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Programme on Safety and Health at Work and the Environment (SafeWork)International Labour OrganizationRoute des Morillons 4CH -1211 Geneva 22Switzerland
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Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems ( ILO-OSH 2001)
InternationalLabourOffice
Geneva
ISBN 978-92-2127059-1
9 789221 270591
-
Programme on Safety and Health at Work and the Environment (SafeWork)
Audit Matrixfor the ILO Guidelines on Occupational Safety and Health Management Systems (ILO-OSH 2001)
International Labour Office, Geneva
-
Copyright International Labour Organization 2013First published 2013
Publications of the International Labour Office enjoy copyright under Protocol 2 of the Universal Copyright Convention. Never-theless, short excerpts from them may be reproduced without authorization, on condition that the source is indicated. For rights of reproduction or translation, application should be made to ILO Publications (Rights and Permissions), International Labour Office, CH-1211 Geneva 22, Switzerland, or by email: [email protected]. The International Labour Office welcomes such applications.Libraries, institutions and other users registered with reproduction rights organizations may make copies in accordance with the licences issued to them for this purpose. Visit www.ifrro.org to find the reproduction rights organization in your country.
Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems (ILO-OSH 2001)First published 2013
ISBN 978-92-2-127058-4 (print)ISBN 978-92-2-127059-1 (web pdf)
This publication has been produced with the assistance of the European Union. The contents of this publication are the sole responsability of the ILO and can in no way be taken to reflect the views of the European Union.
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This guide was produced under the project Linking safety and health at work to sustainable economic development: From theory and platitudes to conviction and action (2009-2012), funded by the Swedish International Development Cooperation Agency (SIDA).
The project promotes the improvement of occupational safety and health for all workers through the development of global products addressing the methodological and informational gaps in this field, and through the mobilization of national stakeholders towards the implementation of practical meas-ures at national, local and enterprise levels. The outputs of the project include training materials, practical tools and policy guidance to reinforce national and local capacities in occupational safety and health, and to help constituents design and implement occupational safety and health policies and programmes.
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vPreface
Preface
Governments, employers and workers now recognize the positive impact on productivity, and on the reduction of hazards and risks, of introducing occupational safety and health (OSH) management systems at the organization level.
In 2001 the ILO therefore developed the ILO Guidelines on Occupational Safety and Health Management Systems, ILO-OSH 2001, to help governments, employers and workers to continually improve their OSH performance.
This user guide has been designed to help auditors in measuring the effectiveness of an organizations OSH management system, and should be used in tandem with the Implementation Guidance for the ILO Guidelines on Occupational Safety and Health Management Systems, ILO-OSH 2001. Auditing is one of the key steps in both implementing an OSH management system and evaluating its performance. This guide is a practical tool that will help in identifying the strengths and weaknesses in an organizations OSH management system, and in highlighting opportunities for improvement.
By using the guide, auditors will be able to measure an organizations OSH performance, and compare it against the 16 items described in ILOOSH 2001, with a view to identifying weaknesses, providing solutions for improvement, and continually improving OSH performance.
It would not have been possible to develop this audit guide without the financial contribution from the Swedish International Development Cooperation Agency (SIDA). Mr Tony Smith, Manager, Smith EHS Services, drafted the guide. Mr Pavan Baichoo and Mr Tsuyoshi Kawakami from the ILO SafeWork Programme provided technical contributions for finalizing the contents. Ms Amlie Schmitt, Chief Technical Adviser of the SIDAfunded project, coordinated the development of the guide.
I am sure that this guide, in conjunction with ILO-OSH 2001 and the Implementation Guidance for the ILO Guidelines on Occupational Safety and Health Management Systems, ILO-OSH 2001, will provide a valuable set of tools for employers and workers organizations, as well as for those responsible for OSH within their organizations, for continually improving their OSH performance.
Seiji Machida, Director, SafeWork.
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viiContents
Contents
Preface . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . v
User guide . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1
Policy 9
3.1. Occupational safety and health policy . . . . . . . . . . . . . . . . . . . . . . . 11
3.2. Worker participation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15
Organizing 21
3.3. Responsibility and accountability . . . . . . . . . . . . . . . . . . . . . . . . . 23
3.4. Competence and training . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 29
3.5. Occupational safety and health management system documentation. . . . . . . . 34
3.6. Communication . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 39
Planning and implementation 43
3.7. Initial review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 45
3.8. System planning, development and implementation . . . . . . . . . . . . . . . . 49
3.9. Occupational safety and health objectives . . . . . . . . . . . . . . . . . . . . . 54
3.10. Hazard prevention . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 58
3.10.1. Prevention and control measures . . . . . . . . . . . . . . . . . . . . . 58
3.10.2. Management of change . . . . . . . . . . . . . . . . . . . . . . . . . . 61
3.10.3. Emergency prevention, preparedness and response . . . . . . . . . . . . . . 65
3.10.4. Procurement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 69
3.10.5. Contracting. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 72
Evaluation 75
3.11. Performance monitoring and measurement . . . . . . . . . . . . . . . . . . . . 77
3.12. Investigation of workrelated injuries, ill health, diseases and incidents, and their impact on safety and health performance. . . . . . . . . . . . . . . . . 82
3.13. Audit. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 86
3.14. Management review . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91
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viii Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems
Action for improvement 95
3.15. Preventive and corrective action . . . . . . . . . . . . . . . . . . . . . . . . . . 97
3.16. Continual improvement . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 100
Appendices 105
Appendix 1 Item 3.2 Worker participation First worked example . . . . . . . . . . 107
Appendix 2 Item 3.2 Worker participation Second worked example . . . . . . . . . 111
Appendix 3 Sample audit summary . . . . . . . . . . . . . . . . . . . . . . . . . . 115
Appendix 4 Preaudit planning. . . . . . . . . . . . . . . . . . . . . . . . . . . . . 117
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1User guide
User guide
This audit matrix has been designed to measure the effectiveness of an organizations occupational safety and health (OSH) management system and OSH performance, and to compare them against the Guidelines on Occupational Safety and Health Management Systems, ILO-OSH 2001. It is designed to identify the strengths and weaknesses that exist in an organizations OSH management system, and to highlight opportunities for improvement. The matrix incorporates the requirement to complete a SWOT analysis for each item of the ILOOSH 2001 guidelines. This will show the strengths, weaknesses, opportunities and threats that exist within the organization being audited.
The matrix is intended to help auditors measure the 16 items recommended in the ILOOSH 2001 guidelines, and which make up the OSH management system in an organization:
Policy
Occupational safety and health policy
Worker participation
Organizing
Responsibility and accountability
Competence and training
Occupational safety and health management system documentation
Communication
Planning and implementation
Initial review
System planning, development and implementation
Occupational safety and health objectives
Hazard prevention
Prevention and control measures
Management of change
Emergency prevention, preparedness and response
Procurement
Contracting
Evaluation
Performance monitoring and measurement
Investigation of workrelated injuries, ill health, diseases and incidents, and their impact on safety and health performance
Audit
Management review
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2 Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems
Action for improvement
Preventive and corrective action
Continual improvement
In order to assess the OSH management system and OSH performance accurately, the audit measurements should be honest and accurate. Marks need to be allocated carefully, and should be given only when the organization closely matches one of the five statements on each horizontal line of the matrix. In total, 159 separate lines of statements are used in the matrix, which provides an overall maximum score of 795 marks.
