Category Archives: ISO 45001

ISO 45001 Clause 6 Revision – Streamlining Proposal

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ISO committee TC 283 has begun a Systematic Review of ISO 45001 that is expected to be completed in early 2027. Clause 6 on Planning is one of the key areas of focus for the committee. Once the systematic review is complete a revision will be finalized and the current version of the standard (ISO 45001:2018) will be repealed.

The revision process offers the opportunity to incorporate changes to the ISO High Level Structure (HLS). It also provides an opportunity to review areas of the standard that have caused confusion for users since it was first published in 2018. One of these areas is Clause 6, the planning part of the management system standard. This section is currently over 1100 words and three pages long. User have complained about confusing terms including risk, opportunity, OHS hazard OHS risk, other risks and other opportunities.

ISO 45001 systematic review

Simplify and Clarify Clause 6

For some users, these confusing terms make it difficult to comprehend what the standard is supposed to be managing. It also duplicates of requirements in other parts of the ISO 45001 standard. One proposal to simplify and clarify clause 6 would reduce the number of words from 1100 to a little over 300. Comments from other committee members of this proposal rang from “this is great, all standards should be this concise” to “this goes way too far and should not be considered”.

Make a Fresh Start

The concept is to begin the review clause 6 revision process with an almost clean sheet of paper and build on the text from there. If committee members believe that additional text is needed they should justly the addition including:

  • Why the addition is needed in the requirement part of the standard and not as guidance in the annex part of the standard
  • A description of what evidence auditors should look for a conformance to the requirement
  • It does not duplicate another requirement somewhere else in the standard.

If the additional desired text is more guidance than requirement it should be placed in the annex of the standard, not in the requirements part or perhaps, in an entirely different document like ISO 45002.

Reduce Confusing Terms

The streamlining proposal also clarifies what ISO 45001 is supposed to be managing by eliminating some confusing terms in clause 6. Terms like “Risk and Opportunity, “other risk” and “other opportunity” and replacing them with the term “OHS Hazard Risk”. This proposal for streamlining and simplifying clause 6 is already controversial with some members. It is likely to be hotly debated over the next few months as the ISO 45001 revision process gathers momentum in committee meetings later this fall..

Big 3 Standards Now Under Revision – What You Need to Know

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The 3 big ISO standards are now under revision. ISO 14001, 45001 and 9001 are being reviewed and revised simultaneously.  Recently, ECSI attended meetings of the US Technical Advisory Groups (TAG) for both ISO 14001, and 9001 in Washington DC where the upcoming revisions were discussed. We have also been participating in the US TAG to ISO 45001 and in meetings discussing revisions to that standard.

The revised standards will be released in a few years when organizations will be need to conform with the revisions. The following is a brief discussion of what to expect for revisions to each standard.

ISO 14001

ISO 14001 was first published in 1996.  Since then, it has been revised twice. Once in 2004 and again in 2015.  The 2015 revision incorporated a major change. This change involved converting the entire standard to the ISO High Level Structure (HLS).  Although the revision will not introduce new requirements, it may make changes to clarify some of the key requirements such as the relationship between risk and opportunity and significant environmental aspects.

The revision will integrate changes to the HLS and address concerns raised by users of the standard over the past 9 years.   Initially the ISO 14001 revision committee considered issuing an amendment with the few HLS changes.  The committee thought that this would be easier and take less time than a full revision.  The committee was also concerned about opening the standard up to a broader revision that could result in additional requirements.

Recently however, the committee discovered that the amendment option has significant drawbacks making it an unlikely choice.  The amendment route would have resulted in issuance of a separate 28 plus page document to be used with the current 2015 version of the standard.  Users would have to reference 2 different documents when using the new amended standard.  The committee is looking at other amendment options, but it appears the only way to avoid the 2 document problem is to do a full revision and then issue a single revision document.

If a full revision does occur, it provides more opportunity to address sections of the standard that have caused confusion for users.  Additionally, it creates an opportunity to take advantage of changes in the HLS that offer flexibility when using the term “risk and opportunity” in the planning section of the standard.

ISO 45001

The committee revising ISO 45001 has decided to do a full revision instead of just a limited amendment.  This option avoids the 2 document problem created by the amendment route and gives the committee greater flexibility in what can be changed. This includes clarifying and streamlining parts of the standard that users have found confusing and redundant.

Clause 6 (Planning) is one of the parts that has potential for improvement to make it more user friendly for small and medium sized organizations.  Clause 6 of the standard in the current version was over 1100 words and three pages in length.  One proposal being circulated for the revision by the committee would dramatically reduce the text by two thirds to only 318 words and 1 page.

