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IMPLICATIONS OF CHANGES TO OHSAS 18001 FOR CLIENTS

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clientsdefined in 4.3.3 and 4.3.4

be consistent with operating experienceand the capabilities of risk controlmeasures employed

provide input into the determination offacility requirements, identification oftraining needs and/or development ofoperational controls;

provide for the monitoring of requiredactions to ensure both the effectivenessand timeliness of heir implementation

Note. For further guidance on hazardidentification, risk assessment and riskcontrol see OHSAS 18002.

i) modifications to the OH&Smanagement system, includingtemporary changes, and their impactson operations, processes, andactivities.

j) any applicable legal obligations relatingto risk assessment and implementationof necessary controls (see also the

Note to 3.12)k) the design of work areas, processes,

installations, machinery/equipment,operating procedures and workorganization, including their adaptationto human capabilities

The organizations methodology for hazardidentification and risk assessment shall:a) be defined with respect to its scope,

nature and timing to ensure it isproactive rather than reactive; and

b) provide for the identification,prioritization and documentation ofrisks; the application of controls, asappropriate.

For the management of change, theorganization shall identify the OH&S hazardsand OH&S risks associated with changes in

the organization, the OH&S managementsystem, or its activities, prior to theintroduction of such changes.

The organization shall ensure that the resultsof these assessments are considered whendetermining controls.

When determining controls, or considering

changes to existing controls, considerationshall be given to reducing the risks according

geological events, neighbours incidents;transportation incidents; external societalactions.

(e) Must be aware of foreseeable significanthazards beyond their boundary of theirmaking are assessed

(g) Must be able demonstrate a currentstatus quo in regard to risk assessment

(h) as (g) must more systemic

(j) Against your hazards are their any specificlegal obligations and have these beenassessed using required RA methodology

Risk should be classified in prioritizedmethod & be documented

a) Must be able to demonstrate linksbetween Assessments & controls

establish =process capability, repeatable

defined capability.

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clientsto the following hierarchy:

a) eliminationb) substitutionc) engineering controlsd) signage/warnings and/or administrative

controlse) personal protective equipment.

The organization shall document and keepthe results of identification of hazards, riskassessments and determined controls up todate.

The organization shall ensure that the OH&Srisks and determined controls are taken intoaccount when establishing, implementing

and maintaining its OH&S managementsystem.

NOTE For further guidance on hazardidentification, risk assessment and riskcontrol, see OHSAS 18002.

4.3.2 Legal andotherrequirements

The organisation shall establish and maintaina procedure for identifying and accessing thelegal and other OH&S requirements that are

applicable to it.

The organisation shall keep this informationupto-date. It shall communicate relevantinformation on legal and other requirementsto its employees and other interested parties.

The organization shall establish, implementand maintain a procedure(s) for identifyingand accessing the legal and other OH&S

requirements that are applicable to it.

The organization shall ensure that theseapplicable legal requirements and otherrequirements to which the organizationsubscribes are taken into account inestablishing, implementing and maintainingits OH&S management system.

The organization shall keep this informationup-to-date.

Need to see visible links with H/S legalframework

Duty expanded to persons under Clientscontrol (contractors, visitors etc)

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for ClientsIt shall communicate relevant information onlegal and other requirements to personsworking under the control of the organization,and other relevant interested parties.

4.3.3 Objectivesandprogramme(s)

The organisation shall establish and maintaindocumented occupational health and safetyobjectives, at each relevant function andlevel within the organisation.

Note objectives should be quantifiedwherever practicableWhen establishing and reviewing itsobjectives, an organisation shall consider itslegal and other requirements, its OH&Shazards and risks, its technological options,its financial, operational and businessrequirements, and the views of interestedparties. The objectives shall be consistent

with the OH&S policy, including thecommitment to continual improvement.

The organization shall establish, implementand maintain documented OH&S objectives,at relevant functions and levels within theorganization.

