Implementing an OHSMS — a Consultant's Viewpoint

Occupational health and safety appears to have no logical beginning or indeed end, which can deter companies from adopting a systematic approach. When considering the development and implementation of a health and safety management (HSM) system, many companies are surprised that they already have many of the components in place that would constitute such a system.

This paper considers the following:

  • Pressures on the employer
  • Benefits of a health and safety management system
  • Elements of a health and safety management system
  • Back to policy
  • Getting started
  • Planning
  • Safety management programme
  • Performance measurement and monitoring
  • Management review
  • And finally

This article has been written by Colin Rider FIOSH, RSP, and director of health, safety and environment consultancy, Messam and Rider Ltd. For further information please visit

  • www.SaferOption.com

A regulatory framework

A regulatory framework

Moving away from industry specific, fragmented law, the first significant piece of holistic health and safety legislation introduced into the UK was the Health and Safety at Work etc. Act 1974 which established a statutory requirement that was the same for all employers, irrespective of the activities being undertaken.

The Act introduced a broad brush approach to health and safety, referred to as “goal setting” legislation which required employers to adopt a reasonably practicable approach to the management of health and safety, the decision of what to do and how far to go primarily lay with them, relative to their risks.

A radical part of the Act was the requirement for employers to produce a health and safety policy which set out a statement of intent for health and safety and established the organisational roles and responsibilities necessary to fulfil the intentions to implement the arrangements for putting policy into practice which helped lead to a gradual reduction of workplace injuries during the 1970’s and 80’s.

The next significant milestone was the HSE’s guidance document “Successful Health and Safety Management” (HSG 65) in 1991. This contained advice and examples of best practice for employers to adopt in order to manage health and safety to the same standards as other core business activities. The guidance provided an outline structure for managing health and safety, comprising:

  • Policy
  • Organising
  • Planning and implementation
  • Monitoring
  • Review, and
  • Audit

The adoption of European Directives in the early 1990’s saw the further development towards the need to employ a health and safety management system. The European derived Management of Health and Safety at Work Regulations ,not only overlapped many of the concepts of the Health and Safety at Work etc. Act but also introduced a more explicit requirement for the need for the management of health and safety. Formal risk assessments became a legal requirement as did arrangements for health and safety, which were to include the necessary planning, organisation, control and monitoring of a HSM system.

While HSG 65 suggested the content for each element of a health and safety management model, it did not include a structured auditable approach. However, it was at this time that British Standards published A Guide to Occupational Health and Safety Management Systems (BS 8800), a forerunner to OHSAS 18001. This document took the structure of ISO 14001 and the safety components of HSG 65 combining them into a certifiable health and safety management system.

Pressures on the employer

Pressures on the employer

“As far as I am concerned, those who cannot manage health and safety, cannot manage. We need to create a positive health and safety culture which sees business go beyond doing the statutory minimum.”

Bill Callaghan, Chairman of the Health and Safety Commission

The need for a certifiable health and safety management standard became more apparent at the end of the 1990’s, with the introduction of reforms, initiatives and strategies including:

  • The Woolf Reforms of Civil Justice
  • The Turnbull Report on Corporate Governance
  • Revitalising Health and Safety

The Woolf reforms addressed concerns with the cost, delay and fairness of claims for compensation arising out of injuries. A significant change was that in the event of an employer choosing to deny liability for a workplace injury, the need to disclose full documentary proof of denial within strict timescales became necessary. In such instances, the employer is required to demonstrate that they have arrangements in place to record information such as training, inspections, maintenance and accident investigation records, together with information storage and retrieval systems.

The adoption of the Turnbull Report by the stock exchange required stock market listed companies to produce and submit a business risk management plan, including records of health and safety management performance. In order to produce this plan, a full understanding of organisational risk is required in addition to the ability to demonstrate that control systems are in place to eliminate, reduce or mitigate risk.

