CHAPTER 4: ORGANISATIONAL ROLES AND WORKER PARTICIPATION
4.1 Organisational roles, responsibilities and authorities (ISO 45001:2018, Clause 5.3)
ISO 45001 places the responsibility on senior management to ensure that the roles and responsibilities for tasks relating to OHSMS are assigned and communicated to all concerned persons. The assigned roles and responsibilities are required to be maintained as documented information. ISO 45001 categorically states that although the responsibility and authority can be defined and assigned to all concerned levels and functions within an organisation, the final responsibility and accountability for the functioning of an OHSMS shall continue to reside with senior management. The final responsibility and accountability for OH&S cannot be assigned or transferred to others.
As well as assigning various responsibilities relating to OHSMS, ISO 45001 requires senior management to designate a competent individual to undertake certain specific OH&S functions. The tasks for such a designated individual are:
•To ensure that the OHSMS is established, implemented and maintained in accordance with the requirements defined by ISO 45001. This is a huge responsibility and calls for a high degree of understanding and coordination relating to various activities of the OHSMS.
•To report on the performance of the OHSMS to senior management. This can be as an ongoing exercise or at defined intervals. It is yet another critical responsibility that calls for considerable skills in coordination, measuring, monitoring, data collection and analysis.
Traditionally, an individual performing the above tasks is often referred to by various names such as ‘OH&S Management Representative’ or ‘OH&S Coordinator’. However, ISO 45001 suggests no name for this designation and simply requires the required tasks to be performed by the designated individual. A good understanding of the requirements of ISO 45001 and how they are applied in an organisation are crucial skills for the effective performance of this task.
4.2 Consultation and participation of workers (ISO 45001:2018, Clause 5.4)
The fact that ISO 45001 has mentioned more than once the need for consultation and participation of ‘workers’, suggests the importance the standard attaches to this activity. ‘Workers’ are defined as all those persons performing work or work-related activities under the control of an organisation, including senior management, managerial staff and non-managerial staff. Consultation and participation of workers is essential during the development, planning, implementation, performance evaluation and continual improvement stages of the OHSMS.
An organisation must perform the following tasks in order to meet the requirements of Clause 5.4 of ISO 45001:
•Defining processes for consultation and participation of workers at all levels, which include workers’ representatives where they exist. Defining a process would entail its description, linkages, responsibilities, mechanism, criteria, verification and timings. Consultation and participation are always a two-way process.
•Implementing and maintaining the above processes.
•Providing the time, training and resources deemed necessary for consultation and participation. This may include enabling workers to attend meetings, undergo training sessions or participate in OH&S activities. Some of the typical OH&S activities for participation of workers could be identifying hazards and assessing risks, determining actions to eliminate hazards, determining competence requirements, conducting training needs analysis, determining control measures, investigating incidents, determining corrective actions and developing new procedures.
•Providing timely access to easily understandable and relevant information about OHSMS to workers. Easy access to procedures, information displayed on noticeboards, awareness sessions, posters, leaflets, briefings and trainings could be some of the modes of communicating the required OH&S information.
•Removing any obstructions to the two-way flow of communication, such as failure of an organisation to respond to workers’ inputs or suggestions. There may be other factors such as language, literacy levels or threats of reprisals that act as barriers and should be considered when creating an effective consultation and participation process.
Although the term ‘worker’ includes all personnel, the Standard requires a special focus on the consultation process with non-managerial workers. Consultation has been defined as seeking views before making a decision. Consultation often requires the involvement of health and safety committees and workers’ representatives where they exist. The Standard emphasises consultation with non-managerial personnel for making decisions in the following situations:
•When determining the needs and expectations of workers. Every workplace has its unique set of OH&S issues and so does every work process. These can be best articulated by those who experience them first-hand.
•When establishing the OH&S policy. The OH&S policy sets a shared vision of an organisation that is not possible without the consultation of non-managerial personnel.
•When assigning roles and responsibilities. An organisation is also a social arrangement that involves numerous interrelationships between and among individuals and organisational groups. It is therefore often necessary to see the competence as well as the compatibility of individuals before assigning various responsibilities. A discussion with workers could provide many insights and help in assigning OH&S functions to suitable individuals.
•When complying with legal requirements. Workers can provide useful inputs on many issues of legal compliance and on how best to fulfil these requirements.
•When establishing OH&S objectives. Consultation with workers before setting up OH&S objectives is helpful not only in making them more realistic but also in obtaining workers’ ownership and commitment. The same is also true when making plans to achieve these objectives.
•The Standard emphasises that consultation with non-managerial workers should be carried out when determining controls for outsourcing, procurement and contractors. Non-managerial personnel are often the ones in closest contact with contractor and outsourcing processes. They have first-hand knowledge of difficulties and potential hazards associated with outsourced services, purchased products and contractual activities. Thus, they are in an excellent position to suggest effective controls needed for the safe operation of these processes. The same holds true for consultation on OH&S issues that need to be measured, monitored, supervised or audited. The Standard also requires consultative inputs from non-managerial personnel on the management of audits as well as continual improvement programmes.
To summarise, ISO 45001 lays a great emphasis on establishing consultative processes with workers for all important stages and activities of the OHSMS.
4.2.2 Participation
‘Participation’ refers to the active involvement of workers in the process of decision-making. Participation enables workers to contribute towards both decision-making and the implementation of activities undertaken within the OHSMS. ISO 45001 emphasis the participation of non-managerial workers in determining the mechanisms (processes) for the consultation and participation processes of the organisation. This could help in developing a common understanding of different aspects of consultation and participation processes, such as activities involved, timings, frequency, methodology and attendees. ISO 45001 specifies a number of activities where the participation of non-managerial workers (though this does not exclude managerial staff impacted by OH&S) has been emphasised. These are:
•Identification of OH&S hazards and assessment of risks. It is natural for workers who spend many hours working on a process every day, to know a lot about its potential hazards and risks. They are also in a good position to suggest possible options (opportunities) for elimination or reduction of hazards and risks.
•Identification of training needs, competence requirements and training implementation is yet another area where ‘participation’ has been called for. Provision of training (especially, in-house) is itself an excellent means of improving ‘participation’.
•ISO 45001 places emphasis on ‘participation’ for establishing two-way communication with workers. The Standard also places special emphasis on the ‘participation’ of workers in the process of deciding ‘controls’ and determining their effectiveness.
•Thorough investigations and effective corrective actions play an important role in the continual improvement of an OH&S system. Acknowledging this fact, the Standard emphasises the need for participation of non-managerial workers in the process of investigating (incidents and nonconformities) and determining suitable corrective actions.