Mandatory Documented Procedures in OHSAS 18001?

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Bilijaf

#1
Hi,
I am getting confused about what are the mandatory documented procedures in OHSAS 18001. We found at different places in the standard that procedures should be "identified and maintained'', i do not know if that will lead to the fact that these should be documented.
Please advice
 
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Jen Kirley

Quality and Auditing Expert
Staff member
Admin
#2
Re: Documented Procedures in OHSAS 18001?

Hi,
I am getting confused about what are the mandatory documented procedures in OHSAS 18001. We found at different places in the standard that procedures should be "identified and maintained'', i do not know if that will lead to the fact that these should be documented.
Please advice
Good morning, happy May!

Randy can answer this better than I can - in fact, it's possible that one of the related threads linked at the bottom of this page already covers this, as I recall it's been discussed before.

However, I will tell you how I describe it to my customers:

In general, "process" can be written or unwritten - a way we do things that's regular and defined somehow. Procedure implies it's written.

But that isn't the end of the story:

  • 18001 does include specific references to documentation, for example the OH&S Objectives and Programs referred to in 4.3.3.
  • In order to describe and show results of needed processes like identifying risk in 4.3.1, we generally need something written; otherwise it can be rather awkward during registration audits.
  • It can be pretty hard to plan, execute and evaluate improvements when something isn't documented in any way so we can refer to them, control the activities and keep consistency among groups. So, beyond where specifically mentioned in 18001, documentation should be established to the extent it facilitates the activities your organization uses to establish and maintain an effective management system.
I hope this helps!
 
S

samsung

#3
Re: Documented Procedures in OHSAS 18001?

Hi,
I am getting confused about what are the mandatory documented procedures in OHSAS 18001. We found at different places in the standard that procedures should be "identified and maintained'', i do not know if that will lead to the fact that these should be documented.
Please advice

OHSAS mandates only one documented procedure "to cover situations where their (documents related to control of operations associated with identified hazards) absence could lead to deviations from the OH&S policy and the objectives".

If the 'absence' of documented procedure doesn't lead to any deviation whatsoever, such a procedure need not be documented.

If documenting a procedure helps to achieve the OHS objectives or improving the OHS performance, they must be documented.
 
Last edited by a moderator:
B

Bilijaf

#4
Re: Documented Procedures in OHSAS 18001?

Thanks for the clarification.
But the ISO 9001 indicates to have documented procedures at 6 different places, why the same concept is not applicable by OHSAS 18001?
 

Sidney Vianna

Post Responsibly
Staff member
Admin
#5
Re: Documented Procedures in OHSAS 18001?

OHSAS 18002:2008 stipulates:
The organization should maintain up-to-date documentation that is sufficient to ensure that its OH&S management system can be adequately understood and effectively and efficiently operated. Typical inputs include the following items:

details of the documentation and information systems the — organization develops to support its OH&S management system and OH&S activities, and to fulfil the requirements of OHSAS 18001,

details of responsibilities and authorities, — information on the local environments in which documentation — or information is used, and constraints that this can put on the physical nature of documentation, or the use of electronic or other media.

The organization should review its documentation and information needs for the OH&S management system, before developing the documentation necessary to support its OH&S processes. In deciding what documentation is required the organization should determine where there is any risk that a task, through lack of written procedures or instructions, will not be performed in the required manner.
There is no requirement to develop documentation in a particular format in order to conform to OHSAS 18001, nor is it necessary to
replace existing documentation such as manuals, procedures, or work instructions where these adequately describe required arrangements. If the organization already has an established, documented OH&S management system, it can prove more convenient and effective for it to develop, for example, an overview document describing the inter-relation between its existing procedures and the requirements of OHSAS 18001. Account should be taken of the following:

the responsibilities and authorities of the users of the — documentation and information, as this should lead to consideration of the degree of security and accessibility that needs to be imposed (particularly with electronic media) and change controls (see [FONT=Frutiger 45 Light,Frutiger 45 Light][FONT=Frutiger 45 Light,Frutiger 45 Light][FONT=Frutiger 45 Light,Frutiger 45 Light]4.4.5[/FONT][/FONT][/FONT]),

the manner in which physical documentation is used, and the — environment in which it is used, as this can require consideration of the format in which it is presented (e.g. an instruction could be incorporated into a sign rather than a paper document). Similar consideration should be given concerning the environment for the use of electronic equipment for information systems.
 
S

samsung

#6
Re: Documented Procedures in OHSAS 18001?

Thanks for the clarification.
But the ISO 9001 indicates to have documented procedures at 6 different places, why the same concept is not applicable by OHSAS 18001?
Very good question ! All those things are also required to be earnestly followed while maintaining an OHS management system even though their 'documentation' isn't mandatory in OHSAS (also in 14K). I can't guess why ? Let's see what OHSAS itself says about (lack of) documentation :
NOTE: It is important that documentation is proportional to the level of complexity, hazards and risks concerned and is kept to the minimum required for effectiveness and efficiency.
Let's wait for other Covers.
 

Randy

Super Moderator
#7
Re: Documented Procedures in OHSAS 18001?

So far so good but there is one small final piece to the puzzle...


4.4.4 Documentation... e) documents, including records, determined by the organization to be necessary to ensure the effective planning, operation and control of processes that relate to the management of its OH&S risks.


NOTE It is important that documentation is proportional to the level of complexity, hazards and risks concerned and is kept to the minimum required for effectiveness and efficiency.


In the end, if the organization can prove that it can effectively plan, operate, control processes and control risk, not deviate from policy committments, and achieve its objectives it doesn't "HAVE" to have any documented procedures other than what might be called for by law or in oder for it to meet an "other" requirement.

BUT, if deviation is identified, effective control and all that other stuff not performed and objectives not met, the organization will be hard pressed to not have those things pointed out to them in the form or nonconformity issuance from whoever audits them, especially a CB.
 
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ChrissieYorks

#8
I also have a query about documenting procedures in both 18001 and 14001. My current certfication body is insisting that we document procedures for just about every clause in these two standards irrespective of whether the standard asks for a documented procedure. For example 4.5.1 states the organisation shall establish, implement and maintain a procedure(s) to monitor and measure OH&S performance on a regular basis. It does not specify 'document a procedure'.

Is anyone else getting the same reaction from their CB's?
 
B

Boingo-boingo

#9
My current certification body is insisting that we document procedures for just about every clause in these two standards irrespective of whether the standard asks for a documented procedure.
When a CB shows lack of understanding on something as simple as the difference between having a procedure and the need for the procedure to be documented, you should ask yourself if they deserve your continuing business.

But, are you talking to someone at the CB or an auditor? In principle, an auditor representing a CB should know the CB's policies about something such as this, but, in my experience, that is not always the case. Sometimes, the auditor does not bring the issue up to a CB technical person, and you, the registrant believes that the auditor's position represent the CB's.

Make sure you bring the issue up. Some magic words such as "I might be bringing my business elsewhere"...tend to make CB's extra responsive and understanding...
 
S

samsung

#10
I also have a query about documenting procedures in both 18001 and 14001. My current certfication body is insisting that we document procedures for just about every clause in these two standards irrespective of whether the standard asks for a documented procedure. For example 4.5.1 states the organisation shall establish, implement and maintain a procedure(s) to monitor and measure OH&S performance on a regular basis. It does not specify 'document a procedure'.

Is anyone else getting the same reaction from their CB's?
You may once again wish to go through Randy's post # 7. I guess that the auditor might have noticed symptoms of inconsistencies owing to lack of documentation and thus might have advised to document the procedures to avoid any potential nonconformity.
 
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