OHSAS 18001: 2007The Changes

Interpretation and Implementation guidelines

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Together we will cover

A Quick Overview Definitions The changes The transition
Exercises and discussions in between!

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22 February 2008

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Why Change?
When OHSAS 18001 was initially drafted in 1999, it was specifically written to be consistent with ISO 14001:1996, the environmental management system standard developed by the International Organization for Standardization (ISO).

With subsequent revision of ISO 14001 in 2004, some of the alignment between the two standards were lost.

In 2005, the OHSAS Working Group decided to revise the OHSAS 18001 standard to again align it with ISO 14001 and to improve it based on the experience of the standards users since it was first published in 1999.

In addition to alignment with ISO 14001, another major factor taken into consideration during the revision process was alignment with other occupational safety and health management system standards such as the ILO and the ANSI/AIHA Z10 standards

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Summary of Changes
Based on these inputs, a number of significant changes has been made to the OHSAS 18001:2007 Alignment with ISO 14001:2004 & improved compatibility with ISO 9001:2000 New requirements related to hazard identification, risk assessment and the selection of controls New requirements for external consultation and worker participation Clarification of the role of incident investigation The importance of health has now been given greater emphasis. OHSAS 18001 now refers to itself as a standard, not a specification, or document, as in the earlier edition. This reflects the increasing adoption of OHSAS 18001 as the basis for national standards on occupational health and safety management systems.

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Summary of Changes
Reference publications in Clause 2 have been limited to purely international documents. New definitions have been added, and existing definitions revised. Significant improvement in alignment with ISO 14001:2004 throughout the standard, and improved compatibility with ISO 9001:2000. The definition of the term HAZARD no longer refers to damage to property or damage to the workplace environment.

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Why change in definition of HAZARD

It is now considered that such damage is not directly related to occupational health and safety management, which is the purpose of this OHSAS Standard, and that it is included in the field of asset management. Instead, the risk of such damage having an effect on occupational health and safety should be identified through the organizations risk assessment process, and be controlled through the application of appropriate risk controls. For purposes of OHSAS 18001, hazards are limited to sources, situations or acts with the potential for harm in terms of human injury or ill health. The focus is on harm to humans not property.

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Summary of Changes
Sub-clauses 4.3.3 and 4.3.4 have been merged, in line with ISO 14001:2004. A new requirement has been introduced for the consideration of the hierarchy of controls as part of OH&S planning (see 4.3.1). Management of change is now more explicitly addressed (see 4.3.1 and 4.4.6). A new clause on the Evaluation of compliance (see 4.5.2) has been introduced. New requirements have been introduced for participation and consultation (see 4.4.3.2). New requirements have been introduced for the investigation of incidents (see 4.5.3.1).

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Scope

OHS risks of employees and other interested parties- Included

Property damage and damage to the workplace environment are no longer part of the scope for OHSAS (also reflected in revised definition of Hazard).

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Scope
As noted in the Scope section of the revised standard, OHSAS 18001 is intended to address occupational health and safety, and is not intended to address other health and safety issues such as employee wellbeing/wellness programs, product safety, property damage or environmental impacts.

Several changes were made to the standard to clarify the intended scope of coverage - most notably in the revision and/or addition of several key definitions.

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What are the new definitions?

Review the OHSAS 18001:2007 Clause 3.0 & identify the new definitions and changes?

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Definitions
6 new terms : Document, Procedure, Record, Corrective Action, Preventive Action and OH&S policy New definitions for ill health and workplace. Revised definitions for hazard, incident and risk Mainly editorial changes for the other terms. Tolerable risk replaced by acceptable risk in new edition.

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Definitions
Hazard (3.6) Source, situation, or act with a potential for harm in terms of human injury or ill health (3.8), or a combination of these

ill health (3.8) Identifiable, adverse physical or mental condition arising from and/or made worse by a work activity and/or work-related situation

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Definitions
Incident (3.9) work-related event (s) in which an injury or ill health (3.8) (regardless of severity) or fatality occurred, or could have occurred

NOTE 1: An accident is an incident which has given rise to injury, ill health or fatality. NOTE 2: An incident where no injury, ill health, or fatality occurs may also be referred to as a near-miss, near-hit, close call or dangerous occurrence. NOTE 3: An emergency situation (see 4.4.7) is a particular type of incident.

