Guidelines
for aN
OCCUPATIONAL
HEALTH AND SAFETY
management
system*)
(OHSMS)
This publication is not to be considered a standard or a
technical specification to be used for third-party certification or for
surveillance purposes by the control authorities in occupational health and
safety matters. The compliance with the guidelines contained in this document
is not compulsory, but only a voluntary decision freely taken.
TABLE OF CONTENTS
B. Cyclic sequence of an OHSMS 5
C. The policy for occupational health and
safety 6
E. System structure and organisation 8
E.2
Definition of duties and responsibilities 8
E.3
Involvement of personnel 10
E.5
Communication, flow of information and co-operation 11
E.7 Health
and safety integration in company processes and operational management 12
F. Survey
and analysis of results and relevant improvement of the system 13
F.1 Internal
safety monitoring 13
F.2
Characteristics and responsibilities of inspectors 14
PREFACE
Considering
the importance of supplying the Italian enterprise sector with a tool for
creating an occupational health and safety management system, UNI and INAIL
have contributed to the setting up of a Working Group charged with drafting
guidelines for this purpose.
This
Working Group is made up of the following organisations:
-
CGIL Italian General Labour Confederation
-
CISL Italian Confederation of Labour Unions
-
CNA National Confederation of Artisans and of Small and
Medium Businesses
-
CONFAGRICOLTURA General Confederation of Italian Agriculture
-
CONFAPI Italian Confederation of Small and Medium Industries
-
CONFARTIGIANATO Italian
General Artisan Confederation
-
CONFCOMMERCIO General Italian Confederation of Commerce,
Tourism, Services and Small and Medium Businesses
-
CONFINDUSTRIA General Confederation of Italian Industry
-
INAIL National Institute for Insurance against Job Accidents
-
ISPESL Superior Institute for Job Accident Prevention and
Safety
-
UIL Italian Labour Union
-
UNI Italian National Standards Body
who
have drafted and approved this document.
UNI
and INAIL hope for any organisation being informed about this document to share
its contents and join this initiative.
INTRODUCTION
Occupational
health and safety management is a key part of the general management of a
company.
Achieving
the health and safety objectives in a company does not mean to make the
adoption of safety management systems as bound or needed.
These
guidelines are a valid support to the companies which are voluntarily willing
to adopt a safety management system.
An
occupational health and safety management system (hereinafter called “OHSMS” or
“System”) integrates health and safety objectives and policies in the planning
and management of work and production systems of goods or services.
The
System defines the method of identifying, in the company organisational
structure, responsibilities, procedures, processes and resources for setting a
company accident prevention policy, complying with the health and safety
regulations currently in force.
The
System, adopted on a voluntary basis[1]
and in strict observance of the law: can be successful because,
Ÿ
monitoring activities are carried out preferably by internal
company/organisation staff;
Ÿ
it is not subject to third-party certification legally
required;
Ÿ
it is economically justifiable, since it also contributes to
management economy;
Ÿ
it is tailored to the specific characteristics of the
company/organisation;
Ÿ
it enables to get adjusted to the evolution of laws,
regulations and good technique standards;
Ÿ
as such, it is not subject to check by surveillance
authorities;
Ÿ
it involves workers and their representatives in the
management system.
The
System described in this guide is generally valid and its application is to be
tuned, bearing in mind the overall characteristics of the company/organisation
(size, type of production, technological cycles, organisational structure,
etc.) that intends adopting it.
In
some sectors and/or divisions, regulated by specific laws, the application of
this guide may require further illustrative and/or supplementary documents.
This
publication contains guidelines and recommendations. It cannot be considered as
a standard or a technical specification to be used either for third party
certification purposes, or for Authorities surveillance.
A. Purpose
The
purpose of an OHSMS is to assure that the health and safety objectives fixed by
the company/organisation itself are achieved according to an effective
cost/benefit outlook.
