 | |
III.Recommendations & Outline for a New International OHSMS
As the ILO moves forward with the consideration of an international OHSMS standard, there are several important issues that must be addressed. These are: 1. What type of document will be developed? Fundamentally, the options include: • an auditable standard that uses "shall" statements;
• a non-auditable standard or code-of-practice that uses "should" statements; or,
• a guidance document. 2. Will the standard be compatible or aligned with ISO 14001 or other standards?
3. Will auditor guidance be provided as an adjunct to the document?
4. How will conformity assessment and recognition of achievement be addressed? Recommendations
Based on the analysis conducted and observations of IOHA, the following recommendations are provided to the ILO for consideration in the development of an international OHSMS. 1. It is recommended that the document is auditable; that is, it uses "shall" statements.
Experience to date indicates that where nationally recognised non-auditable standards or guidance documents are published, "unofficial" auditing and certification schemes proliferate because of the demand from employers. In addition, any international document which does not facilitate audit and certification will inevitably take second place to one which does.
2. Develop an OHSMS document that contains a two-tiered approach.
Many organisations who are inexperienced at management systems approaches find the prospect of implementing a system rather forbidding, especially if they are a small or medium sized enterprise (SME). Organisations with low risk activities may find that some of the requirements necessary for others with high risk activities. The first tier would be more general, and not as detailed as the first tier. This structure would facilitate a phased introduction of an OHSMS.
3. Use the 27 OHSMS variable identified in this report as the basis for the development of both a general and comprehensive OHSMS.
4. Ensure that employee participation and health surveillance are strong components of the OHSMS.
5. Base the standard on ISO 14001 and include implementation guidelines.
Published ISO management-system standards have received worldwide acceptance. Many organisations who have implemented OHSMS's, even in accordance with schemes developed by others, have followed the principles set out by ISO. To maximise acceptability of the ILO OHSMS document, alignment with ISO 14000 and ISO 9000 series standards is important. ISO 14004 and ISO 9004 are good examples for implementation guidelines.
6. Consult ISO.
For example, representatives of Technical Committees 207 and 176, which are responsible respectively for ISO 14000 and 9000. Each of these international standards are currently in various stages of revision. There is momentum in these technical committees to publish more closely aligned or compatible standards, or possibly even an integrated quality and environmental management system. There are also discussions about the need to integrate occupational health and safety in such a standard as it becomes more widely accepted that management commitment and resources for OHS suffer in the presence of certifiable environmental and quality standards.
7. Address conformity assessment.
Ensure that conformity-assessment mechanisms that meet the needs of potential users are thought through, and guidance given, by the time the ILO OHSMS documents are published.
8. OHSMS structure
In addition to the general layout below, if the OHSMS parallels the ISO 14000 and ISO 9000 series of documents, it could contain the following six sections, either in a single document or as a multi-part series. 1. Occupational Health and Safety Management System-Specification
2. Occupational Health and Safety Management System-Guidelines and Principles
3. Guidelines for OHSMS Auditing - General Principles
4. Guidelines for OHSMS Auditing - Audit Procedures
5. Guidelines for OHSMS Auditing - Auditor Qualifications
6. Occupational Health and Safety Management Systems-Definitions IOHA recommends that the following key elements should be included in an ILO International OHSMS document. This is based on the 27 sections described in Table No. 1 and Appendix B. It is recommended that the items under 3 to 18 below, are covered by the suggested (two tier) approach.
1. General Provisions 1.1 Objectives
1.2 Scope
1.3 Definitions 2. OHSMS Policy and Principles 2.1 At International Level
2.2 At National Level
2.3 At Enterprise/organisation Level 3. Management Commitment and Resources 3.1 Recognition of OHS performance as integral to Organisation Business Performance
3.2 Commitment to a high level of performance
3.3 Allocation of Resources
3.4 Establishment of Supporting Structures
3.5 Senior Management Accountability, Responsibility and Authority
3.6 Regulatory Compliance and System Conformance 4. Employee Participation 4.1 Accountability, Responsibility and Authority of Employees
4.2 Employee consultation
4.3 Management/Employee communication 5. Occupational Health and Safety Policy 5.1 At Enterprise/Division/Facility Level
5.2 Formulation and Periodic Review
5.3 Authority
5.4 Documentation Mechanisms
5.5 Understanding at all levels 6. Goals and Objectives 6.1 At Enterprise/Division/Facility/Local Level
6.2 Objectives/Goal Setting process 7. Performance Measures 7.1 Leading Indicators
7.2 Trailing Indicators 8. System Planning and Development 8.1 Initial Planning
8.2 Overall Structure/Form of OHSMS
8.3 Implementation Processes
8.4 Review and Modification Processes
8.5 Baseline Evaluation and Hazard/Risk Review
8.6 Regulatory Compliance Review
8.7 OHS Management Practice/Procedure Review
8.8 Hazard/Risk Assessment of Activities 9. OHSMS Manual/Procedures 9.1 Nature and Form of Manual
9.2 Updating Procedures
9.3 Accessibility by Employees and others 10. Training System/Skills 10.1 Senior Management Training
10.2 Management/Supervisor Training
10.3 Employee Training
10.4 Induction and Refresher Training
10.5 Training for Hazardous Work
10.6 Competence, Expertise and Qualifications
10.7 Competent OHS Advice 11. Hazard Control System 11.1 Hierarchy of Controls
11.2 Effectiveness of Controls
11.3 Modification and Adaptation of Controls
11.4 Process Design
11.5 Safe Working Procedures/Permits etc.
11.6 Assessment of Risks/Hazards
11.7 Accordance/Minimization of Risk
11.8 Emergency Preparedness/Response
11.9 Hazardous Agent Management
11.10 Co-ordination of Departments
11.11 Health Screening 12. Preventive and Corrective Action System 12.1 Anticipation of Events
12.2 Preventive Maintenance
12.3 Routine Inspections/Surveys 13. Procurement and Contracting 13.1 Safety Assessment of Procured Products
13.2 Assessment of Contractors
13.3 Control/Supervision of Contractors
13.4 Rules for Contractors 14. Communication System 14.1 Between the Enterprise and Employees
14.2 External Communication
14.3 Document/Record Management System
14.4 Specialist Advice/Information 15. Evaluation System 15.1 Auditing and Self Inspection
15.2 OHSMS response to changes in circumstances
15.3 Incident Investigation and Risk Cause Analysis
15.4 Health Surveillance 16. Continual Improvement 16.1 Senior Management Commitment
16.2 Mechanisms for Achievement 17. Integration 17.1 Integration of OHS processes into organizational processes
17.2 Common goals for the OHSMS and the organization 18. Management Review 18.1 Performance Evaluation
18.2 Feedback into OHSMS
18.3 Information to Stakeholders 19. External Certification and Accreditation
20. Bibliography
Annexes: OHSMS Auditing General Principles/Procedures/Qualifications
Updated by AS. Approved by EC. Last update: 30.11.2004.
|
