3. OHSAS 18001 - Requirements and comments
N°
Sub-
clause
Requirement PDCA cycle, links, comments
4
OH&S management system
requirements
4.1 General requirements Plan
1 4.1 Establish the occupational health and
safety management system (OHSMS)
Start with an overview of the current
situation; ongoing commitment of
management to its highest level; benefits
and challenges explained to staff
2 4.1 Document the OHSMS Cf. sub-clause 4.4.4
3 4.1 Implement the OHSMS Cf. sub-clause 4.4
4 4.1 Maintain the OHSMS When changes in processes, products,
requirements, infrastructure
5 4.1 Continually improve the OHSMS Cf. sub-clause 4.6
6 4.1 Determine how the OHSMS will
fulfill these requirements
Consider factors, conditions and constraints
that impact on health and safety of
personnel
7 4.1 Define and document the scope of
the OHSMS
Cf. sub-clause 4.5.4
4.2 OH&S policy Plan
8 4.2 Define the OH&S policy Cf. sub-clause 4.5.4; define OH&S policy
which is an inescapable implication, direct
and documented by top management to
establish its principles of action
9 4.2 Authorise the OH&S policy By top management to its highest level
10 4.2 a The OH&S policy is appropriate Is adapted to the activities, work
environment; is realistic but takes into
account the company's vision
11 4.2 b The OH&S policy includes a
commitment to prevention
By top management to its highest level
12 4.2 b The OH&S policy includes a
commitment to continual
improvement
By top management to its highest level
13 4.2 c The OH&S policy includes a
commitment to comply with legal and
other requirements
Cf. sub-clause 4.3.2
14 4.2 d The OH&S policy provides a
framework for the OH&S objectives
Cf. sub-clause 4.3.3
15 4.2 e The OH&S policy is documented Cf. sub-clause 4.5.4; the OH&S policy and
4. objectives are formalized in a relevant and
simple document
16 4.2 e The OH&S policy is implemented
17 4.2 e The OH&S policy is maintained When changes in processes, products,
requirements, infrastructure
18 4.2 f The OH&S policy is communicated Declaration, posters, booklets
19 4.2 g The OH&S policy is freely available To interested public
20 4.2 h The OH&S policy is reviewed Cf. sub-clause 4.6
4.3 Planning Plan
4.3.1
Hazard identification, risk assessment
and determining controls
Top of the page
21 4.3.1 Establish the procedure hazard
identification
Cf. sub-clause 4.4.5; list of hazards; the
procedure required for the hazard
identification answers the questions who,
when, how, under what conditions identify,
plan, implement and maintain control of
OH&S activities of the OH&SMS
22 4.3.1 Implement the procedure hazard
identification
"Identify the hazards is decrease the risks"
23 4.3.1 Maintain the procedure hazard
identification
When changes in processes, products,
requirements, infrastructure
24 4.3.1 a Take into account routine and non-
routine activities
"No-risk situations do not exist"
25 4.3.1 b Take into account activities of all
persons on the workplace
26 4.3.1 c Take into account human factors Behavior, habits, traditions
27 4.3.1 d Take into account the identified
hazards of outside origin
Halted general services (water, electricity,
gas)
28 4.3.1 e Take into account hazards in the
vicinity of the workplace
This can be an environmental aspect (air
emissions, water discharges, noise and
other)
28 4.3.1 f Take into account infrastructure,
equipment and materials
Including those related with customer,
contractor
30 4.3.1 g Take into account changes in the
organization, activities or materials
31 4.3.1 h Take into account changes of the
OHSMS
32 4.3.1 i Take into account legal obligations
relating to risk assessment and
implementation of controls
Cf. sub-clause 4.3.2
33 4.3.1 j Take into account work environment Ergonomy of workstations
34 4.3.1 a Define the methodology for hazard Consider the scope and nature for a
5. ' identification proactive operation
35 4.3.1 b
'
Provide the rating of risks List of risks associated with identified
hazards
36 4.3.1 b
'
Apply controls Cf. sub-clause 4.4.6
37 4.3.1 Analyse changes prior to
implementation
Identify hazards and assess risks of changes
38 4.3.1 Determine controls taking into
account risk assessment
39 4.3.1 Reduce risk giving consideration to
hierarchy of controls
First eliminate then substitute, replace,
integrate safety, report, warn, use of PPE
(personal protective equipment)
40 4.3.1 Document results of hazard
