10 things to consider with ISO 45001

Australian mine works wearing hi-vis and hard hats

Just over a year ago, I wrote an article titled “What’s different in ISO 45001:2016”. Since then, the OH&S standard has changed again and has now become ISO/DIS 45001.2.

So I thought I would revisit what I wrote and see what the changes are now. Essentially this .2 version is more aligned to the other ISO standards such as ISO 9001:2015 and ISO 14001:2015; and whilst all these new standards have to adopt the ISO mandate of using the format of the high level structure (HLS), the way that each of the committees uses the HLS varies. This is of course a little annoying, but it’s most probable partly due to the fact that those writing a new standard learn things along the way so that (hopefully) a later standard is written better.

Let’s have a look at some of the bigger issues that organisations will need to make sure they address as they transition from AS/NZS 4801 and/or OHSAS 18001 to ISO 45001 and the world of international occupation health and safety (OH&S).

I’ve chosen only 10 issues – there are more – and highlighted just some things I found particularly interesting. I hope you do too.

1. Workers

Workers play a big part. The other ISO standards talk about “persons under the organisation’s control”, but ISO 45001 specifically uses the term “worker” which is then explained in the terms and definitions as being: person performing work or work related activities that are under the control of the organisation. There are then three explanatory notes to clarify that “worker” essentially means everyone such as: paid, unpaid, regular, temporary, intermittent, seasonal, casual, and part time; plus top management and both managerial and non-managerial people; as well as those employed by the organisation, or by others such as external providers, contractors, individuals and agency workers. It’s everyone. The reason for this is that the main focus of an OH&S management system is to not hurt people, and this explanation of a worker should ensure that all people are covered. Previously in AS/NZS 4801, it tried to cover everyone by using terms like: employees, all personnel, contractors and visitors. In my experience, people in managerial positions often don’t think that OH&S applies to them.

2. Size

The size of the standard ISO 45001 is significantly bigger than both previous OH&S standards, with AS/NZS 4801 having only seven pages of requirements (and a very large left margin) and OHSAS 18001 having a little more at nine pages. This new ISO 45001 comes in with a whopping 18 pages of requirements. And don’t think I’m including things like terms and definitions and the guidance, because I’m not! These are just requirements pages.

Now is that because ISO has a lot more OH&S requirements now or is it because it has to follow the format of the HLS? Checking a few of the other standards that use the HLS format, we find:

  • ISO 9001 Quality management systems 17 pages
  • ISO 14001 Environmental management systems 11 pages
  • ISO 22301 Business continuity management systems 14 ½ pages.

So yes… it is bigger, and vastly different from the previous OHS standards, but actually not that much bigger than other modern standards. It seems fair to say that the additional requirements come from the HLS rather than OH&S.

3. High Level Structure

Continuing from the point above (and we’ve known this for a long time), ISO 45001 will follow the format of the HLS, so it will have the following 10 sections:

  1. Scope
  2. Normative references
  3. Terms and definitions
  4. Context of the organisation
  5. Leadership and worker participation
  6. Planning
  7. Communication
  8. Operation
  9. Performance evaluation
  10. Improvement

Because ISO 45001 will follow this format, it will make it much better to read in conjunction with other standards; and this will make integrated management systems easier to develop and implement. It must be said however, that businesses need to ensure the integration of the OH&S management requirements into their business processes – not align them with the HLS. If your OH&S management system looks like the HLS, it’s not right; and if a consultant has written the system for you, ask for your money back.

4. Worker Participation

For those aware of the HLS and other standards, you will notice the inclusion of the words “worker participation” in the Leadership section. This is unique for OH&S (other disciplines only have the heading “Leadership”) and has strengthened what was in the previous AS/NZS 4801 OH&S standard which only required consultation. Participation was mentioned in the guidance, although I’m not sure how many people bothered to read the guidance. OHSAS 18001 does have a “Participation and consultation” section, although it is not as explicit as the proposed requirements in this new ISO 45001.

5. Obstacles or barriers to participation

Building on the worker participation is the requirement now that the organisation:

has to determine and remove obstacles or barriers to participation and minimise those that cannot be removed.

And a note further explains that obstacles and barriers can include failure to respond to worker inputs or suggestions, language or literacy barriers, reprisals or threats of reprisals, and policies or practises that discourage or penalise worker participation.

This requirement will be challenging for some organisations, however it is arguably one of the best additions. It is well known that a business is only as good as its people – and this requires that workers do actually have to join in as to how the OH&S is managed at their place of work.

