This is an important distinction. Individuals may work on an organization’s behalf, and therefore need to be competent for purposes of ISO 14001, but that work may not under the control of the organization. In that case, the organization does not need to ensure their competency for purposes of OHSAS 18001. The issue is not the nature of the work being done but the control the organization has over the work activity being performed.

An organization can “ensure” that individuals are competent in a variety of ways. This can include requiring that contractors are able to demonstrate that their employees have the necessary competency to work safely.

Like ISO 14001, this competency requirement also does not apply to every job, position or task. In determining what activities “could impact on OH&S” the organization should consider the results of the organization’s risk assessment, whether the tasks being performed are intended to reduce OH&S risks and/or whether the tasks are specific to the implementation of the OHSMS.