Review of OHS Body of Knowledge BOK New Chapter – OHS Management Systems (OHSMS)

There is a new chapter in the Body of Knowledge (BOK) which is available and free for all to download via the link below. These chapters are quite long and theory – based. I have tried to summarise the key parts of the chapter and have blended various ideas provided to reflect my own thoughts on OHSMSs given my experience in developing and implementing then for various organisations.  It is recommended that you read the chapter, however if you don’t have time, this might be for you.

Definition provided in the BOK:

An OHS management system is a set of tangible and intangible elements that

can vary over time but interact in a coordinated manner under the collective

purpose to protect and promote the physical and psychological integrity of those

present in an occupational setting or directly affected by its occupational

activities

This article attempts to answer the following 10 questions, based on a combination of ideas expressed in the BOK chapter and those of my own views and experience.

  1. What are the Benefits of an OHSMS?
  2. What are the current Standards relating to OHSMSs and does legislation require an OHSMS?
  3. What are the guiding principles for developing an OHSMS as defined in the BOK?
  4. What areas of documentation should be included?
  5. How do we implement our OHSMS?
  6. What channels are required?
  7. What are the success factors for OHSMS?
  8. What are the costs associated with not having an effective OHSMS?
  9. How can we effectively measure of OHS performance via internal or external audits and Performance Reporting?
  10. What do we need to avoid when auditing and checking on the performance of an OHSMS?

What are the Benefits of an OHSMS?

Mainly, to provide guidance for managers and others less experienced in managing OHS. Also to:

  • Create a framework or structure for systematic management of OHS
  • Make safety visible in the workplace
  • Support organisational discipline and consistency in governance, planning, operations, assurance and performance measurement
  • Facilitate alignment of OHS with other business processes
  • Assist in determining priorities and allocation of resources
  • Mediate effects of power and politics in OHS

What are the current Standards relating to OHSMSs and does legislation require an OHSMS?

Australia and New Zealand adopted ISO 45001 by publishing AS/NZS ISO 45001:2018

Occupational Health and Safety Management Systems – Requirements with Guidance for

Use (SA/SNZ, 2018), which superseded AS/NZS 4801:2001.

OHS Legislation does not specifically require an OHSMS, however there is a requirement to provide a workplace and system of work where risks to health and safety are controlled so far as is reasonably practicable. So an OHSMS would be an excellent way of demonstrating your compliance with this requirement, bearing in mind the documents alone wont help, the system must be implemented.

What are the guiding principles for developing an OHSMS as defined in the BOK?

  1. “Secure management commitment and manage expectations
  2. Ensure connectivity of existing OHSMS elements
  3. Evaluate the status of the OHSMS before making changes
  4. Integrate the OHSMS with other organisational systems and processes
  5. Gradually modify or introduce new elements based on system analysis
  6. Ensure customisation to organisational context and needs
  7. Ensure a systems approach
  8. Facilitate ownership of the OHSMS by all stakeholders.”

What areas of documentation should be included?

Elements (institutional, operational and compliance) include context, scope, objectives, roles, integration, evaluation, verification, review, improvement.

  • OHS Policy, resources, and responsibilities
  • Incident management and investigation
  • Consultation arrangements
  • Return to work
  • Risk management
  • Contractor management
  • Procurement and outsourcing
  • OHS education, training and competency
  • Emergency preparedness
  • Management of change
  • Record keeping (Forms and registers)
  • Performance Measuring (audits, inspections, reports, success indicators)
  • OHS Implementation Plan

How do we implement our OHSMS?

  • Commitment & Leadership
  • OHS Training & Education
  • Incident reporting and investigations
  • Audits, inspections, observations, reviews
  • Communication & Participation
  • Documentation & Performance Reporting

What channels are required?

  • inputs
  • processes
  • outputs
  • feedback

What are the success factors for OHSMS?

  • Adequate resources
  • Kind of system used (simplification of documentation & reduction of repetition & audience focussed)
  • Senior management and Board commitment
  • Integration into general management systems
  • Effective employee participation & consultation
  • Developing capabilities and continuously improving
  • Motivation (internal goals preferential as motivators)
  • Customisation (size, complexity, industry, business model, risk profile)
  • Prioritisation (Risk – Based)
  • Effective risk assessment
  • Risk-focus rather than process-driven system
  • Promotion and value in communication
  • Effective performance monitoring
  • Prescription is related to maturity level (ie low maturity – high prescription)
  • Clear allocation of responsibilities

What are the costs associated with not having an effective OHSMS?

  • Direct costs (e.g., damages, medical treatment, regulatory fines, insurance premium increases)
  • Indirect costs (e.g., production capacity losses, delivery delays, inventory disruptions, recruitment and payment of additional staff, investigation costs, diversion of managerial time from other business matters)
  • Immeasurable costs (e.g., damage to business reputation, impact on worker morale).

How can we effectively measure of OHS performance via internal or external audits and Performance Reporting?

  • Include actionable and observable items as indicators
  • encompass quantity, quality and temporal parameters and combine quantitative and qualitative data to provide an inclusive picture
  • Use a combination of 3 auditing approaches
    • Structural – assessment of the system
    • Operational – assessment of the implementation of OHSMS activities
    • Performance – assessment of the results of performance indicators
  • Aim to evaluate proactiveness
    • Top management commitment
    • Flexibility (of work system design)
    • Learning (from both incidents and normal work)
    • Awareness (of system status).
    • Communication
    • Continuous improvement
    • Employee involvement / engagement
    • Competence
  • Ensure regular reporting (ie quarterly,& Annual) including incident statistics and Positive Performance Indicators is provided to senior Management and Board

What do we need to avoid when auditing and checking on the performance of an OHSMS?

  • Unintentional errors of the auditor or deliberate fraud by the auditor
  • Financial interests from auditor consulting causing undue influence
  • Undue influence arising from personal relationships between the auditor and client
  • Failure to allow worker participation
  • Paperwork for the sake of the audit
  • Unintended consequences and potential goal displacement of audit scoring
  • The confusion of audit criteria
  • Lack of auditor independence and skill.

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