ILO/OSH-MS 2001 (draft) MEOSH/2001 INTERNATIONAL LABOUR ORGANIZATION Draft ILO technical guidelines on occupational safety and health management systems Programme on Safety and Health at Work and the Environment (SafeWork) INTERNATIONAL LABOUR OFFICE GENEVA guide_en.doc/v1 iii
Contents Introduction... 1 1. Objectives... 3 2. National OSH management system framework... 4 2.1. National policy... 4 2.2. National guidelines... 5 2.3. Tailored guidelines... 6 3. The OSH management system in the organization... 8 Policy... 8 3.1. OSH policy... 8 3.2. Worker participation... 10 Organizing... 10 3.3. Responsibility and accountability... 10 3.4. Competence and training... 12 3.5. OSH management system documentation... 12 3.6. Communication... 13 Planning and implementation... 14 3.7. Initial review... 14 3.8. OSH objectives... 15 3.9. System planning, development and implementation... 15 3.10. Hazard control system... 16 3.10.1. Hazard/risk control measures... 16 3.10.2. Management of change... 17 3.10.3. Emergency preparedness and response... 17 3.10.4. Procurement and contracting... 18 Evaluation... 19 3.11. Performance measurement... 19 3.12. Accident, disease and incident investigation... 20 3.13. Auditing... 21 3.14. Management review... 22 Action... 23 3.15. Preventive and corrective action... 23 3.16. Continual improvement... 23 Glossary... 25 iv guide_en.doc/v1
References... 28 Appendix: Risk assessment... 27 guide_en.doc/v1 v
Introduction The protection of the worker against sickness, disease and injury arising out of employment is one of the tasks assigned to the ILO in the words of Preamble of its Constitution. More recently, protection of the safety and health of workers was restated as an essential element in achieving decent working conditions for all in the current context of globalization of world economies. Occupational safety and health (OSH) is therefore not only a key prerequisite for achieving decent work, but it is also a major positive factor in favour of economic growth and productivity. Over the past 80 years the ILO has elaborated and adopted 30 Conventions, 28 Recommendations and 25 codes of practice and produced over 100 technical publications, all directly concerned with OSH issues. This represents a unique and formidable body of definitions, principles, obligations, duties and rights as well as technical guidance reflecting the consensus views of labour stakeholders from 174 member States on most aspects of occupational safety and health. As a result of the ever-increasing pace of worldwide liberalization of trade and economies, as well technological progress, the world of work has become increasingly competitive and has to face the rapid changes in working conditions and environment, processes and work organization that are necessary for sustained growth. The traditional command-control approach cannot address these challenges fully, and existing laws and regulations are usually too fragmented to be adapted, while new ones cannot be elaborated fast enough to cover new hazards and risks arising from these changes. Holistic, coherent, flexible and sound approaches which are an integral part of the enterprise business cycle and structure at all levels are the only management strategies which can provide the strong incentive necessary for continual identification, evaluation and control of hazards and risks in constantly evolving workplaces. The positive impact of introducing OSH management systems at the organization level both on the reduction of hazards and risks and on productivity are now recognized by governments, employers and workers. Although a number of OSH management systems have been developed at the international, national, regional and industry levels and are usually well designed and useful, they are not rooted in the body of internationally agreed OSH principles such as those defined by the tripartite constituency of the ILO. Only such a linkage can provide the strength, flexibility and appropriate basis for the development of a sustainable safety culture in the enterprise. A long-term implementation of good safety, health and environmental practices, at all levels of society i.e. the continued implantation of a safety culture as an essential part of general social culture is the only way to curb the spiralling cost of overall health care delivery and environmental protection and remediation, while increasing general productivity. guide_en.doc/v1 1
The ILO has therefore developed guidelines on OSH management systems which reflect ILO values and instruments relevant to the protection of the safety and health of workers but which are designed as a practical tool for assisting organizations and competent national institutions in reducing the heavy human and economic toll that is still exacted by occupational accidents and diseases as well as property losses. By providing a coherent framework for decision-making in the area of OSH, these guidelines also contribute to the promotion of sustainable development at workplaces as recommended by the 1992 United Nations Conference on Environment and Development in its Agenda 21. 2 guide_en.doc/v1
1. Objectives 1.1. At national level, these guidelines should: be used for the establishment of a national occupational safety and health (OSH) management system framework, preferably supported by national laws and regulations, and for the development of voluntary arrangements to strengthen compliance with regulations and standards; provide guidance on the development of both national (section 2.2) and tailored (section 2.3) guidelines to respond appropriately to the real needs of organizations according to their size and the nature of their activities. 1.2. At the level of the organization, these guidelines are intended to: provide guidance regarding the organizing, planning and implementation, evaluation and action of OSH management carried out as a component of policy and management arrangements; motivate managerial staff, workers and their representatives in applying appropriate OSH management principles and methods to improve OSH performance. guide_en.doc/v1 3
2. National OSH management system framework 2.1. National policy 2.1.1. A competent institution or institutions should be nominated, as appropriate, and formulate, implement and periodically review a coherent policy for the establishment and implementation of OSH management systems in organizations. This should be done in consultation with the most representative organizations of employers and workers and other relevant organizations and authorities. 2.1.2. The national policy on OSH management systems should establish general principles and procedures to: promote the implementation and integration of OSH management systems as part of the overall management of an organization; facilitate and improve voluntary arrangements for the systematic identification, planning, implementation and control of OSH activities at national and organization levels; avoid unnecessary bureaucracy, administration and costs; (d) promote collaborative and support arrangements for OSH management systems at the organization by labour inspection, occupational health services and other services, and channel their activities into a consistent framework for OSH management; (e) recognize publicly successful OSH management systems and practice by suitable means. 2.1.3. With a view to ensuring the coherence of the national policy and of measures for its implementation, the competent institution should establish a national framework for OSH management systems to: identify and establish the respective functions and responsibilities of the various institutions called upon to implement the national policy and make appropriate arrangements to ensure the necessary coordination between them; 4 guide_en.doc/v1
