risk – Page 206 – SafetyAtWorkBlog

Mobile phone cancer link still unclear

A new research study into the possible health effects if using a mobile phone remains inconclusive. According to a report in the Journal of Clinical Oncology,

“The current study found that there is possible evidence linking mobile phone use to an increased risk of tumors from a meta-analysis of low-biased case-control studies. Prospective cohort studies providing a higher level of evidence are needed.”

Basically this is saying there is a bit of evidence but more research is needed. In the context of cancer risks from using mobile phones, status quo remains.

Although only the abstract of the research is available online for free, a long discussion is available at Australia’s ABC website. The significant issue in this article is that “high quality” research found evidence of a possible cancer link and “low-quality” research found none.

If one is not a medical researcher, as SafetyAtWorkBlog is not, this research provides no practical guidance for the reduction of risk. In fact, it goes some way to fostering the layman’s suspicion of research.

If one has the task of minimising the (perceived) risk of receiving cancer for workers using mobile telephones, this study is useless. In reducing the increasing concerns from staff about this occupational hazard, this study is useless. The research does indicate that, at least, research is continuing but it adds nothing to the state of OHS knowledge needed to manage the potential hazard.

“Absence of evidence is not evidence of absence”* seems to fit the situation of mobile phones and cancer.

Kevin Jones

* Both Carl Sagan and Donald Rumsfeld have used this phrase. Allocate credit to whichever you choose

GHS is coming to the United States

On 30 September 2009 the Occupational Safety and Health Administration in the United States said in a media statement:

A proposed rule to align the Occupational Safety and Health Administration’s Hazard Communication Standard (HCS) with provisions of the United Nations Globally Harmonized System of Classification and Labelling of Chemicals (GHS) will be published in the September 30 Federal Register.

Jordan Barab, acting Assistant Secretary of Labor for OSHA said

“The proposal to align the hazard communication standard with the GHS will improve the consistency and effectiveness of hazard communications and reduce chemical-related injuries, illnesses and fatalities…… Following the GHS approach will increase workplace safety, facilitate international trade in chemicals, and generate cost savings from production efficiencies for firms that manufacture and use hazardous chemicals.”

On 6 October 2009, Safe Work Australia released the draft “Australian Criteria for the Classification Hazardous Chemicals”.

The closing date for comments is 18 December 2009.

Safe Work Australia stresses what the draft is not and the web page on the issue is very important to read.

Safe Work Australia says it

“…will be preparing guidance material for different audiences on the GHS and introducing two training courses (as basic and an expert one) to understand GHS classification.”

It should also be noted that the draft Classification Criteria is being revised in the context of the OHS harmonisation program of the Federal Government.

Kevin Jones

Harmonised OHS laws – winners and losers

Andrew Douglas, an Australian OHS and employment relations lawyer, has followed up some his points made in a podcast on 2 October 2009 in an article available on his firm’s website.

Part of the article says

So what is different about the Model Act and how will it be interpreted? When interpreting an Act you always turn to the objects of the Act. Courts look at the provisions in dispute through the lens of the objects. For example, the Victorian OHS Act merely looks towards providing a safe place of work for workers and the public and makes it clear that interpretation should be directed by the principles of OH&S. It includes an object to work together without specific mention of the unions. Contrast this with the Model Act (MA). The objects include:

The primacy of a safety management system

Consultation including unions

Rather than being compliance focussed the objects are expansively drafted to include:

“The principle that workers…should be given the highest level of protection.”

As a result – all interpretations of the MA should be considered “aspirationally” rather than “compliance focused”.

The third dot point will be manna for those “best practice” advocates but clearly it will be very difficult to “comply” with this legislation. That raises the question of whether one of the major political aims of the harmonisation processes – to cut red tape and thereby reduce compliance costs – can really be achieved. Or is the compliance cost being made easier for the corporate few at the cost of the small business “many”?

A small but significant omission in the MA aims is “to eliminate hazards, at the source…” This aim in the Victorian Act was extremely useful in advising companies to keep analysing risks in order to get to the core contributory factors on incident and hazards. This motivation disappears in the MA with its focus on “reasonably practicable”.

“Reasonably practicable” allows business operators to consult on whether the control measure reaches what stakeholders feel is adequate and then stop. “Close enough is good enough and, if not, WorkSafe will tell us. If it is way off, WorkSafe may prosecute.” This is lazy safety management.

Looking for the source of the hazard to eliminate it keeps business improving its state of knowledge on safety, looking for new solutions for difficult hazards.

Douglas identifies the winners and losers with this new proposed legislation:

Winners

“Business that crosses borders will have one regime to comply with. That is simpler, cheaper knowledge and easier to train operational staff/increased flexibility.

Unions – expanded rights of entry, locked into consultative mechanisms and cheaper to train in OH&S – across Australia flexibility.

