March 16, 2004
American National Standards Institute (ANSI)
Accredited Standards Committee Z 10
Washington, DC 20036
RE: American National Standard: Occupational Health and Safety Management Systems (ANSI Z 10)
The American Association of Occupational Health Nurses (AAOHN) is pleased to submit comments on the American National Standard Institute (ANSI)’s final review of the Z 10 document.
General Comments
Developing a tool to provide companies or businesses with a standard from which to implement continuous improvement, minimize workplace risk and reduce injury, illness, and fatality occurrences is a major task. The Association applauds the committee for under taking the mammoth task of developing a voluntary management system (MS) standard for U.S. occupational health services (OHS) consistent with the International Organization of Standardization (ISO – 9000 and 14000). The Association also appreciates the flexibility to facilitate integration of standards with other business management systems, i.e., Six Sigma.
The majority of the reviewers’ feedback was positive, however there were a few contradictory comments you may or may not want to take into consideration. The following is a compilation of comments from reviewer and potential management system users.
Readability:
The general consensus was that the document was readable, understandable, clearly written with a format that was easy to understand and follow and provided good examples when needed. However, other comments stated the document was wordy and elementary with no new information on management systems.
Usability:
Again, the majority agreed that the document can be extremely helpful, but appears to be geared to organizations that already have initiated occupational health services management systems (OHSMS). Also, the management system’s performance improvement goals appear to place more emphasis on workplace environmental and safety hazards versus employee health and safety. However, the OHSMS will be a good "reference" document
Compatibility:
The compatibility of the document is an important issue. The overall consensus was that it would be a very effective and useful document. Also, there should be no problem integrating it with existing management systems provided some structural changes are made. The challenge is that the document is a systems approach dealing with complex issues, which crosses organizational disciplines while not being program/service specific; as such, it may cause format/design changes in implementation.
Specific Comments:
There were some grammatical errors in the document that should be corrected (included typographical errors, inconsistencies in format, words missing, etc.). Other suggested changes are:
- Page 16, 5.1.5, 3rd paragraph: Does "emergencies" represent all emergencies, or should it state internal and external?
- Page 16, E5.1.5, 2nd sentence: Does "man-made" represents thermal, biological, nuclear, etc.? Should it be spelled out?
- Page 16, E5.1.5, 6th bullet: Who are the members---emergency response plan member, employees, etc.?
- Page 17, E5.2C, 3rd paragraph: Should include licenses to indicate those who meet criteria for competency, i.e., MD, RN, driver’s license, etc.
- Page 21, "recommendation and explanatory notes": Check for use of words like will, can, need, etc. where "should" should have been used.
- Suggest underlining the words "shall" and "should" when used in the document.
The Association appreciates the opportunity to respond to the ANSI Z 10 occupational health and safety management systems document. As always, we will continue to lend our input and assistance to ANSI and other governmental and professional organizations to facilitate safe and healthful workplaces and communities.
Sincerely,
Susan A. Randolph, MSN, RN, COHN-S, FAAOHN
President
CC: AAOHN Board of Directors
Ann Cox, Executive Director