identification, risk assessment and
determined controls
Cf. sub-clause 4.5.4
41 4.3.1 Keep up-to-date results of hazard
identification
When changes in processes, products,
requirements, infrastructure
42 4.3.1 Take into account risks in the
OHSMS
4.3.2 Legal and other requirements Top of the page
43 4.3.2 Establish the procedure legal
requirements
Cf. sub-clause 4.4.5; the required
procedure for review of legislation answers
the questions who, when, how, under what
conditions identify, access, plan, implement
and maintain the legal watch of
requirements related to OH&S aspects; use
several sources
44 4.3.2 Implement the procedure legal
requirements
Communicate the information - cf. sub-
clause 4.4.3
45 4.3.2 Maintain the procedure legal
requirements
"Ignorance of the law excuses no one. Latin
proverb"
46 4.3.2 Take into account legal requirement
in the OHSMS
Cf. sub-clause 4.5.2
47 4.3.2 Keep up-to-date legal requirements Communicate these requirements to staff,
suppliers and contractors; list of
requirements
48 4.3.2 Share information on legal
requirements
With suppliers and other interested parties
4.3.3 Objectives and programme(s) Top of the page
49 4.3.3 Establish OH&S objectives Opportunity to improve its public image
50 4.3.3 Implement OH&S objectives Commitment to preventions
51 4.3.3 Maintain OH&S objectives When changes in processes, products,
6. requirements, infrastructure
52 4.3.3 The objectives are measurable and
consistent with the OH&S policy
Cf. sub-clause 4.2
53 4.3.3 When determining OH&S objectives
take into account applicable legal
requirements and OH&S risks
Cf. sub-clauses 4.3.2 et 4.3.1
54 4.3.3 Take into account internal and
external constraints
Define performance indicators; consider
technology used, views of interested parties
55 4.3.3 Establish programmes So to be able to achieve objectives;
resources, tasks, time-frame
56 4.3.3 Implement programmes Communicate internally their progress
57 4.3.3 Maintain programmes When changes in processes, products,
requirements, infrastructure
58 4.3.3 a Attribute roles and responsibilies
59 4.3.3 b Include resources Considerations and financial constraints
60 4.3.3 b Include time-frame Time to hold
61 4.3.3 Review programmes Changes if necessary; Cf. sub-clause 4.6
4.4 Implementation and operation Do
4.4.1
Resources, roles, responsibility,
accountability and authority
Top of the page
62 4.4.1 The ultimate responsibility of the
OHSMS rests with top management
"Responsibility cannot be shared. Robert
Heilein"
63 4.4.1 Ensure resources to establish,
implement, maintain and improve the
OHSMS
Cf. sub-clause 4.6 ; "Health is priceless,
but has a cost"
64 4.4.1 Attribute roles, responsibility,
accountabilities and authorities
Clear and available internally job
descriptions, organization chart
65 4.4.1 Document roles, responsibility,
accountabilities and authorities
Cf. sub-clause 4.5.4
66 4.4.1 Communicate roles, responsibility,
accountabilities and authorities
cf. sub-clause 4.4.3
67 4.4.1 Appoint a management representative Cf. sub-clause 4.5.4
68 4.4.1 Attribute roles, responsibilities and
authorities to the management
representative
Cf. sub-clause 4.5.4
69 4.4.1 a Establish the OHSMS Cf. sub-clause 4.1
70 4.4.1 a Implement the OHSMS Cf. sub-clause 4.1
71 4.4.1 a Maintain the OHSMS When changes in processes, products,
requirements, infrastructure
72 4.4.1 b Reports to top management on the
performance of the OHSMS and
On a regular basis
7. improvement opportunities
73 4.4.1 Communicate the identity of top
management appointee
cf. sub-clause 4.4.3
74 4.4.1 Demonstrate commitment to the
continual improvement of the
OHSMS
This applies to all executives
75 4.4.1 Empower staff on OH&S aspects
over which they have control
Pay attention to his own safety but also to
other
4.4.2 Competence, training and awareness Top of the page
76 4.4.2 Train staff working on activities that
may impact on OH&S
Being competent is to apply knowledge and
skills
77 4.4.2 Retain records of staff competence Cf. sub-clause 4.5.4
78 4.4.2 Identify training needs Including as internal auditors - cf. sub-
clause 4.5.5
79 4.4.2 Provide training Identify and fulfil competence improvement
needs (training programme)
80 4.4.2 Evaluate the effectiveness of the
training
Demonstrated competence, enhanced
awareness
81 4.4.2 Retain records Cf. sub-clause 4.5.4
82 4.4.2 Establish the training procedure Cf. sub-clause 4.4.5; the required