There is also a proposal to refer to “OHS Hazard Risk” when describing what the OHSMS is supposed to be managing. It is thought that this may help reduce misuse of the terms “Risk” and “Hazard” interchangeably.

ISO 9001

The ISO 9001 committee has also chosen the full revision route.  However, the committee is taking a more aggressive posture when deviating from the HLS.  For over a decade ISO headquarters has insisted that it will not allow deviations from the HLS text for any of the standards.  The ISO 9001 revision committee wants to exclude certain new requirements introduced by the updated HLS.

The committee believes the new HLS requirement about climate change is not applicable to a quality management system. Although the committee believes that climate change consideration is important, they believe including it as a requirement in 9001 is inappropriate.

Conclusion

The revision of the three big ISO standards is not expected to result in new significant or reorganization of the standards.  The revisions are more likely to improve the standards by reducing unnecessary text and eliminating redundant requirements.  Organizations who meet the requirements of the current ISO standards should not need to make big changes to their Environmental, Occupational Health and Safety (OHS) and Quality management systems.  The revisions will also make these standards more accessible to small and medium sized businesses around the globe.

OHS Hazards and OHS Risk

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The terms OHS Hazards and OHS Risk have been in use for decades.  But these terms are often misused by OHS professionals by casually interchanging them. This creates confusion about what an OHS management system is supposed  to manage because there is a significant difference between an OHS Hazard and OHS Risk.

ISO 45001 defines the term “hazard” as a “source with a potential to cause injury and ill health”.

The standard also defines OHS risk as a “combination of the likelihood of occurrence of a work-related hazardous event(s) or exposure(s) and the severity of injury and ill health  that can be caused by the event(s) or exposure(s)”.  Using the terms hazard and risk interchangeably is a mistake. It is also confusing because a hazard is something that has the potential for harm. Risk is a measure of the likelihood and severity of harm from a hazard.

OHS hazards are identified using terms like burn, laceration, crush, struck by, over exposure, psychological harm and many others.  To make sense in an OHS management system context, risk should be expressed as a value like high, medium or low risk. 

In an OHS management system we identify hazards (hazard identification). We then assess the likelihood and severity of harm that could result from the hazard (risk assessment).  

The term OHS Hazard Risk might be a better way to describe what ISO 45001 is supposed to manage. It may help stem the misuse of the terms hazard and risk in OHS management.  The term OHS Hazard Risk also conveys the notion that OHS hazards are the source of risk. Additionally, it helps users of standards like ISO 45001 understand that OHS management is about addressing the risk (likelihood & severity) of harm.  In an OHS management system we manage the  risk not the hazard.  Risk is managed by implementing controls to reduce the likelihood and/or the severity of the harm.

URGENT ALERT – ISO Climate Change Amendments!

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ISO recently amended all ISO management system standards (MSS) to include requirements for organizations to consider the effects of climate change. If your organization holds a current certification to ISO 9001, 14001 or 45001 you can expect to be asked “has your organization determined whether climate change is a relevant issue?” during your next certification audit.

This new requirement is the result of a change to the ISO Harmonized Structure (Appendix 2 of the Annex SL in the ISO/IEC Directives Part 1 Consolidated ISO Supplement). Here is more background on the Harmonized Structure also referred to as the High Level Structure and Annex SL.

ISO announced the new requirement in an IAF/ISO Joint Communique indicating the climate change text highlighted below is effective immediately for all MSS.

ISO HLS revised requirements for context determination

Most organizations certified to ISO 14001 should be able to answer auditors questions about climate change relevance. Other organizations with current certification to ISO 9001 and/or 45001 might find it more difficult to avoid a nonconformity to these new requirements if they don’t act soon. Each organizations context is different and will influence how they address climate change in their MSS

Contact us if you have questions about how these new requirements might effect your organization ISO certification status.

RDO Equipment Co. Achieves ISO 45001 Certification

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RDO Equipment Co. Founded in 1968, RDO Equipment Co. sells and supports agriculture, construction, environmental, irrigation, positioning, and surveying equipment from leading manufacturers, including John Deere, Vermeer, and Topcon. RDO Equipment Co. is a total solutions provider with more than 75 locations across the United States and partnerships in Africa, Australia, Mexico and Ukraine. RDO contacted ECSI for assistance in developing an Occupational Health and Safety Management System to help improve its OHS performance.

RDO also wanted to show its business partners, customers and employees, their commitment to keeping employees safe. RDO chose to align the OHS management system with ISO 45001. They also decided to initially seek certification from an accredited certification body for their corporate headquarters and one of the company stores. Their intention is to certify the remaining 42 stores over the year or so. ECSI conducted an initial gap assessment that helped RDO identify gaps that needed to be filled before getting certified.