Although the audit matrix expresses the auditors opinions about the OSH management system and OSH performance, these opinions should, wherever possible, be supported by reliable evidence. Auditors need to start the audit with an open mind, and to not prejudge the situation. They need to maintain an investigative approach, and seek evidence and draw conclusions that are supported by facts, wherever possible.
Evidence generally falls into four broad categories:
Documentation. In making the assessments required by the matrix, auditors should use a wide range of evidence sources. This will include an examination of documents relating to policies, procedures, processes, organizational communications, incidents and OSH performance records.
Inquiry. The auditors should ask questions both formally and informally. Many questions will be asked verbally, in an informal manner. These are often supported by more formal questions, which might for example be asked in the form of a written request for information, or as questionnaires and surveys. Auditors should treat evidence gained in this way as soft, because the answers they receive are the opinions of third parties, and may not be impartial, or may even be given to mislead the auditors.
Observation. Auditors will also collect evidence through what they have heard, seen or touched during the audit. Observations and physical examinations are very reliable sources of audit evidence, and carry extra weight because the auditors have gathered the evidence themselves.
Testing and verification. Auditors will normally perform both system tests on the OSH management system and checks on the physical work environment, equipment and tools. This involves checking that the OSH management system and the physical work environment and equipment, tools and safety systems are working as they are supposed to. Auditors will also need to check that the organization is complying with national and state laws.
The auditors need to conduct interviews with workers, supervisors, managers, senior management, contractors, contract workers, the safety and health committee, workers representatives, and also other specialist functions such as a company nurse or doctor, or industrial hygienists. Physical inspections and walkthroughs are also essential, to ensure that the information gained from documents, records and interviews is true and accurate.
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3User guide
How to use the matrix
The basic principle is that, for each of the 159 horizontal lines of the matrix, the auditor will choose the statement that most closely fits the organizations status. The auditor will then allocate a mark that corresponds to the column to which the statement belongs. As explained above, these lines of statements are grouped in 16 tables, which correspond to the 16 thematic items recommended in ILO-OSH 2001.
As an example, let us examine item 3.1, Occupational safety and health policy.
NONE (1) POOr (2) FAIr (3) GOOD (4) ExCELLENT (5) rATING
The organization does not have a written OSH policy.
The organization has a written OSH policy, but it does not comply with national laws and regulations.
The organization has an OSH policy that complies with national laws and regulations, but does not comply with ILO guidelines.
The organization has an OSH policy that complies with national laws and regulations, and also with ILO guidelines.
The organization has an OSH policy that complies with all national laws and regulations, ILO guidelines, and collective agreements.
The written OSH policy is inadequate, although it does provide a limited description of management attitudes to OSH.
The policy briefly outlines the management attitude to OSH and a commitment to prevention of work-related injuries and ill health.
The policy describes the management attitude to OSH and the total commitment to protecting workers by preventing injuries, ill health, diseases and incidents.
The policy describes the management attitude to OSH and the prevention of injury, illness, diseases and incidents, and it has been agreed in consultation with workers and their representatives.
If the organization has no written OSH policy then the correct score would be 1 mark. If the organization has an OSH policy that meets national laws and regulations and ILO guidelines, then it would score 4 marks, unless it has also agreed the policy with workers and their representatives, in which case it would score 5 marks. We then proceed to the second line and again decide which statement most closely fits the organizations status. We proceed through each line in this way until we have completed section 3.1 of the matrix.
In order to make these judgements, auditors need to be able to find reliable evidence that ensures they can allocate the correct scores. This will allow them to identify the strengths and weaknesses, and also to identify both opportunities for improvement and possible threats to the business that need to be brought senior managements attention. This SWOT analysis will figure in the auditors feedback at the bottom of each scored thematic item.
Two completed samples of item 3.2, Worker participation, are provided in Appendices 1 and 2 as examples of how to use the matrix.
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4 Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems
We suggested that an audit summary be established at the end of the audit period, which takes the actual total scores of the organization for each of the 16 items audited and compares them with the maximum possible scores. A traffic light red, orange or green can then be allocated to each of the items, to highlight areas where improvement is necessary. Appendix 3 provides a completed sample of such an audit summary.
General considerations in preparing pre-audit planning
Auditors need to conduct considerable planning before starting the audit. They need to decide when the audit should take place, and establish a sensible schedule for the work. They will need to agree on this workplan with the senior management of the organization being audited, unless it is an unannounced audit.
Auditors need to plan who they want to interview, what they want to see, and what documents and records they need to examine. As the audit progresses they may want to talk to people who were not on their interview list when they made the audit plan.
Auditors should ascertain exactly what documents they will need to examine as part of their audit preparation. A sample audit preparation document is attached as Appendix 4.
Auditors need to have obtained copies of the relevant national OSH laws (both federal and state), and have a copy of the ILO-OSH 2001 guidelines, plus documents relating to industry best practices and the standards expected by certification bodies. They need to have examined the organizations OSH policy document to determine whether it meets the requirements of national OSH laws, regulations, approved codes of practice and the ILO-OSH 2001 guidelines.
Auditors will need to use multiple sources of evidence in order to audit and score the OSH performance of an organization accurately. Evidence will come from examining documents relating to plans, programmes, processes, policies, procedures, rules, records, statistics and data. This information should tell them what should be happening in the business, and the performance that is expected. They can measure then performance against these expectations.
Having examined the above documentary sources of information, they then need to measure whether what was described in the documents is actually happening in reality. Interviews with senior and middle management, supervisors, workers, contractors, contract workers, and OSH and medical personnel should help check their understanding of and compliance with the OSH policy and OSH management system. Interviews should also be held with unions and workers representatives, and with safety and health committee members.
Auditors also need to conduct comprehensive observations of the workplace, and look at housekeeping, and the condition of facilities, machinery, equipment, tools, and devices. They should examine closely all safety equipment and devices, fire and evacuation measures, personal protective equipment (PPE), and the storage and use of hazardous materials. They will use their observations to identify atrisk behaviours, and look at supervision and the organization and control of work.
Auditors should also look at the procedures for controlling energy sources, machine guarding and materials handling, and at whether there is an appropriate system for managing change, and communicating changes to the workforce.
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5User guide
Auditors should examine worker behaviours to identify atrisk behaviours. They should check compliance with standard operating procedures, and that work is being performed in the way prescribed by the job safety analysis or task analysis. They should question workers to ascertain their knowledge of OSH policy, procedures and rules. They should also ask workers and supervisors about the communication of OSH expectations and OSH results.
Audits must focus on identifying weaknesses and looking for improvements. Where problems are identified, corrective actions need to be formulated and remedial measures put in place in a timely manner.