6. OHS opportunities

In trying to keep workers free from harm, ISO 45001 requires an organisation to identify both OH&S risks and OH&S opportunities. Now OHS risks have always been around, and both AS/NZS 4801 and OHSAS 18001 had requirements around opportunities for continual improvement. But these OH&S opportunities are much stronger now. Essentially the existing standards require that you identify hazards and control them to an acceptable level… “As Low As Reasonably Practical” is the term often used, whereas this new standard requires that you seek:

opportunities to enhance OH&S performance, whilst taking into account: opportunities to adapt work, work organisation and work environment to workers. 

This is far more proactive than we had before, where businesses were essentially allowed to manage hazards. Now they have to anticipate, seek out, research and probe (on an ongoing basis) to identify opportunities to eliminate hazards and reduce OH&S risks.

7. Social Hazards

Whilst we are talking about hazard identification, the process for identifying hazards now has to take into account social factors which are explained as including: workload, work hours, victimisation, harassment and bullying. Workload and work hours are in the existing standards, but victimisation, harassment and bullying are new. This fits in well with the worker participation even though it is in a different section; and although these behaviours may not be prevalent in all organisations, they have the capacity to take many forms across many levels and functions within a business. Top management is also required to demonstrate leadership in this area by developing, leading and promoting a culture in the organisation that supports the intended outcomes of the OH&S management system.

8. Elimination of Hazards

Eliminating hazards now has its own section, almost. The section is actually called:

Elimination hazards and reducing OH&S risks

But the focus is definitely on the elimination of hazards because it is mentioned three times. Currently AS/NZS 4801 mentions the hierarchy of control in the guidance, and whilst OHSAS 18001 does include the hierarchy in the requirements, it is not as strong as it is included within “Hazard identification, risk assessment and determining controls”.

This is good, because hopefully it means that organisations place greater focus on trying to eliminate hazards from the workplace rather than go for the easier, far more common (but much less effective) options of:

  1. a) writing more and more procedures and instructions which many people simply do not understand – refer to the next topic, and
  2. b) making people wear more and more protective equipment, which in many instances just makes the job more difficult and awkward.

9. Communication

I think we all agree that one of the most challenging issues in any organisation is communication. You need to tell your people things, keep them informed, instruct them. As far as a method of risk control, this is an administrative control and also includes training, of which a large amount is communicating about how to do something correctly. Now ISO 45001 (like ISO 9001, ISO 14001, ISO 27001, ISO 22301 etc) has a complete section on communication, but ISO 45001 says more, and includes the line:

The organisation shall take into account diversity aspects (for example gender, language, culture, literacy, disability) when considering its communication needs.

This is simply brilliant, and hopefully means the end of long, tedious and poorly written documents such as Safe Work Method Statements that no-one can understand – other than a degree qualified safety professional – but is meant to be read, understood and agreed to by someone who most probably left school at grade 10 or has English as a second language.

10. Coordination between multi-employer workplaces.

Many large projects, especially infrastructure projects, are completed using multiple organisations, with each responsible for certain aspect of the work. In these situations, which OH&S management system is to be used? In most cases, it’s the system used by the principal contractor, however they may not be the most powerful player in the group – so it can be tricky and very messy, with multiple systems at work on the one job. ISO 45001 recognises that this is an issue and has included the line:

At multi-employer workplaces, the organisation shall coordinate the relevant parts of the OH&S management system with the other organisations.

Therefore you now must ensure that your systems work together. In my view, this means the removal of duplication where operators have to complete one piece of documentation for one organisation and a virtually identical piece for another organisation just to satisfy two different systems.

 

In conclusion, the goal of the new standard is very much still the same…  don’t hurt people. However the standard has changed – it is stronger in parts than the existing OH&S standards and some would say it now better aligns with legislation. But don’t forget that in Australia and New Zealand, AS/NZS 4801 was written in 2001 and was quite a bit in advance of legislation back then, so legislation had to do the catching up.

Also, some of you would probably like the standard to be even stronger and more prescriptive – and able to force organisations to do even more to keep people safe. But firstly, this standard is voluntary so organisations don’t have to comply with it; secondly, it is international, so it will apply to some countries which do not have such an advanced culture of safety and health in the workplace.

 

Do you have any concerns with the release of the new global safety standard. We’d appreciate your view. You can comment below, or drop us an


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