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Integrating environmental management and occupational health & safety management

Ann Stewart

Gosford City Council

Overview

This case study will take a retrospective view of the process of integrating, try to convey as much specific information as possible about the system itself, and include some brief information regarding the status of implementation as at February 2008.

Gosford City Council adopted its current Integrated Management System (IMS) in March 2003. The IMS integrates Council’s Occupational Health, Safety and Environmental Management Systems.

Council’s Integrated Management System (IMS) is a tool that Council has developed to ensure that its plans and policies for occupational health, safety and environmental management come to fruition by offering a structured and integrated approach to occupational health, safety and environmental management across all of Council’s operations and services.

Integrating both the Occupational Health and Safety System and the Environmental Management System into the one system was a cross directorate project for Gosford City Council, specifically across the Environmental Planning Directorate and the Corporate Development Directorate.

This project required commitment from the most senior level of management within the Council and consultation with all levels of personnel from within the Council. The officers directly responsible for coordinating the project were Council’s Safety Coordinator and Senior Sustainability Officer.

The process of integration is ongoing and for the most part a seamless process, that is, there is no clear defining line between the two themes of the system, rather they are fully integrated in all aspects at all opportunities.

The IMS has been structured to be consistent with the requirements of the following three documents:

  • WorkCover NSW- Occupational Health and Safety Model for Self Insurers July 2005
  • AS/NZS 4801 -2001 Occupational Health and Safety Management Systems - specification with guidance for use (Standards Australia)
  • AS/NZS ISO 14001:2004 Environmental Management Systems - specification with guidance for use (Standards Australia, Standards New Zealand)

The IMS is a whole of Council system and is currently being implemented throughout the Council. The system is subject to both internal and external audits that contribute to the continuous improvement of the system and its implementation.

Rationale

Prior to March 2003, Gosford City Council had two separate management systems for managing occupational health and safety and environmental management. These systems had many similarities in conceptual content, however, they were remarkably different in procedural detail.

Gosford City Council is licensed by WorkCover NSW to be a self-insurer for workers compensation and as such must meet the requirements set by WorkCover NSW to maintain this licence. The OHS management system was structured around these WorkCover requirements. In 2001 the requirements were changed by WorkCover to reflect changes in OHS legislation and the newly introduced Australian Standard for OHS management systems - AS/NZS 4801.

The newly introduced Australian Standard for OHS management - AS/NZS 4801 was structured to closely align with the International Standard for environmental management systems - ISO 14001. This gave Council a common ground on which it could commence integration as Councils EMS had been structured to meet this standard.

The benefits and limitations of an IMS were identified and after considerable consultation, a decision was made by Council to integrate. The benefits discussed included, but were not limited to:

  • Rationalisation of resources
  • Improved organisational OHS and ENV performance
  • Improved customer satisfaction
  • Reduction of complexity

A guidance document produced by Standards Australia, Step by step guidance on integrating management systems was a useful document that assisted in this decision making process.

Methodology

The officers directly responsible for coordinating the project were Council’s Safety Coordinator and Senior Sustainability Officer. These officers needed to negotiate with their Supervisors to be seconded from their regular duties to work solidly together on this integration process.

An independent systems auditor was engaged to review via desktop audit, the existing systems and offer guidance on opportunities for integration. This audit report became part of a discussion paper that put forward to the executive management of Council, various options for integration and discussed the limitations of the process. It was this discussion that led to the decision to develop the IMS.

Objectives

There were two major objectives of this integration project:

1. To provide a documented corporate system for managing OHS and environment

2. To provide a system that is consistent with the requirements of:

An Occupational Health and Safety Model for Self Insurers (WorkCover NSW)

AS 4801 -2000 Occupational Health and Safety Management Systems - specification with guidance for use (Standards Australia) (since revised to AS/NZS 4801:2001)

AS/NZS ISO 14001:1996 Environmental Management Systems - specification with guidance for use (Standards Australia, Standards New Zealand) (since revised to AS/NZS ISO 14001:2004)

In addition to these objectives there were some user requirements that were also guiding the project. These user requirements were identified during the decision making consultation process and included that the system be:

  • easy to navigate within
  • consistent with existing corporate systems where possible
  • have a reduction in jargon and superfluous text
  • made available for consultation with all staff in the draft stage
  • based upon a continuous improvement model

Consultation

Having determined the objectives and the user requirements the next step was to determine a mechanism for consultation. There are approximately 1200 staff employed by Gosford City Council and it was a requirement that they all be invited into the consultation process with regards to the overall system development.

A Consultation Policy was prepared which detailed the scope of the consultation and Council’s commitment to consultation.

An interactive site was established on Council’s Intranet for the placement of draft documents and for opportunities to comment. This was open to all staff and currently still operates as necessary.

Consultation Committees were established that were representative of all levels and functions of Council. The primary role of the Safety and Environmental Management Committees being to, review OHS and Environmental measures and systems, investigate matters and assist in resolving OHS and Environmental issues. This includes making recommendations about how systems of work can be improved to avoid hazards arising in the first place. The Safety and Environmental Management Committees Structure includes the following:

Responsibility

Responsibilities were then defined and documented for all personnel at all levels within the structure of Council. This included the associated authority to act and accountability of all personnel in order to facilitate effective OHS and environmental management outcomes.