Audits should lead to the correction of weaknesses in the OSH management system and its application in the workplace. Where weaknesses exist, an improvement plan needs to be formulated and put into action. Auditors should look to see whether weaknesses identified by previous audits and inspections have been corrected.
On-site audit activities
The OSH audit is intended to assess and verify the strengths and weaknesses of the OSH management system, and to improve both this system and OSH performance. It is vitally important that everyone understands the purpose of the audit, and that it is seen as a positive measure to improve OSH management and performance. This should ensure higher standards of OSH, and a reduction of incidents and atrisk behaviours.
Opening interview
It is normal audit practice to begin the audit with an opening conference with senior site management. This allows the auditors to introduce themselves and explain the audit process. They will define the scope of the audit, and explain its purpose. They will also discuss the audit schedule. The schedule of activities is agreed with senior management, and communicated to each part of the organization that will be audited.
Auditors are briefed on any hazardous conditions that exist on the site, and on the controls that are used to protect workers. Auditors need to wear appropriate personal protective clothing and equipment for their onsite activities. Arrangements need to ensure that these are available, unless the auditors have their own that provides the same levels of protection.
Auditors and senior management agree a timetable for the exit interview that will be used to present the preliminary findings of the audit. Site management will be given an agreed amount of time to examine the preliminary report, and to challenge any audit findings that they disagree with, or wish to challenge, or on which they need further clarification.
Typically, at the end of the opening interview, auditors will be given an orientation tour of the site with an explanation of expected safety behaviour, emergency response and evacuation procedures. OSH control measures and required PPE are explained as well.
Programme assessment and verification
The OSH audit then moves on to programme assessment and verification by starting a comprehensive review of OSH programme documentation. The auditors will examine policies, programmes, procedures, risk assessments, standards and related documents.
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6 Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems
They will examine accident and incident reports, firstaid injury records, safety inspection records, citations and warnings from regulatory bodies. They will look at previous audit reports, certification assessments, industrial hygiene survey reports, task analysis, job safety analyses (JSAs), materialhandling assessments, process safety management documentation, and risk assessments. They will examine absence, illness and sickness rates. Supporting statistical data and corrective action logs should be reviewed.
The documentation review will be followed by a wide range of interviews with plant managers, departmental managers, supervisors, team leaders, union representatives, safety and health committee members, medical personnel and a wide range of workers. They should be questioned on their awareness of the OSH programme and its implementation. Auditors should look for concerns, and for opportunities for improvement.
The auditors should spend sufficient time on examining the workplace, and this will involve the activities of the various departments. This is when auditors should identify the degree of acceptance and the quality of implementation of OSH policies, programmes, procedures and OSH activities.
During an audit the auditors will collect a huge amount of information and data. It will be impossible for them to remember it all unless they have taken notes as the audit progresses. So, irrespective of the experience of the auditors, it is absolutely essential that they take detailed field notes.
Auditors should look at the housekeeping to see whether a clean, tidy, healthy and safe work environment exists. They should also observe work processes to see whether procedures are followed, and that hazards have been identified and are properly controlled. If the auditors have specific concerns, they may require specialist testing to be undertaken, and will then review the test reports.
Auditors should also spend some time observing both task and nontaskrelated behaviours. They should compare the taskrelated behaviours with those that are described in the task analysis, job safety analysis or permit to work.
Exit interview
An exit interview is held with senior and site management in order to share the preliminary audit results and the observations of the audit team. Site management is given the opportunity to respond to these findings and observations, and to seek or provide clarification of issues arising from the report. A date is agreed for the receipt of any responses or challenges to the audit findings that the site management wish to make. The organization is normally thanked for its cooperation and help, and a date is agreed upon for the delivery of the final report.
Final audit report
The final audit report should include the date and location of the audit, and identify all the participants who took part in or contributed information for the audit. The report should identify clearly which parts or activities of the organization were audited.
The report will include the audit findings, results and observations. It will also propose corrective actions, and set deadlines by which corrective actions or audit responses are to be completed. This would include the means of verifying corrective actions.
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7User guide
Audit response
When the audited organization has received the final audit report, it should respond by describing what corrective actions have been taken and what actions are planned. It is essential that every weakness, every opportunity for improvement, and every threat identified in the audit report is subject to corrective actions and improvements. A log should be created that lists all the items that need to be addressed. This should set the timelines for improvements and corrections of each item needing such action, with responsibility allocated to a designated person for that action.
Audit closure
The audit file is not normally closed until a closure statement has been prepared. This should comprise of a listing of the audit findings, together with the corrective actions relating to each one. Closure occurs only when corrective actions are complete, and have been verified.
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Policy
-
Policy 11
Pol
icy
Item
3.1
Occ
upat
iona
l saf
ety
and
heal
th p
olic
y
NO
NE
(1
)P
OO
r (
2)
FAIr
(3
)G
OO
D (
4)
ExC
ELL
EN
T (5
)r
ATIN
G
ATh
e or
gani
zati
on d
oes
not
have
a w
ritt
en O
SH
pol
icy.
The
orga
niza
tion
has
a
wri
tten
OS
H p
olic
y,
but
it d
oes
not
com
ply
wit
h na
tion
al la
ws
or
regu
lati
ons.
The
orga
niza
tion
has
an
OS
H p
olic
y th
at c
ompl
ies
wit
h na
tion
al la
ws
and
regu
lati
ons,
but
doe
s no
t co
mpl
y w
ith
ILO
gu
idel
ines
.
The
orga
niza
tion
has
an
OS
H p
olic
y th
at c
ompl
ies
wit
h na
tion
al la
ws
and
regu
lati
ons,
and
als
o w
ith
ILO
gui
delin
es.
The
orga
niza
tion
has
an
OS
H p
olic
y th
at c
ompl
ies
wit
h al
l nat
iona
l law
s an
d re
gula
tion
s, I
LO
guid
elin
es, an
d co
llect
ive
agre
emen
ts.
BTh
e or
gani
zati
on d
oes
not
have
a w
ritt
en O
SH
pol
icy.
The
wri
tten
OS
H p
olic
y
is in
adeq
uate
, al
thou
gh
it d
oes
prov
ide
a lim
ited
des
crip
tion
of
man
agem
ent
atti
tude
s
to O
SH
.
The
OS
H p
olic
y br
iefly
ou
tlin
es t
he m
anag
emen
t at
titu
de t
o O
SH
and
a
com
mit
men
t to
pre
vent
ion
of
wor
k-re
late
d in
juri
es
and
ill h
ealt
h.
The
OS
H p
olic
y de
scri
bes
the
man
agem
ent
atti
tude
to
OS
H a
nd t
he t
otal
co
mm
itm
ent
to p
rote
ctin
g w
orke
rs b
y pr
even
ting
in
juri
es, ill
hea
lth,
di
seas
es a
nd in
cide
nts.
The
OS
H p
olic
y de
scri
bes
the
man
agem
ent
atti
tude
to
OS
H a
nd t
he p
reve
ntio
n of
inju
ry, ill
ness
, di
seas
es
and
inci
dent
s, a
nd it
ha
s be
en a
gree
d in
co
nsul
tati
on w
ith
wor
kers
an
d th
eir
repr
esen
tati
ves.