Regulators – shared knowledge, resources, and training.

Losers

Small to middle size businesses who cannot afford the new documentation boom that follows duty compliance and whose officers will lack the knowledge and time to positively comply.”

It will be interesting to see the submissions from the small business sector, if available, over the next few weeks. Similarly, the employer and industry associations will need to show how they represent the range of business interest of all their members and not just the multi-state companies.

The recent stats quoted by SafetyAtWorkBlog that showed a high degree of ignorance on harmonisation changes by most businesses are understandable because if you operate in only one State, why would harmonisation bother you? Now the MA is out, the state impacts of the national program are becoming clearer and more worrisome.

Kevin Jones

[Please note that in this article WorkSafe is used as a generic term representing OHS regulators across Australia]

What Trevor Keltz gets right

Madonna has just released another greatest hits CD. Trevor Kletz has done similar in releasing the fifth edition of “What Went Wrong?” He admits that almost all of the content has appeared elsewhere. It’s been almost 20 years since I had to read Kletz’s books and articles as part of working in a Major Hazards Branch of an OHS regulator in Australia. Not being an engineer, the books informed me but were a chore. This is not the case with the last edition.

Kletz has two parts to the book. The first is a collection of short case notes recording as he says

“…the immediate technical causes of the accidents and the changes in design and methods of working needed to prevent them from happening again”.

The second discusses the weaknesses of management systems. In short, the book reflects the expanding nature of safety management over the last forty years. Kletz may be from the Olde School of safety engineers (he is 87 years old) but often one needs a fresh perspective on a profession and coming from a person with such extensive experience, Kletz is worth listening to. Thankfully, he does not sound like a grumpy old man.

Kletz notes that process industry lessons seem to fade after a few years. In my opinion this may be an effect of the transience of modern careers where corporate memory is often fragmented. It may also be due to the shipping of manufacturing and process industries off-shore and the establishment of large complexes in countries with different (lax) safety requirements. It may also be due to a corporate performance regime where maintenance is not valued or understood as that supports long term thinking rather than quite returns on investment.

Regardless of the cause, the short-term memory makes the need for such books as this as more important than never.

In anticipation of his look at management systems he notes in his preface, that management systems need maintaining and, more importantly, reading. In some circumstances, too much faith is placed in the system (I would refer to the Esso Longford explosion as an example). Kletz says all systems have limitations.

“All they can do is make the most of people’s knowledge and experience by applying them in a systematic way. If people lack knowledge and experience, the systems are empty shells.”

What Kletz does not write about is human error because, as he says, “all accidents are due to human error”. He avoids making the weak logic jump that the behaviouralists make where, “if all accidents are due to human error then fix the human and you fix the hazard”. Kletz devotes a whole chapter to his classification of human errors as

Mistakes;
Violations or noncompliance;
Mismatches;
Slips and lapses of attention.

This edition of “What Went Wrong?” provides a baseline for the safety concepts we have come to accept but also a critical eye on safety and manufacturing management shortcomings. The style is very easy to read although occasionally repetitive. Thankfully the process technicalities are avoided unless they relate to the technical point Kletz is making. I found part B hugely useful but it is recommended for all safety professionals.

Kevin Jones

Increasing risk of silicosis in the majority world

Australian safety expert and activist Melody Kemp reported from the annual meeting of the Asian Network for the Rights of Occupational Accident Victims (ANROAV) that was held in late September 2009 in Phnom Penh.

The meeting featured many stories about the increasing risk of silicosis in Asia. Melody writes in the 27 September edition of the blog “In These Times”:

“Silicosis afflicts workers working with gems, ceramics, rock blasting, drilling and crushing, and mining. It haunts unprotected workers in glassworks, mines and foundries, as well as those who live within reach of the dust. It’s usually fatal by the time it is diagnosed.

Largely eradicated in the economic North, silicosis is now the scourge of the Global South. Millions die from the illness each year.”

The size of the growing occupational and community threat is frightening.

“China alone reports over 100,000 new cases of industrial lung disease per year, and has more than 4 million existing cases. And those are just the official figures. Even industrially advanced South Korea sees over 1,000 new cases of occupational chest disease each year, reported Dr. Domyung Paek, a pulmonary specialist from Seoul National University.”

Melody has contacted SafetyAtWorkBlog asking for assistance in attracting occupational medical experts to Cambodia and other countries undergoing rapid industrialisation. She can be contacted by clicking HERE.

Kevin Jones

Leadership, MBAs and Community

The G20 summit in Pittsburgh, United States, this week will include a lot of analysis of the global financial crisis and various stimulus packages. Some, such as Professor Henry Mintzberg, have pointed the finger at business courses, such as the Master of Business Administration, that have encouraged personal greed. Some in the executive industry describe (rationalise?) this as creating “shareholder value”. Regardless of which ideological side one takes, MBA’s are getting a makeover.