publish and review periodically national guidelines on the voluntary application and systematic implementation of OSH management systems in organizations; establish criteria for the designation and respective duties of the institutions responsible for the preparation and implementation of tailored guidelines on OSH management systems; (d) ensure that guidance is available to employers, workers and their representatives to help them understand and take advantage of the national policy. 2.1.4. The competent institution should make arrangements and provide guidance to labour inspection, OSH services and other public or private services, including occupational health care and non-governmental organizations (NGOs), to encourage and help organizations to implement OSH management systems. 2.2. National guidelines 2.2.1. National guidelines on the voluntary application and systematic implementation of OSH management systems should be elaborated based on the model provided in Chapter 3. 2.2.2. National guidelines should be designed with sufficient flexibility to permit: the immediate use of the ILO guidelines in organizations with a welldeveloped management structure where the OSH management provisions can be integrated immediately; the adaptation of the ILO guidelines to tailored guidelines on OSH management systems (see section 2.3) which take account of and respond to the specific conditions and needs of organizations; the promotion of effective cooperation of the organization with the regulatory authorities, labour inspection and occupational health services and other services, including NGOs; (d) the avoidance of excessive bureaucracy and unnecessary burdens; (e) suitable and applicable means of recognition for successful OSH management systems and practice. guide_en.doc/v1 5
2.3. Tailored guidelines 2.3.1. Based on the national guidelines on OSH management systems, tailored guidelines should be designed to reflect the specific conditions and needs of organizations or groups of organizations, taking into consideration: their size (large, medium, small) and infrastructure; the types and degree of hazards and risks; their branch of economic activity; (d) other special conditions that justify tailored systems. 2.3.2. Tailored guidelines on OSH management systems may consider only those requirements from the national guidelines which are relevant and applicable in the organizations for which they were designed. The links between the national framework for OSH management systems (OSH-MS) and its essential elements are illustrated below: ILO guidelines on OSH-MS National guidelines on OSH-MS OSH-MS in organizations Tailored guidelines on OSH-MS 6 guide_en.doc/v1
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3. The OSH management system in the organization 3.0. The employer should show strong visible leadership and commitment to OSH activities in the organization, and make appropriate arrangements for the establishment of an OSH management system. The OSH management system should contain the main elements of policy, organizing, planning and implementation, evaluation and action, as shown in the diagram below: Policy OSH policy; Worker participation Organizing Responsibility and accountability; Competence and training; OSH management system documentation; Communication Planning & implementation Initial review; OSH objectives; System planning, development and implementation; Hazard control system (hazard/risk control measures; management of change; emergency preparedness and response; procurement and contracting) Continual improvement Evaluation Performance measurement; Accident, disease and incident investigation; Auditing; Management review Action Preventive and corrective action; Review and back to Organizing Policy 3.1. OSH policy 3.1.1. The employer should set out in writing an OSH policy which should be: specific to the organization and appropriate to, and consistent with, its size and the nature of its activities; concise, clearly written, dated and made effective by the signature or equivalent of the employer or the most senior person in the organization; communicated and readily accessible to all members of the organization, including workers and/or their representatives; 8 guide_en.doc/v1
(d) reviewed for continuing suitability; (e) made available to relevant external interested parties, as appropriate. 3.1.2. The OSH policy should include the following key principles and objectives to which the organization is committed, in particular: preventing occupational accidents and diseases, and other work-related adverse health effects; promoting the health of all members of the organization; complying with relevant OSH legal requirements, voluntary protection programmes and other requirements to which the organization subscribes; (d) recognizing OSH as an integral part of the overall management structure and OSH performance as an integral part of the organization s business performance; (e) requiring all members of the organization to hold OSH management as a prime responsibility; (f) defining preferably measurable objectives; (g) ensuring that workers and their representatives are consulted and participate as appropriate in all levels of OSH organizing, planning and implementation, evaluation and action processes; (h) allocating duties, responsibilities and accountability for OSH in the organization s structure; (i) ensuring that management and workers are competent to carry out their assigned duties and responsibilities, and understand their rights; (j) allocating the necessary resources, whether human, financial or other, for the implementation of the OSH management system; (k) continual improvement in performance of the OSH management system. guide_en.doc/v1 9
