Block 3: Occupational Health Management - Section 2: Occupational Health Programme
OHM2.2: A 10 step approach to establishing an Occupational Health Programme

A 10-Step approach to the Occupational Health Programme:  

GEORGE THIS IS A BIT JUMBLED UP

MY COMMENTS ARE INBLACK CAPS AND THEN GREG'S RESPONSES ARE IN BLUE LOWER CASE. MY RESPONSES TO HIM ARE IN UPPER CASE AFTER HIS COMMENTS

THE BOTTOM LINE IS THAT THE BASE TEXT IS STILL IN HERE AS IS WITH SOME ADDITIONS AND THEN THERE ARE A NUMBER OF SUGGESTIONS FOR RESOURCE MATERIALS THAT NEED TO BE LINKED TO THIS PAGE FROM THE SYNERGEE CD.

 

Introduction:

All Health and Safety programmes have, as a core process, a common sequence of events. These are the 10 steps described below. Depending on the scope of the programme envisaged, all evaluated hazards can be included in the process described below. Alternatively, one specific hazard (noise) could be the focus and the process still applies.
Step 1-3: Health Risk Assessment (HRA) (hyperlink to the HRA Guideline)

This is the process whereby the hazards in the workplace are evaluated in terms of their potential risk to the health of the employees. Remember that a hazard is not a risk unless there is significant potential exposure. Hence risk is a function of harmfulness ("consequence") and degree of exposure ("probability"). HRA’s should take into account both of these components, not only simply listing the hazards, but prioritising them according to their composite risk. HRAs vary in their intensity according to the requirements of the company. They can be very simple (a Hazard Scan), or very complicated. Complexity should only be necessary in companies where toxic materials are handled by a number of people or where hazards exist which pose serious threats to health. Often a Hazard Scan is used as a first step in complex HRAs. Whatever the complexity, the outputs are essentially the same - Steps 1, 2 and 3 of the process (see below).

Step 1: Occupational Risk & Exposure Profiles ("OREPs") (hyperlink to the OREP SOP)

This step outlines the key features of each occupation in the company - including the inherent requirements (ARE THESE THE FITNESS STANDARDS? Yes, indeed!! WHERE CAN THEY BE ACCESSED BY WAY OF LINKAGE FROM HERE TO ANOTHER DOCUMENT The Inherent Requirements standards are recorded in tables which are built into the OREP SOP. On the disc.) to meet the standards allocated to the job, as well as a description of the potential health risks to which this job is exposed. OREP stands for Occupational Risk Exposure Profile. Line management is best placed to complete these documents, with the assistance of the medical staff, instructions and guidelines ?HOW ABOUT LINKS HERE TO THE INSTRUMENTS. Absolutely. The hyperlink at the subheading for step 1 would probably suffice (see top of paragraph). The establishment of rational OREPs is critical to the rest of the programme and particularly to the development of defendable recruitment practices in terms of the Labour Relations Act and Employee Equity Act (Step 5).

Step 2: Hazardous Substance Risk Assessment (hyperlink to the Toxicology SOP)

This step covers the detailed evaluation of all the hazardous substances (especially the chemicals) in the company. This includes a listing of all the substances, followed by a detailed analysis of their toxicological effects on the human body (taken from reliable material safety data sheets (MDSDS’s). When this is completed, the various chemicals are linked with the occupations and workplaces where the exposures take place. This is performed by the use of specially designed analytical datasets. WHAT ARE THESE? Tee hee. These are my jaw-droppers. An example is on the cd, under "SYNERGEE\STARTER PACK\03 - PROJECT MANAGER - HRA\HRA Forms & Templates\02 - Haz Chem Substances\Databases, and called "Toxicology Profile" (Excel spreadsheet). The version you have has since being substantially updated. I will have to show you how it is used to transform the modern approach to Chemical Risk Assessment!! I am uncomfortable with putting this file on the disc, as it is commercially valuable, and carries some company stuff. But, I am willing to work at this and find a way to make something available, that can be "played with". GREG TO PROVIDE A SCALED DOWN VERSION AS AN APPROACH TO THE TOPIC

Step 3: Workplace Health Risk Assessment ("WREPs") (hyperlink to the WREP SOP)

