OHSAS Cl 4.4.3.2 & 4.4.6a - Please guide me in its interpretation

[Zubin]

Hi, Thought to address a similar situation I am in now..

We are proceeding with the certification - a combined certification on OHSAS and EMS. We are doing the entire certification process of our own and dont have a consultant in between. After the Aspect - Impact - Risk assessment, we started off with procedures. Listed down all the required procedures as per standards. Almost alla re ok, but 2 of them seems little difficult to understand. I request the experienced members to guide me in this context

1. Clasuse 4.4.3.2 (OHSAS) - Reporting: A procedure shall be establisehd for reporting. I can understand that an incident reporting mechanism is required and the procedure by which it works needs to be documented, but is it all what is needed here??

2. Clause 4.4.6.1(OHSAS) - Design and Engineering control. How far wil be this different from Operational control?. Is it mandated to have a separate procedure or shall it be a combined one with Operational Control?

Appreciate if you could spare some time in helping me..

Thanks in Advance

Zubin

 

[harry]

Welcome to the Cove.

I moved your post to a new thread to enable it to receive maximum attention.

I believe you are referring to Cl 4.4.6a instead of 4.4.6.1 as posted. I will leave it to the experts in this area to extend their help. Meanwhile, check the OHSAS forum for previous discussions. Example: 4.4.3.2 and 4.4.6

 

[somashekar]

Hi, Thought to address a similar situation I am in now..

We are proceeding with the certification - a combined certification on OHSAS and EMS. We are doing the entire certification process of our own and dont have a consultant in between. After the Aspect - Impact - Risk assessment, we started off with procedures. Listed down all the required procedures as per standards. Almost alla re ok, but 2 of them seems little difficult to understand. I request the experienced members to guide me in this context

1. Clasuse 4.4.3.2 (OHSAS) - Reporting: A procedure shall be establisehd for reporting. I can understand that an incident reporting mechanism is required and the procedure by which it works needs to be documented, but is it all what is needed here??

2. Clause 4.4.6.1(OHSAS) - Design and Engineering control. How far wil be this different from Operational control?. Is it mandated to have a separate procedure or shall it be a combined one with Operational Control?

Appreciate if you could spare some time in helping me..

Thanks in Advance

Zubin

Hi Zubin.
4.4.3.2 is about participation and consultation. I see no reporting here. It is about your OHSAS implementation and operation, concerning participation and consultation.
How you :
1. get your workers to be active and involved people in your OHSAS
2. consult with contractors when any changes could effect the contractor's OHS
needs to be established and implemented

4.4.6.a) is about the operations controls that are established in the implementation and operation of your OHSAS, for those operations and activities where hazards are identified and risks are managed by these controls.

Design and engineering controls are the OHSAS planning activities where you are to determine controls based on the top down hierarchy of ...
Elimination:
Do not do that operation or activity thereby get rid of the hazard and risk.
If not then ...
Substitution:
Do an other operation or activity in place of the one having some hazards and risks, thereby those hazards and associated risks gets removed and some new and lesser hazards and risks are coming in.
If not then ...
Engineering controls:
Bring in some foolproofing, sensing and activation to prevent harm, hands free operation, any other innovative and practical solution so as to manage risks.
If not then the rest as said in d) and e) and these two are mostly applied together.

 

[samsung]

1. Clasuse 4.4.3.2 (OHSAS) - Reporting: A procedure shall be establisehd for reporting. I can understand that an incident reporting mechanism is required and the procedure by which it works needs to be documented, but is it all what is needed here??

OHSAS does not stipulate any requirement for incident reporting. However, it does require a procedure "to record, investigate and analyse incidents" but not necessarily a documented one although a documented procedure is always better than a non-documented one. You may wish to refer to the attached document for guidance on incident investigation and reporting.

2. Clause 4.4.6.1(OHSAS) - Design and Engineering control. How far will be this different from Operational control?. Is it mandated to have a separate procedure or shall it be a combined one with Operational Control?

Design controls are the built-in controls that a machine/equipment/building must have and are considered at the time of system (plant) design. e.g. an industrial fan equipped with a safety guard and/or a silencer, a hoist with 1.5 times the load bearing capacity than the max. working load, car windshields with 'toughened safety glass' etc. etc. Design controls are generally mandated by the law or standards.

