OHSAS 18001:2007 Section 3 - Controlling Work Place Risks


Rabab Salah

Good Day,

Reference to section 3 in OHSAS 18001:2007
work place is defined as below:

any physical location in which work related activities are performed
under the control of the organization
NOTE When giving consideration to what constitutes a workplace, the
organization (3.17) should take into account the OH&S effects on
personnel who are, for example, traveling or in transit (e.g. driving,
flying, on boats or trains), working at the premises of client or customer,
or working at home.

Could you please help clarifying
1. how can an organization control risks at employee home?
2. how can an organization control risks at customer premises?
3. how can an organization control risks associated to employee transportation from working site to home and vice versa?

Have a great day
Many thanks in advance,

Jen Kirley

Quality and Auditing Expert
Good day Rabab,

There are limits to risk control away from the organization's premises, which is why 3.17 stipulates "under the control of the organization." The word "control" was not used in that clause to indicate risks away from the workplace must be controlled. Some things really are out of our sphere of influence. The Notes are therefore added to provide guidance, but are not "shalls." Merriam-Webster defines consideration as:

  • careful thought: the act of thinking carefully about something you will make a decision about
  • something that you think about when you make a choice or decision
That said, there is an expectation of general "due care" so some things might be done, such as:

- Supply personal protective equipment for working at home or traveling to clients
- Review the home office with the work-from-home employee to determine if electrical supply is sufficient and safe, if ergonomic improvements can be made, and make arrangements to assist with the improvements where practical.
- If an employee is using a taxi or other hired mode of transportation, the organization can review the provider's safety performance and provide policy or guidance resulting from their findings.
- If the employee's personal vehicle is unsafe, the organization could consider providing hired transportation.

I hope this helps!
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Quite Involved in Discussions
Much of this will be down to the assessed risks. Start by assessing the risks posed to people in certain situations, then use the hierarchy of control in clause 4.3.1 (right near the end) to determine the best way of reducing the risks to a tolerable level.

Jen is absolutely correct in saying that there are some things outside of our control too. An example of a simple control is to set policies for activities to protect people from themselves e.g. your company might have a policy that bans people from using mobile phones whilst driving - hands free or not.

Steve Prevette

Deming Disciple
Super Moderator
"Tele commuting" is definitely something that stretches a company's risk. For example, see this link https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=2254 for OSHA policy on home workplaces.

"OSHA respects the privacy of the home and has never conducted inspections of home offices. While respecting the privacy of the home, it should be kept in mind that certain types of work at home can be dangerous/hazardous. Examples of such work from OSHA's past inspections include: assembly of electronics; casting lead head jigs for fishing lures; use of unguarded crimping machines; and handling adhesives without protective gloves."

However, I assume it would be looked on poorly if an employer of a significant number of data entry clerks says "I am not going to provide you a workplace or proper ergonomic equipment - work out of your house and figure it out". Although, I am sure that sort of thing de facto goes on now.

I can definitely tell you employers are "on the hook" to report injuries that occur while on assigned travel, though the commute from house to worksite is not reportable.

More from OSHA:


Section 1904.5(b)(7) states: How do I decide if a case is work-related when the employee is working at home? Injuries and illnesses that occur while an employee is working at home, including work in a home office, will be considered work-related if the injury or illness occurs while the employee is performing work for pay or compensation in the home, and the injury or illness is directly related to the performance of work rather than to the general home environment or setting. For example, if an employee drops a box of work documents and injures his or her foot, the case is considered work-related. If an employee's fingernail is punctured by a needle from a sewing machine used to perform garment work at home, becomes infected and requires medical treatment, the injury is considered work-related. If an employee is injured because he or she trips on the family dog while rushing to answer a work phone call, the case is not considered work-related. If an employee working at home is electrocuted because of faulty home wiring, the injury is not considered work-related.

This is why some employers do not allow tele-commuting.
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