Topic III: Health and Safety Programs -- Risk Assessment

  1. The work group strongly believes that safety and health management systems (SHMS) can significantly contribute to safe and healthful workplaces.
  2. We encourage the competent authorities in the US and the EU to continue with the development of requirements for SHMS.
  3. SHMS should address both traditional hazards and issues of work organization which affect safety and health. This is especially important because changes in work organization can increase risks to workers. 
  4. Two essential conditions for an effective SHMS are management commitment at all levels of the organization, and the participation of workers and their representatives. 
  5. There is limited statistical, peer-reviewed evidence on the impact of SHMS on actual injury and illness rates. This is due in part to the unreliability of injury and illness data and to the long latency period for many occupational diseases. Nevertheless, there is extensive anecdotal evidence that SHMS are effective in eliminating hazards and reducing risks. In addition, incident investigations frequently identify the lack of, or ineffective application of a SHMS as a contributing factor. Taken as a whole, and with the understanding that additional research is always desirable, the existing evidence provides strong support for SHMS. 
  6. SHMS are fully justified on the grounds of safety and health. In addition, the elimination and control of hazardous conditions has ancillary benefits, including reducing the societal burden of disease and disability, and improvements in corporate productivity, quality, morale and reputation. 
  7. While risk assessment was the primary focus of the work group, risk assessment is only one aspect of an effective SHMS. For example, risk assessment is useless without a mechanism for eliminating or reducing risks. 
  8. While SHMS should be mandatory in all workplaces, the requirements should be flexible, and should be designed to facilitate compliance by small and medium enterprises. 
  9. Key elements of an effective SHMS include:
    • mechanisms for leadership and participation by all levels of management and by workers and their representatives;
    • defined roles, responsibilities and authority;
    • the identification of applicable legal requirements and their application;a process for hazard identification and risk assessment;
    • procedures for investigating work-related injuries, illnesses, accidents, incidents, process upsets, deficiencies and concerns;
    • a method for evaluating the safety and health implications of the initial design of, and changes in, technology, processes, materials, equipment and work organization;
    • a mechanism for addressing the results of risk assessments, investigations and evaluations, and assuring that identified risks are reduced or eliminated through a hierarchy of controls giving substitution, engineering controls and changes in work organization priority over personal protective equipment;
    • a method for addressing the safety and health of contractors and contracted work;
    • a process for assuring that safety and health is considered in procurement decisions, including design specifications, product selection procedures, and quality control;
    • appropriate and effective education and training;
    • appropriate metrics, including leading indicators like audit results, process deviations, exposure information and the time it takes to correct problems;
    • a method for documenting and tracking problems and corrections;
    • a process for assuring communication and transparency throughout the application of the SHMS;
    • regular evaluations of the SHMS, with the aim of continuous improvement; and
    • a process for assuring that sufficient resources are allocated to implementing and sustaining the SHMS.
  10. Given the importance of accurate information, workers should be encouraged to report injuries, illnesses, accidents, incidents, deficiencies and concerns. There must be no policy, practice or program which penalizes or discourages such reporting. 
  11. Risk assessment and preventative action are essential in any workplace, and are required by law for all workplaces in the European Union. 
  12. Risk assessment can be made more effective and less burdensome through user-friendly, interactive tools such as those currently used in the Netherlands and under development by the European Agency for Safety and Health at Work. Simple, easy to use tools are especially important for small and medium enterprises. 
  13. Risk assessment tools should be developed, both for routine operations and for non-routine tasks such as infrequent maintenance procedures and responding to upset or emergency conditions, which often involve higher risks. 
  14. The development of risk assessment tools by the competent authority should be done with the participation of employers and worker representatives. Likewise, the development of risk assessment tools by employers should be done with the participation of worker representatives. 
  15. The application of risk assessment tools to particular enterprises or tasks is the responsibility of employers, but it should be done with the participation of workers and their representatives. 
  16. The development of risk assessment tools is an important area for US-EU collaboration. That collaboration and the development of such tools in general, must be adequately resourced. The collaboration should begin with:
    • developing and exchanging information on the effectiveness of SHMS;
    • further discussion of leading indicators that predict SHMS performance; and
    • continued work on the application of SHMS to concrete issues, in particular, chemical safety at work and problems of work organization.