Engineering controls are infact physical & technological controls applied when the existing design controls are not sufficient to mitigate/ control the risk and additional physical controls are required to be put in place. e.g. speed retarders/ beakers on the roads, hand railings, toe guards, putting up water sprinklers along haul roads, sound enclosures, cooling & ventilation systems etc.

Operational Control means controls applied to operations/ activities where hazards have been identified. They can be administrative or engineering, signage & warnings, access control, use of safe work procedures/ MSDS etc.

 

[Zubin]

Thanks Somashekar,

We purchased the standard IS 18001:2004 from BIS (Bureau of Indian Standards). Now I coudlsee that there is marked didfferences in the clauses. For eg: 4.3.1 in the BIS standard refers to Initial OHS Review, which I am sure is not part of the standard as a separate clause. While 4.4.3.2 in BIS refers to "Reporting" (quote: The org shall establish, implement and maintain documented procedures for relevant and timely reporting of .....) but in the other ones it is Participation and consultation. Can this be possible?. I understand that OHSAS being a non ISO standard, there can be different interpretations. But how far is this acceptable?. Are we using a wrong standard (guidance)

As a new entrant may be I am thinking too much...Kindly give your suggestions/guidance..

Thanks

Zubin

 

[Zubin]

Thanks Samsung,

I got a fairly good understanding now. I am stariting off now. But the basic question of BIS Standard or Gudelines for OHSAS is still persisting. I will wait for the answers.

Right now, the below are the procedures which are identified.. Hope this will suffice and will justify..

1 Hazard Identification, Risk Assessment and Risk Control
2 Identification of Legal and Other requirements
3 OH&S Objectives, Targets and Programs
4 Roles, Responsibility, Accountability and Authority
5 Competence Training and Awareness
6 Communication - Internal and External
7 Incident Reporting and Investigation
8 Control of Documents and Records
9 Operational Control
10 Design and Engineering control
11 Emergency Preparedness and Response
12 Performance Measurement and Monitoring
13 Calibration and Maintanance of Measurement equipments
14 Evaluation of Compliance (Legal and Others)
15 Accident, Incident Non Confirmance, corrective action and preventive action
16 Internal Audit and Management Review

Thanks once again,

Zubin

 

[Zubin]

Thanks Harry for guidance.. Have a little confusion on the respective clauses in the guidelines we have purchased..

 

[somashekar]

Thanks Somashekar,

We purchased the standard IS 18001:2004 from BIS (Bureau of Indian Standards). Now I coudlsee that there is marked didfferences in the clauses. For eg: 4.3.1 in the BIS standard refers to Initial OHS Review, which I am sure is not part of the standard as a separate clause. While 4.4.3.2 in BIS refers to "Reporting" (quote: The org shall establish, implement and maintain documented procedures for relevant and timely reporting of .....) but in the other ones it is Participation and consultation. Can this be possible?. I understand that OHSAS being a non ISO standard, there can be different interpretations. But how far is this acceptable?. Are we using a wrong standard (guidance)

As a new entrant may be I am thinking too much...Kindly give your suggestions/guidance..

Thanks

Zubin

You are just doing fine. These mix-up do happen and then clarity makes things easy.
You must be pursuing towards certification to OHSAS 18001:2007 in which case this stated OHSAS standard is the standard to align with. This and the BIS standard IS18001:2004 can differ as they are from seperate bodies, though they contain common elements.

 

[Zubin]

Yes we are going for OHSAS 18001:2007 and the BIS standard we purchased is IS18001:2007. Now I feel I shall get one direcly from OHSAS project group or so to avoid confusion..
Zubin

 

[samsung]

I got a fairly good understanding now. I am starting off now. But the basic question of BIS Standard or Guidelines for OHSAS is still persisting. I will wait for the answers.

OHSAS 18001:2007 is the only standard you must concentrate on since it's a certifiable standard whereas IS 18001:2004 is a specification (like previous version of OHSAS) although you may seek guidance from other documents such as ILO-OSH, IS 18001:2004, ILO codes of practices etc.

I would advise you to have a copy of OHSAS 18002:2008 which do contain all the requirements of OHSAS 18001 plus a lot more on how to implement it.

Thanks.