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Definitions
interested party (3.10) person or group, inside or outside the workplace (3.23), concerned with or affected by the OH&S performance (3.15) of an organization (3.17). preventive action (3.18) action to eliminate the cause of a potential nonconformity (3.11) or other undesirable potential situation

NOTE 1 There can be more than one cause for a potential nonconformity. NOTE 2 Preventive action is taken to prevent occurrence whereas corrective action (3.4) is taken to prevent recurrence. [ISO 9000:2005, 3.6.4]
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Definitions
risk (3.21) combination of the likelihood of an occurrence of a hazardous event or Exposure (s) and the severity of injury or ill health (3.8) that can be caused by the event or exposure (s)

risk assessment (3.22) process of evaluating the risk (s) (3.21) arising from a hazard (s), taking into account the adequacy of any existing controls, and deciding whether or not the risk (s) is acceptable

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Definitions
workplace (3.23) any physical location in which work related activities are performed under the control of the organization

NOTE: When giving consideration to what constitutes a workplace, the organization (3.17) should take into account the OH&S effects on personnel who are, for example, traveling or in transit (e.g. driving, flying, on boats or trains), working at the premises of a client or customer, or working at home

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What are the new requirements?

Review the OHSAS 18001:2007 Clause 4.1 to 4.6 & identify the new changes?

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4.1 General Requirements

OHSAS:2007 more explicit on Continual improvement of the OHSAS.

Need for the organization to define and document the scope for the OHSAS.

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4.2 OH&S Policy

OHSAS:2007 more explicit on:

Communication of policy to all persons working under the control of the organization and not only to employees as in previous edition. Inclusion in b) of a commitment to prevention of injury and ill health and . This substantiates more focus on Health

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4.3.1 Hazard Identification, risk assessment and determining controls

Process steps clarified : Hazard Identification Risk assessment Determination of controls OHSAS:2007 more explicitly addresses Management of change

A new requirement on hierarchy of controls: Version

Elimination Substitution Engineering controls Signage/ warning. Administrative controls Personal Protective Equipment (PPEs)
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4.3.1 Hazard Identification, risk assessment and determining controls

Changes align OHSAS 18001 more closely with other OH&S management system standards such as ANSI/AIHA Z10:2005. This section now sets out additional details on both the inputs to be considered and the methodology to be used for the hazard identification and risk assessment process. The standard now clearly links the requirements in 4.3.1 with those set out in 4.4.6 (operational control) so it is clear that the controls identified during the OH&S planning process need to be implemented and maintained as an integral part of operational control.

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Inputs for Hazard Identification, risk assessment

Routine & Non-routine activities Activities of all persons at workplace Human behavior, capabilities and other human factors (included in 4.3.1 from 4.4.6) Identified hazards originating outside workplace but have adverse effects (New) Hazards created in the vicinity of workplace by activities Infrastructure, equipments, materials in workplace Changes or proposed changes in organization, activities, or materials (Newaligned with ISO 14001:2004) Modification in OHSAS including temporary changes & their impacts Applicable legal requirements Design of work areas, processes, machinery and ergonomic factors (included in 4.3.1 from 4.4.6)

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Buzz groups- (10 minutes)

What is Behavioural Safety?

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Human Behavioral Safety

Behavioral safety is the systematic application of psychological research on human behavior to the problems of safety in the workplace.
Example: Ducking under or climbing over assembly lines to reach the controls, not holding the handrail when ascending/ descending stairs, not putting equipment away after completing a job, etc., are all unsafe behaviors.

Given that 96 percent of all workplace accidents are triggered by unsafe behavior, most people will be aware that reducing accidents and improving safety performance can only be achieved by systematically focusing upon those unsafe behaviors in the workplace

These are in the direct control of the person engaging in them, and therefore can be targeted for improvement via a workforce driven behavioral safety initiative.

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Why Behavioral Safety?

Fully engages the workforce in safety management, perhaps for the first time in their working lives. Behavioral safety overcomes traditional Top-down approach towards Safety management & allowing the work force been divorced from the safety improvement process by deliberately adopting a bottom-up approach so that those most likely to be hurt are actively engaged in eliminating the occurrences of unsafe behaviors. Ensure workforce involvement so that the ownership of, and commitment to, the process does not lack and the initiatives does not fail. Focus on that small proportion of unsafe behaviors that are responsible for the lions share of a companys accidents/ incidents. Targeting Unsafe Acts/conditions will soon eliminate the accidents historically associated with them.

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Planning for Behavioral safety

It involves a systematic, observational, improvement intervention by ;
Introduction of planned schedule of events that combine to create an overall improvement intervention. Through briefing sessions for all those work areas and departments that will be involved. Formation of Project Team with Cross Functional approach. Asking the people to volunteer to either become observers or part of the project team or steering committee and are subsequently being trained to carry out their respective duties. Development of Behavioral Safety checklist.

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Planning for Behavioral safety

Trained observers carry out observations for a certain period of time to establish a baseline (usually four weeks), with which subsequent performance can be compared. Setting improvement targets after based on average baseline scores. The observers continue to monitor their colleagues safety behaviors on a regular basis. The observation scores are then analyzed & trended so that fine detailed feedback can be given to the workgroups or people concerned on a regular basis so that improvements can be highlighted and praised or corrective actions can be taken thus incorporating the principles of continuous improvement.