Concerns with the lack of progress in the reduction of accidents at work during the 1990’s led, in June 2000, to the introduction of the Government Strategy: “Revitalising Health and Safety”. This 10 point strategy and 44 point plan set out the government’s 10 year vision for occupational health and safety, together with targets for accident and ill health reduction. In order to adopt such a strategy, an organisation will need to have achievable objectives set and the necessary monitoring and review arrangements by which to measure progress.

While significant improvements have been made since the days of prescribed legislation, the next step change could be achieved only by embracing the original goal setting vision of the Health and Safety at Work etc. Act and the principle of risk management.

The ability to demonstrate that health and safety is being systematically managed is also critical when considering proposals for future initiatives, including a draft Bill expected before the end of the current Parliamentary session on Corporate Killing, possible future legislation for directors responsibilities and increase in penalties for health and safety offences.

Benefits & Elements of a health and safety management system

Benefits & Elements of a health and safety management system

Promoting the benefits of a health and safety management (HSM) system enables an organisation to maximise buy-in to the system in order to minimise the risk of failure. With respect to HSM systems, the business case is often the most effective persuader amongst senior management and it encourages the integration of the HSM system within the overall business plan.

Accidents, incidents, collateral damage and ill health can be a major financial burden. Accidents not only affect the victims but can also affect business performance and competitiveness. This may include, for example, loss of production, sick pay and diversion of management time, in addition to not fulfilling orders, loss of customer confidence and reduction in employee effectiveness.

Consider also the risk of compensation claims, which if successful, may affect insurance premiums in addition to the obvious results of the consequences of enforcement action, which could have an adverse effect on business performance and the overall profitability of an organisation.

Success in business means getting things right across the spectrum of performance indicators, including finance, production and quality. Health and safety requires that people do things right, with the right equipment and follow the right procedures. Health and safety performance and business performance are therefore inextricably linked. By implementing a HSM, benefits emerge across the whole business as improvements are made in the way things are done. Quality, productivity, commitment and culture can all flourish in a safe working environment. By being able to demonstrate that risks are being managed and failure is minimised then business reputation is enhanced, providing marketing opportunities and improving success in securing tenders and contracts in an increasingly competitive world.

Elements of a health and safety management system

To be successful, a health and safety management system should have a systematic, cohesive structure which can meet the objectives of the organisation. OHSAS 18001 comprises the following elements:

  • Policy
  • Planning
  • Implementation and operation
  • Checking and corrective action
  • Management review
  • Continuous improvement

The similarities with HSG 65 are quite clear, although the requirements for a continuous improvement element is now included. However, to be manageable, auditable and certifiable, each element is broken down into the individual components of the system:

  • Policy
  • Planning
    • Risk assessment
    • Legal requirements
    • Objectives
  • Safety management programme
    • Implementation and operation
    • Structure and responsibility
    • Training, awareness and competence
    • Consultation and communication
    • Documentation
    • Document and data control
    • Operational control
    • Emergency preparedness
  • Checking and corrective action
    • Performance measurement and monitoring
    • Accidents, incidents and non-conformities
    • Records
    • Audit
  • Management review

Back to policy & getting started

Back to policy & getting started

When embarking on the implementation of a HSM system, the belief and commitment in the system must exist in order to adopt the overall goals and business plan of the organisation. As all roads lead from and to the health and safety policy, the policy should be re-visited in order to focus on the commitment already made at senior level within the statement of intent. It is likely that such a policy sets out objectives of a risk free environment or aims to ensure that people will not be injured as a result of work place activities. Such a commitment cannot be delivered unless a structured and measured approach is adopted.

Additionally, the senior officer who has signed the statement of intent in the policy, will need to be assured if, and how, the declaration within the policy is being fulfilled throughout the organisation, along with the arrangements for doing so.

Getting started

The first stage will be to carry out an initial review to ascertain the degree to which the components of the HSM system exist, and whether they are effective. This can be done internally or it may be appropriate to seek help from an external consultant.

