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management,” in order to distinguish it from the more complex voluntary systems. Dalrymple et al. (1998) included mandatory OHSMSs from two non-European countries in their review -- India (the 1988 revision of The Factories Act) and Korea (1990 Industrial Safety and Health Act) -- but considered the Korean system to be weak. Brazil was also included in the review, but was judged to not truly be a management system.

The Workwell audit in Ontario is an example of a special type of mandatory OHSMS intervention that does not arise directly from legislation. Instead, the Workwell audits are administered through a legislated agency, the Workplace Safety and Insurance Board. They are required of workplaces with poor performance in terms of workers’ compensation claims or legislative compliance (Bennett, 2002). Failing an audit results in relatively severe penalties and requires remedial action. Several hundred companies go through the Workwell process on an annual basis (Richard Burton, WSIB, personal communication).

2.6 Controversy surrounding OHSMSs There are several areas of controversy regarding OHSMSs. For instance, there is concern that OHSMS strategies, which foster self-regulation of OHS by workplaces, will weaken the external regulatory approaches developed to date (Bennett, 2002). Indeed, there is evidence that authorities view OHSMS strategies as a means of saving on the costs of enforcement (Frick and Wren, 2000, p. 40).

In addition, Quinlan and Mayhew (2000) argue that the current labour market trends towards precarious employment, outsourcing and subcontracting suggest that mandatory OHSMS strategies will not affect substantial portions of the population. The corresponding growth of smaller organizations means that workplaces will be more difficult to reach through either voluntary or mandatory initiatives. The authors also expect that the ability and motivation for employers to undertake OHSMS innovations will be weakened, due to the complexity of modern organizations and the lowered degree of responsibility they have towards some workers. Finally, they predict that as union membership and leverage decreases, so will their influence over OHSMSs and OHS in general.

There is significant concern expressed by labour representatives about the tendency for some of the proprietary systems, in particular, the Dupont and the Five Star systems, to use worker behaviour-based safety techniques. These can foster an authoritarian, “blame the worker” approach to safety (Nichols and Tucker, 2000; Wokutch and VanSandt, 2000). Also of concern to labour is that such systems can undermine the formal means of worker participation in the workplace, by shifting the control of OHS issues more towards management and by failing to integrate with existing union or joint health-and-safety committee arrangements (Lund, 2004; Nichols and Tucker, 2000). These tendencies are considered to be consistent with the

Institute for Work & Health


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