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Clause 4.

Context of the Organisation


4.1 Understanding the organisation and its context

This sprang naturally from our corporate business plan, strategic growth ambitions and
certification to ISO 9001:2015 and ISO 14001:2015. Firstly, we outlined the purpose of the
organisation, defining our mission, vision and commitment to excellence. Secondly, we
performed a business SWOT analysis to identify any internal or external issues or conditions,
which could affect the intended outcomes of our Integrated Management System (which now
included OH&S).

It is also possible to use a PESTEL analysis to identify and monitor any external influences on
your organisation. However, we decided to use the SWOT analysis as it tends to cover both
internal and external issues and therefore it is slightly more aligned with clause 4.1.

4.2 Understanding the needs and expectations of workers and other interested parties

We felt we had this clause well understood as part of our quality and environmental management
system. However, we needed to update our “Context and Stakeholder Analysis Register” to
reflect the needs and expectations of interested parties insofar as they apply to OH&S. We
identified the following relevant interested parties:

1. Employees
2. Clients
3. Local emergency services
4. Co-tenants of our premises
5. Contractors, sub-contractors and visitors
6. Regulators
7. Neighbours

We then performed a needs and expectations analysis of each interested party to determine what
considerations we needed to make as part of our OH&S management system (see below
example). Furthermore, we determined which of these needs and expectations are legal and/or
other requirements.
Clause 5. Leadership and worker participation
5.4 Consultation and participation of workers

Admittingly, our existing communication and consultation procedure needed some improvement.
Therefore, we took this as an opportunity to completely re-think how we could actively
encourage the consultation and participation of employees at all levels of the organisation. With
this in mind, we applied the following practical means of improving consultation and
participation:

1. We established a safety committee consisting of managerial and non-managerial employees


2. We implemented a safety suggestion box
3. We developed a consultative approach to our office inspection process, affording all employees
an opportunity to voice any health and safety concerns
4. We elaborated on our existing employee opinion survey to understand employee attitudes
towards health and safety
5. We initiated monthly IMS meetings, in addition to our Annual Management Review meeting
6. We added health and safety as a priority item at our annual Strategic Management Meeting
7. We improved our induction process to detail our communication and consultation procedures to
all new employees.

Interestingly, this clause is quite prescriptive in terms of emphasising the consultation and
participation of non-managerial employees with respect to the items listed in clause 5.4 (d) and
(e). Unfortunately, the standard does not define “emphasise” and I felt it was rather abstruse. I
look forward to seeing how other organisations interpret this term and what certification bodies
expect to see in terms emphasising consultation and participation.

Clause 6. Actions to address risks and


opportunities
6.1 Actions to address risk and opportunities

This clause was particularly unclear. Firstly, distinguishing between the terminology was
difficult:

“When determining the risks and opportunities to the OH&S management system and its
intended outcomes that need to be addressed, the organisation shall take into account:

 Hazards
 OH&S risks and other risks
 OH&S opportunities and other opportunities
 Legal requirements and other requirements”

Several questions sprang to mind, for example: how does an organisation take account of OH&S
risks and other risks when determining risks and opportunities to the OH&S management
system? What are other risks? Do these OH&S risks relate to the hazard identification and risk
assessment process?

To meet clause 6.1, we decided to identify OH&S hazards, which are likely to have the most
significant impact on employee safety and business continuity (e.g. driving for work and fire/loss
of premises). These OH&S hazards were documented and assessed (i.e. to determine a risk
rating) via our existing “Risks and Opportunities Register”, which we had prepared as part of our
existing quality and environmental management system. Thereafter, suitable objectives and
targets were planned in accordance with clause 6.2 (OH&S Objectives and Planning to Achieve
Them) to reduce the risk rating of the identified OH&S hazards.

The process of identifying opportunities in relation to the our OH&S management system was
also quite testing. Certainly, it was difficult to determine any opportunities arising from our most
significant OH&S hazards that were not already covered as part of our OH&S objectives.
Instead, we looked at our business as a whole and identified the potential opportunities that could
arise from the publication of ISO 45001. We concluded that becoming experts in ISO 45001
implementation through ongoing professional development and training of our consultants was
the most the valuable opportunity to our business.
I question the value of clause 6.1 in ISO 45001; it over-complicates the standard. I feel many of
the requirements on risks and opportunities are ambiguous and added in vain to provide
alignment to ISO 14001:2015 and ISO 9001:2015. I feel the outcomes of the traditional hazard
identification process and setting of OH&S objectives should determine the key risks and
opportunities to the OH&S management system.

Clause 8 Operation
8.1.4 Procurement

Whilst a specific clause on procurement did not feature in OHSAS 18001:2017, clause 4.4.6
required organisations to implement and maintain:

 controls related to purchased goods, equipment and services;


 controls related to contractors and visitors to the workplace.

ISO 45001 is much more prescriptive, requiring organisations to establish, implement and
maintain processes to control the procurement of products and services to ensure their
conformity to its OH&S management system. Furthermore, clause 8.1.4.2 (Contractors) requires
organisations to identify hazards and assess and control OH&S risks arising from:

 the contractor’s activities that may impact the organisation;


 the organisation’s activities that may impact on the contractor’s workers; and
 the contractors’ activities and operations that impact other interested parties in the workplace

There is also a specific requirement to ensure that health and safety criteria is applied to
procurement processes for contractor selection. For many companies, this is likely to form part
of contractual documents.

In the context of our organisation, clause 8.1.4.2 was less important as we do not rely heavily on
contractors. Nonetheless, we updated our contractor selection procedures to account for various
OH&S criteria when selecting contractors and we also instituted a contractor code of practice,
which is communicated to all contractors prior to engaging in any work at our premises.

For the delivery of larger and highly specialised consultancy projects, we often require expertise
in the form of sub-contractors. Therefore, clause 8.1.4.3 (Outsourcing) was particularly
important to our organisation as it requires organisations to ensure that outsourced functions and
processes are controlled. To meet this clause, we set mandatory OH&S criteria that sub-
contractors were required to meet prior to selection. Such criteria included:

 Level of insurance cover


 Submission of safety documentation, i.e. Safety Statements/Manuals/Policies
 Certifications to relevant ISO standards
 References
 Trade body membership
 Professional body membership
Secondly, we reviewed our existing sub-contractors to ensure they were in receipt of our
necessary safety information, such as a copy of our Safety Statement, relevant risk assessments
and operational control procedures. Thirdly, we extended our pre-site risk assessment to all sub-
contractors to ensure they assessed each site prior to arrival. Lastly, sub-contractor performance
formed part of the monthly IMS meetings and the annual management review meeting. The
aforementioned was supported by increased consultation and communication with all of our sub-
contractors.

In summary, having gone through the implementation process, I can attest to the efficiency of the
Annex SL framework, which did allow for a relatively straight forward integration of ISO 45001
to our existing quality and environmental management system. In essence, we had the
fundamentals addressed as part of our certification to ISO 9001:2015 and ISO 14001:2015.
Therefore, we simply studied the nuances of ISO 45001, implemented the additional
requirements where necessary and updated our documentation accordingly.