During the November OFFSHC meeting Stephanie Schroeder, OSH Specialist, provided an overview of Safety Management Systems to include OSHA VPP, OHSAS 18001 and ANSI Z10. She discussed the challenges and successes that the FAA has experienced while implementing these systems.
3. FAA Mike Monroney Aeronautical Center
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1,100 acres of land
125 buildings with 3.5 million square feet of space
Approximately 7,500 employees and 1,300+ students daily
Largest concentration of DOT employees outside of
Washington DC
• Customer Base
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Entire FAA
All branches of DOT
Other Federal Agencies
Foreign Governments
Passengers, Pilots, media, aircraft owners, and commercial air carriers
Safety Management Systems – OFFSHC
November 2013
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4. Move from Compliance to Best Practices
Best
Practices
OHSAS 18001
ANSI Z10
VPP
Other Requirements
(FAA, Corporate,
Consensus Standards)
Regulatory Requirements
(OSHA)
Safety Management Systems – OFFSHC
November 2013
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5. Challenges
• Large Campus
• Diverse Activities
• Management from different locations
and at different levels
• Tenant Organizations
• Red Tape
• Limited Resources
• Compliance
Safety Management Systems – OFFSHC
November 2013
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6. Safety Management Systems
SMS utilized by MMAC
• OSHA Voluntary Protection Program
• OHSAS 18001:2007
• ANSI Z10:2012
Safety Management Systems – OFFSHC
November 2013
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7. SMS Elements Comparison
VPP
OHSAS 18001:2007
ANSI Z10: 2012
Scope
Scope, Purpose and Application
Reference Publications & Terms
Definitions
Management Leadership &
Employee Participation
OH&S Policy
Management Leadership and
Employee Participation
Planning
Planning
Implementation and Operation
Implementation and Operation
Checking
Evaluation and Corrective Action
Management Review
Management Review
Hazard Prevention and Control
Safety and Helath Training
Employee Participation
Worksite Analysis
Safety Management Systems – OFFSHC
November 2013
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8. VPP Elements
VPP
OHSAS 18001:2007
ANSI Z10: 2012
Scope
Scope, Purpose and Application
Reference Publications & Terms
Definitions
Management Leadership &
Employee Participation
OH&S Policy
Management Leadership and
Employee Participation
Planning
Planning
Implementation and Operation
Implementation and Operation
Checking
Evaluation and Corrective Action
Management Review
Management Review
Hazard Prevention and Control
Safety and Helath Training
Employee Participation
Worksite Analysis
Safety Management Systems – OFFSHC
November 2013
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9. VPP Program Requirements
• Management Leadership and
Employee Involvement
• Worksite Analysis
• Hazard Prevention and Control
• Safety and Health Training
Safety Management Systems – OFFSHC
November 2013
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10. VPP at MMAC
• Approved as Merit Site in 2004
– Employee Involvement
– LOTO Program
• Reapproved as Merit Site in 2008
– Employee Involvement
• Withdrawal from VPP in 2010
– Considered changing application format
– Moved towards OHSAS 18001
Safety Management Systems – OFFSHC
November 2013
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11. Benefits during VPP Participation
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Reduced injury and illness rates by 50%
Increased visibility of EOSH Staff
MMAC further evaluated SMS approach
Established SMS as a business goal
Safety Management Systems – OFFSHC
November 2013
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11
12. 18001 Program Elements
VPP
OHSAS 18001:2007
ANSI Z10: 2012
Scope
Scope, Purpose and Application
Reference Publications & Terms
Definitions
Management Leadership &
Employee Participation
OH&S Policy
Management Leadership and
Employee Participation
Planning
Planning
Implementation and Operation
Implementation and Operation
Checking
Evaluation and Corrective Action
Management Review
Management Review
Hazard Prevention and Control
Safety and Helath Training
Employee Participation
Worksite Analysis
Safety Management Systems – OFFSHC
November 2013
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13. OSHMS Manual
• OSHMS procedures for:
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Identifying Significant OSH Hazards*
Setting Objectives and Targets
Legal and Other Requirements
Establishing Operational Controls
Communication*
Emergency Preparedness
Control of Documents and Records
Conducting Audits and Management Reviews*
Safety Management Systems – OFFSHC
November 2013
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14. Risk Assessments
