Worker Participation and Consultation Under ISO 45001
The transition to ISO 45001:2018 is more complicated than some might think, especially in the area of participation and consultation. You may feel like your OHSAS 18001 system already includes significant interaction with your workers, but business as usual will not satisfy the requirements of the standard.
Leadership and Worker Participation
Under Section 5 of the standard, the same requirements as OHSAS 18001 are in place for ISO 45001: leadership and commitment, OH&S policy, organization roles, responsibilities and authorities; but there is an additional element (5.4) for consultation and participation of workers. If your system follows the outline of the standard, and you don’t have a section 5.4, one has to ask whether you have fully evaluated that clause.
Participation v. Consultation
The standard defines these terms as follows:
Participation – involvement in decision-making
Consultation – seeking views before making a decision
In both cases, the terms are defined as “engaging health and safety committees and workers’ representatives.” This means a two-way communication involving dialogues and exchanges. For example, a newsletter, although it could be one piece of a system, does not constitute two-way communication even if it asks for feedback. Likewise an anonymous “suggestion” box could be one piece of a system but is unilateral communication. On the other hand, an effectively implemented safety committee with representation from front-line and shop floor personnel could be one way to engage employees.
Why Participation and Consultation?
Consultation allows informed feedback to be considered by the organization before they make a decision. Participation enable workers to contribute to decision-making processes that affect OH&S performance. Feedback is dependent upon worker participation, and workers at all levels should be encouraged to report hazardous situations that preventive measure can be put in place. Although documentation is not required under the standard, it can go a long way to supporting a solid OH&S system. This documentation can demonstrate how the results of the dialogue were used to influence the system and outcomes.
Consult Workers on What?
Workers should be consulted on specific requirements of the standard:
Needs and expectations of interested parties (clause 4.2)
The OH&S policy (clause 5.2)
Assignments of roles and responsibilities (clause 5.3)
Meeting compliance obligations (clause 6.1.3)
OH&S objectives and associated planning (clause 6.2)
Outsourcing, procurement and contractor controls (clause 8.1.4)
Monitoring and measure (clause 9.1)
Audit programs (clause 9.2.2)
Continual improvement (clause 10.1)
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Worker Participation in What?
Workers should participate in:
Methods for consultation and participation
Hazard identification (clause 6.1.1, 6.1.2) and elimination (clause 6.1.3)
Competence and training (clause 7.2)
Communication – what and how (clause 7.4)
Control measures (clause 8.1 and 8.2)
Incident and nonconformity investigation and follow-up (clause 10.2)
Training and Resources
In order for employees to engage, they must be provided with a means to do so, the time to do so, the training necessary to engage effectively and the resources to do so. Where there are obstacles or barriers to participation, they should be evaluated and removed or minimized. Examples of obstacles or barriers include failure to respond to worker inputs, language barriers, literacy barriers, or practices or policies that discourage or penalize worker participation.
It’s all in the details. Make sure you have a copy of the standard and are using it to build and check your system. That way, there won’t be any surprises at your next surveillance or re-certification audit.
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About the Author
Joyce Kristiansson, M.S., is a Certified Environmental Professional Auditor and part-time registrar auditor for an ISO certification body. With more than 35 years of environmental experience, including twelve years in ISO 14001 Environmental Management Systems, Joyce has experienced EMS systems and processes from all perspectives: developing, maintaining, sustaining and auditing (both internal and certification). Recognizing the improved environmental performance and positive financial results that can result from an effective EMS, Joyce wants to make the process as simple and inexpensive as possible so that small and medium-sized businesses can have the same competitive advantages as larger companies - without using a consultant.