LRQA Guidance

10 pitfalls to avoid when implementing OHSAS 18001 LRQA Business Assurance Improving performance, reducing risk

10 pitfalls to avoid when implementing OHSAS 18001

10 pitfalls to avoid when implementing OHSAS 18001

Companies are coming under increasing commercial, regulatory and ethical pressures to control risks that are linked with their operations. Most organisations now believe they comply with current health and safety legislation. But many are now realising the benefits of a formalised approach to occupational health and safety management, certified to OHSAS 18001. This Guide provides you with a brief introduction to OHSAS 18001 and outlines 10 of the common pitfalls organisations make when implementing an occupational health and safety (OHS) management system to OHSAS 18001. Mick Fredricks, Technical Manager for health and safety (H&S) and Tim Dove, Quality, Environmental and H&S Trainer, have written this Guide using valuable input from LRQA health and safety assessors. The common pitfalls outlined are drawn from practical experience during 2007 to 2012*.

*To protect client identities and to ensure we continue to adhere to any confidentiality agreements, no company names are referred to in this Guide.

LRQA Guidance OHSAS 18001

This Guide has been written in conjunction with ‘Why is OHSAS 18001 good for you?’; LRQA’s practical Guide to implementing OHSAS 18001. What is OHSAS 18001? OHSAS 18001 is the international specification for occupational health and safety management and was developed in response to industry demand. Whether you are a large, multi-national or a small organisation, it defines a set of occupational health and safety requirements suitable for any organisation. An effective and robust OHS management system can help you turn uncontrolled hazards into controlled risks and so better safeguard the wellbeing of both your people and your business. Our technical specialists were instrumental in the development OHSAS 18001 and with over 11 years assessment experience, we are ideally placed to help you avoid the common drawbacks some organisations experience.

1. Believing safety inspections are system audits Typical Causes/Symptoms Some organisations believe that safety inspections are system audits, and therefore never or very slowly improve safe conditions (because safety inspections do not demand corrective actions in the same way as audits). This is often a result of unchallenged management system failures, and an emphasis placed on wearing PPE, preventing slips and trips or guarding. Potential Cures To help change opinions, continue inspections, safety tours and walkabouts, as these demonstrate operational control (cl 4.4.6). Ensure that your audit team have received high quality auditor training and that your top management team have high quality OHS management system briefings.

2. Audit programme is not linked to risk Typical Causes/Symptoms It is often found that the audit programme is not linked to risk, because organisations have just reviewed the clauses of the standard and have not identified failing controls of significant hazards, and the audit system falls into disrepute because it’s looking at the wrong things! Potential Cures Prioritise the hazards by their uncontrolled significance and review audit programmes. Educate employees on what hazards are significant and the expected controls of those significant hazards.

3. ‘Other’ is not addressed Typical Causes/Symptoms Often, organisations miss requirements from trade associations and other contractual requirements resulting in contracts not being renewed, or penalty clauses applied. Potential Cures It is essential to identify what ‘other’ (other than strict H&S legal requirements) or contractual requirements are applicable to the business, and that the requirements are addressed within the OHS management system. As with legal requirements, ‘other’ requirements should be reviewed and any legal register or list updated as needed.

4. No link between H&S objectives and risk assessment Typical Causes/Symptoms Often there are no links between H&S objectives and risk assessment resulting in things being done because they are easy and quick fixes, leaving significant risk(s) without improvement. This is often due to inappropriate resources focusing on less significant risks. Potential Cures To address this, effective management awareness of accountability and responsibility is essential to ensure effective prioritisation of residual risk levels. Effective Management Review should aid this process to ensure that objectives are indeed related to areas of greatest residual risk.

5. Organisation has tried to risk assess everything Typical Causes/Symptoms Organisations often try to risk assess everything resulting in thousands of risk assessments. Due to the extensive quantities, few are read, and many are duplicated. Huge numbers of unnecessary corrective actions which are not necessary are generated. Potential Cures Don’t conduct a risk assessment just because you can, prioritise your efforts and focus on the few significant hazards. Remember that a risk assessment is the management tool which should be distilled into information, practices, processes, procedures, etc. to keep staff safe.

6. Records no longer accessible Typical Causes/Symptoms Records are no longer accessible for a number of reasons including: • electronic files stored on personal PC’s or drives • paper files lost due to staff changes, company location or reorganisation, making it difficult to confirm that equipment is safe to use, staff are competent and incidents records have been maintained. Potential Cures To ensure records are accessible, store files on shared drives that are routinely backed up, and only have paper copies if considered critical to the business. Clearly define the H&S records to be retained, where they are to be held, on what medium they are to be kept, and for how long before disposal.

10. Safety is left to the Health and Safety Manager Typical Causes/Symptoms Often, when staff are asked the question “Who is ultimately responsible for health and safety?” many respond with “the Health and Safety Manger”. The reason for this is that many procedures within an OHS management system include the requirement 'if problems are encountered, contact the H&S Manager‘.

7. Lots of safety, not much health Typical Causes/Symptoms Organisations tend to have lots of safety but not much health, which may be characterised by excessive medical absenteeism for chronic problems. Such as high level claims for industrial injury and ill health, problems with stress, skin disorders, bad backs, lung function, hearing loss, work related neck and upper limb disorders (WRULDs), etc. Potential Cures Organisations must review their Risk Assessment process to ensure it covers health and chronic injury hazards, and educate the workforce about health issues and associated controls.

