We recently undergo a stage 1 audit for OHSAS 18001, and amongst the findings was "IMR is found not a member of top management." (Which they gave a Major Nonconformity :mad: ). I am currently the IMR (my position is considered as junior manager) since no one in the company would want to hold this position. And if ever I would ask the management to appoint one of them as MR for ohsas they wouldn't cooperate anyway leaving me redoing the work all over again. They are known to work fast if it is client’s requirement but they are not keen in following procedures and was not totally sold to the whole ISO and OHSAS thing.

Please give me some options that would help resolve this problem.

Thank you so much in advance.

Why not re-read clause 4.4.1 (Resources, roles, responsibility, accountability and authority).

The top management appointee may delegate some of their duties to a subordinate management representative while still retaining accountability.

Somebody from your organizations top management should be appointed and made accountable - you as MR will report to him/her.

And if ever I would ask the management to appoint one of them as MR for ohsas they wouldn't cooperate anyway leaving me redoing the work all over again. They are known to work fast if it is client’s requirement but they are not keen in following procedures and was not totally sold to the whole ISO and OHSAS thing.While delegation of responsibilities is one of those things management does all the time, the intent of the standard is pretty clear. If your top management has cultural incompatibility with the concept of being accountable, involved and participative with a MANAGEMENT system, then they are undeserving of being certified.

Keep in mind that the management rep for the OHSMS must be identified to all people working for the organization and part of the system implementing the OHSAS 18001.

good day kabayan!

1st, what is the finding so that we could be more specific on our analysis.:o

there would be factors on the findings, one of which is that the HR have no specific details JD of your position or just a documented letter of authority given by the HR or the top management.

a simple letter signed by them will be enough to authorize you as the company rep. this should be distributed and as much as possible, posted, etc (it depends on the company).

:notme:

What was the incentive to become registered? I would geuss your clients are asking for the certification. Show your major nonconformity to your manager and thier managers. Make it known!!

If they are not willing to assign a new MR or promote you to the necessary level then ISO and/or the clients voice was not important. Move on and forget registration.

I've been audited many times and the auditor always wants to speak with the top level person (owner, president, GM etc..) They are judging to see the importance of the ISO within the company and the authority of the MR. So promotion / new MR alone is not the sole solution. Senior management must agree that this is important to the company.

What were some of the other findings?

We recently undergo a stage 1 audit for OHSAS 18001, and amongst the findings was "IMR is found not a member of top management." (Which they gave a Major Nonconformity :mad: ). I am currently the IMR (my position is considered as junior manager) since no one in the company would want to hold this position. And if ever I would ask the management to appoint one of them as MR for ohsas they wouldn't cooperate anyway leaving me redoing the work all over again. They are known to work fast if it is client’s requirement but they are not keen in following procedures and was not totally sold to the whole ISO and OHSAS thing.

Please give me some options that would help resolve this problem.

Thank you so much in advance.


Want the truth? From your statement above there is a definite lack of commitment with your top management and you'd be hard pressed to find an honest/competent lead auditor that wouldn't issue a major in this case.

This is a self inflicted non-conformity and you can get as mad as you want, but not at the auditor or certification body.

Until you get your management problems honestly and truly rectified you need to set this quest aside. If you find an auditor and certification body that won't issue a major in a case like this the true value of your certificate could be questionable and Sidney is correct....You wouldn't deserve the certificate. These things aren't made to be bought and sold and you wouldn't find my name attached to it.

Thank you for your replies.

The vision to get certified came from the CEO (owner) in which I am reporting directly. He is committed to this but his VPs were not. I fear that if he delegates the MR for ohsas to one of them it would be like giving a key to pandora’s box. They will find a way to use the system to work their way around it and not following it. Then the CEO will be pissed off and will ask me to clean out the mess. I have been strict enough to enforce the system to them and in some ways succeeded but not all battles are won.

I will raise this matter to the CEO and let him decide. And if ever they appoint one of the top management to became an MR for OHSAS, does he needs to undergo the series of training in OHSAS (good luck with that)? Or let him be in paper and let me do the work?