These responsibilities, authority and accountabilities were then defined within the position descriptions of all staff. An education program that explained and clarified these responsibilities was rolled out to all staff.

Managers and Supervisors have the ongoing responsibility of ensuring that IMS Responsibilities are conveyed to staff:

  • at induction to work
  • prior to undertaking relieving duties
  • prior to commencing in any new position

These responsibilities are linked to the performance appraisal of individual staff and continue to be measured for implementation each year at performance appraisal period.

IMS Procedures

A series of integrated system procedures were then written to guide Council employees in the implementation of their OHS and Environmental responsibilities, these procedures were collated and became the IMS Manual. This manual includes procedures for:

Risk Management which includes:

  • Hazard identification
  • Risk assessment
  • Controlling hazards
  • Legal and other requirements
  • Process control
  • Incident reporting
  • Inspection testing and monitoring
  • Design control
  • Review and evaluation

Document Control which includes:

  • Document approval
  • Document formatting
  • Controlled and uncontrolled documents
  • Communication and implementation of documents
  • Maintenance and review of documents

Records which includes:

  • Record identification
  • Record collection, indexing, filing and storage
  • Record maintenance and disposal

Purchasing which includes:

  • Purchasing of goods materials and services
  • Specification process
  • Product assessment process
  • Supply process
  • Delivery to end user process
  • Environmental questionnaire for products and services
  • Contractor management

IMS Training

IMS Audits

Statistics

This entire draft manual went through an extensive consultation process and all Council staff were invited to make submissions, as were all of the Safety and Environmental Management Committees. All comments were collated and changes were made to the manual to reflect staff comments where possible and the final document was adopted in March 2003.

An IMS Awareness training program was rolled out across the entire Council to assist Council staff in familiarisation of the system and to answer any questions in relation to its application. This training and education process is continuous and occurs at regular intervals throughout the year for all new staff and any other staff who require refreshing. Specific training programs have also been developed for a variety of IMS related needs and are considered in the development of all staffs individuals training programs.

Technology

Council reviewed a number of off the shelf software solutions for integrated management systems and were not satisfied that these systems could meet Council's requirements. Council engaged an external consultant to write a new piece of software designed around the specific system requirements.

A software training program was developed and delivered to key staff within the organisation after which the software was readily accepted and used. The user base is currently at around 350 regular users with numbers increasing each year as more training is rolled out. The software has been through four significant upgrades since 2003. In 2007, Council purchased the intellectual property of the software and employed an internal programmer to continue to improve and maintain the system.

Review

The IMS Manual is reviewed every two years to ensure the systems continuing suitability, adequacy and effectiveness. Where a change of circumstances determines, an additional review may occur.

Corporate level objectives and targets are developed and measured by the Strategic Safety and Environmental Management Committee each year to guide Council in working towards continuous improvement and meaningful OHS and ENV outcomes. Service Unit Objectives are set by Managers across Council and apply more narrowly to site specific activities. These objectives are also monitored by the Strategic Safety and Environmental Management Committee for implementation and are linked to all Managers performance appraisals.

There are a variety of reporting mechanisms to report to the Council as a whole and the community regarding Councils progress toward achieving their corporate level and service unit level objectives and targets.

Challenges to Date and How They Have Been Addressed

Communication and Negotiation

The first challenge for Council was to decide what to integrate into this management system, with OHS, environment and quality all being considered. Council chose to integrate OHS and environment and to acknowledge that quality may be integrated some time in the future. Influencing factors to exclude QMS in the integration process included:

  • the existing internal QMS was based around the Business Excellence Framework and this framework was largely inconsistent with the other framework documents;
  • the existing internal QMS did not have a single dedicated technical expert officer to be seconded into the integration process and additional resources could not readily be identified to account for a new position; and
  • the existing QMS was at a critical stage of implementation and the executive management were reticent to interrupt this process.

Developing an integrated management system at Gosford City Council required cooperation between the different parts of the organization and commitment from the top, this posed the second challenge. In Gosford City Council the two officers tasked with the development of the system, needed to develop a solid working relationship and strong communication and negotiation skills. As the system was structured to meet the requirements of three different base documents (described above), it meant that all policies and procedures that were written for the system, had to be checked three ways and then had to be checked for consistency against any other existing corporate systems in the organization, for example, the records keeping system, or the training management system. This required a great deal of cross program communication and negotiation.

Culture Change

Gosford City Council had a strong entrenched culture of OHS management that had been an accepted part of individual staff members day-to-day business for at least 15 years prior to integration. Integrating environmental management into this well-established culture was difficult to achieve and resistance to change was often encountered at the middle management and grass roots levels. Very often the integrated concept was not picked up and the focus remained on ‘safety’. For example, the Operational Safety and Environmental Management Committees were still colloquially referred to as the ‘safety committees’ and when inspections were carried out they were referred to as ‘safety inspections’.