CTh
e or
gani
zati
on d
oes
not
have
a w
ritt
en O
SH
pol
icy.
The
OS
H p
olic
y ha
s no
t be
en a
gree
d w
ith
wor
kers
or
the
ir r
epre
sent
ativ
es.
The
OS
H p
olic
y ha
s be
en
agre
ed w
ith
only
ver
y lim
ited
con
sult
atio
n w
ith
wor
kers
.
The
OS
H p
olic
y ha
s be
en
agre
ed in
ful
l con
sult
atio
n w
ith
wor
kers
and
the
ir
repr
esen
tati
ves.
Wor
kers
are
enc
oura
ged
to p
arti
cipa
te a
ctiv
ely
in
all a
spec
ts o
f th
e O
SH
m
anag
emen
t sy
stem
, an
d ar
e co
nsul
ted
on a
ll m
atte
rs r
elat
ing
to O
SH
po
licie
s.
-
12 Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems
NO
NE
(1
)P
OO
r (
2)
FAIr
(3
)G
OO
D (
4)
ExC
ELL
EN
T (5
)r
ATIN
G
DTh
e or
gani
zati
on d
oes
not
have
a w
ritt
en O
SH
pol
icy.
The
OS
H p
olic
y
is n
ot a
ppro
pria
te f
or t
he
type
or
size
of
busi
ness
.
Som
e el
emen
ts o
f th
e O
SH
pol
icy
are
appr
opri
ate
for
the
type
and
siz
e of
bu
sine
ss.
The
OS
H p
olic
y is
ge
nera
lly a
ppro
pria
te
for
the
type
and
siz
e
of b
usin
ess.
The
focu
s of
the
OS
H
polic
y is
to
find
way
s to
pr
even
t w
orkp
lace
inju
ries
, ill
ness
es a
nd d
isea
ses,
an
d to
ens
ure
the
wel
fare
of
the
wor
kfor
ce.
ETh
e or
gani
zati
on d
oes
not
have
a w
ritt
en O
SH
pol
icy.
The
OS
H p
olic
y
is n
ot w
ritt
en in
a c
onci
se
way
, an
d la
cks
clar
ity.
The
OS
H p
olic
y is
not
su
ffici
entl
y cl
earl
y w
ritt
en,
and
is t
here
fore
not
al
way
s un
ders
tand
able
by
ever
yone
.
The
OS
H p
olic
y is
con
cise
an
d cl
earl
y w
ritt
en, an
d is
und
erst
anda
ble
by
ever
yone
.
The
OS
H p
olic
y m
akes
it
cle
ar t
hat
ever
yone
has
O
SH
res
pons
ibili
ties
, th
eir
perf
orm
ance
of
thes
e du
ties
is m
onit
ored
, an
d pe
ople
are
hel
d ac
coun
tabl
e.
FTh
e or
gani
zati
on d
oes
not
have
a w
ritt
en O
SH
pol
icy.
The
OS
H p
olic
y is
not
ef
fect
ivel
y co
mm
unic
ated
or
eas
ily a
cces
sibl
e to
ev
eryo
ne in
the
wor
kpla
ce.
The
OS
H p
olic
y is
co
mm
unic
ated
, bu
t is
not
re
adily
acc
essi
ble
by
eve
ryon
e in
the
ir p
lace
of
wor
k.
The
OS
H p
olic
y is
ge
nera
lly e
ffec
tive
ly
com
mun
icat
ed, an
d is
re
adily
acc
essi
ble
to
ever
yone
in t
heir
pla
ce o
f w
ork.
The
OS
H p
olic
y is
ver
y w
ell c
omm
unic
ated
, an
d en
sure
s th
at t
he O
SH
m
anag
emen
t sy
stem
is
com
pati
ble
wit
h or
is
inte
grat
ed in
to t
he o
ther
en
terp
rise
org
aniz
atio
nal
man
agem
ent
syst
ems
GTh
e or
gani
zati
on d
oes
not
have
a w
ritt
en O
SH
pol
icy.
The
OS
H p
olic
y fa
ils
to c
omm
unic
ate
the
resp
onsi
bilit
ies
and
expe
ctat
ions
of
wor
kers
an
d m
anag
ers.
The
OS
H p
olic
y pr
ovid
es
som
e lim
ited
des
crip
tion
s of
the
res
pons
ibili
ties
and
ex
pect
atio
ns o
f w
orke
rs
and
man
ager
s.
The
OS
H p
olic
y de
scri
bes
the
over
all
the
resp
onsi
bilit
ies
and
expe
ctat
ions
of
wor
kers
an
d m
anag
ers.
The
OS
H p
olic
y de
scri
bes
in d
etai
l res
pons
ibili
ties
an
d ex
pect
atio
ns o
f w
orke
rs a
nd m
anag
ers,
m
akin
g it
cle
ar t
hat
perf
orm
ance
will
be
mon
itor
ed a
nd p
eopl
e he
ld
acco
unta
ble.
-
Policy 13
NO
NE
(1
)P
OO
r (
2)
FAIr
(3
)G
OO
D (
4)
ExC
ELL
EN
T (5
)r
ATIN
G
HTh
e or
gani
zati
on d
oes
not
have
a w
ritt
en O
SH
pol
icy.
Ther
e is
no
exte
rnal
co
mm
unic
atio
n of
OS
H
polic
y, r
espo
nsib
iliti
es
or e
xpec
tati
ons.
Very
lim
ited
co
mm
unic
atio
n of
OS
H
polic
y re
spon
sibi
litie
s an
d ex
pect
atio
ns is
pro
vide
d
to e
xter
nal b
odie
s.
The
OS
H p
olic
y is
als
o co
mm
unic
ated
to
all
cont
ract
ors,
vis
itor
s an
d ne
w h
ires
, an
d is
cov
ered
in
wor
ker
orie
ntat
ion.
The
OS
H p
olic
y is
als
o co
mm
unic
ated
to
ext
erna
l gro
ups
and
th
e co
mm
unit
y so
tha
t th
ey m
ay u
nder
stan
d
the
orga
niza
tion
s a
ttit
ude
to O
SH
.
I*Th
e or
gani
zati
on d
oes
not
have
a w
ritt
en O
SH
pol
icy.
The
OS
H p
olic
y is
dat
ed,
and
has
not
been
rev
iew
ed
or u
pdat
ed f
or s
ever
al
year
s.
The
OS
H p
olic
y is
upd
ated
on
ly in
freq
uent
ly, an
d ha
s no
t be
en r
evie
wed
or
upda
ted
for
the
past
tw
o ye
ars.
The
OS
H p
olic
y is
re
gula
rly
revi
ewed
, up
date
d, a
nd s
igne
d
by s
enio
r m
anag
emen
t.
The
OS
H p
olic
y is
re
view
ed a
nd u
pdat
ed a
t le
ast
annu
ally
. It
is s
igne
d
by s
enio
r m
anag
emen
t
and
also
des
crib
es
the
card
inal
OS
H r
ules
of
the
ent
erpr
ise.