• Applied to activities within each organization
• Measures the Risk
– Usage
– Severity of Injury
– Likelihood
• Identified Priority
Safety Management Systems – OFFSHC
November 2013
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15. Communication, Participation
and Consultation
• External and Internal communications
• Meetings
– OSH Representatives
– Management and Labor
– Organizations
• Employee participation
– Incident investigations
– Hazard identification
Safety Management Systems – OFFSHC
November 2013
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16. Audit Program
• Not a Compliance Audit
• Minimum of Two OSHMS Audits per Year
– One Internal & One External
• Audits consist of:
– Document Review
• OSH Documents – Operational Controls, SOP’s
• Records – Training certificates, Maintenance Logs
– Walkthrough
– Interviews
Safety Management Systems – OFFSHC
November 2013
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17. Management Review
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Gauges OSHMS performance annually
Covers key elements of the OSHMS
Reaffirms objectives and targets
Assess continual improvement
Safety Management Systems – OFFSHC
November 2013
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18. OHSAS 18001 at MMAC
• MMAC Certified September 2010
– Root Cause Analysis
– Corrective Action Tracking
• Recertified in May 2013
– Emergency Preparedness
• Integrating EMS & OSHMS
• Automate Change Management
Safety Management Systems – OFFSHC
November 2013
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19. Benefits of 18001
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Employee Involvement
Program Documentation
Continual Improvement of OSHMS
Prioritization
Safety Management Systems – OFFSHC
November 2013
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20. ANSI Z10 Program Elements
VPP
OHSAS 18001:2007
ANSI Z10: 2012
Scope
Scope, Purpose and Application
Reference Publications & Terms
Definitions
Management Leadership &
Employee Participation
OH&S Policy
Management Leadership and
Employee Participation
Planning
Planning
Implementation and Operation
Implementation and Operation
Checking
Evaluation and Corrective Action
Management Review
Management Review
Hazard Prevention and Control
Safety and Helath Training
Employee Participation
Worksite Analysis
Safety Management Systems – OFFSHC
November 2013
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21. ANSI Z10 2012
• FAA Flight Inspection Services
– Initial stages of implementation at MMAC
– Six line stations for aircraft maintenance
• Implement system framework
• Conducted Gap Analysis in 2010
• Established Internal Audit Process
Safety Management Systems – OFFSHC
November 2013
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24. Associated Costs
• VPP
– Promotional Materials
– VPP SGE Support
• OHSAS 18001
– Annual External Audit Team
– Internal Audit and Corrective Actions
– Document Maintenance
• ANSI Z10
– Risk Assessments
– Continual Improvements
Safety Management Systems – OFFSHC
November 2013
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25. MMAC Benefits from SMS
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OSHA recordable accidents reduced by 88%
Reduced inspection findings and severity
OSH program moved into best practices
Greater employee participation
OHSAS 18001 certified in 2010
Estimated cost savings of $10 million in direct
and indirect costs since FY 2001
Safety Management Systems – OFFSHC
November 2013
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26. Implementing an SMS
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Choose a method and move forward
Ensure top management commitment
Involve employees in every step
Include independent verification
Focus on continual improvement
Safety Management Systems – OFFSHC
November 2013
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27. For More Information
• Contact
– Stephanie Schroeder, CSP
• Stephanie.Schroeder@FAA.gov
• 405-954-0371
Safety Management Systems – OFFSHC
November 2013
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Editor's Notes
During this briefing we will discuss the implementation of SMS at FAA MMAC. We will discuss the various SMS that MMAC has implemented and how they have functioned. We will discuss the benefits and challenges we experienced and how each was overcome. We will also discuss our continued growth.
Initial MERIT site approval required MMAC improvement in quarterly inspections and LOTO programs. Escalation to a STAR site required more employee involvement from our 6000 employees. Due to the various reporting structures and different bargaining unions MMAC had challenges to display enough employee involvement to meet VPP STAR levels. OSHA suggested breaking the different MMAC groups (ie. Hosts and tenants) into smaller subgroups and reapplying in as many as six different applications.