The objectives shall be measurable, wherepracticable, and consistent with the OH&Spolicy, including the commitments to theprevention of injury and ill health, tocompliance with applicable legalrequirements and with other requirements towhich the organization subscribes, and tocontinual improvement.

When establishing and reviewing itsobjectives, an organization shall take intoaccount the legal requirements and otherrequirements to which the organizationsubscribes, and its OH&S risks. It shall alsoconsider its technological options, itsfinancial, operational and businessrequirements, and the views of relevant

interested parties.

The organization shall establish, implementand maintain a programme(s) for achievingits objectives. Programme(s) shall include asa minimum

a) designation of responsibility and authorityfor achieving objectives at relevant functions

and levels of the organization, and

No new requirements of objectives, althoughmore clearly defined, practical.

Note the use of the word implement

Measurable where possible.

Wider context for these Objectives to belinked back to Policy - Focus on Ill-health

There is now a defined requirement foradjustment of programmes.

Objectives should be related to the policycommitments including compliance with*legal & other requirements and*the prevention of injury & ill health*delivery of Continual improvement

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clientsb) the means and time-frame by which theobjectives are to be achieved.

The programme(s) shall be reviewed atregular and planned intervals, and adjustedas necessary, to ensure that the objectivesare achieved.

4.3.4 OH&S

managementprogramme(s)

The organization shall establish and maintain

(an) OH&S management programme(s) forachieving its objectives. This shall includedocumentation of:a) The designated responsibility and

authority for achievement of theobjectives at relevant functions andlevels of the organization; and

b) The means and time-scale by whichobjectives are to be achieved.

The OH&S management programme(s) shallbe reviewed at regular and planned intervals.Where necessary the OH&S managementprogramme(s) shall be amended to addresschanges to the activities, products, services,or operating conditions of the organization.

4.3.4 is Not in 14001:2004, as it is now

merged into clause 4.3.3. The sametreatment has been applied here.

4.4.1Structure and

responsibility

(4.4.1 Resources,roles,responsibility,accountabilityand authority)

The roles responsibilities and authorities ofpersonnel, who manage, perform and verify

activities having an effect on the OH&S risksof the organizations activities, facilities andprocesses, shall be defined, documentedand communicated in order to facilitateOH&S management.Ultimate responsibility for occupational healthand safety rests with top management. Theorganization shall appoint a member of topmanagement (e.g. in a large organization, a

Board or executive committee member) withparticular responsibility for ensuring that the

Top management shall take ultimateresponsibility for OH&S and the OH&S

management system.

Top management shall demonstrate itscommitment by

a) ensuring the availability of resourcesessential to establish, implement,maintain and improve the OH&Smanagement system.

NOTE 1 Resources include human

Specific requirement for definedaccountability holders to be defined (this new

term and needs to be clarified).Accountable person is the person who hasbeen charged by management to undertakethe described activities, but may havedelegated the responsibility to a subordinatewhilst retaining the accountability to topmanagement.

Reference to accountabilities.

All persons effected by the

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clientscontinual improvement of OH&Sperformance.The organization shall ensure that persons inthe workplace take responsibility for aspectsof OH&S over which they have control,including adherence to the organizationsapplicable OH&S requirements.

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clients4.4.3Consultation andcommunication

(4.4.3Communication,participation andconsultation)

The organization shall have procedures forensuring that pertinent OH&S information iscommunicated to and from employees andother interested parties.Employee involvement and consultationarrangements shall be documented andinterested parties informed.Employees shall be:

a) Involved in the development and reviewof policies and procedures to managerisks;

b) Consulted where there are any changesthat affect workplace health and safety;

c) Represented on health and safetymatters; and

d) Informed as to who is their employeeOH&S representative(s) and specified

management appointee (see 4.4.1).

