Transition to ISO 45001
|Compliance Briefing: Transition to ISO 45001|
|Author: Dawn Pope||Date: 20-4-18|
|Key issues: ISO Management Systems, Occupational Health & Safety Management Systems. Annex SL OHSAS 18001|
Compliance Briefing: Transition to ISO 45001
The purpose of this briefing note is to provide an insight into the reasons for, and the benefits of the changes to the occupational health and safety management system of the newly published ISO 45001:2018 and to provide some guidance to organisations on how to effectively implement these changes into their existing management system.
Firstly, to say we all should just relax, as there is three years to complete this transition. I could suggest that this transition will be easy if you already have OHSAS 18001:2007 and have transitioned to ISO 14001:2015 with the new Annex SL format. After all, it’s the same clauses, designed to make integration of the management systems simple, so what could possibly go wrong?
This summary of some of the changes is based on a gap analysis between the two standards. Obviously this briefing is no substitute for reading the standard itself, but hopefully it will give some insight into the subtle differences in the clause requirements.
There are 16 significant clause differences in the requirements for both standards and this provides an opportunity to enhance the ISO 14001 system by incorporating these additional ISO 45001 requirements if appropriate. The terminology differences such as compliance issues and legal and other requirements could be addressed by the organisation as part of their own terms and definitions.
A summary of the changes is provided in Table 1 below;
Table 1 A clause comparison of ISO 14001:2015 and ISO 45001:2018
|ISO 45001:2018||ISO 14001:2015||Element||Additional requirement|
|5.1 a-l||5.1 a-j||Leadership in 14001
Leadership & Worker participation in 45001
|Culture, Protecting workers from reprisals and ensuring the organisation applies a process for consultation and participation of workers.|
|5.2 a-f||OHSAS 18801
|OH&S Policy||Commitment to consultation and participation of workers|
|5.4||None||Consultation & Participation of workers||New requirement|
|6.1||6.1||Actions to address risks and opportunities.||Includes changes temporary and permanent workers|
|6.1.2||6.1.2 Aspects||Hazard Identification||8 processes defined for consideration
Assessment of OH&S opportunities
|184.108.40.206||None||Assess OH&S opportunities||New|
|6.1.3||6.1.3||Compliance Obligations||Still called legal and other requirements
Requirement to communicate
|6.1.4||6.1.4||Planning Action||Adds emergency situations|
|7.3 a-f||7.3 a-d||Awareness||3 additional issues|
|7.4.1 a-d||7.4.1 a-d||Communication||4 additional issues|
|8.1.1 – 8.1.4||8.1||Operational planning & control||Adds change management, contractors, outsourcing and procurement requirements|
|8.2 a-g||8.2 a-f||Emergency Preparedness||Adds interested parties|
|9.2.2. a-f||9.2.2 a-c||Internal Audit||1 reporting requirement|
|9.3 a-g||9.3 a-g||Management Review||2 extra inputs to review|
|10.2 a-g||10.2 a-e||Incident, nonconformity & corrective action||Adds Incident requirement|
|10.3 a-e||10.3||Continual Improvement||Sets five criteria|
Clause 5.1 Leadership and Worker Participation.
Additional to the ISO 14001:2015 requirements are the elements j) Developing, leading and promoting a culture… That supports the OHSMS, k) Protecting workers from reprisals when reporting OHS incidents, hazards, risks and opportunities and l) Ensuring the organisation establishes and implements a process for consultation and participation of workers. The onus on workers participation is key throughout the standard as workers are expected to be actively involved in the development of the arrangements.
Clause 5.2 Policy
The clause elements include; a) … conditions for the prevention of work related injury and ill health, b) A commitment to fulfil legal and other requirements (rather than compliance in ISO 14001), d) A commitment to eliminate hazards and reduce OH&S risks and f) include a commitment to consultation and participation of workers, and, where they exist workers’ representatives.
Clause 5.4 Consultation and Participation of Workers
This new clause requires process(es) for consultation and participation of workers at all applicable levels and functions and where they exist workers’ representatives… for improvement of the OH&S management system which corresponds to the statements on participation in clause 5.1.
Clause 220.127.116.11 Hazard Identification
This clause adds eight hazard factors to be considered for hazard identification which should be ongoing and proactive. The processes to be considered, but not be limited to include: Organisation of work, Social factors, Routine and non-routine activities, Past incidents, Potential emergency situations, People, Other issues, Actual or proposed changes, and Changes in knowledge or information.
Clause 7.3 Awareness
In addition to the requirements in ISO 14001 the following elements apply;
Workers shall be made aware of …. d) incidents and the outcomes of investigations that are relevant to them, e) Hazards, OH&S risks and actions determined that are relevant to them and f) The ability to remove themselves from work situations that they consider present an imminent and serious danger to their life or health, as well as the arrangements for protecting them from undue consequences for doing so.
Clause 8.1 Operational Planning and Control
This clause gives extended attention to third parties, and requires consideration of contractors, agency workers and occupants of shared sites.
Regrading procurement the clause requires that the organisation coordinate its procurement process with contractors … to assess and control OHS risks arising from contractor’s activities or organisation on contractor or contractor’s activities on other interested parties. And that the organisation shall ensure that all outsourced processes are controlled and consistent with legal and other requirements and the degree of control is defined within the OHSMS.
Clause 8.2 Emergency Preparedness and Response
Element g) requires that organisations consider the needs and capabilities of all relevant interested parties, and ensuring their involvement, as appropriate in development of the planned response.
Clause 9.2 Internal Audit
Additional requirement to Ensure that the results of the audits are reported to workers,… workers’ representatives and other relevant interested parties.
9.3 Management Review
The extra requirements for the management review include consideration of information of OH&S performance including … incidents and Consultation and Participation of workers.
10.2 Incident, nonconformity and corrective action
Having introduced the term incident this clause continues regarding incident investigation and risk assessment review. It states that the organisation shall evaluate with the participation of workers and involvement of other relevant interested parties the need for corrective action to eliminate the root cause in order that it does not recur or occur elsewhere. Review existing assessments of OH&S risks …. Determine and implement any action needed… in accordance with the hierarchy of control and the management of change. And assess OH&S risks that relate to new or changed hazards prior to taking action.
10.3 Continual Improvement
The new standard adds five criteria to demonstrate continual improvement, which are;
By enhancing OH&S performance, Promoting a culture that supports the OH&S management system, Promoting the participation of workers in implementing actions for the Continual Improvement of the OH&S management system, Communicating the relevant results of continual improvement to workers and… workers representatives. And Maintaining and retaining documented information as evidence of Continual Improvement.
Safe Environment Ltd have also provided an ISO 45001 gap analysis tool which may help you to determine your transition requirements. Please contact us via the website or call 01785 662967 for more details.
The opinions and comments in this article are personal to the author, and are provided purely to create an awareness of this compliance issue. The information is not comprehensive and the interested reader is recommended to review the ISO standard directly.