Clause 8.2: Management of Change of ISO/DIS 45001
One in a series of occasional blogs on ISO/DIS 45001 Occupational health and safety management system.
One of the more significant changes proposed in the draft ISO 45001 relates to Clause 8.2: Management of Change. There is no comparable clause to this in OHSAS 18001 although management of change is alluded to in a number of the OHSAS 18001 clauses and subclauses inter alia:
Clause 4.3.1: Hazard identification, risk assessment and determining controls subparagraph g: changes or proposed changes in the organisation, its activities, or materials and paragraph h: modifications to the OH&S management system, including temporary changes, and their impact on operations, processes and activities. Clause 4.3.1 further states “for the management of change, the organisation shall identify the OH&S hazards and OH&S risks associated with changes in the organisation, the OH&S management system, or its activities, prior to the introduction of such changes”.
Clause 188.8.131.52: Participation and consultation requires consultation with workers and contractors where there are any changes that affect their OH&S.
The preamble to clause 4.4.6: Operational control requires the organisation to determine those operations and activities that are associated with the identified hazards where the implementation of controls is necessary to manage the OH&S risks. This shall include the management of change.
Clause 4.6: Management review states that reviews shall include assessing opportunities for improvement and the need for changes to the OH&S management system.
The outputs from the management review shall include any decisions and actions related to possible changes to:
- OH&S performance
- OH&S policy and objectives
- Other elements of the OH&S management system
Clauses 8.2 of ISO/DIS 45001 requires the company to establish a process for the implementation and control of planned changes that influence its health and safety performance such as:
- New products, processes or services
- Changes to work processes, procedures, equipment, or the company’s organisational structure
- Changes to applicable legal and other requirements
- Changes in knowledge or information concerning hazards and associated risks
- Developments in knowledge and technology
The company is required to control both temporary and permanent changes, to review the consequences of unintended changes and, where applicable, to take action to mitigate any adverse effects that might arise as a result of the occurrence of change.
The overall purpose of the management of change process is to minimise the introduction of new hazards and risks into the workplace as a result of changes in:
- Plant and equipment
- Work practices and procedures
- Design specifications
- Raw materials
- Company personnel
- Standards or regulations
Depending on the nature of any anticipated change, the company must use a suitable methodology for assessing the risks and the opportunities that might arise as a result of the change.
The company must ensure that new, unforeseen hazards are not introduced or the risk profile increased as a result of the introduction of the change. Where the company decides to implement the change it must ensure that all affected employees are properly informed and are competent to cope with the change.
It should also be noted that the management of change is also embedded in ISO 9001:2015 and ISO 14001:2015 because of the introduction of the Annex SL format and terminology. Annex SL was developed in order to ensure that all future ISO management system standards (including the putative ISO 45001) share a common format irrespective of the specific discipline to which they relate.