Third Parties, Conformity Assessment and You

Article excerpt

A new column from the president-elect of the American Industrial Hygiene Association examines the critical issue of third-party audits and its import for OHS pros.

For the past several years, the use of third parties in occupational health and safety (OHS) has been an issue in legislative and policy debates, OSHA policy discussions and the OHS community in general. We, as an OHS profession, need to understand that all third-party auditor proposals for OHS inspections must include a strong conformance-assessment system for these legislative and policy proposals to be acceptable.

What Is a "Third-Party Audit"?

Let's start with the issue of "parties." An audit can be performed by auditors who have the designation "first," "second" or "third" party.

A "first-party" audit is one in which an organization audits itself. That is, the auditor is employed by the organization that he is auditing.

First-party audits have been the preferred mode of operation for organizations. Industrial hygienists, especially those who work for large, well-funded departments within companies, have always had this role. There is a great advantage in using first-party auditors. Those auditors, by virtue of their being part of the organization, have a unique, high degree of access and understanding that might not be available to auditors who are hired from the outside.

A "second-party" audit is one in which a customer is auditing a supplier or contractor.

To me, the second-party audit is the most powerful weapon in our arsenal. The power that a customer has over a supplier or contractor is extraordinary. A customer who includes occupational health and safety requirements for being a responsive and responsible bidder on a contract can clearly define the level of protection of the worker for the jobs that need to be done. The financial impact of such specifications can be far greater than the impact of a citation given by OSHA.

The "leverage" diagram shown below is a simple illustration of this.

A "third-party" audit commonly refers to the use of qualified individuals or entities whose services are usually paid for by the organization that is to be audited.

Third-party audits have been used in the practice of occupational and environmental health for many years. OSHA uses special governmental employees to help with Voluntary Protection Program inspections. AIHA uses members to perform audits of accredited laboratories. NSF International inspects and certifies all bottled drinking water in the United States All of these use third-party processes and audits. It is a common and well-proven mechanism.

Why Be Interested?

Third parties are being used throughout the OHS field. With third-party audits, the application of existing standards, regulations or other structures to the registration or certification of OHS programs or management systems is complex.

The elevation of the third-party issue can be attributed to three factors:

1. Proposed OSHA-reform legislation in recent sessions of Congress has contained requirements for the use of third parties in activities traditionally performed by OSHA.

2. The conformity-assessment structure developed by the International Organization for Standardization (ISO), as reflected in the ISO 9000 "quality assurance management system" and ISO 14000 "environmental management system."

3. The reference in the National Performance Review (NPR) of 1993 to the potential use of third parties in the Department of Labor. The NPR recommended that "the secretary of labor issue new regulations for work-site safety and health, relying on private inspection companies or nonmanagement companies." Such approaches are usually presented as a means of meeting legislated mandates in the face of diminishing resources and in response to calls for increased industry-government cooperation.

What Is "Conformity Assessment"? …