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Methods to Implement Behavioral Safety

These behaviors can be discovered via Pareto analyses or other systematic means of examining a companys accident / incident records. Utilizing Applied Behavioral Analytic techniques- to identify the workplace factors that drive or trigger particular unsafe behaviors and the consequences or rewards to the person for engaging in these unsafe behaviors. Identifying associated management system faults so that they can be addressed in order to stop them triggering unsafe behaviors. The unsafe or safe behaviors identified from such a process are written onto a checklist of some form. By monitoring peers safety behavior on a regular basis through trained observers

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Monitoring Behavioral Safety

Very act of observing and measuring peoples safety behavior alters the behavior of those being observed. Example : If someone is descending the stairs without holding the handrail and is seen by a trained observer during an observation tour, that person will probably change their behavior to that of holding the handrail. Greater the number of observations, the more reliable the data is, and the more likely it is that safety behavior will improve. Communicating the trends of unsafe acts over a period of time to all employees under various categories e.g. Housekeeping, Use of Tools, Line of Fire, Personal Protective Equipment, etc., for their approval or buy-in. As the behavioral safety observation system matures, people identify other unsafe behaviors and place these on the checklists as the original unsafe behaviors are eliminated or bought under control. The golden rule for these behaviors is that they are directly observable: i.e. anybody can see them as they occur.

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Acting on Behavioral safety

It requires visible on-going support from managers and front-line supervision:
Managements visible and demonstrable commitment to the process is vital by - Demonstrate their commitment by allowing the observers the time to conduct their observation tours; - Praise and recognition to those working safely; - Provide the necessary resources and assistance for remedial actions to take place; - Help to set up and run regular feedback sessions; and generally promote the initiative whenever and wherever the opportunity arises.

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Management Of Change
Although it is often used as a term of art in the safety field, management of change is not a defined term in OHSAS 18001:2007. It is, however; vital to an effective OH&S management system.

Explicit requirements for management of change were added into section 4.3.1 of OHSAS 18001 in the 2007 revision of the standard. This addition was an explicit request of the American Industrial Hygiene Association for purposes of aligning OHSAS 18001 with the U.S. Occupational Health and Safety Management System standard ANSI/AIHA Z10-2005. In addition, management of change is also an explicit requirement for safety management systems implemented to comply with the Seveso II Directive (see Annex III of EU Council Directive 96/82/EC).

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Buzz groups- (10 minutes)

What do you understand by Management of Change?

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Management of Change
The following requirements related to management of change were added in section 4.3.1: The procedures for hazard identification and risk assessment shall take into account: - changes or proposed changes in the organization, its activities or materials;
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modifications to the OH&S management system, including temporary changes, and their impacts on operations, processes and activities;. For the management of change, the organization shall identify the OH&S hazards and risks associated with changes in the organization, the OH&S management system or its activities, prior to the introduction of such changes. In addition, reference to Management of Change is also included in section 4.4.6:

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What is Change?
For purposes of management of change within an OH&S management system, the changes that need to be addressed include: - Organizational changes (e.g. personnel or staffing changes) - Activity changes (e.g. changes to processes, equipment, infrastructure, software) - Material changes (e.g. new chemicals, packaging) - Changes to the OH&S management system (e.g. procedures)

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Why Management of Change?

Why is management of change so important?
Ineffective management of change is one of the leading causes of serious incidents.
- Refer: U.S. Chemical Safety and Hazard Investigation Board (CSB), In industry, as elsewhere, change often brings progress. But it can also increase risks that, if not properly managed, create conditions that may lead to injuries, property damage or even death. (from CSB press release announcing its 8/28/2001 Safety Bulletin concerning Management of Change)

Ineffective management of change is one of the major contributing factors in many of the incident investigations. Please visit CSB web site at http://www.csb.gov/ for further reference.

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Where to apply Change concepts?

These new requirements cover four important concepts: - Identification of the hazards associated with change - Assessment of the risks associated with change - Consideration of OH&S hazards and risks prior to the introduction of the change - Implementation of the controls needed to address the hazards and risks associated with the change

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4.3.2 Legal and Other Requirements

OHSAS:2007 explicit to require that applicable legal requirements and other requirements to which the organization subscribes are taken into account in establishing, implementing and maintaining its OH&S management system

Communication of relevant information to employees and other interested parties

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4.3.3 Objectives and Programs

at each relevant function have been replaced by at relevant functions in OHSAS:2007

Former 4.3.4 has been merged into this clause

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4.4.1 Resources, Roles, Responsibility, Accountability and Authority

OHSAS:2007 more explicit to require:
Assurance by the organisation that persons in the workplace in general take responsibility for aspects of OH&S over which they have control and adheres to applicable OH&S requirements.