Conditioned FAA management to understand the benefits of SMS
The Occupational Health and Safety Assessment Series (OHSAS) 18001 is an occupational health and safety management system (OSHMS) standard used to promote a safe and healthy working environment. The OSHMS focuses on reducing risk to the lowest level practicable.Ensures compliance with regulations and other requirementsCompatible with ISO 14001OHSAS 18001:2007 is an internationally accepted standard that defines the requirements for establishing, implementing, and operating a management system. It provides an organization with a structured approach to planning, implementing and managing an Occupational Safety and Health Management System, commonly referred to as the OSHMS. OHSAS 18001 was designed to be compatible with ISO 9001 Standard and the ISO 14001 standard. 18001 benefits the organization by reducing the potential for accidents and the their associated costs. 18001 also ensures compliance with OSH regulations and other requirements.The MMAC Occupational Safety and Health Management System, commonly referred to as the OSHMS, is a framework that allows the Aeronautical Center to consistently identify and control safety and health risks, reduce the potential for accidents, assist in achieving and maintaining compliance with safety and health regulations, and to continually improve OSH performance. The Aeronautical Center’s OSHMS is based on the OHSAS 18001:2007 criteria.History/evolution of our OSHMS The Mike Monroney Aeronautical Center’s Occupational Safety and Health Management System was originally certified by ABS Quality Evaluations to be in conformance with OHSAS 18001:2007 on September 30, 2010.The goal of an OSHMS is to allow an organization to control its OH&S risk and improve its performance.
OSHMS manual serves as the repository for documentation related to the OSHMS. The manual contains all of the plans and procedures for the successful implementation and operation of the safety management system. This includes instructions on identifying significant OSH hazards, setting objectives and targets, establishing operational controls, communication, control documents and records, and conduct internal audits and management reviews.The standard only requires that certain procedures be documented.OHSAS 18001 is based to the Plan – Do – Check – Act Model. In the planning phase organizations establish the objectives and processes necessary to deliver results in accordance with the organization’s OSH policy. In the Do phase, the organization implements the processes and procedures. The checking phase consists of monitoring and measuring the processes against the OSH policy, objectives, legal and other requirements, and reports the results. Once the results of checking phase are complete, the organization then takes action to continually improve OSH performance.Give some examples of activities that fall into each of the categories (and state that we’ll be further discussing these activities later in the presentation.Plan : Hazard ID (risk assessments and determining controls), Legal and other requirements, Objectives and ProgramsDo: Training, Communication, Participation and Consultation, Documentation, Control of Documents, Operational Controls, Emergency Preparedness Check: Monitoring and Measuring (of performance), Evaluation of Compliance, Incident Investigation, Nonconformity, Corrective Action and Preventive Action, Audits, and Management ReviewAct: Act upon outputs of the above items in the “check” section (e.g. audits, management review, etc)We’re not able to go into detail about each of them and will only be discussing some of the more important ones today.
Risk assessments have been performed for activities within each organization with identified hazards. The assessment assigns a risk score to each activity by measuring how often the activity is performed, the severity of injury that could potentially be caused by the activity, and likelihood of injury may occur. Activities that score above the minimum risk threshold are deemed to be Significant OSH Hazards. Each location, activity, and hazard assessedRisk Assessment (RA). Facility-specific risk assessments are used to assess the residual risks associated with the significant hazards in a facility or in a portion of a facility with existing controls in place. ……also now have general and activity-specific risk assessmentsControl. Any engineered system or feature, protective equipment, or administrative measure that eliminates the hazard or reduces its likelihood of causing an injury or illness. Usage. The rate at which a specific facility is occupied or task is performed. There are five classes of usage: Less than or equal to once per year.Less than or equal to once per month.Less than or equal to once per week.Less than or equal to once per shift.Greater than once per shift. Hazard. Any existing or potential condition in the workplace that, by itself or by interacting with other variables, can result in injury or illness. Likelihood. The chances that an event will lead to undesirable consequences, when the scenario is carried out identically in each event. The five classes of likelihood are:Extremely unlikely. (1 consequence in 1000 events).Unlikely. (1 consequence in 500 events).Possible. (1 consequence in 250 events).Probable. (1 consequence in 50 events).Expected. (1 consequence in 25 events).Risk. In this context, risk is the product of the usage, likelihood, and severity; given equal weight. Points for usage, likelihood, and severity are based on the ranking system provided in this chapter. A specific range of point values (1 to 125) for risk is associated with one of five descriptive classes of risk: negligible, minor, moderate, serious, and imminent danger. For those items, activities, and/or tasks classified as either “Serious” or “Imminent Danger” additional controls may be needed for these hazards. Risk classification resulting from an FRA requires specific actions: Imminent Danger: shall be verified and abated as soon as possible. Work in area may be suspended until the risk can be re-classified as no greater than serious risk.Serious Risk: requires development and implementation of a written remedial action program with specific objectives and targets. Moderate and Below Risk: addressed through the organization’s normal objective-setting and planning process. Appropriate personnel shall be assigned to review all changes and modifications to facilities. Where hazards have been introduced or resolved, personnel shall conduct a follow up RA of the area or facility. AMP-100 reviewsall RAs at least once every three years. Reviews ensure that risk assessments reflect current facilities, jobs, hazards, and hazard classifications.