Such
a system actually aims at:
Ÿ
progressively reducing the overall occupational health and
safety costs including those due to work-related accidents and illnesses,
minimising the risks that employees and third parties (customers, suppliers, visitors,
etc.) can be exposed to;
Ÿ
increasing the efficiency and the performances of the
company/organisation;
Ÿ
contributing to the improvement of occupational health and
safety levels;
Ÿ
improving the internal and external image of the
company/organisation.
B. Cyclic sequence of an OHSMS
The OHSMS
process is based on the cyclic sequence of the planning, implementation,
monitoring and system re-examination stages, by means of a dynamic method.
The objectives
planned can be achieved just on condition that all company functions and, in
particular the ones at the highest level, are duly committed and involved.
Phases can be
more or less complex in each individual company or productive unit, and this
depends on:
Ÿ
size, type, activity and relevant complexity of the organisation;
Ÿ
significance of the
present, potential or residual dangers and risks;
Ÿ
people potentially exposed.
The
sequences of the phases taken as example and generally applicable, when the
System is running, are:
Ÿ
to set an occupational health and safety policy fixing the
general commitments for risk prevention and the progressive improvement of
health and safety;
Ÿ
to identify legal requirements and applicable regulations;
Ÿ
to identify any danger and evaluate the relevant risks for
all workers, including special cases[2],
associated with working and organisational activities (interaction between them
as well), dangerous substances and preparations, etc.;
Ÿ
to identify the people to be potentially exposed (for
example, independent workers, third parties employees and occasional visitors);
Ÿ
to set specific targets which are appropriate, achievable
and consistent with the general commitments defined in the policy;
Ÿ
to work out programmes for getting to these objectives, by
defining priorities, timing and responsibilities and by allocating the
resources needed;
Ÿ
to establish the most suitable methods, in terms of
procedures and practice, for dealing with these programmes;
Ÿ
to make the company structure aware of the objectives to be
achieved;
Ÿ
to provide for proper monitoring, assessment and inspection,
in order to check whether the system is working;
Ÿ
to undertake the relevant corrective and preventive actions
resulting from the monitoring outcome;
Ÿ
to check periodically whether the system is effective and
efficient enough for achieving the objectives set by the health and safety
policy, as well as it is tailored to the company and the internal/external
changes, by modifying, if necessary, both policy and health and safety
objectives, bearing the continuous improvement always in mind.
The
OHSMS can be described, for example, according to the general outline shown
below.
CONTINUAL INITIAL
REVIEW
IMPROVEMENT
POLICY
MONITORING PLANNING
AND
ORGANISATION
IMPLEMENTING
ACTION
Structure
of an OHSMS
C. The policy for occupational health and safety
The policy for
occupational health and safety should be set and supported by the company’s top
management in line with the general policy of the company itself.
The purpose of
this policy is setting thoughts, essential values and views of the company
regarding OHS as well as guidelines, principles and outcomes to be achieved,
and proving the top management’s commitment in involving staff in such
objectives, making it aware of the results to be realised and the
responsibilities and motivations to be shared.
This policy
helps demonstrate, internally:
Ÿ
the company’s commitment to protect workers’ health and
safety;
and
externally:
Ÿ
the concrete company’s commitment in the occupational health
and safety issues;
Ÿ
the priority to be given to precautionary measures;
Ÿ
the ongoing
improvement chosen by the company as its main target.
The
policy for OHS should include, among other things:
Ÿ
the commitment in observing laws and the agreements
applicable to OHS;
Ÿ
the idea that the organisation as a whole, from the Top
Manager to any single worker, according to tasks and roles, is responsible for
managing OHS;
Ÿ
the commitment in taking OHS and its results as an integral
part of company management;
Ÿ
the commitment in aiming at ongoing improvement and
precautionary measures;
Ÿ
the commitment in providing human and concrete resources
needed for this;
Ÿ
the commitment in having workers aware and trained in order
to carry out their duties safely and take on their responsibilities regarding
OHS;
Ÿ
the commitment in having workers involved and consulted,
personally or through their safety representatives;
Ÿ
the commitment in checking this policy periodically and the
way the management system is implemented;
Ÿ
the commitment in setting and in making the OHS objectives
known inside the company as well as the relevant implementation programmes.