4.4.3.1 Communication

With regard to its OH&S hazards and OH&Smanagement system, the organization shallestablish, implement and maintain aprocedure(s) for

a) internal communication among the

various levels and functions of theorganization,b) communication with contractors and

other visitors to the workplacec) receiving, documenting and responding

to relevant communications fromexternal interested parties.

Clear and more focussed

Explicitly mentions communications withvisitors and contractorsContractors communications need to be

documented also what happens to theresults of the communication

Define process for receiving & responding tocommunications from external interestedparties.

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clients4.4.3.2 Participation and consultation

The organization shall establish, implementand maintain a procedure(s) for:a) the participation of workers by their :

appropriate involvement in hazardidentification, risk assessments anddetermination of controls,

appropriate involvement in incidentinvestigation;

involvement in the development andreview of OH&S policies and objectives;

consultation where there are any changesthat affect their OH&S;

representation on OH&S matters.Workers shall be informed about their

participation arrangements, including who istheir representative(s) on OH&S matters.b) consultation with contractors where thereare changes that affect their OH&S

The organization shall ensure that, whenappropriate, relevant external interestedparties are consulted about pertinent OH&Sissues.

Specific requirements for the involvementand participation of the workforce in

Risk Assessment

Investigation processDeveloping Policies & objectives

More prescriptive in regard to associatesinvolvement in HIRARC & Investigation

4.4.4Documentation The organization shall establish and maintaininformation, in a suitable medium such aspaper or electronic form, that:a) Describes the core elements of the

management system and theirinteraction; and

b) Provides direction to relateddocumentation.

NOTE It is important that documentation iskept to the minimum required for

The OH&S management systemdocumentation shall includea) the OH&S policy and objectives,b) description of the scope of the OH&S

management system,c) description of the main elements of the

OH&S management system and theirinteraction, and reference to relateddocuments,

d) documents, including records, requiredby this OHSAS standard, and

More explicit in regard to particular OH&SDocumented requirements

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clientseffectiveness and efficiency. e) documents, including records,

determined by the organization to benecessary to ensure the effectiveplanning, operation and control ofprocesses that relate to themanagement of its OH&S risks.

NOTE It is important that documentation is

proportional to the level of complexity,hazards and risks concerned and is kept tothe minimum required for effectiveness andefficiency.

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clientsunder specified conditions by:a) establishing and maintaining

documented procedures to coversituations where their absence couldlead to deviations from the OH&S policyand the objectives;

b) stipulating operating criteria in theprocedures;

c) establishing and maintainingprocedures related to the identifiedOH&S risks of goods, equipment andservices purchased and/or used by theorganization and communicatingrelevant procedures and requirementsto suppliers and contractors;

d) Establishing and maintainingprocedures for the design of workplace,

process, installations, machinery,operating procedures and workorganization, including their adaptationto human capabilities, in order toeliminate or reduce OH&S risks at theirsource.

For those operations and activities, theorganization shall implement and maintain:a) operational controls, as applicable to the

organization and its activities; theorganization shall integrate thoseoperational controls into its overallOH&S management system.

b) controls related to purchased goods,equipment and servicesc) controls related to contractors and other

visitors to the workplaced) documented procedures, to cover

situations where their absence couldlead to deviations from the OH&S policyand the objectives.

e) stipulated operating criteria where their

absence could lead to deviations fromthe OH&S policy and objectives

organisation.

Link processes to OHSAS systems.

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clientsc) proactive measures of performance thatmonitor compliance with the OH&Smanagement programme, operationalcriteria and applicable legislation andregulatory requirements;

d) reactive measures of performance tomonitor accidents, ill health, incidents(including near-misses) and other

historical evidence of deficient OH&Sperformance;e) Recording of data and results of

monitoring and measurement sufficientto facilitate subsequent corrective andpreventative action analysis.

If monitoring equipment is required forperformance measurement and monitoring,the organization shall establish and maintainprocedures for the calibration andmaintenance of such equipment. Records ofcalibration and maintenance activities andresults shall be retained.

