Category: OHSAS 18001:2007 Revisions
Participation and Consultation
One of the major criticisms of the 1999 version of OHSAS 18001 was that it was a “management” standard that ignored “labor” interests. Significant changes were made in section 4.4.3 of the standard to address these concerns.
First, this section of the standard was divided into two sub-sections: 4.4.3.1 Communication and 4.4.3.2 Participation and Consultation. The requirements in sub-section 4.4.3.1 for internal and external communication are similar to the communication requirements in ISO 14001. The requirements in sub-section 4.4.3.2; however, are unique to OHSAS 18001 and focused specifically on getting input from workers and contractors.
An organization’s OHSMS communication procedures now need to address communication with several different parties:
- internal communication between various departments and functions
- communicating with visitors to the workplace
- participation of workers in OHSMS activities
- communication and consultation with contractors, and
- consultation with external interested parties, when appropriate
In particular, the procedures developed for worker participation now need to address the following:
- appropriate involvement in hazard identification, risk assessment and determination of controls
- appropriate involvement in incident investigation
- involvement in the development and review of OH&S policies and objectives
- consultation where there are changes that affect a worker’s OH&S
- representation on OH&S matters
- informing workers about the arrangements made for their participation and the identity of their representative(s) on OH&S matters
It should be noted that this worker participation requirement is not strictly a “labor” (employee-employer) issue. In the context of OHSAS 18001, the OHSMS needs to provide for the participation of all persons performing work under the control of the organization.
Improved Alignment with ISO 14001:2004
As discussed in a previous Blog, one of the major drivers in the revision of OHSAS 18001 was alignment with ISO 14001:2004. When OHSAS 18001 was originally developed in 1999, it was drafted to be consistent with ISO 14001:1996 in language and structure. When ISO 14001 was revised in 2004, some of the alignment between the standards was lost.
OHSAS 18001:2007 has been aligned in overall structure and numbering with ISO 14001:2004. In addition, many of the core management system elements (document control, record control, internal audit and management review) are aligned in language as well.
A significant change in OHSAS 18001 that is based on alignment with ISO 14001:2004 is the addition of new requirements related to identification and evaluation of compliance with OH&S legal and other requirements (Sections 4.3.2 and 4.5.2). Section 4.3.2 now requires that organizations ensure that applicable legal and other requirements are taken into account in establishing, implementing and maintaining their OH&S management systems. Section 4.5.2, Evaluation of Compliance, is new. As in ISO 14001, organizations will need to establish a procedure to periodically evaluate their compliance with applicable OH&S legal and other requirements. This new requirement is more expansive than the requirement in the 1999 standard that organizations provide proactive measures of performance to monitor applicable legislation and regulatory requirements.
Not all of the language in OHSAS 18001 is aligned with ISO 14001:2004. There are four areas where there are significant differences between the two standards:
- Identification and evaluation of OH&S hazards and risks (as opposed to the aspect/impact analysis provisions of ISO 14001)
- Requirements related to worker participation and consultation with other parties such as contractors
- Selection and implementation of operational controls
- Specific requirements for incident investigation
© ENLAR® Compliance Services, Inc. (2007)