OVE
rA
LL S
CO
rE
FO
r I
TEM
3.1
OC
CU
PATI
ON
AL
SA
FETY
AN
D H
EA
LTH
PO
LIC
Y (m
ax. sc
ore
for
this
item
is 4
5)
Aud
itor
s f
eedb
ack
Str
engt
hs
Wea
knes
ses
Opp
ortu
niti
es
-
14 Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems
Thre
ats
Gui
danc
e no
tes
OS
H p
olic
y is
the
fou
ndat
ion
of a
n ef
fect
ive
OS
H m
anag
emen
t sy
stem
, an
d w
itho
ut s
uch
a po
licy,
saf
ety
and
heal
th is
not
pro
perl
y m
anag
ed o
r as
sure
d.
Idea
lly, th
e po
licy
shou
ld b
e no
mor
e th
an o
ne A
4 p
age
long
; it
sho
uld
be c
onci
se, an
d si
mpl
e to
und
erst
and
by e
very
one
in t
he o
rgan
izat
ion.
The
OS
H p
olic
y sh
ould
pro
vide
ove
rall
dire
ctio
n an
d gu
idan
ce r
elat
ing
to o
ccup
atio
nal h
ealt
h an
d sa
fety
.
It s
houl
d in
clud
e a
visi
on s
tate
men
t th
at e
ncap
sula
tes
the
orga
niza
tion
s a
ppro
ach
to O
SH
, su
ch a
s
OS
H F
IRS
T o
r
Mai
ntai
ning
an
inju
ry-f
ree
wor
kpla
ce.
OS
H p
olic
y sh
ould
be
trea
ted
as a
con
stan
t va
lue
that
will
nev
er c
hang
e, ir
resp
ecti
ve o
f ch
angi
ng p
rior
itie
s w
ithi
n th
e bu
sine
ss.
A m
issi
on s
tate
men
t sh
ould
als
o de
scri
be t
he o
rgan
izat
ion
s ov
eral
l obj
ecti
ve r
elat
ing
to O
SH
e
.g. to
be
the
safe
st s
teel
com
pany
in t
he U
nite
d S
tate
s.
Man
agem
ent
lead
ersh
ip n
eeds
to
driv
e th
e O
SH
pro
cess
and
add
val
ue b
y el
imin
atin
g or
red
ucin
g in
juri
es a
nd il
lnes
ses.
OS
H p
olic
y sh
ould
set
out
the
pri
ncip
les
and
guid
elin
es f
or O
SH
dec
isio
ns.
The
polic
y sh
ould
sta
te c
lear
ly t
op m
anag
emen
ts c
omm
itm
ent
to s
afet
y an
d he
alth
.
The
polic
y sh
ould
hav
e th
e si
gnat
ure
of t
he p
resi
dent
or
CE
O, or
of
the
mos
t se
nior
man
ager
on
the
site
.
The
polic
y sh
ould
sta
te t
he o
rgan
izat
ion
s co
mm
itm
ent
to c
ompl
ianc
e w
ith
regu
lato
ry r
equi
rem
ents
and
col
lect
ive
agre
emen
ts o
n O
SH
.
Wor
kers
will
be
cons
ulte
d an
d en
cour
aged
to
part
icip
ate
in a
ll el
emen
ts o
f O
SH
, an
d be
em
pow
ered
to
act
whe
n th
ey id
enti
fy u
nsaf
e co
ndit
ions
or
unsa
fe b
ehav
iour
.
OS
H p
olic
y w
ill b
e re
gula
rly
revi
ewed
, up
date
d an
d im
prov
ed t
hrou
gh a
con
tinu
ous
impr
ovem
ent
proc
ess.
Rev
iew
sho
uld
take
pla
ce a
t le
ast
annu
ally
.
OS
H d
utie
s an
d re
spon
sibi
litie
s w
ill b
e de
scri
bed,
and
eve
ryon
e is
hel
d re
spon
sibl
e an
d ac
coun
tabl
e fo
r th
eir
own
and
thei
r co
-wor
kers
saf
ety
and
heal
th.
-
Policy 15
Pol
icy
Item
3.2
Wor
ker
part
icip
atio
n
NO
NE
(1
)P
OO
r (
2)
FAIr
(3
)G
OO
D (
4)
ExC
ELL
EN
T (5
)r
ATIN
G
ATh
ere
is n
o cl
ear
evid
ence
w
ithi
n th
e or
gani
zati
on o
f m
anag
emen
t en
cour
agin
g or
see
king
to
invo
lve
or g
et
wor
kers
to
part
icip
ate
in
OS
H m
atte
rs.
Par
tici
pati
on is
lim
ited
to
fol
low
ing
OS
H
rule
s, p
roce
dure
s, a
nd
inst
ruct
ions
. Th
ere
is li
ttle
in
put
by w
orke
rs in
OS
H
mat
ters
.
Par
tici
pati
on is
en
cour
aged
by
man
agem
ent,
but
is
limit
ed t
o de
alin
g w
ith
spec
ific
OS
H p
robl
ems
wit
hin
the
orga
niza
tion
. M
anag
emen
t do
es n
ot
get
invo
lved
in p
lann
ing
or h
azar
d re
cogn
itio
n ac
tivi
ties
.
Man
agem
ent
has
cl
earl
y de
fined
the
rol
es
and
resp
onsi
bilit
ies
of
indi
vidu
al w
orke
rs, an
d of
the
saf
ety
and
heal
th
com
mit
tee.
The
man
agem
ent
polic
y an
d sy
stem
s do
cum
enta
tion
des
crib
es
the
impo
rtan
ce o
f w
orke
r pa
rtic
ipat
ion
and
invo
lvem
ent
in c
reat
ing
a sa
fe a
nd h
ealt
hy
wor
kpla
ce.
BO
SH
com
mun
icat
ion
wit
h w
orke
rs is
infr
eque
nt,
and
tend
s to
invo
lve
mai
nly
smal
l num
bers
of
wor
kers
and
be
focu
sed
on s
uper
viso
rs.
Man
agem
ent
has
min
imum
com
mun
icat
ion
wit
h w
orke
rs o
n O
SH
m
atte
rs.
Man
agem
ent
mai
ntai
ns
a lim
ited
am
ount
of
com
mun
icat
ion
wit
h w
orke
rs. Th
is
com
mun
icat
ion
is
gene
rally
a t
op-d
own
proc
ess,
and
litt
le
evid
ence
exi
sts
that
m
anag
emen
t kn
ows
wha
t th
eir
wor
kers
con
cern
s ar
e.
Ther
e is
reg
ular
and
fr
eque
nt d
ialo
gue
wit
h w
orke
rs, an
d th
e w
orke
rs
view
s ar
e re
gard
ed a
s be
ing
very
impo
rtan
t.