3.2. Worker participation 3.2.1. Cooperation on OSH aspects between the employer, management and workers and/or their representatives within the organization should be: an underlying principle of the organization s safety and health policy; and an essential element of organizational and other arrangements. 3.2.2. Arrangements should be in place to ensure that workers and/or their representatives: are consulted at all appropriate levels on all relevant aspects of OSH associated with their work; are competent enough and encouraged to participate actively in the planning, implementation, evaluation and improvement processes of the OSH management system. The extent of this participation should be consistent with the size of the organization and the nature of its activities. 3.2.3. The measures taken to facilitate cooperation referred to in paragraph 3.2.2 should include, where appropriate, the appointment of workers safety representatives and of safety and health committees. Organizing 3.3. Responsibility and accountability 3.3.1. The employer should have overall responsibility for the protection of workers safety and health and provide leadership for OSH activities in the organization. 3.3.2. The employer and senior management, consistently with the size and nature of the organization, should allocate responsibility, accountability and authority for the development, implementation and performance of OSH management systems and achieving the relevant OSH objectives; structures and processes should be established which: ensure that OSH is a line management responsibility at all levels; 10 guide_en.doc/v1
define the responsibility, accountability and authority of persons who identify, evaluate or control OSH hazards and risks and promote health; promote cooperation and communication among members of the organization, including workers and their representatives, to achieve compliance with OSH requirements pursuant to national laws and regulations; (d) integrate OSH as a prime responsibility within the management systems for comprehensive planning of the organization; (e) fulfil the principles of OSH management systems contained in relevant national framework documents, tailored systems or voluntary programmes, as appropriate, to which the organization subscribes; (f) establish and implement a clear OSH policy with measurable and preferably quantifiable objectives; (g) establish effective arrangements to control hazards and risks to safety and health (see section 3.10); (h) ensure the participation of workers or their representatives in the implementation of the OSH policy; (i) provide appropriate resources to ensure adequate functioning of the safety and health committee, where it exists; (j) ensure the full participation of workers and their representatives in the safety and health committee, where it exists. 3.3.3. A person or persons at the senior management level should be appointed, where appropriate, with responsibility, authority and accountability for: the development, implementation, periodic review and evaluation of the OSH management system; periodic reporting to the senior management on the performance of the OSH management system; promoting the participation of all members of the organization, including management, supervisors and workers and/or their representatives; guide_en.doc/v1 11
(d) creating opportunities for the members of the organization s management and supervisory staff to demonstrate their commitment to and involvement in the OSH management system. 3.4. Competence 1 and training 3.4.1. The necessary OSH competence requirements should be identified to develop and implement the organization s OSH management system. 3.4.2. Necessary arrangements should be established and maintained to ensure that all persons with safety and health responsibilities at all levels are competent to perform their duties and responsibilities. 3.4.3. Under the arrangements referred to in paragraph 3.4.2, training programmes should: cover all members of the organization as appropriate; be conducted by persons with appropriate skills and experience; provide initial and refresher training at appropriate intervals; (d) evaluate the comprehension and retention of the training by participants; (e) be reviewed periodically by the safety and health committee, where it exists, and modified as necessary to ensure its relevance and effectiveness; (f) be documented as appropriate and be consistent with the size of the organization and the nature of its activity. 3.5. OSH management system documentation 3.5.1. Consistently with the size of the organization and the nature of its activity, OSH management system documentation should be established and maintained, and may cover: the scope of the OSH management system; 1 OSH competence includes education, work experience and training, or a combination thereof. 12 guide_en.doc/v1
the OSH policy and objectives of the organization; the allocated key OSH management roles and responsibilities for the implementation of the OSH management system; (d) the significant OSH hazards/risks arising from the organization s activities, and the arrangements for their control; (e) records of occupational accidents and diseases, dangerous occurrences and incidents; (f) procedures, instructions or other internal documents implemented in the framework of the OSH management system; (g) the interactions between the elements of the OSH management system within the organization. 3.5.2. The OSH management system documentation should be: clearly written and in a language understood by those who have to use it; periodically reviewed, revised as necessary, communicated and readily accessible to all appropriate or affected members of the organization. 3.6. Communication 3.6.1. Procedures should be established and maintained for: receiving, documenting and responding to internal and external communications related to OSH; ensuring the internal communication of OSH information between relevant levels and functions of the organization; ensuring that the concerns, ideas and inputs of workers and their representatives on OSH matters are received and considered. guide_en.doc/v1 13
Planning and implementation 3.7. Initial review 3.7.1. The scope, adequacy, implementation and effectiveness of the existing OSH management system and relevant arrangements in an organization should be evaluated by an initial review. This review should be undertaken periodically. Where no OSH management system exists, the initial review should serve as a basis for its establishment. 3.7.2. The initial review should be carried out, in consultation with workers and/or their representatives, and qualified persons (see paragraph 3.3.2), as appropriate, to: identify the current applicable legal OSH requirements, voluntary protection arrangements and other requirements to which the organization subscribes; identify hazards and assess risks to workers safety and health arising from the working environment; determine whether planned or existing controls are adequate to eliminate hazards or control these risks. 3.7.3. The result of the review should: be documented and become the basis for making decisions regarding changes to the OSH policy or the planning and implementation processes for the improvement of the OSH management system; provide the baseline from which continual improvement of the OSH management system can be measured. 3.7.4. The initial review should include an analysis of the records on occupational accidents and diseases, dangerous occurrences and incidents and the data provided from workers health surveillance, in line with the provisions of the ILO Technical and ethical guidelines for workers health surveillance (Geneva, 1998). 14 guide_en.doc/v1
