How to meet participation and consultation requirements in ISO 45001
The year 2016 will see ISO 45001 replace OHSAS 18001 as the standard that guides organizations with respect to operational health and safety in the workplace. A critical part of maintaining OH&S (operational health and safety) is “participation and consultation,” the belief that all interested parties should have some input and feedback into the establishment and ongoing maintenance of the OH&S system. Given that this clause has a dual purpose: both the satisfaction of a requirement to meet compliance requirements, and also good common sense in terms of the identification and prevention of hazards and incidents, how should an organization go about ensuring that participation and consultation requirements are satisfied?
Participation and consultation; what does it mean?
OHSAS 18001 specifies that an organization should establish a procedure where the employees are involved in development and review of OH&S policies, incident investigation, and hazard identification, as well as being represented in general OH&S matters. In ISO 45001, Clause 5.4 deals with participation and consultation, and is slightly more prescriptive. When thinking of health and safety it seems easy to imagine that ensuring everyone in your organization is consulted before making policies, rules, and regulations is a positive, but who do we need to consider?
- Employees: leaders, managers, operatives – in short, everyone
- Shareholders and partners
- Unions and representatives of unions
- Stakeholders – these may be contractors, partners, suppliers, or even local focus or community groups
So, given that we understand whom we need to include in “participation and consultation” to maximize our chances of a successful OH&S system, what exactly do we need to do to ensure we are achieving what the standard specifies?
- Ensure that participation and consultation is considered when setting up the OH&S system and policies, also ensuring that time, resources, and information about the OH&S are available and all barriers are reasonably removed.
- Ensure that special attention is given and consultation is taken by non-managerial workers when it comes to hazard identification; control actions, training needs, incident investigation, and communication should all be considered specifically.
- Ensure that non-managerial consultation and participation is also sought in terms of writing the OH&S Policy, identifying interested parties, assigning roles and responsibilities and identifying legal requirements, establishing the objectives and the controls required to achieve them, assessing the evaluation and analysis that must take place as a result, and managing and scheduling an audit process – which should eventually yield continual improvement.
Therefore, it can be seen clearly that all relevant consultation and input must be considered in the establishment of an OH&S Policy, and also if the stated objectives are to be met and systemic improvement ideas are to be gathered by the administrators of the system itself. So, given that we understand what we have to do to satisfy this clause, what is the best way to achieve it in practice?
Participation and consultation: The inclusive approach
It is generally established that a representative team or forum within a reasonably sized organization can fit this requirement best; the day-to-day OH&S administrator, a member of the top management team, the OH&S manager, an employee representative, and union members can all come together to form an excellent health and safety team, which not only can bring different points of view, but can carry suggestions back and forth from their respective departments to the team itself. Critically, this can ensure that there is a channel of communication and information both up and down and that all ideas, suggestions, and information regarding hazard and risk can be identified at all levels, and also at the earliest opportunity. This is all good, but is it enough?
Make feedback work for you
The ISO family of standards encourages the user to seek feedback over various aspects of the management system performance, so why not use the same methodology here? Produce an OH&S feedback form, gauge if your employees and stakeholders feel that they are being properly consulted and their opinions listened to, and act on the basis of that feedback. Ensure your leaders communicate in a clear and timely manner, and that important information is shared by your team. Why not leave one place open on your OH&S team and invite a different member of staff to every periodic meeting to ensure all staff are engaged, informed, consulted, and made to feel part of the decision-making process? Excellent participation and consultation leads to increased engagement, mitigated risk, and excellent OH&S results. Doesn’t that sound like something that benefits everyone?
Why not use our free Gap Analysis Tool to compare your OH&S system with the OHSAS 18001 standard?