Company Structure for OHSAS Certification - Holding Company with Subsidaries

[SaintJK]

Hi Everyone,

Hope you can give me some expert advice.

We are a group of companies, i.e. one holding company and +- 40 subsidiaries. It's hard to keep count!

The shareholders have given a mandate for us to expand the business into the oil and gas (OGP) sector so we have been tasked to get OHSAS 18001 certification which is a standard requirement for contractors doing work in this industry.

We are now looking at the option of getting one of the smaller holding companies OHSAS 18001 certified, instead of the entire group. The plan is to sign OGP contracts through this company that will be 18001 certified to get the work. This company will be structured as lean as possible and all supporting services will be contracted in.

This will however mean that we will have to run 2x separate Health and Safety Management Systems (HSEMS). One HSEMS for the new company that meets OHSAS and OGP standards and the other will be the existing HSEMS that we have in place for the group. So we will use the OHSAS certified company and its HSEMS exclusively for OGP work.

The thinking behind this is that OHSAS will be too restrictive for operations in third world countries since the majority of our work is in Africa. It is not that we are being unsafe as the existing HSEMS meets our industry standards and we've had no serious accidents or incidents for the past 5 years.

We will implement OHSAS 18001 in the new company and the picture that will be shown to the certification body is one of a management company with minimum staff that outsources all of its services to third party suppliers, which may include its own subsidiaries.

What are your thoughts about doing it like I've explained above?

Thanks for your help.

 

[somashekar]

Re: Company Structure for OHSAS Certification

a) establish an OH&S management system to eliminate or minimize risks to personnel and other interested parties who could be exposed to OH&S hazards associated with its activities
Above is the first of the OHSAS applicability under the scope of OHSAS18k.
The third party suppliers including your own subsidiaries, come into other interested parties.
These are my thoughts..... Does your thought change now ?

 

[SaintJK]

Hi Someshka,

Thanks for the advice.

No it doesn't because the subsidiary company that will be OHSAS certified will comply with this requirement from the standard. So no problems setting it up in this way.

The only issue I see is running two separate HSEMS', i.e. one based on OHSAS and the other other the existing HSEMS for the rest of the group.

Cheers

 

[somashekar]

Hi Someshka,

Thanks for the advice.

No it doesn't because the subsidiary company that will be OHSAS certified will comply with this requirement from the standard. So no problems setting it up in this way.

The only issue I see is running two separate HSEMS', i.e. one based on OHSAS and the other other the existing HSEMS for the rest of the group.

Cheers

If it makes business sense to you, I do not see an issue...
People who manage OHSAS and the HSEMS at the separate holding companies must get familiar with the scope and the zone to where it applies. Learning from one can be taken into the other.
Good luck...

 

[SaintJK]

It will be the same HSE manager handling both HSEMS'.

 

[Paul Simpson]

Hi Everyone,

Hope you can give me some expert advice.

We are a group of companies, i.e. one holding company and +- 40 subsidiaries. It's hard to keep count!

The shareholders have given a mandate for us to expand the business into the oil and gas (OGP) sector so we have been tasked to get OHSAS 18001 certification which is a standard requirement for contractors doing work in this industry.

OK so far but I can predict you're not going to like the rest of my reply!

We are now looking at the option of getting one of the smaller holding companies OHSAS 18001 certified, instead of the entire group. The plan is to sign OGP contracts through this company that will be 18001 certified to get the work. This company will be structured as lean as possible and all supporting services will be contracted in.

So it looks to me as if you plan to tick a box and then bid for work. Please let me know if I have misunderstood.

Firstly the good news is that it is possible to certify a single company (holding or otherwise). It will also get your foot in the door with the industry.

Now the bad news : Any CB worth their salt will have to dig into the company structure and the deployment of the policy and system to contractors - it is a fundamental part of OHSAS 18001. See 4.2 f, 4.3.1 b, 4.4.3.1 b, 4.4.3.1 b, 4.4.3.2 b, 4.4.6 c,

This will however mean that we will have to run 2x separate Health and Safety Management Systems (HSEMS). One HSEMS for the new company that meets OHSAS and OGP standards and the other will be the existing HSEMS that we have in place for the group. So we will use the OHSAS certified company and its HSEMS exclusively for OGP work.

This is one area where you will likely run into problems. As you bring a contractor in you have to raise their game to 18001 level and then when they are off the job they 'can' lapse back to standard. The whole of the premise for Oil and Gas E & P contractors is that H & S is a cultural thing based around personal behaviours. Totally alien to the approach you are looking to adopt.

The thinking behind this is that OHSAS will be too restrictive for operations in third world countries since the majority of our work is in Africa. It is not that we are being unsafe as the existing HSEMS meets our industry standards and we've had no serious accidents or incidents for the past 5 years.

OHSAS is no more restrictive than any other effective H & S management system. Oil and Gas is but that is why the core element of an OH and S system is risk assessment.

We will implement OHSAS 18001 in the new company and the picture that will be shown to the certification body is one of a management company with minimum staff that outsources all of its services to third party suppliers, which may include its own subsidiaries.

What are your thoughts about doing it like I've explained above?

Thanks for your help.

Any procurement function from one of the 'Majors' will see through this in the blink of an eye ... or at least it should do.

My apologies if this sounds negative but I have spent my whole career looking to 'keep it real' and I don't get the feeling that is what you are trying to do.