In choosing a consultant, membership of the Institution of Occupational Safety and Health (IOSH) is essential, either a corporate member, (MIOSH) or a fellow member, (FIOSH) would be appropriate. Additionally, the consultant should be a registered safety practitioner (RSP). This demonstrates that they are on a continuous professional development programme (CPD), which is monitored by IOSH and is an indication that the consultant is regularly updating themselves in health and safety matters.

You should start with an overall aim of developing a system that will help achieve corporate objectives – and not just set out to gain certification.

To plan for health and safety requires a thorough understanding of hazards and risks. Risk assessments need to provide a detailed analysis of the organisation’s activities and recognise where injury could arise within those activities. By evaluating the effectiveness of existing control measures, the likelihood of injuries occurring from workplace activities and their resulting severity can then be assessed. This will enable the risk profile of the organisation to be established.

To decide if the current controls are adequate, a starting point will be - as an absolute minimum - compliance with the law and relevant guidance. Therefore, a register of legislation pertinent to the organisation needs to be compiled and employees should understand the relevant legal requirements to which they must adhere. It should also be recognised that legal compliance is a minimum standard and does not necessarily provide a risk free environment.

Safety management programme

A management programme for health and safety sets out day-to-day control strategies, which requires the responsibilities for health and safety to be established and personnel to be trained to fulfil their individual roles.

Working procedures need to be documented, available and up to date. Work methods and systems of work should be developed in consultation with the workforce, via safety committees, safety representatives or representatives of employee safety to enable requirements to be effectively communicated to all. This must also include any necessary procedures required to mitigate and manage the results of identified emergencies.

Performance measurement and monitoring

Performance measurement and monitoring

In order to demonstrate that objectives are being met (or otherwise), effective monitoring systems should be in place. These should be both active, for example, inspections and safety tours and reactive by measuring accident/incident and ill health performance and be followed by corrective actions, preventative measures and ongoing reviews. Performance measurement and monitoring activities should be recorded and records need to be made available and retrievable. Other records will also be required for both statutory purposes (such as inspections of lifting equipment, risk assessments and accident reporting forms), and records of internal activities such as training and maintenance. Again, these should be available and up to date.

Risk assessment results and records of safety monitoring will establish the ongoing organisational risk and give an indication of compliance with the HSM system. This should be audited internally at regular intervals to ensure that each step is being complied with and effectively managed, which will also prepare an organisation for an external certified audit, such as OHSAS 18001.

However, HSG 65 states that, while auditing is an essential part of the HSM system, it is no substitute for other parts of the system and that safety cannot be managed by audit alone. The success of a HSM system therefore depends on the day-to-day management of health and safety.

Management review & final thoughts

Management review & final thoughts

An organisation’s policy statement sets out its overall objectives and it is the starting point of the development of a HSM system. Once implemented a health and safety policy requires ongoing review by senior management in order to measure performance and progress.

A formal review, which should be recorded, will identify success in addition to any changes necessary to meet the objectives. Changes may be required to the overall policy objectives and other elements of the HSM system such as the resources necessary for its successful implementation. Such a review should also embrace the concept of continuous improvement as required in OHSAS 18001.

And finally

The objectives of developing and implementing a HSM system may vary, which will be dependant on the roles of individuals within an organisation. A HSM system may be seen by some to be necessary as part of a supply chain, to improve an organisation’s reputation, for example, in the fulfilment of sub-contracting tenders, to ensure legal compliance, to improve the financial viability of an organisation and most importantly to ensure that employees do not suffer adverse health or incur unnecessary injury by workplace activities.

However, the successful implementation of a HSM system cannot be left to a handful of individuals, such as safety advisers. The system should be integrated within the ethos of the organisation and be visible from top to bottom (and bottom to top), which all need to understand and willingly work towards.

Although this will require commitment and resources, the rewards and satisfaction of managing effectively the health and safety of individuals is an accomplishment that should be shared by everybody.