procedure for training answers the questions
who, when, how, under what conditions
identify needs, raise employee awareness,
achieve competence
83 4.4.2 Implement the training procedure Cf. sub-clause 4.3.2
84 4.4.2 Maintain the training procedure When changes in processes, requirements
85 4.4.2 a Make persons aware of the OH&S
consequences of their activity and
behaviour
Commitment of top management to his
highest level
86 4.4.2 b Make persons aware of the
importance in achieving conformity
to the OH&S requirements
Cf. sub-clause 4.4.7; response to
emergencies
87 4.4.2 c Make persons aware of the potential
consequences of departure from
specified procedures
Show the link between individual
responsibility and health and safety impacts
88 4.4.2 a
'
For the trainings take into account
differing levels of responsibility,
ability, languages
Promote images
89 4.4.2 b
'
For the trainingd take into account
differing levels of risk
4.4.3
Communication, participation and
consultation
Top of the page
8. 4.4.3.1 Communication
90 4.4.3.1 Establish the communication
procedure
Cf. sub-clause 4.4.5; the procedure
required for communication answers the
questions who, when, how, under what
conditions identify, plan, implement and
maintain communication about OH&S
aspects and OH&SMS; assess the
effectiveness of communication at least
once annually
91 4.4.3.1 Implement the communication
procedure
"Good news walk, bad ones run. Swedish
proverb"
92 4.4.3.1 Maintain the communication
procedure
When changes in processes, products,
requirements, infrastructure
93 4.4.3.1
a
Communiquer internally Particula attention to feedback from staff (
surveys, suggestion box)
94 4.4.3.1
b
Communiquer externally Contractors, visitors (customers, regulation
organizations)
95 4.4.3.1
c
Receive requests from interested
parties
Interested parties can be customers,
suppliers, regulation authorities, regional
organizations
96 4.4.3.1
c
Document requests from interested
parties
Cf. sub-clause 4.5.4
97 4.4.3.1
c
Respond to requests from interested
parties
Including emergencies - Cf. sub-clause
4.4.7
4.4.3.2 Participation and consultation
98 4.4.3.2 Establish the procedure participation
and consultation
Cf. sub-clause 4.4.5
99 4.4.3.2 Implement the procedure
participation and consultation
Active employee involvement to improve
the OH&SMS
100 4.4.3.2 Maintain the procedure participation
and consultation
When changes in processes, products,
requirements, infrastructure, staff,
representatives
101 4.4.3.2
a
Involve workers in hazard
identification
And assessing risks and determining the
means of control
102 4.4.3.2
a
Involve workers in incident
investigation
The staff knows best the working conditions
103 4.4.3.2
a
Involve workers in the development
and review of OH&S policies and
objectives
Staff are informed at the outset of the
various proposals
104 4.4.3.2
a
Consult workers where changes affect
their OH&S
Including when choosing means of control
105 4.4.3.2
a
The workers are represented on
OH&S matters
9. 106 4.4.3.2 Inform workers about their
representative on OH&S matters
107 4.4.3.2
b
Consult contractors about changes
that affect their OH&S
New hazards, new means of control, various
changes
108 4.4.3.2 Consult interested parties on OH&S
matters
Emergency provisions, neighborhood
hazards, legal requirements
4.4.4 Documentation Top of the page
109 4.4.4 a Include OH&S policy and objectives Cf. Cf. sub-clauses 4.2 and 4.3.3
110 4.4.4 b Include scope of the OHSMS Cf. sub-clause 4.1
111 4.4.4 c Include the main elements of the
OHSMS and their interactions
For example in the OH&S manual (which is
not mandatory)
112 4.4.4 d Include documents and records
required by the OHSMS
Cf. sub-clauses 4.4.5 and 4.5.4
113 4.4.4 e Include documents of processes of
risk management
Can be combined with other documents
from other management systems
4.4.5 Control of documents Top of the page
114 4.4.5 Control OH&SMS documents The 12 mandatory procedures are:
- hazard identification (cf. sub-clause 4.3.1)
- legal requirements (cf. sub-clause 4.3.2)
- training (cf. sub-clause 4.4.2)
- communication (cf. sub-clause 4.4.3 )
- control of documents (this sub-clause)
- operational control (cf. sub-clause 4.4.6)
- emergency situations (cf. sub-clause
4.4.7 )
- measuring and monitoring (cf. sub-clause
4.5.1)
- evaluation of compliance (cf. sub-clause
4.5.2 )
- incidents and nonconformities (cf. sub-
