ISO 26000:2010 (Social Responsibility Guidance) Released Reply

The ISO 26000:2010 social responsibility guidelines have been finalized and published.  It is now possible to add social responsibility “core subjects” from these new guidelines to an ISO 14001:2004 or ISO 9001:2008 program.  This would create an integrated sustainability management system. The ISO 26000:2010 guidelines cannot be used alone as a sustainability management system.

CAPACCIO thinks ISO 26000:2010 will facilitate the development of effective sustainability programs since it clearly articulates a wide range of social responsibility issues that sustainable companies need to watch closely; e.g., community involvement, human rights, labor issues, and consumer/customer issues.  Incorporating conformance to social issues within a management system will help coordinate those who manage the environmental responsibilities with those that manage the social responsibilities.

A recent survey (found here) found that 86% of employees are not engaged by their employers on sustainability even though the same amount – 86% – said that their organization promotes employee sustainability.  It is possible to engage employees more effectively using a management system rather than relying only on training and awareness.  A properly implemented management system can make sustainability part of what every employee does every day by including it in the work instructions and every aspect of their involvement with the organization.  CAPACCIO is already seeing this make a difference with our clients that are integrating their sustainability efforts directly with their management system efforts.  The new ISO 26000:2010 standard will make this effort easier and more effective.

CAPACCIO is preparing a “white paper” on how to use ISO 26000:2010 with your management systems.  Please reserve a copy by contacting Bob Pojasek at rpojasek@capaccio.com or calling him at 508-970-0033 extension 137.

The Vision of OSHA Reply

On October 15, 2010, OSHA Assistant Secretary, Dr. David Michaels sent a letter to all OSHA personnel that outlined the progress being made to transform the agency.  This letter was an update to a July 19 document Michaels issued to OSHA staff, “OSHA at Forty: New Challenges and New Directions.” In his July letter, Michaels discussed transforming OSHA by focusing on nine areas.

  1. Stronger Enforcement
    OSHA is increasing its inspection activity and imposing more stringent penalties.  OSHA has shifted its employees from compliance assistance to enforcement and plans to hire additional enforcement officers. OSHA conducted 40,600 total inspections during Fiscal Year 2010, compared to 39,004 inspections during Fiscal Year 2009.

    OSHA is issuing more press releases that explain more clearly why a specific employer was cited. “The primary purpose of our enforcement program is deterrence.  By inspecting workplaces and issuing and publicizing penalties where violations are found, we hope that all employers will recognize the risk they take by not abating serious hazards,” wrote Michaels in his October letter.

    OSHA will be changing the way that it calculates penalties.  An outline of the changes can be found here:  http://www.osha.gov/dep/administrative-penalty.html

  2. Ensure workers have a voice
    OSHA is reaching out to vulnerable workers who may be low pay, non-English speaking, low literacy, or not in a labor organization through events like the National Action Summit for Latino Worker Health and Safety.  Workers must know about their rights under the law and feel that they can exercise those rights.  OSHA is reviewing the Whistleblower Protection Program and ensuring that officers talk to workers privately and confidentially during inspections.
  3. Refocus and Strengthen Compliance Assistance Programs
    OSHA is refocusing its compliance assistance programs.  Michaels still supports programs like the Voluntary Protection Program (VPP), but the funding has been redirected to focus on enforcement.  OSHA will develop more compliance assistance materials that all workers can understand and use.
  4. Change Workplace Culture
    OSHA seeks to improve the workplace safety culture, so that employers do not merely just do what’s necessary to comply with OSHA standards.  Employers must “find and fix” all workplace hazards.  This does not just apply when there is a particular hazard covered by an OSHA standard.  This change in culture would require employers to implement risk-based safety programs and focus on hazard assessment and control.
  5. Develop Innovative Approaches to Addressing Hazards: Improve Intra-Agency Cooperation
    OSHA is working to ensure that directors and field operations personnel work together closely and cooperatively.  OSHA will improve its coordination with other agencies whose work is closely aligned, such as the Environmental Protection Agency (EPA) and the National Institute of Occupational Safety and Health (NIOSH).
  6. Improve and Modernize Workplace Injury and Illness Tracking
    OSHA is concerned that employers may be under-recording or incorrectly reporting injuries on the OSHA 300 log. Injury and illness data that is reported to OSHA is used to target inspections.  Under the Recordkeeping National Emphasis Program (NEP), OSHA has conducted 187 inspections and found recordkeeping violations in almost 50% of the inspections.  OSHA is looking into electronic recordkeeping programs in order to obtain more up-to-date information and better focus NEPs. 
  7. Strengthen OSHA’s use of Science
    OSHA is going to begin addressing the outdated Permissible Exposure Limits (PELs), many of which were developed in the 1970s.  Also, there are many chemicals for which a PEL has not been developed.  OSHA held a web forum and received 130 nominations for chemicals that should be added to the list. 
  8. Conduct OSHA’s work with transparency
    OSHA will share useful information with people.  For example, OSHA is posting employer specific injury and illness data and sampling data results.  The sampling data from OSHA inspections can be found on the web and accessed at: www.osha.gov/opengov/healthsamples.html
  9. Strengthen state OSHA plans
    OSHA evaluated the operation of 25 State Plans to ensure that there are not problems with the state-run programs.  OSHA found that many State Plans were operating effectively, but also found some Plans with discrepancies that OSHA will begin to address. 