The
docu
men
tati
on
desc
ribe
s sp
ecifi
c w
orke
r pa
rtic
ipat
ion
goal
s, a
nd
the
bene
fits
that
are
ga
ined
for
the
org
aniz
atio
n an
d it
s w
orke
rs. It
m
akes
saf
ety
and
heal
th
com
mun
icat
ions
to
be
vita
l to
ensu
re t
hat
ever
y pe
rson
in t
he o
rgan
izat
ion
unde
rsta
nds
thei
r ro
les
and
resp
onsi
bilit
ies.
-
16 Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems
NO
NE
(1
)P
OO
r (
2)
FAIr
(3
)G
OO
D (
4)
ExC
ELL
EN
T (5
)r
ATIN
G
CW
orke
rs s
afet
y an
d he
alth
re
pres
enta
tive
s ha
ve
been
app
oint
ed b
ut r
arel
y m
eet.
The
ir r
ole
has
not
been
defi
ned,
and
the
y ha
ve li
ttle
invo
lvem
ent
in p
lann
ing,
eva
luat
ing
or s
eeki
ng im
prov
emen
t an
d so
luti
ons
to O
SH
pr
oble
ms.
A s
afet
y an
d he
alth
co
mm
itte
e ha
s be
en
form
ed, bu
t ha
s no
cle
ar
role
, an
d m
eets
ver
y in
freq
uent
ly. S
afet
y an
d he
alth
rep
rese
ntat
ives
ha
ve li
ttle
invo
lvem
ent
in
plan
ning
.
The
ente
rpri
se h
as
esta
blis
hed
a sa
fety
and
he
alth
com
mit
tee
that
co
nfor
ms
and
com
plie
s w
ith
the
requ
irem
ents
of
nat
iona
l law
s an
d re
gula
tion
s, a
nd p
ract
ice.
Th
e co
mm
itte
es
role
ha
s be
en d
efine
d,
and
incl
udes
wor
king
w
ith
man
agem
ent
in
eval
uati
ng, pl
anni
ng a
nd
impl
emen
ting
sol
utio
ns
and
impr
ovem
ents
.
The
ente
rpri
se h
as
esta
blis
hed
a sa
fety
and
he
alth
com
mit
tee
that
co
nfor
ms
and
com
plie
s w
ith
the
requ
irem
ents
of
nat
iona
l law
s an
d re
gula
tion
s, a
nd
prac
tice
. Th
e ro
le o
f th
e co
mm
itte
e ha
s be
en
defin
ed, an
d in
clud
es
haza
rd r
ecog
niti
on a
nd
OS
H c
omm
unic
atio
ns.
The
com
mit
tee
also
ha
s an
act
ive
role
in
eval
uati
ng O
SH
cha
nges
, an
d in
bui
ldin
g w
orke
r co
mpe
tenc
es in
OS
H.
The
orga
niza
tion
ens
ures
th
at a
ll ch
ange
s to
the
w
ork
envi
ronm
ent
and
proc
edur
es a
re d
iscu
ssed
w
ith
wor
kers
and
the
ir
repr
esen
tati
ves.
The
be
nefit
s ar
e co
mm
unic
ated
so
tha
t w
orke
rs c
an
prop
erly
und
erst
and
why
ch
ange
s ar
e be
ing
mad
e,
and
how
the
se c
hang
es w
ill
be b
enefi
cial
. Th
e sa
fety
an
d he
alth
com
mit
tee
is
high
ly in
volv
ed in
all
OS
H
mat
ters
, an
d en
sure
s th
at
wor
kers
con
cern
s ar
e de
alt
wit
h in
a t
imel
y m
anne
r.
DW
orke
rs a
nd t
heir
re
pres
enta
tive
s ar
e ra
rely
co
nsul
ted
on c
hang
es t
o pr
oces
ses
and
proc
edur
es.
Ther
e is
onl
y m
inim
al
cons
ulta
tion
wit
h w
orke
rs
rega
rdin
g O
SH
mat
ters
, an
d ch
ange
s to
pro
cess
es
and
proc
edur
es.
Ther
e is
onl
y lim
ited
co
nsul
tati
on w
ith
wor
kers
re
gard
ing
OS
H m
atte
rs,
and
chan
ges
to p
roce
sses
an
d pr
oced
ures
.
Ther
e is
a p
osit
ive
appr
oach
to
invo
lvin
g w
orke
rs in
OS
H m
atte
rs,
and
this
incl
udes
co
nsul
tati
on o
n ch
ange
s to
pr
oces
ses
and
proc
edur
es.
The
ente
rpri
se e
nsur
es
that
wor
kers
and
the
ir
repr
esen
tati
ves
are
cons
ulte
d, in
form
ed a
nd
trai
ned
on a
ll as
pect
s of
O
SH
tha
t im
pact
on
thei
r w
ork
and
safe
ty.
ETh
e or
gani
zati
on m
akes
no
tim
e av
aila
ble
for
wor
kers
or
the
ir r
epre
sent
ativ
es t
o ha
ve m
eeti
ngs
insi
de t
heir
no
rmal
wor
king
hou
rs.
The
orga
niza
tion
mak
es
littl
e ti
me
avai
labl
e fo
r w
orke
rs o
r th
eir
repr
esen
tati
ves
to h
ave
mee
ting
s. T
hese
are
ver
y in
freq
uent
; th
ey f
ocus
m
ainl
y on
issu
es r
aise
d by
man
agem
ent,
and
onl
y ra
rely
on
issu
es r
aise
d by
w
orke
rs.
The
orga
niza
tion
doe
s ha
ve m
eeti
ngs
on a
re
gula
r ba
sis,
but
the
se
tend
to
occu
r on
ly
once
per
qua
rter
, an
d th
e ag
enda
item
s fo
r di
scus
sion
ten
d to
not
in
clud
e is
sues
rai
sed
by w
orke
rs o
r th
eir
repr
esen
tati
ves.
The
orga
niza
tion
mak
es
tim
e an
d re
sour
ces
avai
labl
e to
allo
w r
egul
ar
mee
ting
s to
dis
cuss
OS
H
issu
es. W
orke
rs h
ave
the
oppo
rtun
ity
to p
ut
issu
es o
n th
e ag
enda
for
di
scus
sion
.
The
orga
niza
tion
mak
es
tim
e an
d re
sour
ces
avai
labl
e to
allo
w w
orke
rs
and
thei
r sa
fety
and
hea
lth
repr
esen
tati
ves
to a
ctiv
ely
part
icip
ate
in e
valu
atin
g,
orga
nizi
ng, pl
anni
ng a
nd
impl
emen
tati
on o
f ac
tion
s to
impr
ove
the
OS
H
man
agem
ent
syst
em.
-
Policy 17
NO
NE
(1
)P
OO
r (
2)
FAIr
(3
)G
OO
D (
4)
ExC
ELL
EN
T (5
)r
ATIN
G
FTh
e O
SH
cul
ture
wit
hin
the
orga
niza
tion
is t
hat
safe
ty a
nd h
ealt
h is
an
extr
a ex
pens
e, a
nd c
ause
s ex
tra
wor
k to
be
done
.