In
defining or updating the OHS policy, the following must be kept in mind:
Ÿ
the activity carried out and the company size;
Ÿ
the type and the level of the present risks;
Ÿ
the type of labour contracts;
Ÿ
the results of the initial analysis or the subsequent
monitoring.
D. Planning
Setting a
policy goes through a planning process aimed at working out a specific plan in
the OHSMS framework.
Planning OHS should
be consistent with the company’s general management system.
The methods
used for planning the OHS objectives are to be achieved should be the same used
for planning the overall company objectives are achieved (for example:
commercial, technological, market opportunities, company costs, personnel
management, etc.). Within this scope the organisational/working procedures
needed for managing company activities should be integrated by the necessary
health and safety components, without creating any overlapping.
The key
requirements of the planning process to be born in mind should be the
following:
Ÿ
definition and determination of the objectives aiming at
keeping and/or improving the system;
Ÿ
the determination, preferably in the very moment the
objectives are laid down, of the evaluation criteria for proving that
objectives are actually achieved;
Ÿ
the preparation of a plan for achieving each objective,
containing the intermediate goals where necessary, identifying the
individuals/structures involved in realising the plan and assigning the
relevant tasks and responsibilities;
Ÿ
the definition of the resources needed, including the
economic ones;
Ÿ
the definition of the ways which are expected to be used to
check the actual and efficient achievement of objectives
This
planning should take the following into account:
Ÿ
ordinary and extraordinary working activities, including
emergency situations;
Ÿ
the activities of any personnel (including workers with
special contracts, suppliers, visitors, etc.) accessing work places and/or
involved in the working activities performed;
Ÿ
structures, places and methods of work, machinery, systems,
equipment, substances used, be they belonging to the company or supplied by
third parties;
Ÿ
the most suitable methods for supervising company processes,
in order to prevent inefficiencies as well as to identify and plan any
organisational, structural, procedural, productive, technological change,
bearing in mind that OHS requirements are to be complied with.
E. System structure and organisation
E.1 Management system
The company
should work out the OHSMS according to the guidelines given in this document,
although it has to implement what set out in the OHS policy that the company
itself has defined.
An OHS
management system should have the following characteristics:
Ÿ
be part of the company’s general management system;
Ÿ
contain the organisational structure, the responsibilities,
the practices, the procedures, the processes and the resources for realising
its own occupational health and safety policy;
Ÿ
be tailored to the activities carried out, the company size,
the kind and dimensions of the risks present in the company
E.2 Definition of duties and responsibilities
Responsibilities
and the relevant competence in OHS matters are to be in line with the company’s
organisational and functional chart.
While defining
the organisational and working tasks assigned by the company top management to
common workers, the ones regarding safety are to be defined as well, together
with the responsibilities connected with their application[3],
and the duties of inspection, check and surveillance on OHS matters.
Furthermore,
roles and tasks assigned to the person or the persons responsible for the
Prevention and Protection Service, the Workers’ Representative for Safety as
well as the ones in charge with emergencies, and to the company doctor, should
be expressed and made known at all company levels.
INITIAL
REVIEW
RISKS • Compliance
ASSESSMENT with laws and
regulations
• Identification of
sources
of
danger
• Risks
assessment
• Duties and
responsibilities
CONTINUAL • Involvement of
IMPROVEMENT personnel
• Communication,
SYSTEM PLANNING information flow,
AND
ORGANISATION co-operation
• Documentation
• Operational
management
MONITORING
PREVENTING
• Modifying
work PLANNING
organisation
• Development
and adjustment
interventions
• Information,
training
• Management of the IMPLEMENTING
information flow ACTION
and consultation
• Management
of
documentation
• Procedures and INTEGRATION
integration
with WITH
company
processes COMPANY
PROCESSES
• Emergency plans (productivity,
budget,
etc.)