8. Performance monitoring is focussed on accidents Typical Causes/Symptoms Organisations tend to conduct performance monitoring which is focused on accidents that often occur as a result of unsafe procedures, processes, work activities or unsafe plant and/or equipment available for use. Potential Cures To identify the potential for accidents in the first place, a fresh look should be taken at procedures, processes and work activities using operators (if not already used) from different areas of the business. Look at ‘what if’ scenarios alongside top tree events.

The organisation must ensure that plant and equipment are inspected as required and that appropriate records are maintained, in order to prove that they are safe. Audit results, accidents and incidents should be analysed as should right performance data for the business. Ongoing monitoring should be at least at the same frequency as financial or performance data.

9. Management review is not effective Typical Causes/Symptoms Management reviews are often not effective as many organisations do not confirm the ongoing suitability of the OHS management system. As a result there is no reaction to poor performance, and no reaction to changing requirements, processes and/or staffing. Potential Cures To ensure that management reviews are effective, management should receive training about their accountability and responsibilities. The management team should analyse the collated H&S information and ensure that outputs are determined and recorded in accordance with requirements of clause 4.6.

Potential Cures Ensure top management are clear about their responsibilities; they are ultimately accountable. They need to know that while responsibility may be delegated, accountability cannot. Ensure the procedures define responsibility for correction and corrective action to the line managers, and ensure that top and line managers are adequately trained in their H&S responsibilities.

Together with 'Why is OHSAS 18001 good for you?' and this article, we are hoping to provide valuable insight into implementing OHSAS 18001. Health Check This tool is designed as a simple checklist requiring yes or no answers for you to clearly see how you are progressing with the implementation of your OHS management system. At the end of the questionnaire, you will get a percentage result indicating how close you are to achieving certification to OHSAS 18001. For more information on our OHS assessment and training services, please visit www.lrqa.co.uk

Turn uncontrolled hazards into controlled risks

“LRQA’s Business Assurance approach throughout the certification process enabled us to achieve our objectives ahead of the programme. Our continuing relationship with LRQA is bringing about benefits beyond certification while helping drive continual improvement.” M. Mohammed Fleet Quality Manager EDF Energy Nuclear Generation Limited LRQA certifies EDF Energy Nuclear Generation Ltd to OHSAS 18001, ISO 9001, ISO 14001 and PAS 55-1.

Why choose LRQA?

15% Discount

We’re committed to helping our clients get the most business benefit from their management systems. And this is reflected in everything that we do. Through our ‘Business Assurance’ portfolio, we can give an insightful, challenging yet realistic assessment of your business.

For a limited period, LRQA is offering 15% discount on the cost of the OHSAS 18001 Appreciation and Interpretation course.

Selecting LRQA means you’ll be working with a company that is synonymous with the business of safety.

To claim your discount, contact us on: 0800 328 6543 Quoting CS10

Our technical specialists were instrumental in the development of the specification and as part of the Lloyd’s Register Group, which has been involved in the business of safety since 1760, we know what we’re talking about. After all, we have been assuring the management systems of some of the world’s best known brands for over 20 years. In the UK, LRQA became one of the first to gain accreditation from UKAS, meaning you can rest assured you'll be working with an organisation recognised as having the expertise and experience to provide a high quality service. Choosing LRQA means you’ll be working with one of the world’s most trusted and respected management system bodies providing you – your customers, prospective customers and other stakeholders – with business assurance.

Booking to be made by 1 July 2012 and training to be taken by the end of 2012. Discount is only available on the costs for the course and excludes other discounts, accommodation and sundry costs. Terms and conditions apply.

Training Whether you are just beginning to implement your system, looking to improve what you have or an experienced practitioner wanting to gain a formal qualification we have a course to meet your objectives. Our public events are held throughout the UK and give you the added benefit of sharing experiences with other delegates while our in-company courses are tailormade to suit. We have also teamed up with a third-party training body which has enabled us to extend our health and safety offering to include IOSH accredited courses and the NEBOSH National General Certificate. Further information including full course outlines are available from: www.lrqa.co.uk/training

LRQA is dedicated to supporting our clients to help them make the most of their management systems. Our website: www.lrqa.co.uk contains useful advice to organisations looking at implementing management systems. Contact us T 0800 783 2179 E [email protected] W www.lrqa.co.uk

Lloyd's Register Quality Assurance Limited Hiramford, Middlemarch Office Village, Siskin Drive, Coventry, CV3 4FJ, UK Lloyd’s Register Quality Assurance Limited is a member of the Lloyd’s Register Group Registered office: 71 Fenchurch Street, London EC3M 4BS Registered number: 1879370

Lloyd’s Register and LRQA are trading names of the Lloyd’s Register Group of entities. Services are provided by members of the Lloyd’s Register Group. For details, see www.lr.org/entities

Care is taken to ensure that all information provided is accurate and up to date. However, LRQA accepts no responsibility for inaccuracies or changes to information. © LRQA 2012. Lloyd’s Register Quality Assurance Limited. All rights reserved. Pub. Feb 2012