ISO 45001:2018 Clause 8 Operation – Minimising hazards and risks
In this article, we consider the aspects of ISo 45001:2018 Clause 8 ‘Operation’. Building on requirements made within other clauses it covers the operational planning and control aspect of management systems, focusing on the elimination of hazards, reducing risks, the management of change, procurement considerations, the control of contractors, outsourcing and emergency preparedness.
Within Clause 8 practitioners will recognise the familiar hierarchy of control measures namely, elimination, substitution, the use of engineering controls, the implementation of administrative controls and the use of personal protective equipment (PPE). This hierarchy strategy can be used to good effect when ‘managing change’ and when minimising hazards and risks.
Hazards and risk are best eliminated at the design and planning stage, and by eliminating or substituting them at the procurement stage. Thoughtful procurement can prevent unnecessary hazards creeping into the organisation.
Engineering controls are perhaps the most visible control measures we find in the workplace, and those most subject to workplace inspections. Barriers, local exhaust ventilation, machine guards, and control systems are examples. All these will deteriorate over time and should be subject to planned preventative maintenance and periodic inspection. This might be of a statutory nature, thorough examinations and inspection for instance, or by scheduled servicing, or routine in-house inspections.
Health and safety practitioners will also be well versed in the importance of robust procedures and safe systems of work as ‘administrative’ control measures. Written safe systems of work remain a thread of continuity when key personnel leave the company or move on to other roles. They reduce the chance of shortcuts and bad habits creeping in. They also enhance the competence of workers by instructing some, and by acting as an aide memoir for others. These are the documents that tell you how to do it right, every time!
What other administrative controls do we have in our health and safety toolbox? Permits to work, site and contractor rules, and signage for example. Also, training sits well here, the full spectrum of induction training, job specific training, and health and safety training; all the elements which make up a competent workforce.
Personal protective equipment (PPE) finds itself at the bottom of the control hierarchy because it is offers individual protection rather than collective protection. Nevertheless, for many jobs PPE remains an essential measure and a resource to be properly supported. Whatever the nature of control measures we should maintain them and seek to improve them where we can.
Clause 8 also covers the selection and control of contractors and outsourced services whatever their function. There should be systems in place for ensuring vendor competence prior to their attendance on site or prior to service delivery. This can be achieved using a mix of pre-qualification performance questionnaires and clearly defined contractual arrangements. If contractor selection is stage one of the process, then stage two is communicating relevant information and agreeing performance metrics and stage three is co-ordinating and monitoring their activities on site. Consideration should be given to access arrangements, agreeing site rules, compliance with permit to work systems, process safety, the provision of risk assessments and method statements, consultation mechanisms, incident reporting and emergency procedures. Importantly, are they actually performing in the ways stipulated by the organisation?
Emergency preparedness requires robust plans to mitigate incidents and to prevent them escalating. A sign of our times perhaps, but we are all too well aware of flooding and other natural disasters; on site failures leading to fire, explosion, gas leaks and critical breakdowns; threats of terrorism and cyber-attack; and of course, pandemics. To respond promptly, flexibly and efficiently requires rehearsal and training. Practice emergency response via desk-top exercises and drills. Ensure that duty-holders know their roles and lines of communication amongst those involved within the organisation, and with external authorities too.
A thread that runs throughout Clause 8 is ‘managing change’. Change encompasses opportunities as well as risks. What kind of temporary or permanent changes might we expect to manage? The consequences from introducing new technology, work equipment and facilities. Also the introduction of new staff, work practices and procedures, or perhaps design and specification changes. New national standards and regulations will have to be integrated into the organisation periodically, so keep abreast of post-Brexit legislation, and keep your Red-On-Line legal registers up to date.
In developing the change-management arrangements, it is vital you fully engage and adequately consult the workforce on all aspects of the process (Clause 5) and ensure the involvement and commitment of relevant parties. Good two-way communication and interpersonal skills are crucial to ensure that you engage everyone during periods of transition.