Process NOT Perfection

| July 13, 2011

I received the following question from a reader last week –

 When it comes time for our company to be audited on the OHSAS 18001 system, our auditor usually says, “Your Company has not identified ALL the hazards at your facility.”

…  I don’t believe that every potential hazard needs to be identified in order to be compliant.  I always explain this to the auditor, and address what it states in 4.3.1:

“The organization shall establish, implement and maintain a procedure(s) for the ongoing hazard identification, risk assessment, and determination of necessary controls.”

… I don’t feel our auditor is correct in saying we are not compliant because we have not identified all potential hazards.

I really would appreciate your thoughts on this matter.

You are correct in your analysis of the requirement in Section 4.3.1 of OHSAS 18001. What is required – and what auditors should be looking for – is a process NOT perfection.

This is an important distinction and a fundamental principle underlying all of the ISO management system standards and OHSAS 18001.  It is one of the 14 Points for Management that Deming emphasized in his 1982 book, Out of the Crisisand it is what the plan-do-check-act (PDCA) approach is all about.

To illustrate the difference, consider how one goes about controlling a manufacturing line making widgets.  There are 2 different approaches that can be used to ensure quality widgets – an inspection approach and a management system approach.

In an inspection approach, an individual sits at the end of the line and either accepts or rejects each widget on the basis of whether it is conforming or nonconforming.  Conforming widgets become products and nonconforming widgets become waste.

In a management system approach, procedures and operational criteria are put in place to ensure that quality products are made in the first place.  Quality is ensured by the process controls in place during manufacture not by a final inspection.  If a final inspection is done, the primary purpose is for evaluating the adequacy of the process controls not for product acceptance or rejection.

Some OHSMS auditors approach management system auditing with a “final inspector” mentality.  Rather than focusing on evaluating the adequacy of the management system, they gravitate to focusing on the OHSMS equivalent of looking for nonconformity products.  Rather than looking for system conformance, they look for isolated problems.  They act as inspectors not as auditors.

As in manufacturing widgets, isolated deficiencies do not establish the lack of an OH&S management system.  There can be many reasons for “flaws” – only some of which indicate management system failure.  The focus needs to be on evaluating the sufficiency of the management system procedures in place not on substituting auditor judgment for organizational process.

© ENLAR® Compliance Services, Inc. (2011)

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Category: OHSMS Auditing, OHSMS Implementation, Standards & Certification

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