A. Review Issues and Questions

1.	Publication date.	1995.
2.	Status: final, draft, other.	Draft. Work on this document was suspended in 1996.
3.	Pending revisions.	No. No further action to be taken. Replaced by ISO 14001 activities and ISO’s decision to not to persue an OHSMS.
4.	Publishing Organization type.	International standards organization.
5.	Type of OHSMS.	Would have been an international voluntary standard.
6.	Is it used by regulatory agencies to achieve agency mandate?	No.
7.	Is it meant to be an auditable standard?	No.
8.	Is it used as an auditable standard?	Can be. Contains should statements.
9.	Is it a management system?	Yes.
10.	Are there technical appendices?	Yes.
11.	Is there a companion audit guidance document?	No.
12.	Are there stated limitations of use?	No.

 B. Review Comments

This draft standard was prepared by Technical Committee ISO/TC 67, Materials, equipment and offshore structures for petroleum and natural gas industries, Sub-Committee SC 6, Processing equipment and systems.

Activity on the Standard was suspended in 1996 because 1) ISO 14001 was nearing final approval, and 2) the OHSMS issues was being considered as an independent issue within ISO.

Even though the development of this Standard was suspended, it is being analyzed for this project because it represents another way that an OHSMS can be structured and provides insight on how ISO may have proceeded if an OHSMS standard had been pursued.

This is an integrated EHS system. It is called a Health, Safety and Environmental Management System (HSEMS). This Standard presents seven key elements of the HSEMS (they refer to them as elements and not principles as do other standards).

1. Leadership and commitment

2. Policy and strategic objectives

3. Organisation, resources and documentation

4. Evaluation and risk management

5. Planning

6. Implementation and monitoring

7. Auditing and review

The requirement for a Management Representative defined (3.3.2). An interesting section is titled "Management of Change." Annex I provides a detailed review of this topic.

Monitoring (3.6.2) presents the distinction between active vs. reactive monitoring. Integration can be inferred in the introduction, but it is not explicitly stated. It is mentioned in the auditing section 3.7.1 "...integration into line activities."

Hazardous material management is not explicitly addressed. Identification and control of hazards and risks is stated. It does not go into the kind of depth that, for instance that OSHA’s Hazard Communication standard covers.

A comprehensive EHS management system. It covers more detail than other systems reviewed. This could be because it was prepared for a specific industry and thus specific guidance was provided.

Employee involvement and medical surveillance was noticeably missing. Also, continual improvement and integration were not explicitly stated in the standard. While not excluded, they were not prominently addressed.

There are several good aspects: 1) it addresses the need for refresher training; 2) the "controlled document" structure is comprehensive; and, 3) it addresses performance criteria in terms of "screening criteria"... this is well done.

C. Outline

0 INTRODUCTION

1 GENERAL

2 NORMATIVE REFERENCE

3 GUIDELINES

3.1 Guidelines for leadership and commitment

3.2 Guidelines for policy and strategic objectives

3.3 Guidelines for organisation, resources and documentation

3.3.1 Organisational structure and responsibilities

3.3.2 Management representative

3.3.3 Resources

3.3.4 Competence

3.3.5 Contractors

3.3.6 Communication

3.3.7 Documentation and its control

3.4 Guidelines for evaluation and risk management

3.4.1 Identification of hazards and effects

3.4.2 Establishing screening criteria

3.4.3 Evaluation

3.4.4 Document hazards and effects

3.4.5 Detailed objectives and performance criteria

3.4.6 Risk reduction measures

3.5 Guidelines for planning

3.5.1 General

3.5.2 Asset integrity

3.5.3 Procedures and work instructions

3.5.4 Management of change

3.5.5 Contingency and emergency planning

3.6 Guidelines for implementation and monitoring

3.6.1 Activities and tasks

3.6.2 Monitoring

3.6.3 Records

3.6.4 Non-compliance and corrective actions

3.6.5 Incident reporting

3.6.6 Incident follow-up

3.7 Guidelines for auditing and reviewing

3.7.1 Auditing

3.7.2 Reviewing

4 BIBLIOGRAPHY

ANNEXES (Informative)

Annex A Typical examples of roles which may require competence assessment

Annex B Typical examples of training requirements

Annex C Typical consideration for the interface with contractors

Annex D Typical information to be available for facilities involved in the development of oil and gas resources

Annex E Evaluation and risk management for existing facilities

Annex F Guidance on setting objectives and performance criteria

Annex G Typical examples of issues to be covered by operating procedures

Annex H Typical examples of activities which are likely to require work instructions

Annex I Typical examples of changes which may affect HSE plans

Annex J Issues to be considered in planning audits

D. Analysis Checklist

	Management System Variable		Notes
1.0	Management Commitment and Resources	x
1.1	Reg. Compliance and OHSMS Conformance	x	Need knowledge of regulations.
1.2	Accountability, Responsibility, and Authority	x
2.0	Employee Participation
3.0	Occupational Health & Safety Policy	x
4.0	Goals and Objectives	x
5.0	Performance Measures	x
6.0	System Planning and Development	x
6.1	Baseline Eval. and Hazard/Risk Assessment	x
7.0	OHSMS Manual and Procedures	x	No explicit manual requirement. Individual procedure requirements.
8.0	Training System	x	Refresher training required.
8.1	Technical Expertise and Personnel Qualifications	x
9.0	Hazard Control System	x	Can be inferred. Not explicitly stated in terms of OHS control.
9.1	Process Design	x
9.2	Emergency Response	x
9.3	Hazardous Agent Management
10.0	Preventive and Corrective Action	x
11.0	Procurement and Contractor Selection	x
12.0	Communication System	x
12.1	Document and Record Management System	x
13.0	Evaluation System	x
13.1	Auditing and Self-Inspection	x
13.2	Incident Investigation and Root Cause Analysis	x
13.3	Medical Program and Surveillance
14.0	Continual Improvement	x	Not explicitly stated in text. Inferred in policy requirements.
15.0	Integration	x	Integration not explicitly stated. Inferred.
16.0	Management Review	x

IOHA Report to ILO on an International OHSMS - Appendix C [Title page]     [Table of Contents]     Chapters: I II III     Appendices: A B C D E F G

Updated by AS. Approved by EC. Last update: 30.11.2004.