Reassuring Commitment from top management on OH&S management.

Accountability is a new term!

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Buzz groups- 5 minutes

What is Accountability?

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What is Accountability?
It is worthwhile, in this context, to explore the differences between authority, responsibility and accountability in an organization:

Authority is the right to make a decision or take an action

Responsibility is the obligation to ensure that an action is taken

Accountability is to be answerable for a particular activity or action to a particular entity

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Accountability
There are five key elements of an effective accountability system:

- Clearly specified standards for authority and responsibility - Adequate resources to meet the assigned responsibilities - Monitoring and assessment of individual performance - Appropriate consequences for taking or failing to take action
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Consistent and unbiased application It should be noted that accountability is not necessarily the same as blame. Often, organizations seek to assign accountability only when they are looking for someone to blame.

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4.4.2 Competence, training and awareness

OHSAS:2007 more explicit on:

Addressing awareness training for persons working under its control and not limited to employees as in previous edition.

Retaining records of relevant training, education and experience

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4.4.3 Communication, Participation and Consultation

OHSAS:2007 more explicit on:

Addressing communication to contractors and other visitors to the workplace with regard to the OH&S hazards and consultation with contractors when there are changes affecting their OH&S

Appropriate involvement from workers in hazard identification, risk assessment and determination of controls and within incident investigation and development of OH&S policies and objectives.

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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 is divided into two sub-sections:
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4.4.3.1 Communication for internal and external communication are addressed similar to the communication requirements in ISO 14001.

4.4.3.2 Participation and Consultation. is unique to OHSAS 18001 and focused specifically on getting input from workers and contractors.

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Communication
An organizations OHSMS communication procedures now need to address communication with several different parties:

- Internal communication with Employees & between various departments and functions

- Communicating with Visitors to the workplace

- Participation of Workers in OHSAS activities

- Communication and Consultation with Contractors, and

- Consultation with External Interested Parties, when appropriate

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Communication
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 workers 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.
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4.4.5 Control of documents

OHSAS:2007 explicitly requires control of documents of external origin

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4.4.6 Operational Control

OHSAS:2007 explicitly refers that operations and activities related to management of change shall be considered for needed operational controls.

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4.5.1 Performance measurement and monitoring

OHSAS:2007 includes new clause c) for monitoring the effectiveness of controls and stating explicitly that this shall be done for health as well as for safety.

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4.5.2 Evaluation of Compliance

New clause in OHSAS:2007, requirements fully aligned to ISO 14001

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4.5.3 Incident Investigation, Nonconformity, Corrective Action and Preventive Action

OHSAS:2007 includes new clause 4.5.3.1 on Incident investigation. Although partly covered in previous edition more emphasis have been put on this issue.

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4.6 Management review

OHSAS:2007 largely aligned with ISO 14001. Compared to previous edition OHSAS:2007 lists the following required input to Management review: - results of internal audits and evaluations of compliance with applicable legal requirements and with other requirements to which the organization subscribes, - the results of participation and consultation (see 4.4.3) - relevant communication (s) from external interested parties, including complaints, - the OH&S performance of the organization, - the extent to which objectives have been met, - status of incident investigations, corrective actions and preventive actions, - follow-up actions from previous management reviews, - changing circumstances, including developments in legal and other requirements related to OH&S, and - recommendations for improvement.
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Alignment with ISO 14001

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.

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Alignment with ISO 14001:2004

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.

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Alignment with ISO 14001:2004

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

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Implementation
The Scope of the system shall be defined Hazard Identification and Risk assessment : The procedure has to incorporate many new inputs as mentioned in 4.3.1. Damage to property and workplace environment may be excluded. Occupational health must occupy the central position Risk Controls: Must follow the hierarchy of controls as per Cl.4.3.1 Accountability of employees on key issues shall be defined Procedure for workers participation in HIRA, incident investigation, development of policy & objectives Procedure for Evaluation of compliance to Legal requirements Management Review- Inputs and Outputs shall be defined. Relevant output to be made available for communication and consultation

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Guidelines for conversion

For those organizations that have already achieved certification to OHSAS 18001:1999, or are in the final stages of achieving it, a two year Transition Period has been agreed, in order to allow them to make the change to using the new standard. The transition period will end on 1st July 2009. For those organizations that are just starting down the path towards seeking certification to OHSAS 18001, and are looking for guidance to assist them, OHSAS 18002:2000 Occupational health and safety management systems Guidelines for the implementation of OHSAS 18001 is recommended. While the guideline is aligned on a clause by clause basis against OHSAS 18001:1999, it does still contain valuable advice on what you need to do to achieve compliance. Work will now be starting in the OHSAS Project Group to revise OHSAS 18002:2000, with a target of the end of the 3rd quarter of 2008 for publication of a revised edition.

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