This step covers the detailed evaluation of health risks in the various working places of the company. WREP stands for Workplace Risks & Exposure Profiles, which is the workplace equivalent of the OREP. The use of checklists and inventories is essential. It provides a useful crosscheck of the information collected for the OREPs. This is conducted by those trained in health risk assessment, such as the risk officer, occupational health nurse and doctor, but can also be conducted by trained line staff and health & safety representatives.  NEED TO EXPLAIN WHY THESE ARE NECESSARY IN ADDITION TO OREPS.  NEED SOME SORT OF SUMMARY HERE   - OCCUPATIONS, WORKPLACES AND SUBSTANCES CARRY HAZARDS AND PROBABILITY OF EXPOSURE TOGETHER WITH KNOWN EXPOSURE EFFECTS.  Hmmm. These concepts (reasons for OREPs plus WREPs, and their relationship) are explained in some detail in the HRA Guideline and the HRA Policy. Could we not refer to these documents, or even include links?  GREG TO PROVIDE A SUMMARY EXPOSITION OF THE RELATIONSHIP AND WHY OREPS ARE IMPORTANT FROM THE POINT OF MEDICAL SURVEILLANCE AND PARTICULARLY LINKING EXPOSURE SURVEILLANCE IN A MEANINGFUL MANNER TO HEALTH SURVEILLANCE RATHER THAN THE CURRENT RELIANCE ON THE WREP APPROACH ONLY WHICH IS VERY DIFFICULT TO RELATE TO MEDICAL SURVEILLANCE.

WE ALSO NEED A WORKED EXAMPLE OF EACH  WHICH CAN BE LINKED - USE A HYPOTHETICAL WORKPLACE TO ILLUSTRATE THE POINTS.  THIS IS TYPICALLY CONFUSING FOR PEOPLE AS THE NAME HRA IS QUITE THREATENING TO ALL CONCERNED.  IT WOULD BE GOOD TO UNPACK THIS BY WAY OF EXAMPLES ESPECIALLY SHOWING THE LINKAGES BETWEEN COMPONENTS AND STEPS.  Good idea. I will work on something. It can also be something that they should work towards during their factory visit exercise.

THERE ARE SOME STEPS MISSING THUS FAR AS YOU GO ON TO THE RISK MATRIX IN THE NEXT STEP WITHOUT DEFINING IT Good point. Sometimes one cannot see the wood for the trees! Once again, this is covered in detail, with an illustraive example, in the HRA policy. It reads as follows: 

The Risk Matrix is the formal documentation of the results of the Risk Assessment, listing all the elements of the assessment in a single record, including location and exposure group. It comprises a matrix of the following:

·         Down the left (vertical) axis, is a list all the occupations, grouped by their departments and other relevant demographics, (such as cost centre). The choice of demographic data included is limited only by the needs of the programme co-ordinator.

·         Along the top (horizontal) axis is a list all the various possible hazards, recorded in the OREPs.

The relevant fields are populated by risk-related data, in an easy to see format (“blank” means not applicable, and asterisks from * - ****, indicating degrees harmfulness, exposure or risk, from low (*) to extreme (****)). Instead of asterisks (*), numbers from 1-4 can be used.

+          Illustrative images of a Risk Matrix are presented in the Tables in the HRA Appendix.

Analysis of this data enables easy evaluation of the risks (high or low) associated with various workplaces, departments and occupations, for every conceivable hazard. Inter-departmental and cross-occupational comparisons are therefore easy. Furthermore, subsequent risk reduction interventions are used to update the matrix, thereby enabling trends downwards, or upwards.

This enables rapid comparative analysis of relative risk, across the organisation. It is also a powerful tool for planning and organising proposed risk reduction strategies, and measuring the effects of these strategies.

KEY ASPECTS OF THE HRA POLICY NEED TO BE INSERTED AS A RESOURCE   - EITHER THE WHOLE THINK AND GEORGE CAN HYPERLINK TO RELEVANT SECTIONS OR TO A POTTED SUMMARY WHICH GREG MAY WISH TO DO.

Step 4: Training

The Occupational Health and Safety Act and Regulations repeatedly refer to the employer’s obligation to provide sufficient training to employees in order to enable them to protect themselves from unnecessary health risk. Its importance is reflected in its repeated reference throughout this piece of legislation, most notably the Occupational Health and Safety Act, Section 13(a), in which it requires employees to be conversant with the hazards of the job. This training is largely determined by the outcomes of the HAZOC Risk Matrix YES WE NEED TO LINK TO THIS - WHY HAS IT NOT YET BEEN MENTIONED?(Note from GRD: what is this and should we define it somewhere?) and OREPs, which outline the potential health risks and the job’s inherent requirements. The HAZOC Matrix is a term that has been phased out of my documents - this particular word must have have escaped my searching eye! Please replace with "Risk" Matrix. It is described in detail in the HRA Policy and the HRA Guideline.

Step 5: Recruitment Practices   IS THIS STEP IN THE RIGHT SEQUENCE?  DO YOU MEAN ALL THE ABOVE SHOULD BE PUT TOGETHER WITH THE RESULTS OF THE MEDICAL SURVEILLANCE SYSTEM ? (the OREP SOP covers this in detail)

The establishment of OREPs and inherent (fitness) standards (WHERE DO THESE COME FROM - HAVE NOT BEEN MENTIONED YET) They are mentioned in the section on OREPs (step 1) enables rational recruitment practices without fear of reprisal under the Labour Relations Act or the Employment Equity Act. However, these standards need to be defendable and underpinned by a sound HRA. Prospective employees (job applicants) should not be engaged (or allowed to leave employment ) until the appointed Occupational Medical Practitioner has cleared them. Furthermore, an induction programme should be instituted, including training.

