The Safety Through Design Implications In Z10
By Fred A. Manuele, P.E., CSP
On July 25, 2005, the American National Standards Institute approved a new
standard titled Occupational Health and Safety Management Systems. Its designation
is ANSI/AIHA Z10-2005. Thus, for the first time in the US, a national consensus
standard for a safety and health management system applicable to organizations
of all sizes and types has been issued. Z10 is an ANSI standard, not a guideline.
This is a major development. The societal implications of this standard are
substantial. It defines the minimum requirements for occupational health and safety
management systems and provides senior managements with a well conceived state of-the-art concept and action outline to improve th eir safety and health management
systems.
Very few employers have management systems in place that meet all of the
provisions of the standard, particularly with respect to its safety through design
implications. To make that point and provide a base for r eview and comparison with
safety management systems with which safety professionals are familiar, the Z10
Table of Contents is duplicated here.
Foreword
1.0 Scope, Purpose, and Application
1.1 Scope
1.2 Purpose
1.3 Application
2.0 Definitions
3.0 Management Leadership and Employee Participation
3.1 Management Leadership
3.1.1 Occupational Health and Safety Management system
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3.1.2 Policy
3.1.3 Responsibility and Authority
3.2 Employee Participation
4.0 Planning
4.1 Initial and Ongoing Review
4.1.1 Initial Review
4.1.2 Ongoing Review
4.2 Assessment and Prioritization
4.3 Objectives
4.4 Implementation Plans and Allocation of Resources
5.0 Implementation and Operation
5.1 OHSMS Operation Elements
5.1.1 Hierarchy of Controls
5.1.2 Design Review and Management of change
5.1.3 Procurement
5.1.4 Contractors
5.1.5 Emergency Preparedness
5.2 Education, Training, and Awareness
5.3 Communication
5.4 Documentation and Record Control Process
6.0 Evaluation and Corrective Action
6.1 Monitoring and measurement
6.2 Incident Investigation
6.3 Audits
6.4 Corrective and Preventive Actions
6.5 Feedback to the Planning Process
7.0 Management Review
7.1 Management Review Process
7.2 Management Review Outcomes and Follow Up
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At first glance, the Z10 Table of Contents seems comparable to other safety
and health management system outlines. But, some of the standard’s provisions
related to safety through design concepts do not appear in typical safet y management
systems, even those of some very large companies.
What does safety through design mean? In the book Safety Through Design,
published by the National Safety Council in 1999 under the auspices of the Institute
For Safety Through Design, this definition is given.
Safety Through Design: The integration of hazard analysis and risk
assessment methods early in the design and engineering stages and taking the
actions necessary so that risks of injury or damage are at an acceptable level.
This model displays the Safety Through Design concept.
Safety Through Design
A Pre-Thought, Not An After Thought
Design
Project
Conception
De s
ign
Retrofit
Operate,
Produce,
Maintain
ild
Bu
Retire
Eliminate,
Recycle,
Revise
Ease of Integrating Safety
Cost of Integrating Safety
Safety includes: fire, environment, ergonomics, health, vehicle, construction workers.
Projects include: facilities, processes, equipment, products.
This diagram promotes the idea that hazards and risks are most effectively and
economically addressed in the design stage, as a “pre -thought, not an after thought.”
The ease of integrating safety into facilities, hardware, equipment, products, tooling,
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materials, energy controls, layout, and configuration transitions into the more
difficult if hazards and risks are not dealt with in the design process. Also, if
retrofitting is necessary to achieve acceptable risk levels after activities have been
commenced to build equipment or when it is in operation, the costs increase
progressively.
Z10 moves forward on safety through design concepts. How so? In the
Planning section (4.0), and the Implementation and Operations section (5.0), the
standard (an ANSI standard) states that employers “shall” establish and implement
processes to:

identify and control hazards in the design process and when changes are
made in operations – which requires that
a. safety design reviews be made for new and altered facilities and
equipment, and
b. a management of change system be put in place through which
hazards and risks are identified and evaluated in the change process;

assess the level of risk for identified hazards – for which knowledge of
risk assessment methods will be necessary;

utilize a specifically prescribed hierarchy of controls in dealing with
hazards to achieve acceptable risk levels – in which the first steps relate to
safety through design principles; and