clause 4.5.3)
- control of records (cf. sub-clause 4.5.4)
- internal audit (cf. sub-clause 4.5.5 )
You can combine several procedures into
one
115 4.4.5 Control records of the OH&SMS Cf. sub-clause 4.5.4
116 4.4.5 Establish the procedure control of
documents
The mandatory procedure for documents
answers questions, when, how, under what
conditions write, identify, verify, validate,
distribute and retain documents
117 4.4.5 Implement the procedure control of
documents
Master list of documents
10. 118 4.4.5 Maintain the procedure control of
documents
When changes in processes, products,
requirements, infrastructure
119 4.4.5 a Approve documents By the authorized person
120 4.4.5 b Update and re-approve documents Following any change
121 4.4.5 c Identify changes and revisions Change and indices (versions) management
of documents is done by a person with
responsibilities and authorities established
122 4.4.5 d Ensure that the right document is at
the right place
"The right document, at the right place, at
the right moment" and with the right
version
123 4.4.5 e Ensure that documents are legible and
identifiable
Codification is updated, each document is
clear, simple to understand, easy to
categorize
124 4.4.5 f Identify documents of external origin Documents of external origin (standards,
laws, decrees, specifications) are under
control (list, location, version)
125 4.4.5 f Control the distribution of external
origin
List (folder)
126 4.4.5 g Prevent use of obsolete documents Expired documents (obsolete) are retained,
archived, destroyed or locked up so that we
can not use them in normal cases
127 4.4.5 g Identify obsolete documents Red stamp
4.4.6 Operational control Top of the page
128 4.4.6 Determine activities to manage the
OH&S risks
Control measures, including staff training -
cf. sub-clause 4.4.2
129 4.4.6 Include the management of change Cf. sub-clause 4.3.1
130 4.4.6 a Implement operational controls Consider all activities of the company
(management, realization and support
processes) and feedback
131 4.4.6 a Maintain operational controls Cf. sub-clause 4.3.2; establish operational
monitorings
132 4.4.6 a Integrate operational controls into the
OHSMS
Maintenance of equipment, floor space,
environment (air, temperature, humidity),
emergency plans, protective equipment
(PPE)
133 4.4.6 b Implement controls of purchased
goods
Prevention and protection measures of
hazardous materials, criteria for approval
before purchase
134 4.4.6 b Maintain controls of purchased goods Specific requirements communicated to
supplier
135 4.4.6 c Implement controls related to
contractors and visitors
Supplier evaluation and selection criteria
11. 136 4.4.6 c Maintain controls related to
contractors and visitors
When changes in processes, products,
requirements, infrastructure
137 4.4.6 d Implement procedures where their
absence could lead to deviations from
OH&S requirements
Cf. sub-clause 4.4.5; the procedure
required for operational control answers the
questions who, when, how, under what
conditions identify, plan, implement and
maintain the company's activities
(management, realization and support
processes)
138 4.4.6 d Maintain procedures where their
absence could lead to deviations from
OH&S requirements
When changes in processes, products,
requirements, infrastructure
139 4.4.6 e Implement operating criteria where
their absence could lead to deviations
from OH&S requirements
Specific equipment, work instructions,
skills, forms of hazardous materials, PPE
140 4.4.6 e Maintain operating criteria where
their absence could lead to deviations
from OH&S requirements
Periodic evaluation of the effectiveness of
operational control used; proposal for new
means if needed
4.4.7
Emergency preparedness and
response
Top of the page
141 4.4.7 Establish the emergency procedure Cf. sub-clause 4.4.5; the procedure
required for emergency situations answers
questions, when, how, under what
conditions identify, plan, implement and
maintain preparedness and response to
potential emergencies and their impact on
OH&S
142 4.4.7 Implement the emergency procedure Identify potential hazards, define methods
to respond, communicate action plans, test
the ability to respond, train staff
143 4.4.7 Maintain the emergency procedure When changes in processes, products,
requirements, infrastructure
144 4.4.7 a Identify emergency situations List of emergency situations