Step 6: Occupational Hygiene Programme

This step is conducted by an approved inspection authority (DEFINE THIS IN GLOSSARY FROM THE OHSACT) (can Georges apply the tool that I have seen, whereby, upon double-clicking on this text, a definition is splashed onto the screen?) and includes measurement of environmental exposures. This includes exposures to hazards such as noise, dust, illumination and air-borne contaminants (organic compounds, vapours, fumes etc). The hazards identified in the HRA (Step 1) are now formally evaluated by means of measurements. A report is submitted to the company including suggestions for controlling the hazards that pose significant health risks to employees. This information is channelled to Step 9, at which corrective measures are contemplated.

Step 7: Safety Management Programme 

This component includes a wide variety of safety interventions, including safe working procedures, safety controls (such as permits to work etc), and safety mechanisms on equipment, (such as guards, railings, lockout procedures etc). These processes are largely the responsibility of line management and, possibly, the Risk Officer. Other components include incident investigation, housekeeping and the general organisation of the Safety Programme (such as the functioning of the Health and Safety Committee and the Health and Safety Representatives etc.). Periodic inspections and audits (internal and external) are used to measure progress and these reports are fed into Step 9, at which corrective measures are contemplated.

Step 8: Medical Surveillance Programme (hyperlink to the HRA Guideline)

Medical surveillance means a planned programme of periodic examination (which may include clinical examinations, biological monitoring or medical tests) of employees by an Occupational Health Practitioner or in prescribed cases by an Occupational Medicine practitioner. Biological monitoring simply measures the levels of the toxic substance in the body (thereby providing a more accurate indication of target organ exposure than simple air-borne monitoring). Biological effect monitoring comprises medical examination and testing, which seeks to identify early adverse health effects of exposure to the hazard. These tests might include x-ray changes, audiometric changes, lung function changes or other clinical findings. The key elements of this step include test selection, setting required standards, and determining test frequency. These are described in detail in the SOP on designing Worker-Allocated Surveillance Programmes ("WASP's"). (A hyperlink should be placed here). Other important objectives of Medical Surveillance include suitability assessment (ensuring that employees meet the inherent requirements of their occupationsIS THIS FITNESS TESTING AND LINKED TO THE STANDARDS REFERRED TO ELSEHWERE IN THIS DOCUMENT? (see blue text above), progress evaluation of rehabilitating employees, and assistance in their return to suitable work. Results of these interventions (outcomes) are fed into Step 9 (see below).

Step 9: Data Analysis and Reporting (hyperlink to the Health Information System Guideline)

This step brings together the outcomes of Steps 6, 7 and 8. The objective is to identify critical findings in the Occupation Health Programme as a whole, including:

These three components should be highlighted and appropriate recommendations issued in a composite report.

Step 10: Corrective Measures

The recommendations drawn from the report (Step 9) should be listed in an Action Plan with appropriate time deadlines and accountabilities. GIVE AN EXAMPLE OF A TABULAR SCHEDULE WITH TIMELINES AND RESPONSIBILITIES. I guess I could construct one. The checklist tool that we will give them (actually have already done, in previous blocks), includes these fields (timelines, and responsibilities). A blank sample is attached to the WREPs SOP, but also stands alone as a document (spreadsheet, actually), which is referenced on the cd in the HRA section.  A WORKED EXAMPLE WOULD BE GOOD HERE.  Overall responsibility for this should be at the highest level in the company in order to drive the implementation of the recommendations effectively. As these corrective measures are instituted and completed they actually change the health risk profile of the company, which ultimately requires a re-visitation of the Health Risk Assessment (Step 1). This cycle should occur at least every two years as prescribed by the Occupational Health and Safety Act.

REFERENCES

  1. Occupational Health and Safety Act (OHSA), No 85 of 1993 and Regulations.
  2. Compensation for Occupational Injuries and Diseases Act (COIDA), No 130 of 1993 (as amended 1997).
  3. The Mines Health and Safety Act (MHSA), No. 29 of 1996 and Codes of Practice.
  4. Occupational Diseases in Mines and Works (ODIMWA), Act No. 78 of 1973 and Regulations.
  5. Occupational Diseases in Mines and Works Amendment Act (ODIMWA), Act No. 208 of 1993.
  6. The Hazardous Substances Act No 15 of 1973 and Regulations.
  7. The Health Act No 63 of 1977 and Regulations as amended.
  8. The Labour Relations Act No 28 of 1956 as amended in 1996.
  9. The Basic Conditions of Employment Act No 3 of 1983 as amended - Act 75 of 1997.
  10. The Employment Equity Act 55 of 1998.
  11. The Codes of Good Labour Practice (including Hours of Work, Pregnancy, HIV & testing, Disability, etc.)
  12. The National Road Traffic Act No. 93 of 1996, and Regulations.