3.8. OSH objectives 3.8.1. Based on and consistently with the OSH policy and initial review of the organization, measurable and quantifiable objectives for the implementation of the policy and continuously improved OSH protection of the workers should be established. Such objectives should be: specific to the organization, and appropriate to and consistent with its size and the nature of its activity; consistent with the relevant and applicable legal, technical and business obligations of the organization with regard to OSH; realistic and achievable; (d) communicated to all relevant functions and levels of the organization; (e) documented and accessible to all members of the organization. 3.8.2. The objectives should be periodically reviewed and modified, if necessary, to reflect the organization s commitment to the process of continual improvement of the OSH management system and related performance. 3.9. System planning, development and implementation 3.9.1. Based on the results of the initial review and other available data (see section 3.7), arrangements should be made for adequate and appropriate OSH planning. The purpose of the planning should be to achieve: compliance with legal requirements, as the minimum, and the organization s OSH objectives; and continual cost-effective improvement in OSH performance. 3.9.2. These arrangements should contribute to prevention through identifying, evaluating and controlling hazards and risks and should include: a clear definition, priority setting and quantification, where appropriate, of the organization s OSH objectives; guide_en.doc/v1 15
the preparation of a plan for achieving each objective with defined responsibility and clear performance criteria indicating what is to be done by whom and when; the selection of suitable measurement criteria for confirming that the objectives are achieved; (d) the provision of adequate resources, including human and financial resources and technical support, as appropriate. 3.9.3. The OSH planning arrangements (see paragraph 3.9.1) of the organization should cover or be related to the following key areas: implementation of the OSH policy (see section 3.1); control of the hazards and risks identified in the initial review or made known by other data (see sections 3.7 and 3.10); overall objectives (see section 3.8); (d) performance measurement (see section 3.11), audits (see section 3.13) and management reviews (see section 3.14); (e) implementation of corrective action as necessary (see paragraph 3.10.2 and section 3.15). 3.10. Hazard control system 3.10.1. Hazard/risk control measures 3.10.1.1. Hazards should be identified and risks to safety and health assessed. Preventive and protective measures should be implemented in the following order of priority: eliminate the risk; control the risk at source, through the use of engineering or organizational measures; minimize the risk by means that include the design of safe work systems; 16 guide_en.doc/v1
(d) in so far as the risk remains, provide for the use of personal protective equipment. 3.10.1.2. Hazard control procedures should: be adapted to the hazards and risks encountered by the organization; be reviewed and modified if necessary on a regular basis; meet legal requirements and reflect good practice. 3.10.2. Management of change 3.10.2.1. The impact on OSH of internal changes (such as those in staffing or due to new processes, working procedures, organizational structures or acquisitions) and of external changes (for example as a result of amendment of laws and regulations and developments in OSH knowledge and technology) should be evaluated and appropriate steps taken prior to the introduction of changes. 3.10.2.2. An OSH impact evaluation should be carried out before any modification or introduction of new work methods, materials, processes or machinery. Such prior to change evaluations should involve workers and/or their representatives. 3.10.2.3. Implementation of a decision to change should ensure that all concerned members of the organization are properly informed, and trained if necessary. 3.10.3. Emergency preparedness and response 3.10.3.1. Emergency preparedness and response arrangements should be established and maintained. These arrangements should be appropriate to the size of the organization and the nature of its activities, and should make provisions for: communication and coordination with the relevant neighbourhood and emergency response services; first aid and medical assistance, fire fighting and evacuation of people; training of all members of the organization, at all levels, including regular exercises in emergency preparedness and response procedures. guide_en.doc/v1 17
3.10.3.2. In major hazard installations, emergency plans should be drawn up in conformity with the arrangements recommended in the ILO Code of practice on prevention of major industrial accidents (Geneva, 1991). 3.10.4. Procurement and contracting 3.10.4.1. Procedures should be established and maintained to ensure that: compliance with safety and health requirements is identified, evaluated and incorporated into purchasing and leasing specifications; legal and the organization s own OSH obligations/requirements are satisfied prior to the procurement of goods and services. 3.10.4.2. Arrangements should be established and maintained for ensuring that the same safety and health requirements apply to contractors and their workers as to the workers employed directly by the organization. 3.10.4.3. Arrangements for assessing and controlling contractors should: include procedures for evaluating and selecting contractors; set up communication links between appropriate levels of the organization and the contractor prior to commencing work, including provisions for communicating hazards associated with the work and information on accidents, diseases and incidents suffered by the contractors workers while performing work for the organization; provide relevant safety and health hazard awareness and training, if necessary, to contractor workers prior to commencing work; (d) monitor regularly OSH performance of contractor activities on site; (e) ensure that site OSH rules and procedures are followed by the contractor(s). 18 guide_en.doc/v1
Evaluation 3.11. Performance measurement 3.11.1. Procedures to monitor and measure OSH performance on a regular basis should be developed and periodically reviewed. 3.11.2. Both qualitative and quantitative measures appropriate to the needs of the organization should be considered, and should: be developed preferably in conjunction with the OSH policy; be consistent with the organization s hazards and risks, the OSH variables expressed in the OSH policy (see section 3.1) and the OSH objectives (see section 3.8); support the organization s evaluation process and the management review (see section 3.14). 3.11.3. Performance monitoring and measurement should: be used as a means of determining the extent to which OSH policy and objectives are being implemented and risks are controlled; include both active and reactive monitoring and not be based only upon occupational accident and disease statistics. 3.11.4. The selection of reasonable and appropriate outcome indicators should be made according to the size of the organization and the nature of its activities and the chosen OSH objectives. Responsibilities for monitoring at different levels in the management structure should be allocated. 3.11.5. Active monitoring should provide: feedback on OSH performance before an accident, disease or incident; information to determine whether the day-to-day arrangements for hazard and risk control are in place and operating effectively; guide_en.doc/v1 19
