Many would say, incorrectly that is, that the Occupational Safety and Health Administration (OSHA) and ISNetworld® compliance are the same. After all, at a cursory glance one would likely place the two organizations in the same category. However, OSHA and ISNetworld® are two separate entities with very different intentions.
ISNetworld® provides their subscribers with an account where documents can be uploaded, reviewed, verified for accuracy, and put to various other tests. The organization is a privately owned company and does not serve any governmental function. Moreover, ISNetworld® does require that its subscribers (who are also suppliers) submit written health and safety programs for the review process.
The interesting part about this process is that ISNetworld® compliance does not, by any means, meet all of the OSHA compliance standards germane to specific health and safety programs. The best example we can provide by comparison is the Hazardous Waste Operations and Emergency Response (HAZWOPER) standards found in the Title 29 CFR part 1910.120 regulations and the emphasis ISNetworld® places on a mere portion of those standards.
That is, ISNetworld® requires suppliers to comply with paragraphs B, E, F, G, H, K, P, and Q. More specifically, the more precise HAZWOPER standards that ISNetworld® specifically requires are as follows:
- Title 29 CFR part 1910.120(b)(1)
- Title 29 CFR part 1910.120(e)(1)(i)
- Title 29 CFR part 1910.120(f)(2)(i)
- Title 29 CFR part 1910.120(f)(5)
- Title 29 CFR part 1910.120(g)(1)(i)
- Title 29 CFR part 1910.120(h)(1)(i)
- Title 29 CFR part 1910.120(k)(2)
- Title 29 CFR part 1910.120(k)(2)(iii)
- Title 29 CFR part 1910.120(k)(2)(iv)
- Title 29 CFR part 1910.120(k)(3)
- Title 29 CFR part 1910.120(k)(5)
- Title 29 CFR part 1910.120(k)(6)
- Title 29 CFR part 1910.120(k)(8)
- Title 29 CFR part 1910.120(p)(7)(iii)
- Title 29 CFR part 1910.120(q)(1)
- Title 29 CFR part 1910.120(q)(2)
- Title 29 CFR part 1910.120(q)(3)
- Title 29 CFR part 1910.120(q)(6)
- Title 29 CFR part 1910.120(q)(6)(i)
- Title 29 CFR part 1910.120(q)(8)
- Title 29 CFR part 1910.120(q)(9)
It would seem as though other paragraphs of the HAZWOPER regulations are not considered. For example, paragraph C on Site Characterization and Analysis and paragraph D on Site control are not required yet the importance of these regulations is paramount to an effective HAZWOPER written health and safety program (HASP).
An OSHA compliant written health and safety program (HASP), on the other hand, would address all 17 paragraphs of the HAZWOPER regulations. Additionally, other related programs such as lockout/tagout or respiratory protection may be needed to supplement the written HASP. OSHA has presented us with a very comprehensive template on what a proper HAZWOPER HASP should look like. Granted, the template is geared towards the cleanup and removal of anthrax, a dangerous biological agent, but one could revise the sections offered by OSHA to create a more site-specific program manual.
The differences between an OSHA compliant and ISNetworld® compliant written safety program are vast. Firstly, OSHA regulations exist for worker protection with the aim of providing guidance to employers on how to create safer working conditions for employees. OSHA regulations are consistently amended to reflect improvements and a rapidly changing workforce. Secondly, the intentions of OSHA are clearly outlined in the Occupational Safety and Health Act of 1970 whereby the Administration’s very existence was geared towards regulating industry in a way that lowered the incident rates of worker fatalities, illnesses, and work-related injuries.
The intentions of ISNetworld® appear to be geared more towards a risk management perspective in which the company provides its services. However, even the risk management component can easily be challenged when one considers the requirements set forth by ISNetworld® in their safety program mandates. More to the point, the Title 29 CFR part 1910.120 HAZWOPER regulations are extremely complicated standards because emergency response and cleanup operations work is very dangerous. And, each organization must have a site-specific HASP that is oriented towards the relevant risks and hazards of that workplace, which means that no single program will work for every organization.
Further compounding this matter is the fact that many suppliers, who perhaps do not fully grasp the exceedingly complex nature of HAZWOPER regulations, become confident that their ISNetworld® HAZWOPER program is fully compliant with OSHA standards on hazardous waste operations and emergency response. It goes without saying that many companies perform work under the HAZWOPER scope and application without fully understanding the risks, without proper employee training, and without the necessary personal protective equipment. Coupled with the fact that many employers fail to abide by HAZWOPER standards in the first place, an ISNetworld® compliant program could convince some subscribers that the elements of proper safety protocol are satisfied when, in fact, they are not.
We argue that ISNetworld® seemingly selects OSHA standards at random and enforces only these OSHA standards during their review process for compliance. Furthermore, we have noticed that with respect to most OSHA mandated written programs like Hazard Communication standards found under Title 29 CFR part 1910.1200 and Respiratory Protection standards in accordance with Title 29 part 1910.134 among many others that only a mere seven to nine standards are selected for ISNetworld® compliance. Thus, many OSHA regulations are largely ignored by the ISNetworld® team during the review process of written safety manuals.
All in all, we can understand that ISNetworld® accepts and reviews written safety programs and tests them according to their selected OSHA standards. However, the most concerning issue with this process is that because so many OSHA standards are not required for ISNetworld® compliance, are employers then led to believe such standards are not as important or not to be adhered to? With the overwhelmingly fast pace ISNetworld® is growing, many suppliers may be more likely to adhere to the regulatory standards set forth by ISNetworld® than they are actual OSHA regulations—at least that is reasonable conjecture.
The major shortfall of the ISNetworld® review process is that not all OSHA standards are included, which can be confusing and deceptive to many without the requisite background in occupational health and safety. The review process is simply an evaluation of a company’s required contractual obligations with aim of reducing risk to the primary contractor by verifying the existence of documentation. However, this process of selecting specific OSHA standards, without objective reasoning or justification, only misleads employers by associating ISNetworld® compliance with that analogous to meeting the complete standards mandated by OSHA.
ISNetworld® has created a novel method of review of safety documents like written safety program manuals, but has in doing so, created an avenue of confusion, especially when we measure the ISNetworld® required standards against those in the various OSHA 1910 and 1926 subparts. Put plainly, safety manuals that satisfy the scrutiny of ISNetworld® are not necessarily compliant with OSHA standards. Employers who are relying upon their ISNetworld® written safety manuals as their primary means of reducing the likelihood of workplace illnesses and injuries should consider a more comprehensive approach.
OSHA mandates that an employer must maintain a workplace free from known and recognized hazards. The OSHA regulations were designed to guide employers towards this very purpose and that has remained the primary intention and mission of the agency. ISNetworld® provides its services not to necessarily reduce the risk of suppliers, but rather to reduce the risk of its primary contractor base or, as they are known, owner-clients. The primary strategy an employer should implement is to ensure that all written safety programs are fully compliant and meet all requisite OSHA standards. If this is done correctly, ISNetworld® will likely approve such programs since those standards are also based on OSHA regulations. Remember the intention of OSHA regulations are rooted in the principles of injury prevention and ISNetworld® has intentions geared towards liability, risk management, and asset protection.