The
OS
H c
ultu
re w
ithi
n th
e or
gani
zati
on f
ails
to
prop
erly
see
the
val
ue o
f go
od O
SH
pro
cedu
re a
nd
prac
tice
s. T
his
nega
tive
at
titu
de is
tra
nsm
itte
d to
w
orke
rs.
The
OS
H c
ultu
re in
th
e or
gani
zati
on is
in
diff
eren
t to
OS
H, an
d ta
kes
no r
eally
pos
itiv
e in
itia
tive
s to
pro
mot
e w
orke
r pa
rtic
ipat
ion
or
invo
lvem
ent
in O
SH
m
atte
rs.
The
OS
H c
ultu
re in
th
e or
gani
zati
on is
po
siti
ve, an
d th
is h
as
enco
urag
ed g
ood
leve
ls o
f w
orke
r in
volv
emen
t an
d pa
rtic
ipat
ion.
The
OS
H c
ultu
re is
ex
trem
ely
posi
tive
, an
d is
val
ued
by b
oth
man
agem
ent
and
wor
kers
. W
orke
rs a
re f
ully
eng
aged
an
d pa
rtic
ipat
e w
idel
y on
O
SH
mat
ters
.
GW
orke
rs f
eel l
ittl
e re
spon
sibi
lity
for
OS
H
perf
orm
ance
. Th
ey r
egar
d it
as
the
resp
onsi
bilit
y of
th
e m
anag
emen
t or
the
O
SH
pro
fess
iona
l.Jo
b de
scri
ptio
ns d
o no
t de
tail
OS
H p
erfo
rman
ce.
Wor
kers
acc
ept
som
e re
spon
sibi
lity
for
OS
H
perf
orm
ance
, bu
t ar
e no
t gi
ven
the
oppo
rtun
ity
to
part
icip
ate
fully
in O
SH
m
atte
rs.
OS
H is
not
det
aile
d in
job
desc
ript
ions
.
Wor
kers
see
OS
H a
s pa
rt o
f th
eir
role
and
re
spon
sibi
lity,
and
OS
H
is a
n el
emen
t in
the
ir jo
b de
scri
ptio
ns.
Wor
kers
do
not
rece
ive
feed
back
or
reco
gnit
ion
for
OS
H p
erfo
rman
ce.
Wor
kers
see
OS
H a
s pa
rt
of t
heir
res
pons
ibili
ties
, w
hich
is s
tate
d in
th
eir
job
desc
ript
ion.
Th
ey a
re e
ncou
rage
d to
mak
e su
gges
tion
s th
at w
ill im
prov
e O
SH
pe
rfor
man
ce.
Wor
kers
rec
eive
fee
dbac
k on
OS
H p
erfo
rman
ce,
but
no f
orm
al a
war
d or
re
cogn
itio
n pr
oces
s ex
ists
.
Wor
kers
tak
e ow
ners
hip
of O
SH
pro
gram
mes
; th
ey
appl
y th
em d
ilige
ntly
, an
d ta
ke p
ride
in p
rom
otin
g th
em. O
SH
per
form
ance
is
sub
ject
to
a ri
goro
us
appr
aisa
l pro
cess
by
supe
rvis
ors
and
man
ager
s.
A r
ewar
d an
d re
cogn
itio
n pr
oces
s is
in p
lace
.
HW
orke
rs h
ave
rece
ived
ve
ry li
ttle
info
rmat
ion
or
trai
ning
on
OS
H is
sues
.Th
ey a
re u
nabl
e to
sta
te
the
maj
or h
azar
ds in
the
ir
wor
k en
viro
nmen
t, o
r th
e m
easu
res
to b
e ta
ken
to
min
imiz
e ri
sks.
Wor
kers
rec
eive
d ba
sic
OS
H in
form
atio
n an
d tr
aini
ng a
t th
e ti
me
of
thei
r in
duct
ion.
They
hav
e re
ceiv
ed
no r
efre
sher
or
OS
H
com
pete
nce-
build
ing
trai
ning
, an
d ha
ve li
mit
ed
unde
rsta
ndin
g of
OS
H.
Wor
kers
hav
e re
ceiv
ed
basi
c O
SH
tra
inin
g, a
nd
som
e ad
diti
onal
tra
inin
g re
gard
ing
OS
H la
ws,
re
gula
tion
and
rul
es.
They
are
abl
e to
id
enti
fy h
azar
ds in
the
ir
wor
kpla
ce, an
d st
ate
the
risk
s th
at e
xist
and
the
m
easu
res
to b
e ta
ken
to
min
imiz
e th
ese
risk
s.
Wor
kers
hav
e re
ceiv
ed
basi
c O
SH
tra
inin
g an
d re
fres
her
trai
ning
. Th
ey
can
stat
e th
e ha
zard
s in
th
eir
wor
kpla
ce.
They
are
cap
able
of
unde
rtak
ing
task
ana
lysi
s to
iden
tify
haz
ards
, an
d ar
e ab
le t
o ev
alua
te
pote
ntia
l sol
utio
ns.
The
orga
niza
tion
has
de
velo
ped
and
use
com
pete
nce-
build
ing
tool
s w
hich
ens
ure
that
all
wor
kers
hav
e a
thor
ough
un
ders
tand
ing
of O
SH
co
ncep
ts a
nd t
he s
ite-
spec
ific
risk
s th
at t
hey
may
enc
ount
er.
Wor
kers
are
cap
able
of
und
erta
king
haz
ard
iden
tific
atio
n an
d ri
sk
asse
ssm
ent,
and
are
ab
le t
o co
nduc
t sa
fety
be
havi
our
obse
rvat
ions
.
OVE
rA
LL S
CO
rE
FO
r I
TEM
3.2
WO
rK
Er
PA
rTI
CIP
ATIO
N (
max
. sc
ore
for
this
item
is 4
0)
-
18 Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems
Aud
itor
s f
eedb
ack
Str
engt
hs
Wea
knes
ses
Opp
ortu
niti
es
Thre
ats
Gui
danc
e no
tes
In m
any
case
s, n
atio
nal l
aws
will
man
date
tha
t th
e or
gani
zati
on m
ust
enco
urag
e an
d nu
rtur
e w
orke
r pa
rtic
ipat
ion.
Eve
n if
not
man
date
d by
nat
iona
l law
s, w
orke
r pa
rtic
ipat
ion
is a
n es
sent
ial e
lem
ent
of a
n ef
fect
ive
OS
H m
anag
emen
t sy
stem
, ir
resp
ecti
ve o
f th
e si
ze o
r ty
pe o
f or
gani
zati
on.
Em
ploy
ers
shou
ld e
nsur
e th
at w
orke
rs a
nd t
heir
rep
rese
ntat
ives
are
con
sult
ed, in
form
ed a
nd t
rain
ed o
n al
l asp
ects
of
OS
H, in
clud
ing
emer
genc
y ar
rang
emen
ts,
asso
ciat
ed w
ith
thei
r w
ork.
