Work Environment - ISO 9001 Clause 6.4 vs. OSHA Requirements

[NAVYBILL]

A question seeking opinions:

Scenario: Company utilizes safety procedures as part of it's satisfaction for ISO 9001 Clause 6.4 "Work Environment".

From an Auditing Standpoint-

Question: When auditing the current system in place, (e.g. lock-out tag-out procedure) do I look at the contents strictly as ISO or at the regulatory (OHSA) requirements. As I know there are major flaws to the procedure based the OSHA regulation.

To me, auditing both ISO clauses 6.3 and 6.4 is difficult due to the generality of the clauses. I believe that the Health and safety procedures should be independent of the ISO Management system. You can still discuss human or physical factor within ISO Management System clause 6.4 in a generality manner.

 

[pilchard]

Just reference your HSE or Safety manual

 

[NAVYBILL]

Thank you for your reply, While I agree I could ref. the HSE., I would still be subject to the contents. If the contents have flaws to the OSHA regulatory requirements, but I am following the procedure to what is written within ISO 9001 (DOCUMENT WHAT YOU DO, DO WHAT YOU DOCUMENT AND PROVE IT...), during an ISO audit would the process conforming or not based on other regulatory requirements discussed?

 

[Reg Morrison]

Read section 0.4 of ISO 9001:2008 and you will realize that ISO 9001 does not involve itself with occupational health and safety. So, sections 6.3 and 6.4 of the standard have requirements concerning how the work environment affects PRODUCT QUALITY.

Lock-out, tag-out has nothing to do with product quality.

Having said that, ISO 9001 is not say what you do, do what you say. That is an over simplistic, archaic, dumb-down approach. ISO 9001 is based on the PDCA approach.

Progressive organizations develop and audit their processes in a holistic way and don't compartmentalize disciplines when assessing the health and effectiveness of their systems.

 

[somashekar]

Thank you for your reply, While I agree I could ref. the HSE., I would still be subject to the contents. If the contents have flaws to the OSHA regulatory requirements, but I am following the procedure to what is written within ISO 9001 (DOCUMENT WHAT YOU DO, DO WHAT YOU DOCUMENT AND PROVE IT...), during an ISO audit would the process conforming or not based on other regulatory requirements discussed?

NAVYBILL...Welcome here to the COVE.
There are two sides to your issue.
The ISO 9001 side: Keep to your documents that covers your HSE requirement.
The Bigger side: As an organization you are aware of the gaps between OSHA regulatory requirement, and your procedure and practice.
Regulation does not care if you have a OHSAS 18k system or not, for not following the laid down regulations. So take it up as a project and bridge the gaps suitably to your organization size. This does not need an ISO 9001 observation to trigger.
On the larger side your OSHA requirements will be addressed suitably, strengthening your ISO 9001 system

 

[pilchard]

Yes if your HSE system is based on and references OSHA, if your HSE system is just good practices and uses OSHA requirements, to improve the work environment and you can reference your TRIR (total recordable incident rate -osha recording standard) as proof that the system works or not to your goal - instead of trying to meet every OSHA regulation which is virtually impossible.

If HSE doesnt look good look at Human resources for benefits, education, training that improve the work environment that effect the quality your product or service.

 

[NAVYBILL]

Read section 0.4 of ISO 9001:2008 and you will realize that ISO 9001 does not involve itself with occupational health and safety. So, sections 6.3 and 6.4 of the standard have requirements concerning how the work environment affects PRODUCT QUALITY.

Lock-out, tag-out has nothing to do with product quality.

Having said that, ISO 9001 is not say what you do, do what you say. That is an over simplistic, archaic, dumb-down approach. ISO 9001 is based on the PDCA approach.

Progressive organizations develop and audit their processes in a holistic way and don't compartmentalize disciplines when assessing the health and effectiveness of their systems.

While I agree lockout tag-out has nothing to do with product quality. The company has a written QMS that uses these procedures as part of ISO 9001 Clause 6.4. and taken a different approach. (while neither of us agree to this approach, it is their system) So essentially these documents need to audited as part of that clause . My question I guess was more towards the disconnect of the procedure to the OSHA requirements. which was answered in a later post.

 

[John Broomfield]

The work environment must be conducive to quality services and products. Workers who feel unsafe are unlikely to find this aspect of their work environment conducive to quality.

...so by all means cite your health and safety management but more controls may be required for confidence that quality requirements will be fulfilled.

 

[Frankie11]

You don't have to only audit to ISO 9001. If you're concerned about the gaps between what you're company is doing and what the law says it must, perform an audit against relevant OHS legal clauses.

 

[Big Jim]

If it were me, I would not include the HSE topics in your quality management system.

That does not mean that they are not important, they are, but so are financial considerations, and finance is rarely included in the quality management system.