the basis for decisions about improvement in hazard and risk control and the OSH management system. 3.11.6. Active monitoring should include: monitoring the achievement of specific plans, established performance criteria and objectives and the operation of the OSH management system; the systematic inspection of work systems, premises, plant and equipment; surveillance of the working environment; (d) workers health surveillance to determine the effectiveness of health control measures and to detect early signs of harm to health; (e) compliance with applicable legislation and regulations. 3.11.7. Reactive monitoring should include the identifying, reporting, recording and investigation of: accidents, diseases (including monitoring of sickness absence records) and incidents, in line with the provisions of the ILO Code of practice on recording and notification of occupational accidents and diseases (Geneva, 1996); other losses, such as damage to property; deficient safety and health performance and OSH management system failures. 3.12. Accident, disease and incident investigation 3.12.1. The origin and underlying causes of occupational accidents, occupational and other work-related adverse health effects, as well as incidents, should be identified. The investigation should determine any related deficiencies in the OSH management system. 3.12.2. Such investigations should be carried out by competent persons, with the appropriate involvement of workers and/or their representatives. 20 guide_en.doc/v1
3.12.3. The results of such investigations should be communicated to and be considered by the safety and health committee, where it exists, and the committee should make any appropriate recommendations. 3.12.4. The results of the investigation and any recommendations of the safety and health committee should be communicated to appropriate persons for corrective action (see section 3.15), included in the management review (see section 3.14) and considered for continual improvement activities (see section 3.16). 3.13. Audit 3.13.1. In addition to routine monitoring of OSH performance, periodic audits should be conducted to verify the adequacy, strengths and weaknesses of the OSH management system and each of its components. Audits should determine whether the system: conforms to the OSH policy and objectives of the organization; has been effectively integrated, implemented and maintained for achieving the required standard of OSH performance, or whether there are possible organizational causes of OSH-related deficiencies; complies with statutory requirements and other obligations with respect to OSH. 3.13.2. An audit policy and programme should be developed taking into consideration the status and importance of the activities and areas to be audited, as well as the results of previous audits. The scope, frequency and methodologies of the audit should be defined accordingly. 3.13.3. Audits should be conducted by competent persons who are independent 2 of the activity being audited. 3.13.4. Audit procedures should be developed that assign the responsibilities and make provisions for: conducting audits; 2 This does not necessarily mean an independent external audit (i.e. by an auditor(s) from outside the organization). guide_en.doc/v1 21
recording and reporting results; implementing corrective action (see section 3.15). 3.13.5. Responsible members of the organization, including workers and their representatives, should be informed that an audit is to be performed and be invited to participate in the activity (see section 3.2). 3.14. Management review 3.14.1. The frequency and scope of periodic reviews by management of the OSH management system should be defined according to the organization s needs and conditions. 3.14.2. Management reviews should: evaluate the overall performance of the OSH management system and its individual components to determine whether it meets planned performance objectives; evaluate the OSH management system s ability to meet the overall needs of the organization and its stakeholders, including its workers and the regulating authorities; evaluate the need for changes to the OSH management system, including OSH policy and objectives; (d) identify what action is necessary to remedy any deficiencies in a timely manner, including adaptations of other aspects of the organization s management structure and performance measurement; (e) provide the feedback direction, including the determination of priorities, for meaningful planning (see section 3.9) and continual improvement (see section 3.16). 3.14.3. The management review should consider: the results of accident, disease and incident investigations, the findings of audits and monitoring activities, the results of hazard identifications, risk assessments and surveillance activities, and the report of the management representative, if appointed (see section 3.3); 22 guide_en.doc/v1
the internal and external factors as well as changes, including organizational changes, that could affect the OSH management system; progress towards the organization s OSH objectives and corrective action; (d) the effectiveness of follow-up to earlier management reviews. 3.14.4. The findings of the management review should be recorded and formally communicated to the persons responsible for the affected element(s) of the OSH management system so that they may take appropriate action. Action 3.15. Preventive and corrective action 3.15.1. When the evaluation of the OHS management system (see sections 3.11 to 3.14) or other sources show that preventive and protective measures (see section 3.10) for hazards and risks are inadequate or likely to become inadequate, hazards and risks should be: eliminated by ceasing to use such hazardous processes or substances or replacing them by modified processes or less hazardous substances; minimized by designing and implementing a programme of action. 3.15.2. Preventive and corrective measures for implementing such a programme of action should: be sufficient and appropriate to control hazards and risks; minimize adverse health effects to workers; be documented, as appropriate, and completed in a timely manner. 3.16. Continual improvement 3.16.1. Procedures and arrangements should be established and maintained for the continual improvement of the OSH management system. These procedures and arrangements should include: guide_en.doc/v1 23
