A. Review Issues and Questions

1.	Publication date.	1996. First draft circulated for comment.
2.	Status: final, draft, other.	Draft.
3.	Pending revisions.	Yes.
4.	Publishing Organization type.	Government.
5.	Type of OHSMS.	Governmental regulation (proposed).
6.	Is it used by regulatory agencies to achieve agency mandate?	Yes.
7.	Is it meant to be an auditable standard?	Yes.
8.	Is it used as an auditable standard?	Yes.
9.	Is it a management system?	Yes. Closed system. Missing key formulation and open system variables.
10.	Are there technical appendices?	No, not at this time.
11.	Is there a companion audit guidance document?	No, not at this time.
12.	Are there stated limitations of use?	Yes. Industry restrictions.

B. Review Comments

In 1996 the United States Department of Labor’s Occupational Safety and Health Administration (OSHA) began preliminary rule making activities for an OHS program standard. Stakeholder meetings have been held and comments received on draft standard that was circulated for review.

The design of the proposed standard closely resembles OSHA’s VPP. Since this standard-development process is underway, it is not known at this time what the final form of the standard will be.

The proposed OSHA standard does not contain the following OHSMS variables: regulatory compliance/conformance; OHS policy; goals/objectives; performance measures; technical expertise/personnel qualifications; hazardous agent management; medical program and surveillance; continual improvement; integration; and, management review.

C. Outline

a. Scope and application

b. Basic obligation

c. Management leadership and employee participation

d. Hazard assessment and control

e. Information and training

f. Program evaluation

g. Dates

h. Definitions

D. Analysis Checklist

	Management System Variable		Notes
1.0	Management Commitment and Resources	x
1.1	Reg. Compliance and OHSMS Conformance
1.2	Accountability, Responsibility, and Authority	x
2.0	Employee Participation	x
3.0	Occupational Health & Safety Policy
4.0	Goals and Objectives
5.0	Performance Measures
6.0	System Planning and Development	x
6.1	Baseline Eval. and Hazard/Risk Assessment	x
7.0	OHSMS Manual and Procedures
8.0	Training System	x
8.1	Technical Expertise and Personnel Qualifications
9.0	Hazard Control System	x
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
15.0	Integration
16.0	Management Review

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.