Example
of the elements of an OHSMS
The realisation
and the policy of an OHSMS, maintenance and/or improvement objectives, the
technical and economical organisation and resources devoted to the creation of
this system and the achievement of relevant objectives fall within the
employer’s exclusive competence and responsibility, or of the Top Management,
if different. The employer can select a person[4],
proving he is capable and authoritative enough, to be charged with this duty,
fully or partially, regardless of any other company tasks, in order to co-ordinate
and check whether OHSMS is realised in compliance with this document.
E.3 Involvement of personnel
The OHS may be
effectively managed, if it is supported by employees involved in it, and, in
the same way, workers’ know how and expertise are a necessary resource for
developing an OHSMS.
The company
should find the most suitable way to have workers and/or their representatives
involved, especially in carrying out
Ÿ
the preliminary consultation aimed at assessing risks and
defining precautionary measures; and
Ÿ
holding periodic meetings which should take place in
observance with the requirements fixed by the legislation in force.
As
to the requirements fixed and the company structure, more involvement can be
achieved first through the meetings planned for the ordinary company
management, and then through analysis groups or committees and discussions on
particular OHS topics.
Still more involvement could be got to, by
collecting remarks and comments on the precautionary measures adopted, on the
OHSMS organisation, on working procedures and methods.
These
remarks and comments can also be used during the OHSMS re-examination phase.
E.4 Training and Awareness
The company
should decide and use methods for being sure that personnel, at every level, is
aware of:
Ÿ
the importance of their actions in relation to OHSMS policy
and requirements;
Ÿ
the consequences their activity has vis-à-vis OHS;
Ÿ
the consequences that could arise if what established by the
OHS is not fully kept to.
In
the framework of an OHSMS it would be suitable to check how competent any
person charged with a task affecting OHS is.
Competence
is checked according to a proper training and/or expertise.
The
company should take any useful measure so that workers and their
representatives may be competent enough for actively contributing to a proper
working of OHSMS and should encourage their participation.
The
company should arrange training activities according to the needs periodically
identified, also by consulting workers and their representatives.
E.5 Communication, flow of information and co-operation
A good
information flow within the company is a fundamental element for assuring
suitable levels of awareness and involvement in the policy adopted for the OHS.
The
co-operation among all those concerned, inside and/or outside the company,
should be the principle on which information flow is to be based.
Co-operation
should be part of an enterprise culture, according to which information can be
spread only if all company personnel and workers in particular may actively
participate.
The more
information and active participation in the system management is assured, the
more work-related accidents and illnesses may be prevented.
Communication
and information are essential for making personnel participating and involved
in the OHSMS and for achieving the objectives set for a company OHS policy.
The Top
Management should define and apply effective methods for informing about
policies, objectives, programmes and outcomes; it should encourage the feedback
on OHS topics and the personal communication in order to improve human
relations.
Therefore,
workers should be:
Ÿ
consulted, even through their representatives, about matters
concerning the OHS and above all when changes affecting OHS are planned, as
well as in the following implementation phase;
Ÿ
informed about who is responsible for the OHS and to which
extent, and who has specific responsibilities vis-à-vis the OHS within the
company.
For
this purpose, the following should be realised:
1) a
proper internal communication, aimed at collecting and spreading information,
(from the top to the bottom and viceversa), by using suitable tools according
to the company needs and size, thus improving co-operation among workers at any
level;
2) a
proper communication towards outside, that is:
Ÿ
external personnel (buyers, suppliers, external
collaborators);
Ÿ
public (customers, visitors, persons concerned);
Ÿ
authorities;
3) information about the company health and
safety policy.
E.6 Documentation
Documentation
is an important organisational tool that enables a company to deal with
information concerning its specific manufacturing situation, with the purpose
as well of contributing to the implementation and monitoring of the
occupational health and safety management system.
Documentation
should be kept and updated in such a way that the system may be always
efficient and effective, without, however, being affected.