145 4.4.7 b Respond to emergency situations Response sheets; most appropriate methods,
including abnormal conditions
146 4.4.7 Mitigate OH&S consequences of
emergency situations
List of measures and actions for every
potential situation
147 4.4.7 Take into account the needs of
interested parties
List of support organizations (coordinates)
148 4.4.7 Test periodically how to respond to
emergency situations
Cf. sub-clause 4.4.2
149 4.4.7 Review and, where necessary, revise
preparedness and response to
After analysis of tests undertaken and
occured; cf. sub-clause 4.5.3
12. emergency situations
4.5 Checking Check
4.5.1
Performance measurement and
monitoring
Top of the page
150 4.5.1 Establish the procedure measurement
and monitoring
Cf. sub-clause 4.4.5; the mandatory
procedure for monitoring and measuring
answers questions, when, how, under what
conditions identify, plan, implement and
maintain the verification OH&S
performance of all company's activities
through the analysis of data collected
151 4.5.1 Implement the procedure
measurement and monitoring
"If you can't measure it, you can't manage
it. Peter Drucker"
152 4.5.1 Maintain the procedure measurement
and monitoring
When changes in processes, products,
requirements, infrastructure
153 4.5.1 a Provide for qualitative and
quantitative measures
Number of incidents, illnesses, compliance
with OH&S policy commitments, skills
assessment
154 4.5.1 b Monitor the performance of the
OH&SMS
Cf. sub-clauses 4.4.6 and 4.5.5
155 4.5.1 c Monitor the effectiveness of controls On health and on safety
156 4.5.1 d Include proactive measures of
performance
Evaluation of compliance, training,
monitoring results, internal audits,
programme implementation
157 4.5.1 e Include reactive measures of
performance
Incidents, illnesses, work stoppages
158 4.5.1 f Keep records of results of monitoring
and measurement
Cf. sub-clause 4.5.4
159 4.5.1 Establish the procedure for
calibration and maintenance of
equipment
Cf. sub-clause 4.4.5; Monitoring and
measuring equipment (hardware and
software) are calibrated and verified
regularly, the staff is qualified, the methods
used are appropriate
160 4.5.1 Maintain the procedure for calibration
and maintenance of equipment
When changes in equipment, software and
methods
161 4.5.1 Keep records of calibration and
maintenance
Cf. sub-clause 4.5.4
4.5.2 Evaluation of compliance Top of the page
162 4.5.2.1 Establish the procedure evaluation of
compliance
Cf. sub-clause 4.4.5; "Safety is never for
ever", the mandatory procedure for
evaluation of compliance answers the
questions who, when, how, under what
conditions identify, plan, implement and
13. maintain the evaluation of compliance with
applicable legal requirements and other
requirements to which the company
subscribes
163 4.5.2.1 Implement the procedure evaluation
of compliance
Evalute the status of compliance; cf. sub-
clauses 4.3.2 and 4.5.5
164 4.5.2.1 Maintain the procedure evaluation of
compliance
When changes in processes, products,
requirements, infrastructure
165 4.5.2.1 Keep records of evaluations to legal
requirements
Cf. sub-clause 4.5.4
166 4.5.2.2 Evalute compliance with other
requirements
Cf. sub-clause 4.3.2; procedure separated
or combined with sub-clause 4.5.2.1
167 4.5.2.2 Keep records of evaluations to other
requirements
Cf. sub-clause 4.5.4
4.5.3
Incident investigation,
nonconformity, corrective action and
preventive action
Top of the page
4.5.3.1 Incident investigation
168 4.5.3.1 Establish the procedure control of
incidents
Cf. sub-clause 4.4.5; the procedure
required for the control of incidents answers
the questions who, when, how, under what
conditions identify, correct and investigate
incidents and their causes, evaluate need of
actions, eliminate root causes, review the
effectiveness of actions, communicate
results
169 4.5.3.1 Implement the procedure control of
incidents
Cf. sub-clauses 4.3.2 and 4.5.5 ; real and
potential consequences, frequency,
responsibilities and authorities
170 4.5.3.1 Maintain the procedure control of
incidents
When changes in processes, products,
requirements, infrastructure
171 4.5.3.1
a
Determine deficiencies related with
occurence of incidents
Anything that can contribute to the
occurrence of an incident
172 4.5.3.1
b
Identify the need for corrective action What could be achieved if the action is
applied? Are the needed resources
available?