avoid bringing hazards into the workplace through incorporating design
and material specifications in procurement contracts for facilities,
equipment and materials.
As the standard attains the quasi-official stature that ANSI standards acquire,
it will become the benchmark, the minimum, against which the adequacy of safety
and health management systems will be measured. Societal expectations of
employers with respect to their safety and health management systems will be
defined by the standard’s provisions.
A good number of companies have issued safety policy statements that say
they will comply with or exceed all relative laws and standards. Those employers,
particularly, will want to implement those provisions in the standard that are not a
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part of their safety management systems. Further, having occupational safety and
health management systems in place that comply with the standard is the right thing
to do.
Z10 presents both opportunity and responsibility for members of the
Engineering Practice Specialty. As employers move toward adopting the safety
through design implications in the standard, consulting opportunities will arise for
safety professionals skilled in design reviews, risk assessments, management of
change systems, writing design specifications for purchasing contracts, and applying
the prescribed hierarchy of controls. Of course, the more enterprising safety
professionals so skilled will create those opportunities.
This new standard also presents a matter of concern for safety consul tants.
Consider this scenario. An employer receives a citation from OSHA which says that
the safety management system must be improved. You, a safety consultant, receive a
phone call from the obviously stressed employer asking that you provide counsel on
the improvements to be made so that the safety management system meets good
standards.
You call on the employer, agree on a course of action and a price, and the
arrangements are confirmed through a letter contract.
You decide that the framework you will use to help the employer improve the
safety management system is contained in a typical safety management system,
which does not contain the safety through design provisions in Z10. All goes well.
Your counsel is well received and acted upon. Your contract is fulfilled and you
have been paid.
Later, an incident occurs in the employer’s operations and an employee is
severely injured. Since workers compensation laws govern, the employee can not sue
the employer. The employee’s lawyer casts a large net to ide ntify defendants. She
discovers that you provided counsel on improvements to be made in the employer’s
safety management system.
You are deposed. The employee’s lawyer is ready. She studied the safety
management system document on which you based you cons ultation with your client.
And she has knowledge of the ANSI standard approved in July 2005 on Occupational
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Health and Safety Management Systems, and takes the position that Z10 represents
the state-of-the-art.
You are led through the entirety of the substance of your advice to the
employer. Then, the lawyer establishes that you, as a safety professional, are
familiar with ANSI standards. You agree that, over time, they acquire a quasi official stature, and that they establish the minimum requirements for the subjects to
which they apply. The lawyer works you through the safety through design elements
in Z10 that were not addressed in the counsel you gave to your client and relates
your omissions to the causal factors for the incident and injuries that occu rred to her
client.
She establishes that you, as a safety professional, have an obligation to be
familiar with and apply the state-of-the-art in the counsel you give. She emphasizes,
particularly, that your counsel was not based on the state -of-the-art. You were
negligent, and therefore liable.
Is the foregoing not plausible? It implies that consultants who give counsel on
improving safety management systems should become thoroughly familiar with the
requirements of Z10.
Z10 applies to all organizations of all sizes. Since many safety practitioners
do not have the skills necessary to assist employers in meeting the safety through
design aspects of the standard, members of the Engineering Practice Specialty are
obligated to arrange and conduct work shops and seminars to further their education.
It would be folly for safety professionals to ignore the long range impact Z10
will have on societal expectations concerning the quality of the safety management
systems employers have in place. Prudent safety pro fessionals will study the
requirements of the standard to explore the skills and capabilities needed to give
counsel on its provisions and:

move forward to acquire those skills if additional capability is required; or

limit their consultancy to fields of activity in which they are competent; or

partner with other safety professionals to provide the supplementary
competency required, and

reconsider their insurance coverage.
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To conclude: This standard represents an important step in the evolution of
the practice of safety. Realistically, it can be expected that, over time, it will
become the benchmark, the minimum, against which safety and health management
systems will be measured.
This Newsletter contribution is based on an article written by Mr. Manuele
and published in the February issue of Professional Safety. Its title is “ANSI Z10:
The new benchmark for safety management systems.”
References
ANSI/AIHA Z10-2005. Occupational Health and Safety Management Systems .
Fairfax, VA: American Industrial Hygiene Association, 2005.
www.aiha.org/marketplace.htm [ASSE has made an arrangement with AIHA so that
the standard can be purchased through ASSE at a reduced price.]
Christensen, W.C. and Manuele, F.A., editors. Safety Through Design. Itasca,
Illinois: National Safety Council, 1999. www.nsc.org
BIO
Fred A. Manuele, CSP, PE, is president of Hazards, Ltd., which he formed after
retiring from Marsh & McLennan where he was a managing director and manager of
M&M Protection Consultants. Manuele is an ASSE Fellow, an inductee into the
Safety and Health Hall of Fame International and a recipient of the National Safety
Council’s Distinguished Service to Safety Award. He is also a former board member
of ASSE, the Board of Certified Safety Professionals, and NSC, and a former
member of ASSE’s Editorial Review Board. Manuele is a professional member of
ASSE’s Northeastern Illinois Chapter.
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