Any
consultation, involvement, information and worker training activity should be
documented and filed.
A good
documentation management system is successful if data can be easily collected,
used and filed in the possible greatest number as well as regularly updated.
Company
documentation is needed for developing and keeping an efficient management
system, in a simple and quick way.
Minimum
documentation requirements are:
Ÿ
laws, regulations, accident prevention standards pertaining
company activity;
Ÿ
company regulations and agreements;
Ÿ
the OHSMS Manual, if any;
Ÿ
the legal requirements concerning the OHS[5];
Ÿ
manuals, instructions for use of machinery, equipment,
personal protective equipment (PPE) supplied by manufacturers;
Ÿ
information about production processes;
Ÿ
organisational charts;
Ÿ
internal regulations and working procedures;
Ÿ
emergency plans.
In
conformity with company characteristics, it should be established how documents
are to be handled, according, among others the following information:
Ÿ
the person in charge of the document system management;
Ÿ
how long documents
are to be kept (renewed);
Ÿ
the connection between the document management and the
information flow inside and outside the company;
Ÿ
contents and form (electronic, paper, audio-visual
supports).
In
any case, the company decides and keeps the information needed for describing
the key elements of the management system and their interaction, and gives
guidelines for the preparation of any correlated documentation.
This
documentation can be collected globally or if needed, even by resorting to
suitable I.T. tools.
E.7 Health and safety integration in company processes and operational management
The
integration of health and safety protection in company processes is the core
aspect of a management system in accident prevention on workplace, because it
is the practical application of the policy and the organisation decided by the
company, as described in the previous chapters.
In order to
implement what was declared in the OHS policy, the safety management system
should be integrated and consistent with the overall company management.
Every company
process should assess not only risks and the relevant preventive measures, but
also the way in which such process may affect OHS matters and all the questions
connected with this, the way in which OHSMS works and in which the targets
fixed may be achieved.
The company
should ensure that:
1) all company employees are aware and actively
involved in OHS objectives;
2) any overlapping of efforts and waste of
resources are to be avoided;
3) OHS responsibilities[6]
are suitable, clear and well-defined;
4) collaboration among all workers is increased;
5) the decisions taken do not have to disregard
the effects on the OHS;
6) the evaluation of the results achieved by the
personnel and company structures are also to take account of the performances
provided by the OHS.
The company
should also define the methods to:
- identify processes and the way they may
mutually be connected and affect each other;
- analyse and find out the solutions for any
possible change to the processes and their methods in order to achieve the OHS
objectives and/or improve the efficiency and effectiveness of the OHSMS.
Once
identified the areas of intervention connected with the OHS issues, in line
with its objectives and targets, the company should handle with them regularly.
In particular
it should:
Ÿ
point out the precautionary and protection measures
(including the organisational and relational aspects) and the interrelations
between the people involved and the company processes affecting OHS;
Ÿ
define “who does what”;
Ÿ
define the management methods in order to assure that the
targets fixed may be achieved.[7]
The
company should set and update:
Ÿ
the procedures to handle situations other than the policy
and the objectives fixed, while defining their working criteria;
Ÿ
the procedures concerning the significant OHS aspects in
terms of purchase of goods and services used by the company, communicating this
information to suppliers and contractors;
Ÿ
procedures for emergencies.
The
company should re-examine and review its procedures, on the basis of its
experience, in particular after emergencies.
The
company should also identify and define, on the basis of what decided with a
view to the goals concerning health and safety and a properly working OHSMS,
give instructions to the company staff involved concerning the way of:
Ÿ
employing and training workers;
Ÿ
organising work and work stations;
Ÿ
purchasing equipment, tools, raw materials, subsidiary
materials and consumables;
Ÿ
providing for ordinary and extraordinary maintenance;
Ÿ
training and selecting suppliers and contractors.
F. Survey and analysis of results and relevant improvement of the system
F.1 Internal safety monitoring
Like any
management system, an OHSMS should cover a check phase pertaining the
achievement of objectives and one pertaining the system operation.