the OSH objectives of the organization; the results of hazard identifications and risk assessments; the results of performance measurements; (d) accident, disease and incident investigations and the results and recommendations of audits; (e) the outcomes of the management review; (f) recommendations from all members of the organization, including the safety and health committee, where it exists; (g) the results of health promotion programmes. 3.16.2. The safety and health processes and performance of the organization should be compared with others to learn how to reduce accidents and diseases, improve compliance with safety and health law and/or cut compliance costs (benchmarking). 24 guide_en.doc/v1
Glossary In these guidelines, the following terms have the meanings hereby assigned to them: Audit: A systematic, independent and documented process for obtaining evidence and evaluating it objectively to determine the extent to which defined criteria are fulfilled. This does not necessarily mean an independent external audit (by an auditor(s) from outside the organization). Competent institution: A government department or other authority with the right to establish the national policy on OSH management systems, to give effect to this policy by means of a national framework for the establishment and implementation of such systems in organizations and to provide relevant guidance. Competent person: A person possessing adequate qualifications, such as suitable training and sufficient knowledge, experience and skill, for the safe performance of specific work. The competent institution may define appropriate criteria for the designation of such persons and may determine the duties assigned to them. Continual improvement: Process of enhancing the OSH management system in order to achieve improvements in overall OSH performance, in line with the organization s OSH policy. Employer: Any physical or legal person who employs one or more workers. Hazard: The potential to cause physical injury or damage to health of people. Incident: An unsafe occurrence arising out of or in the course of work where no personal injury is caused, or where personal injury requires only first-aid treatment. Management review: Evaluation by management of the overall performance of an OSH management system, from a standpoint of whether the system meets the overall needs of the organization, its stakeholders and workers, and the regulating authorities. Occupational accident: An occurrence arising out of or in the course of work, which results in fatal or non-fatal occupational injury. guide_en.doc/v1 25
Occupational disease: Disease known, under prescribed conditions, to arise out of exposure to substances or dangerous conditions in processes, trades or occupations. Occupational health surveillance: The ongoing systematic collection, analysis, interpretation and dissemination of data for the purpose of prevention. Surveillance is essential to the planning, implementation and evaluation of occupational health programmes and to the control of work-related ill health and injuries, as well as to the protection and promotion of workers health. Occupational health surveillance includes workers health surveillance and working environment surveillance. Occupational safety and health (OSH) management system: Set of interrelated or interacting elements to establish OSH policy and OSH objectives and to achieve those objectives. Occupational safety and health (OSH) policy: Overall intention and direction of an organization in relation to OSH as formally expressed by the employer and top management. Organization: A company, operation, firm, undertaking, establishment, enterprise, institution or association, or part thereof, whether incorporated or not, public or private, that has its own functions and administration. For organizations with more than one operating unit, a single operating unit may be defined as an organization. Risk: The likelihood that a specified undesired event will occur causing physical injury or damage to the health of people. Risk assessment: The process of evaluating and ranking the risks to safety and health at work arising from hazards at the workplace. Worker: Any person who performs work, either regularly or temporarily, for an employer. Workers representative: In accordance with the Workers Representatives Convention, 1971 (No. 135), any person who is recognized as such by national law or practice, including: trade union representatives, namely, representatives designated or elected by trade unions or by members of such unions; or elected representatives, namely, representatives who are freely elected by the workers of the undertaking in accordance with provisions of national 26 guide_en.doc/v1
laws or regulations or of collective agreements and whose functions do not include activities which are recognized as the exclusive prerogative of trade unions in the country concerned. guide_en.doc/v1 27
References Relevant ILO Conventions and Recommendations Conventions No. Title 115 Radiation Protection, 1960 135 Workers Representatives, 1971 136 Benzene, 1971 139 Occupational Cancer, 1974 148 Working Environment (Air Pollution, Noise and Vibration), 1977 155 Occupational Safety and Health, 1981 161 Occupational Health Services, 1985 162 Asbestos, 1986 167 Safety and Health in Construction, 1988 170 Chemicals, 1990 174 Prevention of Major Industrial Accidents, 1993 176 Safety and Health in Mines, 1995 28 guide_en.doc/v1
Recommendations No. Title 114 Radiation Protection, 1960 144 Benzene, 1971 147 Occupational Cancer, 1974 156 Working Environment (Air Pollution, Noise and Vibration), 1977 164 Occupational Safety and Health, 1981 171 Occupational Health Services, 1985 172 Asbestos, 1986 175 Safety and Health in Construction, 1988 177 Chemicals, 1990 181 Prevention of Major Industrial Accidents, 1993 183 Safety and Health in Mines, 1995 ILO codes of practice Prevention of major industrial accidents (Geneva, 1991) Safety and health in opencast mines (Geneva, 1991) Safety and health in construction (Geneva, 1992) Safety in the use of chemicals at work (Geneva, 1993) Accident prevention on board ship at sea and in port (Geneva, 1996) guide_en.doc/v1 29
Management of alcohol and drug-related issues in the workplace (Geneva, 1996) Recording and notification of occupational accidents and diseases (Geneva, 1996) Protection of workers personal data (Geneva, 1997) Safety and health in forestry work (Geneva, 1998) Ambient factors in the workplace (Geneva, 2001) Relevant publications Agenda 21 (Chapter 19 on environmentally sound management of chemicals). United Nations Conference on Environment and Development (UNCED), Rio de Janeiro, Brazil, 1992. American Industrial Hygiene Association (AIHA): Occupational health and safety management system: An AIHA guidance document, AIHA OHSMS 96/3/26 (Fairfax, Virginia, 1996). Bavarian Ministry of State for Labour and Social Affairs, Family, Women and Health: Management systems for occupational health and plant safety, Volume 1: Occupational health and risk management system (OHRIS) Principles and system elements (Munich, 1998). BS 8800:1996. Guide to occupational health and safety management systems (London, British Standards Institution, 1996). Council of the European Communities: Council Regulation (EEC) No. 1836/93 of 29 June 1993, allowing voluntary participation by companies in the industrial sector in a Community eco-management and audit scheme, in Official journal of the European Communities (Brussels), No. 168, 10 July 1993, pp. 1-18. Health and Safety Authority (Ireland): Workplace health and safety management: Practical guidelines on the implementation of an occupational safety, health and welfare management system (Dublin, 1998). Health and Safety Executive (HSE): Successful health and safety management (HSG65) (United Kingdom, HSE Books, second edition 1997, reprinted 1998). 30 guide_en.doc/v1