Gaps were entered into a database application tool (CorrectTrack) and assigned to the OHSMS implementation team for follow-up. One of the gaps identified was the need for a comprehensive Job Hazard/Job Safety analysis. ECSI helped develop process maps that supported JHA/JSA development at one of the RDO maintenance facilities. Below is an example of how the results of the JHA/JSA risk analysis were recorded.

This tool helped RDO evaluate the effectiveness of existing risk controls and identify priority hazards for additional risk reduction. The tool also helped internal auditors identify what material risks need to be audited during the internal audit process.

ECSI also helped RDO train its internal auditors in performing audits to the ISO 45001 standard. This was done in a three day combined internal audit training and actual audit at the corporate headquarters and one of the RDO maintenance facilities. ECSI assisted RDO in preparing for several management review meetings that were conducted prior to the Stage 1 and Stage 2 audits by an accredited certification body. Congratulations RDO on a successful outcome to the ISO 45001 implementation and certification process.

ISO 45001 Webinar – FREE!

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Watch Webinar

ISO 45001 is an international standard that helps organizations improve Occupational Health and Safety (OHS) performance.  The ISO 45001 standard can be used to ensure workers are safe by protecting them from workplace injury and ill health.  As the Vice Chair of the US Technical Advisory Group to ISO 45001, I have been seeing a significant rise in awareness of ISO 45001 benefits.  Environmental Compliance Systems, Inc has also helped many organizations plan, implement and integrate an ISO 45001 OHSMS with their other business management systems.   A recent webinar produced with ASSP describes the many benefits of an ISO 45001 OHSMS.  Here is a link to free ASSP webinar: https://player.vimeo.com/video/844292169?. Please watch if you are interested in improving your organizations OHS performance.

Join US at the 2022 ASSP Risk, Health & Safety for All Conference.

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We are looking forward to seeing you at the 2022 ASSP Risk, Health & Safety for All Conference Thursday, September 29 & Friday, September 30, 2022 at The Ingleside Hotel in Pewaukee, Wisconsin. With two days of educational sessions, workshops, and panel discussions, this event is full of super rich networking and collaboration opportunities. More

Preview our Presentation

Please be sure to come see us at session #12 where we will be sharing information on Semi-quantitative Risk Analysis – An OHS Leading Indicator. Here is a description of the presentation:

OHS Managers need to find good ways to predict and influence future OHS
performance. These predictors of OHS performance are referred to as “leading indicators”. Semi-quantitative OHS risk analysis is now being recognized as a good leading indicator of OHS performance. This session describes how semiquantitative risk analysis is used as a leading indicator of OHS performance

Come see us at our booth at the show to say hello  or for a quick demo of the CorrectTrack app.. Be sure to put your name into our raffle that will award a lucky winner at our ever-popular beer tasting on Thursday evening and taste premium beers with one of the Tyranena brewers..

ISO 45001:2018 7.4.1 (d) Views of External Interested Parties

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Here is a question that was recently posed on the ISO 45001 LinkedIn Group page and our response.

Question –

ISO 45001…Looking at requirement 7.4.1 (d) “The organisation shall ensure that the views of external interested parties are considered in establishing its communication process(es).”  Anyone have any thoughts on how they will address this requirement, bearing in mind that OHSAS 18001 required, where appropriate external interested parties…are consulted?

Our Response – 

I assume when you ask “how will they address this requirement” you are referring to certification bodies (CB’s) performing 3rd party independent audits of the OHSMS.  I suspect that the answer to this question will be largely determined by how the CB calibrates their auditors for what the CB considers adequate objective evidence of conformity.  My hope is that the CB’s will take a liberal view of what is acceptable here and let the auditee decide who is an external party and what views need to be considered.

I think that this section of ISO 45001:2018 is unnecessarily confusing and will likely be a source of debate between organizations and their CB auditors.  The High-Level Structure text for his section was limited to the following:

7.4  Communication

The organization shall determine the internal and external communications relevant to the XXX management system, including:

— on what it will communicate;

— when to communicate;

— with whom to communicate;

— how to communicate

As a member of the US-Technical Advisory Group I observed that organized labor strongly supported adding additional language in this section and suspect that the intent is that organized labors “views” are considered when establishing the communication process.

So if organized labor is part of an organizations structure asking them to express their views on communication and documenting those views would be a good place to start.  These views can then be discussed with the leadership during management review and “considered” when establishing the communication process.  Producing these records during and audit should help show CB auditors that “the views of external interested parties are considered in establishing its communication process(es)”.