For your information, below are some other OSHA updates which were not addressed in the above nine areas which may be of interest.

Injury and Illness Prevention Program
OSHA is developing a rule that would require employers to have a written safety and health program that would be referred to as an Injury and Illness Prevention Program. 

Even if a hazard is not regulated under a specific standard, developing programs to control hazards is required under the General Duty Clause.

Severe Violator Enforcement Program
OSHA’s Severe Violator Enforcement Program (SVEP) concentrates resources on inspecting employers who commit willful or repeated violations or fail to abate previously issued violations.  Michaels said in the press release outlining the SVEP, “For many employers, investing in job safety happens only when they have adequate incentives to comply with OSHA’s requirements.  Higher penalties and more aggressive, targeted enforcement will provide a greater deterrent and further encourage these employers to furnish safe and healthy workplaces for their employees.” Once an employer is placed in the SEVP, OSHA may conduct enhanced follow-up inspections and inspections of the other locations of the employer.

Site Specific Targeting Program
OSHA is targeting select high-hazard workplaces where the highest rates of injuries and illness occur.  Based on injury and illness data, OSHA developed a list of 4,100 facilities and will randomly select employers to inspect.

Recordkeeping National Emphasis Programs (NEP)
OSHA adjusted the Recordkeeping NEP to focus on larger worksites with higher injury rates.  The NEP is scheduled to run through February, 2012.   

Most Frequently Cited Standards
OSHA published its list of the most frequently cited standards during Fiscal Year 2010 (October 1, 2009- September 30, 2010).  At the top of the list for general industry was the Hazard Communication Standard, followed by Respiratory Protection, Ladders and Lockout/Tagout.   http://www.osha.gov/Top_Ten_Standards.html

For more information or if you would like assistance with any of your Health and Safety programs, contact Colleen Walsh at cwalsh@capaccio.com or 508.970.0033 extension 129.

Growing Number Of Manufacturers Embracing Sustainability Reply

The New York Times (6/12, B3, Bhanoo) reported many of the soccer teams at the FIFA World Cup in South Africa “are wearing jerseys made almost entirely from plastic bottles rescued from landfills in Japan and Taiwan.” Although “many might view [this] as a gimmick,” the move is “also part of a broadening effort by the company to incorporate sustainability, or environmentally responsible practices, into its product design. Around the globe, a growing number of manufacturers are including more recyclable or biodegradable components into products.” The Times noted, “Companies making changes run the gamut – there are furniture makers, carpet manufacturers, clothing retailers and makers of shampoos and household cleaners. And with big-box retailers like Wal-Mart joining in, industry analysts say the sustainable philosophy is no longer viewed as the province of high-end sellers like Nike or Herman Miller, the furniture maker.”

New International Sustainability Management System Standard Reply

After over five years and nearly 2,500 written comments, the International Organization for Standardization (ISO) has announced that it will release a final draft of ISO 26000 (international standard for social responsibility) for a two-month vote (August and September) by ISO member countries. Following the vote, it will become published as a full-fledged ISO International Standard by November, 2010.  This new standard will be in the form of a guidance document like ISO 14004 (environmental management system guidance).  You will not be able to certify to this standard.  Instead, by using the information in the document, your company will be able to convert an ISO 14001 (EMS) into a sustainability management system (SMS).

So what does this mean to you?  While the standard refers to “social responsibility,” it is really outlining what most people are calling “sustainability.”  They have taken all of the three responsibilities of sustainability and divided them into manageable “core subjects.”  For example, there are core subjects on environment, consumer issues, community involvement, labor practices and a number of other social and economic topics.  The current draft has one of the best set of consensus information on each of these topics and how they can relate to a sustainability program.  Like other ISO documents, this standard is not prescriptive.  The guidance clearly states that companies can select the core subjects that pertain to their operations and determine what each should cover.  If you wish to start with environmental sustainability, that is fine.  Social and economic core subjects can be added at a later time.

Next, the ISO 26000 guidance addresses a set of principles that should be considered when planning, implementing and maintaining a sustainability program.  This is very helpful since guiding principles are very important in adapting the program to take advantage of the company culture.  Companies that have already implemented sustainability programs can strengthen them using this new standard.

Finally, the ISO 26000 document provides guidance on how to integrate sustainability throughout the organization.  This is very important to implement a corporate sustainability program at the facility level and make it part of what every employee does every day.

We will be posting more blogs on this topic.  Since this guidance already exists in draft form, there is little need to wait until the final publication to start creating an integrated SMS for your company.