Therefore, at
least two monitoring levels should be provided.
1st
Level
The way for
monitoring the achievement of the objectives should be established, at the
planning stage, together with the way in which methods and responsibilities of
the working management are defined.
This level of
monitoring is generally provided by internal resources, be they checked by the
operator himself or by the supervisor, but, in case of special aspects (such as
tool assessment), it could resort to other in- or outsourcing [8].
It is also recommended that organisational and procedural provisions regarding
the OHS be checked by the persons already in charge with it (managers and
supervisors).
2nd
Level
The purpose of
monitoring whether the system works (internal inspection) is to establish its
compliance with what planned, its proper application and its constant
maintenance and to achieve the objectives.
This kind of
monitoring should allow top management to take strategic decisions falling
within their competence, such as the relevant adjustment of its policy. The
inspection check should be performed by competent, objective and impartial
personnel, and be independent from the work sector where the inspection check
is being done.
It is
fundamental that checks on the way OHSMS works be intended as a rational and
planned choice, in the framework of some other checks aimed systematically
optimising and assuring the proper working of the manufacturing process and the
good supply of services.
F.2 Characteristics and responsibilities of inspectors
Checks should
be performed by competent persons, duly trained, and, in the event of more
people, used to teamwork.
In selecting
inspectors, the following should be taken into consideration:
- how long inspectors may be available;
- the level of expertise required for checks;
- the need for specialist know how or technical
experience;
- the level of education.
Inspectors should be responsible,
within their competence, for:
- acting in conformity with the requirements
fixed for monitoring activities and keeping to the purpose it is made for;
- accomplishing objectively and efficiently the
tasks allocated;
- being in line with the procedures fixed for
this;
- collecting and analysing elements, in
particular remarks and suggestions made by workers and their representatives,
thus coming to conclusions regarding the effectiveness of the OHSMS being
monitored;
- being careful to the elements that could
affect the relevant outcomes;
- documenting and presenting the monitoring
results.
F.3 Monitoring plan
The
organisational and procedural technical provisions covering precautionary and
protection measures realised by the company, the OHS objectives planned, as
well as the OHSMS itself, should be subjected to a planned monitoring.
A monitoring
plan should be developed through:
Ÿ
time-planning of checks (frequency);
Ÿ
allocation of tasks and responsibilities needed for
monitoring;
Ÿ
description of the methods to follow;
Ÿ
warning methods relating to any non-conformity situation.
Non-conformities
should be handled by assigning authority, responsibility and the necessary
resources for a timely intervention. This should take account of the need for
identifying the reason for non-conformity, be they or not connected with the
system structure, in order to define how to provide for a suitable corrective
action.
Some
basic criteria can be used as a guide in setting up an effective monitoring
plan:
a) consistency between the level of risk
identified, the safety degree of the adopted organisational and procedural
technical provisions covering precautionary measures, the frequency and level
of reliability of the monitoring performed[9];
b) allocation of the responsibility for
assessing precautionary measures to people properly trained in the risks that
such measures are to protect.
F.4 Management review
After the
conclusion of the internal monitoring, top management should submit safety
management activities to a review, in order to assess whether the system is
adequately implemented and is fully in line with the objectives to be achieved
and the safety policy set by the company.
This should be
focussed on:
Ÿ
accident statistics;
Ÿ
results of internal monitoring;
Ÿ
corrective actions taken;
Ÿ
reports on emergencies (real or simulated);
Ÿ
reports by the person in charge, appointed by top
management, on the overall performance of the system;
Ÿ
reports on the effectiveness of the management system;
Ÿ
reports on the risk identification as well as on their
assessment.
At
the end, the company is to check whether targets fixed have been achieved and,
in the light of the results deriving from the system monitoring and from the
application of the corrective and preventive actions taken or any possible
modifications to these, it should also set new objectives and plans with a view
to a step-by-step improvement, bearing in mind that policy, procedures and any
other elements of this system may be likely change, if needed.