ISO 45001:2018, the Occupational Health and Safety Management System standard was published in early March 2018. This is the twenty-first in a series of blogs, in which we describe what the implementing company must do in order to meet the requirement of the standard. We will now look at clause 9: Performance evaluation.
ISO 45001 – Clause 9: Performance Evaluation
This clause provides guidance on evaluating the performance of the OH&S management system.
This clause encompasses the following:
- Monitoring, measurement, analysis and performance evaluation;
- Internal audit;
- Management review.
Clause 9.1: Monitoring, Measurement, Analysis and Performance Evaluation
Clause 9.1.1 General
The organisation should have a systematic approach for measuring and monitoring its OH&S performance on a regular basis, as an integral part of its management system.
The organisation needs to monitor and measure the following in order to determine the performance of the OHSMS and evaluate its effectiveness:
- The extent to which legal and other requirements are fulfilled including, where applicable, all applicable OH&S legislation, collective agreements, standards and codes and insurance requirements;
- Characteristics of activities and operations related to the identified hazards, risks and opportunities;
- Progress in the achievement of the organisation’s OH&S objectives;
- Effectiveness of operational and other controls.
This includes the determination of the criteria against which the organisation’s OH&S performance will be evaluated, including appropriate indicators. Criteria are what the organisation uses to compare its performance against (e.g. benchmarking its OH&S performance against other organisations, standards or codes, etc.).
To measure criteria, indicators are used. For example, if the criterion is a comparison of incidents, the organisation could choose to look at frequency, type, severity or number of incidents; the indicator could be the determined rate within each one of these criteria.
The organisation must select appropriate methods for monitoring, measurement, analysis and performance evaluation in order to ensure valid results, decide when the monitoring and measurement will be performed and when the results from monitoring and measurement will be analysed, evaluated and communicated.
The organisation must ensure that monitoring and measurement equipment such as sampling pumps, noise monitors, toxic gas detection equipment, is calibrated or verified and that it is correctly used and maintained.
Insofar as measuring and monitoring are concerned, the organisation should use both reactive and proactive measures of performance but should mainly focus on proactive measures in order to drive OH&S performance improvement.
Examples of proactive measures include:
- Assessment of compliance with legal and other requirements;
- Evaluation of the effectiveness of OH&S training;
- Use of worker surveys to evaluate OH&S culture and related worker satisfaction;
- Completion of statutory and other inspection schedules;
- The extent to which programmes have been implemented;
- The effectiveness of the worker consultation and participation process;
- Use of health screening.
Examples of reactive measures include:
- Occurrence and rates of notifiable accidents and dangerous occurrences;
- Lost time incident rates;
- Monitoring of ill health;
- Actions required following assessments by regulatory bodies such as the HSA/HSE.
The organisation must retain appropriate documented information as evidence of the results of monitoring, measurement, analysis and evaluation and of the maintenance, calibration or verification of measuring instruments.
Clause 9.1.2 Evaluation of Compliance
The organisation must establish, implement and maintain a process for periodically evaluating its compliance with the legal and other requirements that are applicable to its OH&S risks, as part of its commitment to compliance. The organisation can decide to combine these evaluations or establish separate processes. This clause complements clause 6.1.3: Determination of legal requirements and other requirements.
The organisation must:
- Determine the frequency and method for the evaluation of compliance;
- Evaluate compliance and take action if needed;
- Maintain knowledge and understanding of its compliance status with legal and other requirements.
A compliance evaluation programme can encompass multiple (all occupational exposure legislation) or a single legal requirement (the Safety, Health and Welfare at Work Act 2005). The frequency of evaluation can be affected by factors such as past compliance performance or the frequency at which legislation is enacted or modified.
A compliance evaluation programme can be integrated with other assessment activities. These can include management system audits, environmental audits or quality assurance assessments.
It should be noted that legal compliance is the minimum standard in determining the effectiveness of the OH&S management system.
The organisation must retain documented information of the compliance evaluation results.