Module 6: Occupational Health Management - Section 2: Occupational Health Programme
OHM2.2: A 10 step approach to establishing an Occupational Health Programme (Part 1)

A 10-Step approach to establishing the Occupational Health Programme:

(Based on the HRA guidelines document)

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, the totality of evaluated hazards can be included in the process described below. Alternatively, one specific hazard (noise) could be the focus and the process still applies. The first 5 of these steps will be discussed on this page, while the other 5 are treated on the next page.

Steps 1-3: Health Risk Assessment
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")

This step outlines the key features of each occupation in the company - including the inherent requirements for meeting 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, with instructions and guidelines. 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).

The OREP is a unique document, and carries a special place.

Firstly, it comprises the important "Standard-setting" phase required for rational design of the medical screening programme, by providing the operational requirements for each job category. This is used to determine the medical standards for adjudicating job fitness (see design of WASPs later).

Secondly, it describes the health risks associated with each job category, incorporating the hazards as well as the degree of exposure to each, by job category. This is used to determine the medical screening tests necessary to identify early adverse health effects of exposure (see design of WASPs later).

Step 2: Hazardous Substance Risk Assessment

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). MSDSs are frequently inadequate when it comes to long term or chronic effects of exposure. Other sources are Medline (and other dedicated toxicology database) searches and the ILO encyclopaedia.

When this is completed, the various chemicals should be linked with the occupations and workplaces where the exposures take place.

Information on chemical exposures should optimally also be able to be linked with results of medical screening for individuals in occupations and workplaces through the health information system if this allows output of subsets of stored data. This is often difficult and may be beyond the capabilities of most occupational health information systems due to limitations on the quality of exposure and medical data available, or the inability to attribute such data to individual workers. However this is a worthy goal for rational prevention

Step 3: Workplace Health Risk Assessment ("WREPs")

This step covers the detailed evaluation of health risks in the various working places of the company. WREP stands for Workplace Risks and 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 and safety representatives.

Workplace risk assessments can be conducted by Process or by Location.

The Process-based risk assessment yields information regarding the risk associated with activities and operational processes. This form of risk assessment is useful to link risks with activities, (and job categories that perform these activities) and product lines (the assessment looks at operational processes, regardless of their location in the company). The final output is a listing of high-risk activities and product-lines, and the underlying causes of the risks. Interventions (and management follow-up) are therefore directed at the activities (work procedures) and product lines (elimination, substitution, etc.).

The Location-based risk assessment yields information regarding the risks associated with specific workplaces. This form of risk assessment is useful to link risks with places of work, (and job categories that are are placed there). The final output is a listing of high-risk workplaces, and the underlying causes of the risks. Interventions (and management follow-up) are therefore directed at the workplaces and conditions of work.

The Risk Assessment culminates in the establishment of a Risk Matrix, which is used in steps 4, 5 and 6

The Risk Matrix

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:

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

Relationship between the OREP and the WREP as alternates for representation in the Risk Matrix

Whilst both OREPs as well as WREPs could be represented in the Risk Matrix, the medical team are much more interested in representing the OREPs, which enable occupation-oriented interventions (training and medical screening) that target high risk activities and occupations. The exposure profile of an individual worker is made up of a series of occupations (OREPs) and as such is more complex and difficult to measure, record and store.

WREPs on the other hand are typically of greater interest to Risk Managers and Line Managers, for whom process (or location) oriented interventions would be appropriate. Workplace exposure profiles are easier and less expensive to measure, record and store in terms of time, cost and expertise. There is a tendency in industry to attribute some type of average exposure for a workplace to an individual who works there as a crude measure of individual or occupation based exposure.

Use of the NIOSH Control Banding approach to categorise exposure hazard

See an example of a Risk Matrix from the HRA Policy Document

Analysis of this data enables easy "birds eye-view" evaluation and prioritisation 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 risks across the organisation. It is also a powerful tool for planning and organising proposed risk reduction strategies, and measuring the effects of these strategies.

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 Risk Matrix and OREPs, which outline the potential health risks and the job’s inherent requirements.

Step 5: Recruitment Practices:

The establishment of OREPs and inherent (fitness) standards (still to come) 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) until the appointed Occupational Medical Practitioner has cleared them. Furthermore, an induction programme should be instituted, including training.