In a recent article Professor Rakesh Khurana of Harvard University has argued that

“…the shareholder model is too blunt and does not capture the reality of business”.

But before one categorises Khurana as an advocate of the left, Khurana operates within a bigger context. Khurana argues that

“…a professional ideology of “service to the greater good” is not at odds with the principal of shareholder value creation. It actually grounds shareholder value morally and integrates it in a richer multidisciplinary context.”

The multidisciplinary approach to management is familiar to anyone who has studied risk management but it seems to be radical in the financial sector. Professor John Toohey of RMIT University’s Graduate School of business has said in the same article as referenced above

“We fail as a business school if we don’t excite and frighten our students, and get them to think about the bigger issues, what sort of moral footprint they will be leaving… We do this by emphasising ‘work-integrated learning’, by trying to give our students experience of how complex issues are considered and managed in reality.”

Earlier this year Professor Toohey chaired an event that discussed the role of science and business.

But that integrated approach to business management requires a receptive audience. Henry Mintzberg, mentioned above, wrote an article on leadership for the Harvard Business Review for July/August 2009 that seems to talk about workplace culture without using that term. Mintzberg talks about reestablishing a sense of “community” in corporations. By community he means:

“…caring about our work, our colleagues, and our place in the world, geographic and otherwise, and in turn being inspired by this caring.”

Some would see this as “engagement”, others could compare this approach to establishing a social consciousness for the workplace. Many OHS professionals will see elements of community in many of their activities around a workplace safety culture.

The full/longer article is well worth obtaining (it was reprinted in the September edition of the AFR Boss magazine in Australia) as it lists the following lessons, amongst others:

Community building in an organisations may best begin with small groups of committed managers.

The sense of community takes root as the managers in these groups reflect on the experiences they have shared in the organisation.

The insights generated by these reflections naturally trigger small initiatives that can grow into big strategies.

The discussion about “communityship” seems to have strong echoes in other business management strategies. At the core are the same concepts being discussed in different terms. The trick is to ignore the competitive claims of ownership or intellectual property to get to the useful truths that lie within.

Kevin Jones

New ISO risk management standard

I am old enough to remember the world of management before it had a risk management standard. In fact I was studying risk management in OHS when the Australian Standard 4360 was released. It substantially changed the way OHS was managed in Australia (and lined the pockets of the publishers). It increased the significance of management standards beyond Quality and helped considerably in progressing an integrated approach to managing a broad range of workplace risks.

[The process also instilled in me a distrust of the standards development process when I sat through a seminar from one of the risk management standards committee members where he spruiked a PC-based management system that “anticipated” the new standard…….. at $30,000 setup fee??? Clearly in this case, and I have been told in almost all cases, the participants always have one eye on the commercial benefits of participation]

Grant Purdy recently discussed the new international risk management standard ISO 31000 :2009. At one of his presentations he said that the new standard has a definition of risk that “shifts the emphasis from “the event” to “the effect” and, in particular, the effect on objectives.”

The previous risk management standard overlapped with auditable elements in other management standards – OHS, environment, and quality. This new definition may cause problems across these sectors.

Purdy said that risk is now not only perceived as a negative.

“Risk has in th past been regarded solely as a negative concept….[but] it is now recognised that risk is simply a fact of life that cannot be avoided or denied.”

He speaks of the traditional way of measuring risk as sometimes creating “phantom risks” due to an overstated likelihood. This seems particularly relevant to OHS and may be part of the reason that some OHS issues are seen as excessive or, at worst, a joke.

Purdy stated that there are 11 statements of effective risk management. [Modern management writers love numbers. I should write a book called “The hundredth time I have had to sit through a numbered list of strategies at conferences before walking out”] The statements are that risk management

creates and protects value

is an integrated part of all organisational processes

is part of decision making

explicitly addresses uncertainty

is systematic, structure and timely

is based on the best available information

is tailored

takes human and cultural factors into account

is transparent and inclusive

is dynamic, iterative and responsive to change

facilitates continual improvement of the organisation.

The implementation of this standard and other international standards is going to be confusing, initially, for Australian managers but the choice is easy. Why follow an Australian standard that needs explaining overseas when there is already an international standard that requires no explanation? Go global and expand your auditing and accountability options.

[Please note that ISO31000 is not an auditable standard but I suspect you will not have to wait long for one.]

Kevin Jones

Category: risk

Mobile phone cancer link still unclear

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GHS is coming to the United States

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Harmonised OHS laws – winners and losers

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What Trevor Keltz gets right

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Increasing risk of silicosis in the majority world

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Leadership, MBAs and Community

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New ISO risk management standard

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