(for health as well as for safety)d) proactive measures of performance that

monitor conformance with the OH&Sprogramme(s), controls and operationalcriteria;

e) reactive measures of performance thatmonitor ill health, incidents (includingaccidents, near-misses, etc.), and other

historical evidence of deficient OH&Sperformance;

f) recording of data and results ofmonitoring and measurement sufficientto facilitate subsequent corrective actionand preventive action analysis.

If equipment is required to monitor ormeasure performance, the organization shallestablish and maintain procedures for thecalibration and maintenance of suchequipment, as appropriate. Records ofcalibration and maintenance activities andresults shall be retained.

4.5.2Acc idents,incidents, non-conformancesand correctiveand preventiveaction

Moved to 4.5.3

(4.5.2 Evaluationof compliance)

New clause 4.5.2.1Consistent with its commitment tocompliance (see 4.2c)), the organizationshall establish, implement and maintain aprocedure(s) for periodically evaluatingcompliance with applicable legalrequirements (see 4.3.2).

New procedure for periodic evaluation ofcompliance in line with ISO 14001requirements.

The records of the outputs need to beappropriate to the risks and controls beingmanaged

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for ClientsThe organization shall keep records of theresults of the periodic evaluations.

Note The frequency of periodic evaluationmay vary for differing legal requirements

New clause 4.5.2.2The organization shall evaluate

compliance with other requirements to whichit subscribes (see 4.3.2). The organizationmay wish to combine this evaluation with theevaluation of legal compliance referred to in4.5.2.1 or to establish a separateprocedure(s).

The organization shall keep records of theresults of the periodic evaluations.

Note The frequency of periodic evaluationmay vary for differing other requirements towhich the organization subscribes

New procedure for periodic evaluation of

compliance in line with ISO 14001requirements.

The records of the outputs need to beappropriate to the risks and controls beingmanaged

Must now evaluate the compliance with theother requirements

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clients

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clients4.5.3 Recordsand recordsmanagement

(4.5.3 Incidentinvestigation,nonconformity,corrective action

and preventiveaction)

4.5.2 The organization shall establish andmaintain procedures for definingresponsibility and authority for:a) the handling and investigation of:

accidents;

incidents;

non-conformances;b) taking action to mitigate any

consequences arising from accidents,incidents or non-conformances;

c) the initiation and completion of correctiveand preventive actions;

d) Confirmation of the effectiveness ofcorrective and preventive actions taken.

These procedures shall require that allproposed corrective and preventive actionsshall be reviewed through the risk

assessment process prior to implementation.Any corrective or preventive action taken toeliminate the causes of actual and potentialnon-conformances shall be appropriate tothe magnitude of problems andcommensurate with the OH&S riskencountered.The organization shall implement and recordany changes in the documented procedures

resulting from corrective and preventiveaction.

4.5.3.1 Incident investigation

The organization shall establish, implementand maintain a procedure(s) to record,investigate and analyze incidents in order to

a) determine underlying OH&S deficienciesand other factors that may be causing orcontributing to the occurrence ofincidents.

b) identify the need for corrective actionc) identify opportunities for preventive

actiond) identify opportunities for continual

improvemente) communicate the results of such

investigations

The investigations shall be performed in atimely manner.

Any identified need for corrective action oropportunities for preventive action shall bedealt with in accordance with the relevantparts of 4.5.3.2.

The results of incident investigations shall bedocumented and maintained.

Focus upon preventive measures relating tomaintenance of equipment as fit for purposenot liable to cause explosions etc, think BP &Exxon, Lessons Learnt from previousincidents! Use of incident investigation.