If organized labor is not a consideration, then it gets a bit tougher.  I would start with of list of who the organizations think might conceivably be consider an external interested party.  These might include:

  • Regulatory agencies
  • Business associations
  • Neighbors
  • The community
  • Local politicians
  • Worker family member and relatives

I do not believe the standard compels an organization to proactively seek out the views of all external interested parties.  This would be overly burdensome and of little value to the effectiveness of the OHSMS.  However, after compiling its list the next question should be, have any of these external parties expressed views on how we communicate externally about our OHSMS?  If the answer is no, then it would be appropriate to state to the auditor that no external parties have express views on our external communication process.

If views have been express by any of those on the list this should also be documented and discussed in management review (also documented) regarding the result of the consideration of these external views.  Lastly, if the CB auditor digs in heals here and expects extensive evidence in this section you will always have the option to appeal a finding the CB’s Executive Committee of the CB for relief.

ISO 45001 Status Update – What’s Next after DIS Vote Failure

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The Committee Draft (CD) of ISO 45001:201x issued July 17, 2014 did not receive enough international support during voting which ended October 18th, 2014.  This means that the Standard will be reissued as another CD2 and will not be moved to the next level of development as a Draft International Standard (DIS) at this time.   The results of the vote were published in PC283 Ballot Report of 10-2014 which showed a 63% approval level, which is 12% shy of the requisite 75% approval for the standard to be moved to the next level.   Of 47 votes cast, 11 were Yes votes to agree to circulation of the draft as a DIS.  18 votes were cast as “Yes with comments” and 17 members cast a no vote.  There was one abstention.

ISO 45001 US TAG Meeting at AIG Headquarters in Ney York, August, 2014

US TAG PC 283 Meeting at AIG Headquarters in New York, August, 2014

The initial proposed date for publication of the final international standard outlined in ISO/PC 283/N68 issued October 24, 2013 was September 2016.  This proposed release date was based on the assumption that the CD and DIS documents would be approved by 75% of the PC members on the first vote.  The consequence of the failure of the CD to be moved to the DIS level is unclear at present but this turn of events is likely to delay the release of the final version of ISO 45001somewhat beyond September 2016.  The International PC will be meeting the third week of January 2015 in Trinidad to work on preparation of the next draft of the Standard (CD2) which is expected to be released in February 2015.

Why Did The ISO 45001 DIS Vote Fail?

The reason for failure of the vote to move to the DIS level is simple to explain. The CD  did not get the required 75% approval needed.  Why there was not enough support is more complicated but in general not enough PC members believed the standard was mature enough to move to the next level of development.  Enough members felt the standard needed more work at the CD level to prevent it from becoming a DIS.

ISO 45001 PC 283 US TAG Meeting August 2014 NYC

US TAG PC 283 Meeting In NYC August 2014

As part of the voting process almost 2500 comments were submitted on the CD which is a good indication that many believe this new standard needs additional effort invested in it before it can be issued as a DIS.  The US submitted 152  comments and the  International Labor Organization (ILO) submitted 174.  Along with its 119 comments Japan submitted a position paper (ISO/PC 283/N134) against ISO/CD 45001 that summed up in three comments, some of the most important issues that need resolution before this important standard can be moved to the next level of development .  The following is a brief summary of these comments.

ILO Participation –  “It is important to fully use the knowledge and experience of the ILO which has dealt with international labor issues”.

ISO and the ILO are having difficulty in reaching agreement on some important terms and concepts and if this tension cannot be resolved to the mutual satisfaction of both parties two conflicting standards may emerge.  This situation will inevitably lead to confusion by users of these standards and diminish the value  of ISO 45001and certification to this standard.

Use of the Term “Risk” Vs OH&S Risk

At present ISO 45001 uses the terms Risk and OH&S risk in several locations in the CD.  The use of these terms is thought to be potential confusing to users and the recommendation is to only use the Term OH&S Risk in the context of ISO 45001.

Annex A Not Thoroughly Reviewed

Unlike The Technical Committee for ISO 14001 which is authorized to issue multiple standards and guidance documents for environmental management such as ISO 14004 and ISO 14064, PC 282 charter was limited to development of one document only, ISO 45001.  At this time there are no plans to issue other guidance documents to supplement ISO 45001.  As a result the only guidance or interpretive information that is likely to come from ISO on OH&S management system will be in an Annex to the standard (Annex A).

Therefore it is vitally important that the information in the Annex A be reviewed and approved by PC members before it is issued.  The current state of Annex A is considered by some of the PC members as not having been reviewed thoroughly and the amount of text is too much and in need on condensation and streamlining.

Conclusion

The failure of PC 283 to move ISO 45001 to th DIS stage will likely result in some delay if the issuance of the final international standard by several months into early 2017.  However, this delay will help insure that all interested parties have an opportunity to contribute to its development.  In the end this will result in a better standard with wide international acceptance.