Training in general environmental awareness was the main mechanism for shifting thinking beyond OHS to include ENV. Regularly reporting the progress towards achieving (or not achieving) objectives and targets both internally and externally was also an important tool for change. Recognition of effort and best practice was significant in improving system implementation.

Gaining a strong commitment from executive management to drive the integrated process was particularly important for success. Maintaining this commitment through to middle management remains an ongoing challenge. One of the strategies used to assist in this process involved Council’s Safety Coordinator and Senior Sustainability Officer attending, as regular speakers, at the monthly combined Managers Meetings. Together they identified and addressed opportunities for improvement in the application of the IMS from a management level and were able to highlight successes.

Issues to Consider

Points that were important to Gosford City Council in the integration process were:

  • Establish which areas of management can be integrated
  • Identify all key stakeholders
  • Prepare a discussion paper identifying as many reasons for integration as possible and the limitations of the integration process. Take this discussion to a forum with management representatives and employee representatives.
  • Gain a commitment to the process from the officers responsible for the systems development and senior management, ensuring willingness for negotiation and realistic timeframes for project planning.
  • Engage an independent consultant/auditor to review existing systems, via desktop audit to establish opportunities for integration against the proposed framework documents.
  • Use recognised models for systems frameworks such as Australian Standards. This can make the process less subjective and allow for ease of negotiation.
  • Consult as broadly as possible in the early draft stages of system development so that the system can be bedded down and not be subject to frequent change. This will give confidence in the system in the long term.
  • Invest in external audits and where appropriate certification to Australian Standards; they are valuable tools for systems improvement, verifying systems implementation, maintaining ongoing management commitment and validating the system for the organisation as a whole.
    Join OHS/Environmental management systems network groups to exchange ideas, successes and failures. These networks can increase your workload but are a wonderful support for complex issues.
  • Invest in training broadly and specifically as it is significant in shifting attitude and culture.

Outcomes to Date

WorkCover NSW continues to audit Council to ensure compliance to the WorkCover model for self insurers. The outcomes of these audits include Council being reissued their self insurers licence from WorkCover, and Council making considerable cost savings with regard to workers compensation insurance premiums.

Since 2003 Council has engaged JAS-ANZ accredited auditors to audit the system to compliance with the Australian Standards (AS/NZS 4801:2001 and AS/NZS ISO 14001:2004). This has been a staged process and in October 2006 Council achieved whole of Council certification to both of these standards.

Council has internally and publicly reported on the progress towards the achievement of IMS objectives and targets and continues to measure the level of success of the system in relation to OHS and environmental management outcomes. Some of the areas measured at the corporate level include:

  • Reduction in illness and injury in the workplace
  • OHS and environmental risk minimisation
  • Implementation of IMS responsibilities
  • Risk minimisation through workplace inspection
  • Education of management regarding risk management and spills management
  • Reduction in corporate greenhouse gas emissions
  • Reduction in the quantity of paper used (both virgin and 100% recycled)
  • Reduction in environmental impact from sewage discharges
  • Reduction in water consumption per property

At the management unit level, since March 2003 to the time that this paper was prepared, 343 IMS objectives had been completed and 435 were in various stages of progress completion. These objectives are largely centred around further reduction of residual risk associated with either environmental aspects and impacts or occupational health and safety hazards and risks.

Summary

While environmental and OHS management is the responsibility of each individual, the individual relies on a system or method for implementing this responsibility. The strength or the impact of the implementation of the individual’s responsibilities will only be as strong and comprehensive as the system empowers.

Officers who are tasked with the development of management systems need to be able to be dedicated to the process and not have it tacked on to an existing workload of other duties. Management need to recognise this and invest in systems development officers for the long-term. Systems development officers need to be supported by competent training staff and systems implementation facilitating officers.

Developing, implementing, maintaining and measuring high quality, effective integrated management systems takes time and dedication, and must be embedded in core functions and duties through policy, procedure and attitude. Organisations undertaking this process will need to set some very long-term goals and invest in careful planning along the way. Outcomes can be diverse and include indirect general business improvements as well as more direct OHS and ENV improvements.

References

Gosford City Council (2003) Integrated Management System Manual - Integrating Occupational Health and Safety and Environmental Management, Gosford City Council (internal document)

Standards Australia (1999) Step by step guidance on integrating management systems - Health and Safety, Environment and Quality, Standards Australia International (public document)

Standards Australia and Standards New Zealand (1996) AS/NZS ISO 14001:1996 Environmental Management Systems - Specification with guidance for use, Standards Australia/Standards New Zealand (public document)

Standards Australia and Standards New Zealand (2004) AS/NZS ISO 14001:2004 Environmental Management Systems - Specification with guidance for use, Standards Australia/Standards New Zealand (public document)

Standards Australia (2000) AS 4801 - 2000 Occupational Health and Safety Management Systems - Specification with guidance for use, Standards Australia International (public document)

Standards Australia (2001) AS/NZS 4801 - 2001 Occupational Health and Safety Management Systems - Specification with guidance for use, Standards Australia International (public document)

WorkCover NSW (2001) An Occupational Health and Safety Model for Self Insurers, WorkCover NSW (public document)

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