CHAPTER 3: LEADERSHIP

3.1 Leadership and commitment (ISO 45001:2018, Clause 5.1)

It is now well established that OH&S is the responsibility of all employees in an organisation. ISO 45001 categorically requires senior management to demonstrate commitment, support and leadership towards its OHSMS. It considers senior management’s support and commitment as critical to the success of the OHSMS and its intended outcomes. The Standard places specific responsibilities and requires specific actions from senior management, including:

•Senior management should take overall responsibility and accountability for OH&S for preventing work-related injuries and ill health, and for providing safe and healthy workplaces. In many countries there may also be legal consequences if senior management fails to take sufficient measures to comply with these requirements. It must be stated that although senior management has the power to delegate authority and provide resources within the organisation, the ultimate responsibility for the OHSMS continues to lie with senior management. If the scope of the management system covers only a part of an organisation, then senior management is considered as those who direct and control that part of the organisation.

•It is the responsibility of senior management to ensure that the OH&S policy and OH&S objectives are established and implemented.

•It is the responsibility of senior management to ensure that the requirements of the OH&S system, such as hazard identification, risk assessment, application of controls, monitoring, audits and employee participation are integrated into all work processes.

•It is the responsibility of senior management to ensure that adequate resources are provided to establish, maintain and continually improve an organisation’s OHSMS. The list of resources needed for an effective OHSMS could include adequately trained and competent human resources, sufficient finances to procure OH&S-related tools and equipment, adequate and safe work spaces, provisions for measuring and monitoring, hygienic facilities, resources to implement ISO 45001 and resources to comply with regulatory requirements.

•Senior management also has the responsibility for communicating the requirements, procedures and practices relating to OH&S to all members of an organisation. This is to emphasise the importance of conforming to OH&S requirements, and the consequences that may result from not doing so. Trainings, regular briefings, toolbox talks, safety committee meetings, procedures, safety leaflets and posters may be some of the tools used for communicating these requirements.

Although the responsibility for achieving OHSMS outcomes has been given to senior management, the Standard does not define the mechanisms that may be adopted for achieving these outcomes. Intended outcomes of the OHSMS refer to prevention of injury and ill health, and provision of safe and healthy workplaces. These can of course be achieved by the rigorous and effective application of all the requirements of the Standard. Activities such as developing and promoting an OH&S-focused culture, and senior management seen as leading this initiative, have now been mandated by ISO 45001. This is necessary to demonstrate senior management’s leadership and commitment towards its OHSMS. An OH&S supportive culture refers to a culture where senior management encourages employees to follow OH&S requirements, cares for their health and well-being and promotes the achievement of OH&S objectives.

ISO 45001 clearly defines the task of directing and supporting employees to contribute towards the effectiveness of OHSMS as a responsibility of senior management. This may also be considered as an act of motivation, best performed when senior management is itself seen to be observing OH&S rules, participating in OH&S activities and promoting OH&S initiatives. This also includes giving active support to department heads and managers in performing their OH&S-related functions.

ISO 45001, like all modern management system standards, is based on the principle of the PDCA cycle. The Standard clearly articulates and assigns the responsibility for continual improvement of the OHSMS to senior management. Senior management are required to promote and ensure that the continual improvement of the OHSMS remains an ongoing endeavour of an organisation.

Often, workers are hesitant to report incidents, hazards, risks or deficiencies in the OHSMS for fear of reprisal from senior management. The Standard requires senior management to ensure that its workers are protected (and not blamed or penalised) in such situations. This can happen only when senior management lays down clear policies and procedures that protect workers from any reprisals for identifying OH&S-related shortcomings. An excellent proactive approach is to create incentives and rewards for those reporting incidents, hazards and near misses, or making suggestions that could result in further improvement to the OHSMS.

Senior management should also ensure that processes are established and implemented to enable workers’ participation in two-way consultation. This consultation is required at a number of occasions and for a number of reasons. Workers should be consulted for ongoing hazard identification, risk assessments, making new procedures, identifying workplace concerns, taking corrective actions, training needs and concerns relating to working conditions. Training, safety committee meetings, noticeboards, posters, daily briefings, toolbox meetings and participation in OH&S activities are routinely followed by most organisations as opportunities or channels for consultation with workers. ISO 45001 places the responsibility for establishment of health and safety committees on senior management. Senior management must support and promote the functioning of OH&S committees to ensure effectiveness of the consultation process with workers.

3.2 OH&S policy (ISO 45001:2018, Clause 5.2)

The responsibility for establishing, implementing and documenting an OH&S policy has been assigned to senior management. The OH&S policy is a mechanism by which senior management can formally articulate its commitment and vision regarding its OHSMS. It is an important document that outlines the overall vision, direction and commitment of senior management towards its OHSMS. In turn these values and commitments should be reflected in the processes and practices of an organisation.

Although an organisation may wish to state many of its views and visions in its OH&S policy, the following aspects (at a minimum) should be included to reflect the commitment and obligations of senior management:

•Senior management must state its commitment to provide safe and healthy working conditions.

•Senior management must express its commitment to the prevention of workplace injuries and ill health. As the nature of hazards and risks and their significance varies in every organisation, the OH&S policy must focus on those that are appropriate to the size and context of the organisation.

•The OH&S policy must provide a framework or basis for setting the OH&S objectives. An OH&S policy itself is not an expression of the OH&S objectives of an organisation. It does however set the major goals that could form the basis for an organisation to set its OH&S objectives.

•Compliance with legal requirements is mandatory for all organisations. The Standard requires senior management to make an upfront commitment to comply with all regulatory and other applicable requirements. This is to let it be known to all interested parties that an organisation’s senior management will not compromise when it comes to compliance to its legal obligations.

•The OH&S policy must include senior management’s commitment to eliminate hazards and reduce OH&S risks. This requirement is also embedded in the earlier requirement for providing safe and healthy working conditions and prevention of workplace injuries and ill health.

•The Standard requires that an organisation must make a commitment to continual improvement of its OHSMS. This is an important requirement as it impacts upon all components and processes of the OH&S system.

•The OH&S policy must include a commitment that an organisation will ensure consultation and participation of workers. In fact, it further requires a commitment for similar arrangements with worker’s representatives where they exist.

The OH&S policy must be approved, documented, periodically reviewed and made available (communicated) within an organisation. The intention here is to ensure that individuals are aware of senior management’s vision and direction relating to OH&S.

Putting together an OH&S policy is the responsibility of senior management within an organisation. To formulate an OH&S policy, senior management must know the nature and scale of its hazards and risks. This helps to establish a framework for OH&S objectives. The OH&S policy (after approval by senior management) must be communicated to all individuals within an organisation. This could be by providing training sessions on policies and procedures, video messages, posters displayed at prominent locations, ongoing briefings, newsletters, emails, etc. An organisation must ensure that the language used for communicating its OH&S policy and procedures is easily understandable by all personnel.

Having defined and communicated its OH&S policy, an organisation must periodically review the policy to ensure that it remains relevant and appropriate. ‘Management review’ is one such platform, which includes the review of the OH&S policy. The frequency of this review must be decided by the organisation itself.

3.3 An example of an OH&S policy