ILO Declaration on Fundamental Principles and Rights at Work and its Follow-up, adopted by the International Labour Conference at its 86th Session, 1998 (Geneva, ILO, 1998). ILO: Encyclopaedia of occupational health and safety, fourth edition (Geneva, ILO, 1998). ILO: Technical and ethical guidelines for workers health surveillance. Occupational Safety and Health Series No. 72 (Geneva, 1998). ISO 9000-1:1994. Quality management and quality assurance standards Part 1: Guidelines for selection and use (Geneva, 1994). ISO 9001:1994. Quality systems Model for quality assurance in design, development, production, installation and servicing (Geneva, 1994). ISO 9002:1994. Quality systems Model for quality assurance in production, installation and servicing (Geneva, 1994). ISO 14001:1996. Environmental management systems Specification with guidance for use (Geneva, International Organization for Standardization, 1996). Japan Industrial Safety and Health Association (JISHA): Occupational safety and health management systems (OHS-MS) guidelines (JISHA guidelines) (Tokyo, 1997). Ministry of Labour of Japan: Guideline for occupational health and safety management systems, Ministry of Labour Notification No. 53 (Tokyo, 1999). NZS 4801(Int):1999. Occupational health and safety management systems: Specification with guidance for use (Wellington, Standards New Zealand, 1999). OHSAS 18001:1999. Occupational health and safety management systems Specification. Occupational Health and Safety Assessment Series (London, British Standards Institution, 1999). OHSAS 18002:2000. Occupational health and safety management systems Guidelines for the implementation of OHSAS 18001. Occupational Health and Safety Assessment Series (London, British Standards Institution, 2000). guide_en.doc/v1 31
Oil Industry International Exploration and Production Forum (E&P Forum): Guidelines for the development and application of health, safety and environmental management systems, Report No. 6.36/210 (London, 1994). Standard for certification of occupational health and safety management systems (OHSMS), 1997 (Norway, Det Norske Veritas AS, 1997). Victorian WorkCover Authority: SafetyMAP: Auditing health and safety management systems (Melbourne, Australia, 1997). 32 guide_en.doc/v1
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Appendix Risk assessment I.1. Key elements of risk assessment I.1.1. The purpose of a risk assessment is to help employers examine systematically all aspects of their work activities so as to determine what could cause injury or harm, whether the sources of injury and harm can be eliminated and, if not, what preventive or protective measures should be in place. The risk assessment will allow decisions on how to manage risks to be made in an informed, rational and structured manner. I.1.2. The process of carrying out a risk assessment should be undertaken by management, whether or not advisers or consultants have been brought in to assist with the detail of the assessment, and should take account of the views of workers and their representatives who have practical knowledge and experience to contribute. I.1.3. Besides the potential harm or injury to their own employees, employers should consider in their risk assessment the effect of their work activities on other parties. For example, there may be employees of other businesses who visit the workplace (e.g. maintenance contractors) or members of the public (e.g. customers). Where employees of different employers work in the same workplace, their respective employers may sometimes have to cooperate to produce an overall risk assessment. I.1.4. A risk assessment involves the following five steps: the identification of hazards; the identification of workers and others who might be harmed by those hazards, and how the harm might occur; an evaluation of the risk from those hazards; recording the findings of the assessment; and reviewing the assessment. The steps are described in greater detail in section I.2 below ( Risk assessment in practice ). 34 guide_en.doc/v1
I.1.5. The level of detail in a risk assessment should be proportionate to the risk. Insignificant risks can usually be ignored, as can those arising from routine activities associated with life in general and not normally thought of as being of concern (e.g. the use by staff of office furniture) unless work activity compounds or significantly alters those risks. The level of risk arising from the work activity should determine the degree of sophistication of the risk assessment: for small businesses presenting few or simple hazards, a risk assessment can be a very straightforward process based on informed judgement and reference to appropriate guidance (as published by regulatory authorities, trade federations and so on). Where the hazards and risks are obvious, they can be addressed directly; no complicated processes or skills will be required to carry out the risk assessment; there may, however, be areas of an assessment for which specialist advice is needed; for example risks which require specialist knowledge of a complex process or technique, or those calling for specialist analytical techniques such as those used in measuring air quality. Whenever specialist advisers are called in, employers should ensure that the advisers have sufficient understanding of the particular work activity; this will often require effective involvement of everyone concerned employer, employees and specialist; large and hazardous sites will need the most developed and sophisticated risk assessments, particularly where there are complex or novel processes, and the regulator may well require the use of techniques such as quantified risk assessment. I.1.6. When assessing risk to determine control measures, relating the assessment to the actual people exposed is of limited usefulness. It would be necessary to carry out a risk assessment for each person exposed, since individuals are affected differently by risk depending, amongst other things, on their physical make-up, abilities, age and the circumstances giving rise to their exposure. It would be very difficult to extract and distil useful information from all the individual assessments. Instead, the assessment can be performed in relation to a hypothetical person, i.e. a person in some fixed relation to the hazard, for example the person most exposed to it, or a person living at some fixed point or with some assumed pattern of life, such as a person who is in good health and works exactly 40 hours a week with the hazard. I.1.7. For the workplace where conditions and processes remain relatively unchanged (such as factories or offices), the risk assessment can be such that it: takes account of the usual conditions; does not need to be repeated where workstations are comparable; identifies the need for a revised or different assessment when circumstances change, e.g. when new machinery, methods or materials are introduced or non-routine work is undertaken. guide_en.doc/v1 35