Ten significant OSH Hazards categorizes have been identified across the center. These include: biological, chemical, electrical, ergonomics, fallsThese are the same hazard categories that are used with the compliance inspections and the JHAs.Biological Splash, spray, needlestick or other physical contact to human by organisms or products of organisms that present a hazard to humans. MMAC potential exposures include: blood Bourne pathogens (BBP), blue water, metal-working fluids and bird droppings. Chemical Health impacts caused by exposure to chemicals. Exposures can result from absorption, skin contact, inhalation, ingestion or injection. MMAC potential exposures include: solvents, paints, heavy metals (cadmium, lead, chromium, etc.), asbestos, PCBs, fuels and oils. Electrical Electrical shock is the flow of electrical current through the body. Electrical arc is the flow of electrical current through the air gap between two conductors. Electrical blast is the rapid expansion of air caused by an electric arc. Unexpected energization functions as a control for electrical hazards. Ergonomics Physical factors within the work environment that harms the musculoskeletal system due to damage of tissue, overexertion (strains and strains) or repetitive motion. MMAC potential exposures include: improper lifting, incorrect workstation layout, body positioning and tool design.Falls Workplace condition that may result in a fall from height, fall to lower level or fall to same level. MMAC potential exposures include: aerial lift platforms, permanent and temporary work platforms, tower or dome work, ladders, scaffolding, roofing, dock areas and floor openings.
Fire/Heat Condition that may result in uncontrolled combustion, explosion or release of heat or pressure. MMAC potential exposures include: ignition of flammable materials; reaction, ignition or explosion of chemicals; electrical overloading of circuits or rupture of a boiler.Noise Continuous or impact noise levels that may result in temporary or permanent hearing damage. MMAC potential exposures include: aircraft operations, industrial equipment and impact noise. PhysicalInteraction between individual and equipment which has a physical affect on human body. May result in being struck by or struck against, crushing, cutting, thermal contact burns and vibration. MMAC potential exposures include: sharp points, pinch points, lockout/tagout activities, overhead falling objects, or soil collapse during excavation.Radiation Ionizing Radiation: Energy or particles that can cause injury (tissue damage) by ionization of cellular components. MMAC ionizing radiation potential exposures result from the following radiation sources: long range radar systems, non-destructive testing, medical or package screening X-rays.Non-Ionizing Radiation: Energy or frequency that causes tissue damage by thermal burn or vibration. MMAC potential exposures result from the following radiation sources: radio, radar and microwave transmitting equipment and shrink wrap machines. Respiratory Loss of consciousness by impairing normal breathing resulting death or disability. May be caused by noxious agents, lack of oxygen, or physically preventing breathing. MMAC potential exposures include: drowning, confined spaces and excavation hazards.Temperature ExtremesConditions that exposure personnel to heat or cold extremes. Temperature that results in heat stress, exhaustion or metabolic slow down such as hypothermia. MMAC exposures may include: outdoor work, radome work, warehouse operations and freezers.
OFFSHCContractor ActivitiesVisitor Activities
(CONFORMANCE)Audits are performed as necessary to determine that the OSHMS is properly implemented in accordance with 18001. Generally two audits are performed each year; one external audit and one internal audit. The audits consist of document review, where auditors look at your OSH documents such as operational controls and training records, site walkthroughs, and interviews with both management and staff.
Management reviews are conducted annually to gauge whether the OSHMS continues to be effective, suitable, and adequate for the MMAC. During the review, management is presented with sufficient information to determine the progress and make necessary decisions or authorize appropriate actions to continually improve the OSHMS. Some of the inputs to the management review: -Results of internal audits-Communications with internal and external parties-The extent to which objectives have been metSome of the outputsOSH PerformanceOSH Policy and ObjectivesResources
This org has held safety stand downs for more than 10 years. These are coordinated and hosted by employees in each area. Employees conduct initial risk assessments followed by a review by EOSH staff for clarity/consistentcy.