMS will be integrated with them, or visa versa.
A management system document pyramid model is a useful tool to help the development and implementation efforts (Figure