Employers controlling a number of similar workplaces where similar activities take place may produce a model risk assessment reflecting the core hazards and risks associated with these activities. Model assessments may also be developed by trade associations, employers organizations or other bodies concerned with a particular activity. To use such a model in a particular workplace, managers should satisfy themselves that it is appropriate to the type of work performed there and adapt it as necessary to the specific conditions of their own work activities, including extending it to include hazards not covered in the model. I.1.8. At workplaces where circumstances and conditions change, the assessment requires an approach which takes an account of these changes. Risks can be assessed generically so that the principles for prevention and protection are applied even though the workplace changes. Thus, for example, the principles of good scaffolding or excavation support can be applied at each building site, account can be taken of the effect of different weather conditions on outdoor work, and so on. I.2. Risk assessment in practice There are no fixed rules about how a risk assessment should be carried out; it will depend on the nature of the work or business and the types of hazards and risks. However, whatever approach is taken, it is important that it be: Comprehensive ensuring all aspects of the work activity are assessed, including routine and non-routine activities. The assessment should cover all parts of the work activity, including those that are not under the immediate supervision of the employer, such as employees working off site as contractors and peripatetic workers. Systematic this can be done, for example, by looking at hazards in groups under headings such as machinery, transport, substances, etc., or dividing up the worksite on a geographical basis. In other cases, an operation-by-operation approach may be needed. Practical looking at what actually happens in the workplace whilst the work activity is taking place. Actual practice may differ from what the work s manual says should be happening. I.2.1. It is often helpful for employers to make a first rough assessment in order to eliminate from consideration those risks on which no further action is needed. This should also show where a fuller assessment is needed, using more sophisticated techniques (such as environmental monitoring for chemicals, noise-level measurement). I.2.2. As indicated in paragraph I.1.4, the following five steps need to be taken: (1) Identifying the hazards: Besides drawing on their own knowledge and experience, employers will help themselves identify aspects of their work with the potential to cause harm by looking at appropriate sources of information such as guidance published by the regulator or manufacturer s instructions. The knowledge and experience of the workforce should also be tapped. 36 guide_en.doc/v1
(2) Identifying who might be harmed and how it might happen: Besides employees, other workers and members of the public should be considered. These might include office staff, night cleaners, security guards and customers. Groups of workers who might be particularly at risk should be identified, such as young or inexperienced workers, new and expectant mothers, those who work alone, or disabled staff. Account should be taken of the fact that workers do not have to be involved in a hazardous process to be at risk from it (e.g. a worker engaged in grinding metal will be at risk of hearing damage, as might workers engaged in other activities nearby). (3) Evaluating the risk from the hazard: The objective of this step is to decide whether existing control measures are adequate or whether more should be done to reduce the level of risk from the hazard. The first consideration should be whether the risk can be removed by eliminating the hazard altogether. Where the hazard cannot be eliminated, in the majority of cases (where the hazards are of little concern and/or the risks are well understood) all that need be done is to compare the existing control measures against those required by established good practice as found in guidance produced by the regulatory authorities, industry representative bodies and so on. No explicit estimation of the risk is required in these circumstances. (However, it can be useful to prioritize the action to be taken following the assessment by making a rough estimate of the risk from a hazard, considering the likelihood of harm occurring and the likely severity of that harm.) However, there will be more complex cases where risk should be explicitly estimated and specialist knowledge support and advice could be required. For example, a quantitative estimation of the risk may be necessary to measure the effectiveness of the existing controls against quantitative risk criteria such as occupational exposure standards for chemicals or noise, etc. In extreme cases, a complete quantitative risk assessment might be required to make a judgement as to the adequacy of controls in complex processes such as those found in large chemical plants. (4) Recording the assessment: A record of the results of risk assessments should be kept with the object of making it a useful tool, i.e. providing both a management record and a source of information for managers and workers. The record should include: a record of the preventive and protective measures in place to control the risks; the criteria, standards or guidance applied (e.g. machine-guarding standards); what further action, if any, needs to be taken to reduce risks; arrangements for review of the assessment. Workers should be informed of the findings that relate to their workstation. The record of the risk assessment should also be made available to workers with special functions in protecting health and safety, i.e. those designated by the employer or those appointed as workers representatives. guide_en.doc/v1 37
(5) Review and revision of the assessment: Risk assessment is not a once-and-for-all activity; assessments need to be reviewed because: (i) the work process might change, say, as a result of further control measures being introduced, or new plant, chemicals, etc., or changes to other work activities may effect it; (ii) new knowledge about the hazards and risks may become available (e.g. as the result of the local investigation of an incident or local health surveillance; new information may be provided by the regulatory authorities, trade organizations or academic experts, etc.); (iii) new technology to control risks more effectively and/or efficiently may become available. In most cases, it is prudent to review assessments at regular intervals. The time between reviews is dependent on the nature of the risks and the degree of change likely in the work activity. 38 guide_en.doc/v1