OHSAS 18001: nine months on
When OHSAS 18001 Occupational health and safety management systems -- requirements was published in 2007, issue 15 of INform examined its potential impacts. Nine months on, looks into further developments and two new guidance documents
The importance of having an effective system for occupational health and safety management has long been recognized, but additional emphasis has recently been added in the UK with the enactment of the new Corporate Manslaughter and Corporate Homicide Act 2007, which will result in employers being liable if they are found guilty of negligence. The need for having an effective OHS system is clearer than ever and OHSAS 18001 is a step towards ensuring you have the correct arrangements in place.
Since its publication there have been a number of further developments in the field, such as the Drafts for Public Comment (DPCs) of OHSAS 18002 and BS 18004. Although many OHS professionals are of the opinion that OHSAS 18001 is in itself sufficient for their needs, in practice many organizations do not have the expertise available on a full-time basis to successfully implement it. It becomes apparent that a reference document is needed to guide them, which is where OHSAS 18002 and BS 18004 come into play.
OHSAS 18002
OHSAS 18002 has been produced in order to help 18001 users understand what is expected from an OHSAS 18001 system and what auditors will be looking for. For example, take clause 4.3.1 of OHSAS 18001:
The procedure(s) for hazard identification and risk assessment shall take into account:
A. routine and non-routine activities
B. activities of all persons having access to the workplace (including contractors and visitors)
C. human behaviour, capabilities and other human factors
D. identified hazards originating outside the workplace capable of adversely affecting the health and safety of persons under the control of the organization within the workplace
E. hazards created in the vicinity of the workplace by work-related activities under the control of the organization
F. infrastructure, equipment and materials at the workplace, whether provided by the organization or others
G. changes or proposed changes in the organization, its activities, or materials
H. modifications to the OH&S management system, including temporary changes, and their impacts on operations, processes, and activities
I. any applicable legal obligations relating to risk assessment and implementation of necessary controls (see also the NOTE to 3.12)
J. the design of work areas, processes, installations, machinery/equipment, operating procedures and work organization, including their adaptation to human capabilities
Apart from A, B and F all sections are new to 18001. These changes, among others, have therefore necessitated further explanation of what is expected in the hazard identification and risk-assessment section of 18002.
OHSAS 18002 is an international document and not a BS guidance document at this point of time. However, should the final document meet UK needs it is expected that it will be adopted as a British Standard. Its international dimensions have many benefits as there are over 25,000 organizations certified in over 80 countries to this standard and a common understanding is necessary for its successful adoption and credibility.
There are great benefits to having an international document, but out of necessity some compromises have been made to reflect legal and cultural differences. For example, there is increasing focus on occupational health issues in the UK where some 30 million working days were lost in 2006 as a result of work-related illnesses. Ill health is an area where there are no comprehensive regulatory requirements and as a result it is often neglected. The risk-based approach of 18001 provides a way of identifying ill health in parallel with safety risks by giving due weight in risk assessment activities.
BS 18004
BS 18004 is a revision of BS 8800:2004 and will help organizations in their implementation of an OHS management system to meet UK needs. It’s a more comprehensive document than OHSAS 18002 and gives additional guidance in its annexes as below:
A. Integration *
B. Guidance on implementation and operation
C. Promoting an effective OH&S management system
D. Guidance on setting objectives and planning and implementing OH&S programmes
E. Guidance on risk assessment and control
F. Measuring performance
G. Incident investigation
H. Internal audit *
I. Occupational health/occupational health provision *
J. Worker involvement *
K. Emergency preparedness and response *
L. Effective leadership for successful health and safety business performance *
A number of these annexes are completely new (see *). The annexes and the main text will be particularly interesting to those organizations seeking to ensure they adopt good practice and will enable them to demonstrate their commitment both to employees and those who might be affected by their activities. Increasing recognition of the importance of leadership and culture is addressed in L and C, while J focuses on worker commitment. Detailed guidance of how to deal with ill health is given in annex I.
Many organisations are finding benefits from an integrated approach to managing business risks – addressed in annex A. The main benefits are identified as:
- a reduction in conflict between different management systems
- OHS becoming an integral part of the organizations operational arrangements
- a reduction in bureaucracy
- increased efficiency in audits
There is obviously going to be a new challenge for auditors of safety management systems as a result of the expansion of OHSAS 18001 requirements which, together with UKAS accreditation, demand even higher standards. The guidance provided both by BS 18004 and OHSAS 18002 will be invaluable in identifying the areas that need to be assessed. The revised requirements for OHSAS auditors issued by IRCA in January 2008 recognise the increased competency needs for OHSAS 18001 assessors.
Why two?
Some will question why there is a need for two guidance standards. Itshould be remembered that OHSAS 18001 has to be universally applicable and its guidance needs to follow that format.
The scope of management systems around the world varies. For instance, in Europe it is required that the impact of the organization’s activities upon the public is considered when identifying hazards and considering the associated risks. In some countries the management system only considers the direct workforce. For this reason, any document produced for the UK has to cover the wider scope. BS 18004 recognizes this wider scope of the OHS management system and enables an organization to meet both international expectations as outlined in OHSAS 18001/2 as well as meeting UK good practice and regulatory expectations.
November 2008 should see the publication of the outcome of the two consultation documents. As well as these documents, others are also being considered for development. Upon the successful completion of BS 18004, there is a proposal to produce a publication that relates to those organizations that are typically low risk, such as offices, where the need for some of the comprehensive guidance given in BS 18004 might be considered more than they need. In addition, a document on terminology is planned to ensure a common understanding of the terms used within the standards and this area of work.
About the author
David Smith is a director of IMS Risk Solutions and is Chair of the committee responsible for health and safety management systems. In addition to training around the world, he is a prolific writer on management systems standards. The latest revision of the highly acclaimed Managing Safety the Systems Way incorporating all the new requirements of OHSAS 18001:2007 has just been published. David can be contacted on david@imsrisksolutions.co.uk www.imsrisksolutions.co.uk
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