Specific reference to determine root cause &assignment of appropriate corrective action

Requirement to record and analyse

Timely manner new

Procedures to specifically a) e) for incidentmanagement

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OHSAS 18001 - 1999 OHSAS 18001 - 2007 Impl ications for Clients4.5.3.2 Nonconformity, corrective action andpreventive action

The organization shall establish, implementand maintain a procedure(s) for dealing withactual and potential nonconformity(ies) andfor taking corrective action and preventiveaction. The procedure(s) shall definerequirements for

a) identifying and correctingnonconformity(ies) and taking action(s)to mitigate their OH&S consequences,

b) investigating nonconformity(ies),determining their cause(s) and takingactions in order to avoid theirrecurrence,

c) evaluating the need for action(s) toprevent nonconformity(ies) andimplementing appropriate actionsdesigned to avoid their occurrence,

d) recording and communicating the resultsof corrective action(s) and preventiveaction(s) taken, and

e) reviewing the effectiveness of correctiveaction(s) and preventive action(s) taken.

Where the corrective action and preventiveaction identifies new or changed hazards orthe need for new or changed controls, theprocedure shall require that the proposedactions shall be taken through a riskassessment prior to implementation.

Any corrective action or preventive actiontaken to eliminate the causes of actual and

potential nonconformity(ies) shall be

Procedure to identify and to correctnonconformity then manage nonconformitiesin line with requirements b) e)

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3) is effective in meeting theorganizations policy and objectives;

b) review the results of previous audits;c) Provide information on the results of

audits to management.The audit programme, including anyschedule, shall be based on the results ofrisk assessments of the organizationsactivities, and the results of previous audits.The audit procedures shall cover the scope,frequency, methodologies andcompetencies, as well as the responsibilitiesand requirements for conducting audits andreporting results.Wherever possible, audits shall beconducted by personnel independent ofthose having direct responsibility for theactivity being examined.NOTE The word independent here does notnecessarily mean external to theorganization.

maintained, and

3) is effective in meeting the organizationspolicy and objectives;

b) provide information on the results ofaudits to management.

Audit programme(s) shall be planned,established, implemented and maintained bythe organization, based on the results of riskassessments of the organizations activities,and the results of previous audits.

Audit procedure(s) shall be established,implemented and maintained that addressa) the responsibilities, competencies, and

requirements for planning andconducting audits, reporting results andretaining associated records,

b) the determination of audit criteria, scope,frequency and methods.

Selection of auditors and conduct of auditsshall ensure objectivity and the impartiality ofthe audit process.

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4.6 Managementreview

The organizations top management shall, atintervals that it determines, review the OH&Smanagement system, to ensure itscontinuing suitability, adequacy andeffectiveness. The management reviewprocess shall ensure that the necessaryinformation is collected to allow managementto carry out this evaluation. This review shallbe documented.

The management review shall address thepossible need for changes to policy,objectives and other elements of the OH&Smanagement system, in the light of OH&Smanagement system audit results, changingcircumstances and the commitment tocontinual improvement.

Top management shall review theorganization's OH&S management system,atplanned intervals, to ensure its continuingsuitability, adequacy and effectiveness.Reviews shall include assessingopportunities for improvement and the needfor changes to the OH&S managementsystem, including the OH&S policy andOH&S objectives. Records of themanagement reviews shall be retained.

Input to management reviews shall includea) results of internal audits and evaluations

of compliance with applicable legalrequirements and with otherrequirements to which the organizationsubscribes,

b) the results of participation andconsultation (see 4.4.3)

c) relevant communication(s) from externalinterested parties, including complaints,

d) the OH&S performance of theorganization,

e) the extent to which objectives have beenmet,

f) status of incident investigations,

corrective actions and preventiveactions,

g) follow-up actions from previousmanagement reviews,

h) changing circumstances, includingdevelopments in legal and otherrequirements related to OH&S, and

i) recommendations for improvement.

The outputs from management reviews shall

Now includes more specific elements to beconsidered in the review.

Clearer output requirements to be met.

Requirement for outputs to be madeavailable to consult and communicate withworkers contractors and external interestedparties.

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Documents

OHSAS 18001 99-07