173 4.5.3.1
c
Identify opportunities for preventive
action
After analysing theinvestigation results
174 4.5.3.1
d
Identify opportunities for continual
improvement
Propose at management review - Cf. sub-
clause 4.6
175 4.5.3.1
e
Communicate the results of
investigations
Cf. sub-clause 4.5.4
176 4.5.3.1 Perform investigations in a timely
14. manner
177 4.5.3.1 Treat corrective and preventive
actions in accordance with the
procedure control of nonconformities
Cf. paragraphe 4.5.3.2
178 4.5.3.1 Keep the results of investigations Cf. sub-clause 4.5.4
4.5.3.2
Nonconformity, corrective action and
preventive action
179 4.5.3.2 Establish the procedure control
of nonconformity
Cf. sub-clause 4.4.5; the procedure
required for the control of nonconformities
answers the questions who, when, how,
under what conditions identify, plan,
implement and maintain control of
noconformities, corrective and preventive
actions
180 4.5.3.2 Implement the procedure control
of nonconformity
identify and treat nonconformities,
determine and eliminate root causes,
evaluate the need for action, implement
actions, evaluate the effectiveness of
actions, find improvement opportunities
181 4.5.3.2 Maintain the procedure control
of nonconformity
When changes in processes, products,
requirements, infrastructure
182 4.5.3.2
a
Identify nonconformities "Any problem hides an opportunity for
improvement"; identification and
segregation of nonconforming product for
treatment or OH&S requirement not
followed
183 4.5.3.2
a
Correct nonconformities Mitigate OH&S consequences
184 4.5.3.2
b
Investigate nonconformities To find the cause
185 4.5.3.2
b
Determine the cause of
nonconformity
Methods to find the causes of
nonconformities (Ishikawa diagramme)
186 4.5.3.2
b
Take actions to avoid recurrence of
nonconformities
Set deadlines and responsibilities
187 4.5.3.2
c
Evaluate the need for preventive
actions
What could be achieved if the action is
applied? The resources needed are they
available?
188 4.5.3.2
c
Implement preventive actions The goal is to prevent occurrence of a
potential nonconformity; before the
implementation assess potential risks
189 4.5.3.2
d
Keep the results of actions Cf. sub-clause 4.5.4
190 4.5.3.2 Communicate the results of actions Cf. sub-clause 4.4.3.1
15. d taken
191 4.5.3.2
e
Review the effectiveness of actions
taken
Set deadlines and responsibilities
192 4.5.3.2 Assess risk of proposed actions prior
to implementation
Cf. sub-clause 4.3.1 ; if new hazards are
identified
193 4.5.3.2 Adapt actions to the magnitude of
problems and OH&S risks
Make arrangements with respect to real
effects (watch out for excess of zeal)
194 4.5.3.2 Change the OH&SMS documentation Cf. sub-clause 4.4.4
4.5.4 Control of records Top of the page
195 4.5.4 Establish OHSMS records The recordings are filled without delay.
