Mark Hammar When reviewing the requirements of ISO 45001:2018 to create your Occupational Health & Safety Management System (OH&SMS), many people find clause 10, Improvement, mystifying. It is easy to understand that improvement is important, but the three subclauses within clause 10 can cause confusion, even though each subclause talks about different ways to improve. In this article, you’ll find a simple explanation of this clause, with an overview of each subclause included.
Clause 10.1 – General
This subclause requires that you identify opportunities to improve your OH&SMS so that it can work toward its intended outcomes. You then need to take actions to make these chosen opportunities happen. When understanding this, and other clauses, it is important to note that ISO 45001:2018 includes Appendix A to help you understand the standard. Appendix A is subdivided into sub-sections that match the clauses of the standard and explain each. So, Appendix A.10.1 explains that you need to consider the results of your OH&S performance analysis and evaluation, as well as other data, to identify opportunities to improve that you want to work towards. Making and completing plans to implement these opportunities will help you to better achieve the OH&S performance you want.
Clause 10.2 – Incidents, nonconformity and corrective action
Clause 10.2 includes the requirements for a system to take corrective action when an OH&S incident occurs, such as an accident or “near miss,” or when you have a process nonconformity. This process includes addressing the nonconformity by investigating the root cause of systemic problems, and then putting in place plans to fix the problem at the root so that it does not happen again. It allows you to ensure that process problems that could recur are solved properly, and that you address the hazards that could lead to future incidents within your OH&SMS.
Again, Appendix A.10.2 gives further advice on this clause. It mentions that some organizations might have separate processes to investigate incidents and process nonconformities. This appendix gives examples of incidents (such as falls), nonconformities (such as not meeting legal requirements), and corrective actions (such as eliminating hazards) that apply to the OH&SMS. It is helpful to review these examples when creating your corrective action process, and possibly include them in any documentation used to explain the process to workers.
It is important to note that this clause is identical across the different ISO management system standards. So, if you have an integrated management system with ISO 9001:2015, Quality Management System requirements, or ISO 14001:2015, Environmental Management System requirements, you can use a common corrective action process for process nonconformities.
For a closer look at how corrective actions work in the OH&SMS, see the article Using corrective actions to eliminate nonconformities and drive health & safety improvements.
Clause 10.3 – Continual improvement
The final subclause is about finding continual improvements of the OH&SMS for suitability, adequacy, and effectiveness; in other words, how do you make your OH&SMS better? So, while clause 10.1 talks about improving OH&S performance, clause 10.3 talks about OH&S process improvement. How do you improve your processes so that they function better within your OHSMS, and by doing so make your workplace OH&S culture more effective? How do you make the process of OH&S management better?
For example, you could find a new material, which is less hazardous, to replace a material that you currently use. This could come to you as a suggestion from your supplier about a cleaning product that they have developed that is less hazardous to employees than the one you are currently purchasing. For more information, Appendix A.10.3 gives examples of continual improvement issues that could be included in an OH&SMS.
Improvement is one of the key principles behind ISO requirements
Improvement is one of the key principles behind all ISO management system requirements, and finding ways to make the system better is ingrained in many of the processes. This is why we are monitoring, measuring, analyzing, and evaluating data per clause 9, performance evaluation – so that we can make data-based decisions to make the system better. Companies that want to implement an OH&SMS are doing so to improve the OH&S performance of their organization, and the requirements of clause 10 are there to provide a good foundational framework to make this happen.
For a simple explanation of this and other clauses of ISO 45001:2018, see this free white paper: Clause-by-clause explanation of ISO 45001:2018.
