SMS Adoption/Crossing Chasm Sofware
A regulatory focus is limiting. Compliance today does not guarantee compliance tomorrow. Lower rates and costs this year does not guarantee year-over-year sustainable reduction. Without a Safety Management System, you will always be at risk of future non-compliance and increased rates and costs.
There are excellent safety management systems available to pick from (VPP, ANSI, BS8800, BSI’s OHSAS 18001 to name a few). The important thing is to leverage from existing systems. Integrate your S&H processes into your existing core business process. Don’t just add a stand-alone system.
Focusing on “Rates and Regs” only works to a point because
- Progress is based on response to accidents – reactive instead of proactive.
- Metrics focus on trailing indicators and primarily look at outcomes.
- Programs are a mix of unstructured activities
- Attention is centered on “What to do” as prescribed by the regulations
A comprehensive management system provides the central focus that will drive your continuous improvement.
What is the difference between a Safety Management System (SMS) and a Safety Program? An SMS is a set of key management processes with clusters of best practices that improve performance outcomes.
- Operates in isolation, unrelated to other concurrent programs under management.
- Focus is compliance with a specific regulation
- Lacks strong feedback processes
- Lacks strong evaluation mechanisms
- Continuous improvement is not sustainable
- LOTO, HAZCOM, PPE are examples of common safety programs
- Addresses compliance (programmatic) requirements
- Broader in scope/addresses many other issues such as the quality of the S&H performance, integration with other business systems
- Focuses on S&H improvement
- Clear feedback and evaluation mechanisms
- A system responds to both internal and external events.
- More comprehensive than any single program.
- A systems approach integrates all individual programs within day-to-day business operations and processes.
- OSHA’s VPP (Voluntary Protection Program)
- ANSI Z10
- Chemical Industries Association, Responsible Care;
- American Industrial Hygiene Association’s OHSMS guidance document.
- British OHSMS, BS 8800; and,
- British Standards Institute BSI OHSAS – 18001
ISO 9000 and 14001 standards are considered strong auditable standards. However, strictly speaking, they are not an SMS, even though many organizations are using them as templates for SMS adoption.
OSHA established the Voluntary Protection Program (VPP) in 1983 in order to recognize and promote effective safety and health management. The VPP model has 4 elements (top-level management processes) and 36 sub-elements (best practices):
- Management Leadership and Employee Involvement
- Worksite Analysis
- Hazard Prevention and Control
ANSI Z10, published in 2005, consists of 7 elements and 32 sub-elements. A side by side comparison of VPP and ANSI Z10 shows they are quite similar. What’s the major difference between them? ANSI contains risk based sub-elements where VPP relies on hazard analysis. A major advantage of VPP is the 3rd party review and certification (OSHA).
Some professionals have argued that VPP is not an SMS because it lacks clear guidelines that require compliance with OSHA regulations and does not specifically require and spell out feedback loops to drive continuous improvement. The counter position points out that the OSHA Act requires compliance and OSHA did not have to restate it. Likewise there are many natural feedback loops in the VPP model that during certification OSHA requires being present.