Without them it's hard (impossible) to
demonstrate compliance with the
requirements of the OHSMS
196 4.5.4 Maintain OHSMS records Evidence that the OHSMS is living and
improving its performance continually
197 4.5.4 Establish the procedure control of
records
Cf. sub-clause 4.4.5; "Spoken words fly
away, written ones stay. Latin proverb"; the
procedure required for records answers
questions, when, how, under what
conditions identify, use, store, distribute,
protect, retain and dispose of records
198 4.5.4 Implement the procedure control of
records
199 4.5.4 Maintain the procedure control of
records
Cf. sub-clause 4.3.2; when changes in
processes, products, requirements,
infrastructure
200 4.5.4 Ensure that records are legible,
identifiable and traceable
The simplest answer to this requirement is
to use a computer or computer system (virus
protection and backup required)
4.5.5 Internal audit Top of the page
201 4.5.5 Conduct planned audits Annual programme for internal audits; find
opportunities to improve the OHSMS; use
ISO 19 011
202 4.5.5 a
1
Determine whether the OHSMS
conforms to OHSMS requirements
Cf. sub-clause 4.3.2
203 4.5.5 a
2
Determine whether the OHSMS is
implemented
Hazards are identified, risks assessed,
control methods inplemented
204 4.5.5 a
2
Determine whether the OHSMS is
maintained
Lagal watch updated
205 4.5.5 a
3
Determine whether the OHSMS is
meeting OH&S policy and objectives
Check compliance of processes
206 4.5.5 b Report results of audits to Input of management review - Cf. sub-
16. management clause 4.6
207 4.5.5 Plan the audit programme The audit programme focuses on sensitive
activities without forgetting the results of
previous audits
208 4.5.5 Establish the audit programme The programme covers the entire scope of
the OHSMS
209 4.5.5 Implement the audit programme Every audit is planned, the scope
established, the auditor appointed
210 4.5.5 Maintain the audit programme Additional audit if unusual nonconformity
211 4.5.5 Establish the procedure internal audit Cf. sub-clause 4.4.5; the procedure
required for audits answers the questions
who, when, how, under what conditions
plan (audit programme), define the criteria,
scope, frequency and audit methods
212 4.5.5 Implement the procedure internal
audit
Train auditors - cf. sub-clause 4.4.2
213 4.5.5 Maintain the procedure internal audit When changes in processes, products,
requirements, infrastructure
214 4.5.5 Include planning and conducting
audits, reporting results and keeping
records
Cf. sub-clause 4.5.4
215 4.5.5 Include audit criteria, scope,
frequency and methods
All this information is in the audit plan; add
the audit objective, schedule and
participants
216 4.5.5 Ensure objectivity and impartiality of
the audit process
"No-one is a judge in his own case. Latin
proverbe" ; auditors don't audit their own
activity
4.6 Management review Act
217 4.6 Review the OHSMS by top
management
"No system is perfect"; usually once or
twice a year, review the entire OHSMS to
monitor the achievement of OH&S
objectives
218 4.6 Assess opportunities for improvement
of the OHSMS
Review opportunities (occasions,
conditions, possibilities, circumstances) for
continual improvement of the OH&SMS
and the need for changes
219 4.6 Keep the records of the management
reviews
Cf. sub-clause 4.5.4 ; the report contains
the agenda, participants, the information
presented, the discussions and decisions
220 4.6 a Include results of audits and
evaluations of compliance
Cf. sub-clauses 4.5.5 and 4.5.2
221 4.6 b Include the results of participation
and consultation
Cf. sub-clause 4.4.3.2
17. 222 4.6 c Include information from interested
parties
Including complaints
223 4.6 d Include the OHSMS performance Cf. sub-clause 4.5.1
224 4.6 e Include the level of achievement of
objectives
Cf. sub-clause 4.3.3
225 4.6 f Include the status of investigations
and actions
Cf. sub-clause 4.5.3
226 4.6 g Include follow-up actions from
previous management reviews
Finalized and postponed actions
227 4.6 h Include changes in requirements Consider, evaluate and analyze any changes
that may impact on the OHSMS (new
products / processes, new customers, new
features and / or responsibilities, legal and
regulatory developments) - Cf. sub-clause
4.3.2)
228 4.6 i Include improvement
recommendations
Suggestions, views, opinions, proposals
from all staff or external interested parties
229 4.6 Include decisions and actions on
continual improvement of the
OHSMS
Evaluate, plan and implement: changes in
resources (human and financial),
environmental policy, objectives and targets
and improvement actions
230 4.6 Make available outputs of the
management review for
communication and consultation
Decisions are communicated internally