OHSAS 18001 Participation and Consultation - Incident investigation under 4.4.3.2

L

lalita1234

#1
Hello

Auditor created non conformance. He says there is no participation of workers in incident investigation under 4.4.3.2

What is the Health and Safety Officer and Worker supervisor required to do and show to resolve this.

Thanks
Lalit
 
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Jen Kirley

Quality and Auditing Expert
Staff member
Admin
#2
Welcome to the Cove! :bigwave:

Since I have the view point that process-level people can understand an issue better than anyone else, I can appreciate your auditor expecting to see involvement of personnel at the level where the incident occurs.

However, the standard does not specifically state operations-level people will be consulted in incident investigations, so if I was in your place I would feel I could argue the NC was invalid.

That said, while I do not see an outright nonconformity it does certainly seem like an opportunity. It makes me want to ask, how your employees are otherwise consulted? If they are consulted in the Risks and Hazards Assessment development and that is, in fact done as a step in each incident investigation and action, (hint hint) a person could argue the employees are a part of the process.

I hope this helps!
 
R

Reg Morrison

#3
Welcome to The Cove, Lalit.

Auditor created non conformance.
Did you mean to say that the auditor REPORTED a nonconformity? Most of the time, auditors do not create a nonconformity, but observe and report it.
He says there is no participation of workers in incident investigation under 4.4.3.2

What is the Health and Safety Officer and Worker supervisor required to do and show to resolve this.
For those who do not have access to the OHSAS 18001:2007 document, the paragraph in question reads:
4.4.3.2 Participation and consultation
The organization shall establish, implement and maintain a procedure(s) for:
a) the participation of workers by their:
• appropriate involvement in hazard identification, risk assessments and determination of controls;
appropriate involvement in incident investigation;
• involvement in the development and review of OH&S policies and objectives;
It is hard to pass judgement on the adequacy of the nonconformity without knowing the evidence that the auditor collected before reporting it. Were there instances of repeat incidents?

Those who are familiar with the techniques behind incident investigation know that YOU MUST not only interview the people involved, but you must do it in a timely manner, as well. Without knowing more about the specifics, I would tend to agree with the auditor and insist that, without involving the actual workers in incident investigations, not only you fail to comply with the OHSAS 18001 standard, but, and even worse, have a VERY ineffective incident investigation process.

As for the solution, I would highly recommend you (and selected colleagues) attend an incident investigation course and put the learning to use.

Good luck.
 

somashekar

Staff member
Super Moderator
#4
Hello

Auditor created non conformance. He says there is no participation of workers in incident investigation under 4.4.3.2

What is the Health and Safety Officer and Worker supervisor required to do and show to resolve this.

Thanks
Lalit
Welcome to the Cove lalit ~~~
The intent of the standard is very clear.
That you have to involve the workers, the hands on working people in the hazard identification, risk assessments and determination of control.
What is to be done to show (I would say the method) is simple.
Involve the workers.
How ?
Talk with them in their language, at the workplace.
Understand their point of view and consider it in the hazard identification.
Educate them about the OHSAS policies and objectives so as to bring about voluntary participation and therefore the ability to appreciate the controls that are put in place. The control methods are therefore not thrust upon them by someone else, but they become an output of their own involvement. Their ideas and view points are considered.
Record them and have them sign off too.
Selected workers from the place of work or the involvement of the workers union members (if there is one) are the simple ways to go.
You have a valid NC to work and bring about a CA process.
 
L

lalita1234

#6
Hi

Thank you very much to Jennifer, Reg and Somasekhar for your valuable replies.

To clarify some of the queries above, I received an email from Management Representative's Assistant informing that a minor non-conformity has been raised by auditor at recent external audit. The MR raised a CPAR on his assistant. MR's assistant accepted the CPAR and forwarded to me asking me to select a team. MR assistant said he is the team lead on the system and he will close the CPAR in the system on my behalf once I have a team selected and action taken. There is an Incident/Accident Reporting process and MR who is the QA Director is the process owner. I do not know who was audited for this process but is sent to me as a CPAR. The incident/accident reporting process states that Supervisor will inform the workers etc.

Sorry to sound complicated. Is the process owner responsible to follow the process and if it covers worker participation then follow it. Otherwise, alter the process to include worker participation?

Thanks
Lalit
 

kgott

Quite Involved in Discussions
#7
Hello

Auditor created non conformance. He says there is no participation of workers in incident investigation under 4.4.3.2

What is the Health and Safety Officer and Worker supervisor required to do and show to resolve this.

Thanks
Lalit
If you have health and safety representative elected by the workforce then get them involved. Otherwise get workerswho do similar work involved in the investigation, identification of root cause and development of the corrective action so that the knowledge spreads and is thereby embeded into the workforce and management system controls for that hazard.
 
#8
One obvious way to keep this in focus is the management review: The state of the company/workforce cooperation and how it worked out should be part of the agenda.

/Claes
 
R

Reg Morrison

#9
Otherwise get workerswho do similar work involved in the investigation, identification of root cause and development of the corrective action so that the knowledge spreads and is thereby embeded into the workforce and management system controls for that hazard.
When I attended incident investigation courses, the strong suggestion was for the ACTUAL people involved in the incident to be interviewed, as promptly as possible, following the incident. The people involved in the situation are the ones that can really provide factual information (even though biased) about the occurrence.

Trying to communicate with other workers transitions the situation from an incident investigation to failure mode speculation and there is a big gap between the two.
 

TPMB4

Quite Involved in Discussions
#10
Possibly a bit of an aside, what do your relevant procedures say? All the good advice above I cannot possibly improve on but is there possibly a higher level issue here too (if higher level is the correct phrase? What I mean is, this NC has come about and you can correct this by incident investigation involving the actual operators involved as said previously, but if that is not in the procedures then is this NC also about the procedures not being up to scratch. If I recall you said the owner is the MR / Quality Director. If he/she has passed it down the chain to you then he/she might have missed picking up on his opportunity for improvement of the system's procedures (his procedures as owner).

Just an idea but of course telling your boss (or boss's boss) he/she needs to sort it might not be diplomatic. Better use the system to flow it back perhaps?
 
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