And if ever the management decides to keep me as MR, what is the least level of management can I belong to comply with the requirement.

Thanks again.

We recently undergo a stage 1 audit for OHSAS 18001, and amongst the findings was "IMR is found not a member of top management." (Which they gave a Major Nonconformity :mad: ). I am currently the IMR (my position is considered as junior manager) since no one in the company would want to hold this position. And if ever I would ask the management to appoint one of them as MR for ohsas they wouldn't cooperate anyway leaving me redoing the work all over again. They are known to work fast if it is client’s requirement but they are not keen in following procedures and was not totally sold to the whole ISO and OHSAS thing.

Please give me some options that would help resolve this problem.

Thank you so much in advance.
IMR is required to be member of 'the management ' and not necessarily 'top management'.There seems to be a confusion here. You may question the auditor.
V.J.Brahmaiah

And if ever the management decides to keep me as MR, what is the least level of management can I belong to comply with the requirement.

Thanks again.

it doesnt mean that the person should be in such a level to represent, just a letter of authority from either the HR or the tops (much better) that you have been designated (and of course the compliance to the training for the position and other reqts).

remember KISS, short and simple.:yes:

IMR is required to be member of 'the management ' and not necessarily 'top management'.There seems to be a confusion here. You may question the auditor.
V.J.BrahmaiahSorry, but you are mistaken. The standard at hand explicitly requires
The organization shall appoint a member(s) of top management with specific responsibility for OH&S, irrespective of other responsibilities, and with defined roles and authority for...

IMR is required to be member of 'the management ' and not necessarily 'top management'.There seems to be a confusion here. You may question the auditor.
V.J.Brahmaiah

You are absolutely and totally wrong!

And there is no confusion between either myself or Sidney Vianna.

Please, unless you have hands on experience in a subject, don't provide advice that could be counter productive to an individual seeking assistance because that's where the confusion starts.

IMR is required to be member of 'the management ' and not necessarily 'top management'.There seems to be a confusion here. You may question the auditor.
V.J.Brahmaiah

Don't forget we're talking about OHSAS 18001 here, not ISO 9001! Different requirements!

Don't forget we're talking about OHSAS 18001 here, not ISO 9001! Different requirements!Good point. The fact that the question was posted in the OHSAS 18001 forum, with the OP stating that this was an OHSAS 18001 audit and 5 or 6 additional mentions to OHSAS could easily go unnoticed...:tg:

Good point. The fact that the question was posted in the OHSAS 18001 forum, with the OP stating that this was an OHSAS 18001 audit and 5 or 6 additional mentions to OHSAS could easily go unnoticed...:tg:

Sidney, as you well know, many folks with :2cents: to share often overlook the context of the thread in their enthusiasm to give those :2cents: ;)

it doesnt mean that the person should be in such a level to represent, just a letter of authority from either the HR or the tops (much better) that you have been designated (and of course the compliance to the training for the position and other reqts).

remember KISS, short and simple.:yes:


Is it some sort of letter of appointment wherein it will state that the top management appoint me as MR and am a member of the top management? even if my position is on a junior management level? Does it fully satisfy the requirement?

Thanks again.

Sidney, as you well know, many folks with :2cents: to share often overlook the context of the thread in their enthusiasm to give those :2cents: ;)Context? If someone will input fault on an auditor, rushing to judgement without reading and paying attention to the original post and subsequent replies, they should not be posting here. If I were a consultant and would show this blatant disregard to the particulars of the scenario at hand, I would not be deserving of serious business.

Does it fully satisfy the requirement?It depends. Are we concerned with:
a) implementing a sustainable system? or
b) passing an audit?

Sorry, but you are mistaken. The standard at hand explicitly requires
Mr.Sidney,
You have read the iISO9001-2008 wrongly.Here is the clause on MR:
"Top Management shall appoint a member of the organization's management who,irrespective of other responsibilities,shall have responsibility and authority etc, etc"
Pl.note MR is required to be a member of the 'management' and not necessarily 'top managment'.
Hope it is clear.
V.J.Brahmaiah

Mr.Sidney,
You have read the iISO9001-2008 wrongly.Here is the clause on MR:
"Top Management shall appoint a member of the organization's management who,irrespective of other responsibilities,shall have responsibility and authority etc, etc"
Pl.note MR is required to be a member of the 'management' and not necessarily 'top managment'.
Hope it is clear.
V.J.BrahmaiahWhy do you keep referring to ISO 9001? This thread, this discussion has NOTHING to do with ISO 9001. You are just digging yourself a deeper hole....

