Health and safety management systems: Liability or asset?

Journal of Public Health Policy,  2002  by Bennett, David

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THE ILO SAFETY AND HEALTH MANAGEMENT GUIDELINES

IN the spring of 2001, the International Labour Organization endorsed its Guidelines on Safety and Health Management Systems. The Guidelines have their background in several national models in the area of what are known as "voluntary standards"; some of these will be examined in due course. But in order to understand the ILO Guidelines, we have to understand the organization itself.

The ILO was founded in 1919 as an agency of the League of Nations; it was the only organization of the League to survive into the era of the United Nations as its oldest agency. The ILO is unique in another way. It is the only agency of the UN which is run by parties in addition to national governments. Thus the ILO is governed by a body comprised equally of representatives of employers, governments, and workers. This tripartite governance extends into the development of the ILO's "instruments" such as Conventions, Recommendations, Codes of Practice and Guidelines; even Guidelines are developed on a tripartite basis and are endorsed by the ILO governing bodies (i). Though some basic rules of industrial relations have to be endorsed by member countries as a condition of membership of the ILO, acceptance of ILO instruments is voluntary. In the case of Codes of Practice and Guidelines there is no formal procedure of national acceptance.

The Safety and Health Management System Guidelines require a translation of their content into a "national system." Where this is done, it is accomplished normally not by the government but by the national "standard-writing body" as a "voluntary standard." This does not preclude the adoption or referencing of the voluntary standard in legislation, though in the case of management standards generally, this is rarely done.

The voluntary acceptance of ILO instruments means that, as such, there is nothing to require a nation to adopt them. Further, the enforcement tools available to the ILO to pressure a country to fulfill its commitments, once an instrument has been ratified, are very limited. Workers are the chief beneficiaries of the work of the ILO, so it is organized workers who have to work the hardest to ensure that their rights and employment standards are implemented and respected.

This is true of the rights and powers embodied in the Safety and Health Management Guidelines. The first thing to be said about the Guidelines is that they differ from previous models in one essential respect: they embody the rights, perspectives and experiences of workers. Workers are an equal partner or player with management in devising and carrying out measures to protect their health and safety; they are participants in securing their own health and safety. After all, it is not management's health and safety that is at risk but the workers' health and safety. "Workers are not objects to be managed, like machines or other factors of production. They are living, breathing, thinking human beings who have the most fundamental stake in any system of health and safety that affects their workplace. They must be involved at the workplace level up to and including any international consensus standard" (2).

The ILO Guidelines are in three parts: a short section on objectives; a rather longer section on translating the Guidelines into national practice; and, a long section on "The OSH management system in the organization" (i.e., the workplace). The opening sections make it clear that the ILO management system is one approach or a "practical tool" for assisting the parties in the workplace (mainly, but not only, workers, their representatives, and management) in fulfilling health and safety duties in the organization of the workplace. The long section on the management system in the organization (the workplace) is comprised of twenty-one topics, including the employer's OSH policy; workers' participation; responsibility and accountability; training; system planning; OSH objectives; hazard prevention; performance monitoring and measurement; health and safety investigations; audits; management review; preventive and corrective action; and, continual improvement.

This listing is exhaustive and much more comprehensive than national models. It is however a curiosity. Virtually all national systems contain such lists and they contain them at the expense of any description or prescription of what a workplace management system looks like, how it is structured, how it functions, how it relates to the management of the enterprise generally, how it is reconciled with the functions and responsibilities of other parties. There is no discussion of key management roles or reporting relationships. Anyone who looks to management system models for clues as to how managements work or could work in relation to health and safety will be disappointed. Health and safety professionals have, in a sense, created their own mystery.

The ILO Guidelines have several distinctive features, which become relevant when they are contrasted with previous models.