DEAR friends,
My opinion on the subject MR was wrong.It was given hastily assuming that the standard in question was ISO9001-2008.I regret the same.
Neverthles the whole exchange of mails was educative.
V.J.Brahmaiah

Is it some sort of letter of appointment wherein it will state that the top management appoint me as MR and am a member of the top management? even if my position is on a junior management level? Does it fully satisfy the requirement?

Thanks again.

Why do you want to put yourself into this position/situation? Do you know what are the implications?

It depends. Are we concerned with:
a) implementing a sustainable system? or
b) passing an audit?


Ofcourse i want both. Implementing a sustainable system and passing the audit at the same. But am a realist. There are things that work well with other companies that wont work with mine and vise versa. And we all have to deal with it.

Why do you want to put yourself into this position/situation? Do you know what are the implications?

Am just checking the option just in case they would decide to go this path. I know the implications ofcourse.



Thanks guys for your help. it really gave me a lot of ideas.

Ofcourse i want both. Implementing a sustainable system and passing the audit at the same. But am a realist.Let me use a very well known marketing campaign to make a point.

Attending a lead auditor course - $2,000
Hiring a consultant - $30,000
Getting certified - $ 8,000
Having good management - PRICELESS
The common denominator amongst QMS, EMS, OHSMS, ISMS, etc... is the letter M, which stands for Management. The kind of management that requires senior, top management to be INVOLVED, participating and ACCOUNTABLE.

The top failure mode for all management system implementation efforts is the lack of TRUE management buy-in, who see certification to any standard as an awards game, and once a decision is made to go after the "cert du jour", they delegate all responsibilities to underlings, who will do their best and, in most cases, make the certification happen. But, immediately thereafter and over time, the management system proves unsustainable because it is not linked nor connected with the business processes.

Why don't you use the fact that the auditor found a major gap in your system during the stage 1 audit to really get what you need?

A letter of delegation might make the external auditor "happy", but will it give you AUTHORITY? The intent of having the MR as part of top management is VERY CLEAR. As long as one searches loopholes to pass the audit, one fails to truly implement a system.

Hi,

I agree completely with Sidney ! "M" is the important point...

For me, the British OHSMS standard requirement (to appoint a member of the top managment about H&S) is clear. According with any other national OHSMS standards, or even the international standard ILO).

If this is a problem for certification, it is an additional problem (certification is not a requirement of these management systems standards).

But if a OHSMS of an entity is not clearly and obviously carried on at the top managment level, then it is initially and especially a problem of effectiveness to this management itself…: this situation is very conclusive that this direction is not involved in H&S domain (personal competences of the junior manager are not the question)!

On the other hand to give to this junior manager a OHSMS delegation letter to save appearances will not change anything with this fundamental problem.

Cordially.

Want the truth? From your statement above there is a definite lack of commitment with your top management and you'd be hard pressed to find an honest/competent lead auditor that wouldn't issue a major in this case.

This is a self inflicted non-conformity and you can get as mad as you want, but not at the auditor or certification body.

Until you get your management problems honestly and truly rectified you need to set this quest aside. If you find an auditor and certification body that won't issue a major in a case like this the true value of your certificate could be questionable and Sidney is correct....You wouldn't deserve the certificate. These things aren't made to be bought and sold and you wouldn't find my name attached to it.
Management Representative not part of Top Management
In my company I have to work in two activities, which they exercise at the same time:
1. Piping designer
2. Management Representative .I am the only person involved in the quality of the company at a total of 60 employees.

QMS was certified recently, but auditors were afraid to require evidence that MR is a member of the management company.
Is my situation a major Non-Conformance for QMS?
I would like know your judgement.
What I have to do for the future?