Em
ploy
ers
shou
ld m
ake
arra
ngem
ents
for
wor
kers
and
the
ir r
epre
sent
ativ
es t
o ha
ve t
he t
ime
and
reso
urce
s to
par
tici
pate
act
ivel
y in
the
pro
cess
es o
f or
gani
zing
, pl
anni
ng, im
plem
enta
tion
, ev
alua
tion
and
act
ion
for
impr
ovin
g th
e O
SH
man
agem
ent
syst
em.
The
orga
niza
tion
sho
uld
ensu
re, as
app
ropr
iate
, th
e es
tabl
ishm
ent
and
effic
ient
fun
ctio
ning
of
a sa
fety
and
hea
lth
com
mit
tee,
and
the
rec
ogni
tion
of
wor
kers
saf
ety
and
heal
th r
epre
sent
ativ
es.
-
Policy 19
Wor
kers
sho
uld
be a
ctiv
ely
invo
lved
in e
mer
genc
y pr
epar
edne
ss, ta
sk a
naly
sis,
saf
ety
asse
ssm
ents
, ev
alua
tion
and
rev
isio
n of
sta
ndar
d op
erat
ing
proc
edur
es, O
SH
tr
aini
ng p
rogr
amm
es a
nd e
valu
atio
ns/a
udit
s.
Wor
kers
at
ever
y le
vel o
f th
e or
gani
zati
on s
houl
d be
act
ivel
y in
volv
ed in
the
dev
elop
men
t, im
plem
enta
tion
and
con
tinu
ous
impr
ovem
ent
of O
SH
arr
ange
men
ts.
Wor
ker
part
icip
atio
n is
an
esse
ntia
l ele
men
t of
sou
nd O
SH
arr
ange
men
ts, an
d id
eally
wor
kers
sho
uld
be e
ncou
rage
d to
ass
ume
owne
rshi
p of
the
OS
H p
roce
ss.
Wor
kers
sho
uld
feel
em
pow
ered
to
act
imm
edia
tely
if t
hey
see
unsa
fe c
ondi
tion
s or
at-
risk
beh
avio
urs
in t
he w
orkp
lace
, an
d sh
ould
hav
e th
e po
wer
to
stop
wor
k w
here
the
y se
e an
y si
tuat
ion
that
cou
ld c
ause
har
m t
o pe
ople
or
prop
erty
.
Goo
d co
mm
unic
atio
ns a
re v
ital
to
ensu
re t
hat
wor
kers
and
man
agem
ent
are
cons
tant
ly u
pdat
ed o
n O
SH
issu
es a
nd m
atte
rs.
The
orga
niza
tion
sho
uld
ensu
re t
hat
wor
kers
hav
e bo
th f
orm
al a
nd in
form
al c
hann
els
to c
omm
unic
ate
thei
r co
ncer
ns r
egar
ding
OS
H is
sues
, an
d to
be
able
to
shar
e th
eir
idea
s to
impr
ove
the
OS
H p
rogr
amm
e.
-
Organizing
-
23Organizing
Org
aniz
ing
Item
3.3
res
pons
ibili
ty a
nd a
ccou
ntab
ility
NO
NE
(1
)P
OO
r (
2)
FAIr
(3
)G
OO
D (
4)
ExC
ELL
EN
T (5
)r
ATIN
G
AN
o on
e in
the
org
aniz
atio
n ha
s ta
ken
resp
onsi
bilit
y fo
r O
SH
or
the
prot
ecti
on
of w
orke
rs.
Man
agem
ent
dem
onst
rate
s lit
tle
inte
rest
in O
SH
, an
d fa
il to
tak
e ov
eral
l re
spon
sibi
lity
for
OS
H.
The
orga
niza
tion
acc
epts
so
me
resp
onsi
bilit
y fo
r O
SH
, bu
t no
ove
rall
cont
rol i
s ex
erci
sed.
The
orga
niza
tion
acc
epts
re
spon
sibi
lity
for
OS
H a
nd
the
prot
ecti
on o
f w
orke
rs.
The
orga
niza
tion
clea
rly d
emon
stra
tes
its
acce
ptan
ce o
f re
spon
sibi
lity
to p
rote
ct w
orke
rs a
nd
othe
rs f
rom
haz
ards
.
BR
oles
and
res
pons
ibili
ties
ha
ve n
ot b
een
defin
ed.
Rol
es a
nd r
espo
nsib
iliti
es
have
bee
n co
mm
unic
ated
ve
rbal
ly, bu
t ha
ve n
ot
been
doc
umen
ted.
Wor
kers
pay
litt
le r
egar
d to
ful
fillin
g th
eir
role
s or
re
spon
sibi
litie
s.
Rol
es a
nd r
espo
nsib
iliti
es
have
bee
n co
mm
unic
ated
bo
th v
erba
lly a
nd in
w
riti
ng. W
hen
ques
tion
ed,
som
e w
orke
rs w
ere
unab
le
to s
tate
cle
arly
wha
t th
eir
role
s an
d re
spon
sibi
litie
s w
ere.
Rol
es a
nd r
espo
nsib
iliti
es
have
bee
n co
mm
unic
ated
bo
th v
erba
lly a
nd in
w
riti
ng t
o m
ost
wor
kers
. W
hen
ques
tion
ed, w
orke
rs
wer
e ab
le t
o de
scri
be t
heir
ro
les
and
resp
onsi
bilit
ies.
Rol
es a
nd r
espo
nsib
iliti
es
have
bee
n co
mm
unic
ated
to
eve
ry w
orke
r, bo
th
verb
ally
and
in w
riti
ng.
Wor
kers
wer
e ab
le t
o de
scri
be t
heir
rol
es a
nd
resp
onsi
bilit
ies
in d
etai
l, an
d w
ere
enth
usia
stic
ab
out
perf
orm
ing
thes
e.
CTh
ere
was
no
mea
sure
men
t of
pe
rfor
man
ce b
eing
mad
e,
and
wor
kers
wer
e ne
ver
mad
e ac
coun
tabl
e fo
r th
eir
perf
orm
ance
.
Ther
e w
as n
o ac
tion
tak
en
by m
anag
emen
t to
mak
e w
orke
rs a
ccou
ntab
le f
or
perf
orm
ing
thei
r ro
les
and
resp
onsi
bilit
ies.
Som
e w
orke
rs w
ere
awar
e of
the
ir r
oles
and
re
spon
sibi
litie
s. T
hey
wer
e aw
are
that
the
y w
ould
be
obse
rved
and
mea
sure
d on
ly o
ccas
iona
lly, an
d th
at
this
did
not
invo
lve
ever
y w
orke
r.
Mos
t w
orke
rs w
ere
awar
e of
the
ir r
oles
and
re
spon
sibi
litie
s, a
nd
they
kne
w t
hat
som
e le
vel o
f ob
serv
atio
n an
d m
easu
rem
ent
wou
ld
gene
rally
be
mad
e.
Wor
kers
kne
w t
hat
they
w
ould
gen
eral
ly b
e m
ade
acco
unta
ble
for
thei
r be
havi
our.
All
wor
kers
kne
w
exac
tly
thei
r ro
les
and
resp
onsi
bilit
ies,
and
w
ere
awar
e th
at t
heir
pe
rfor
man
ce w
as b
eing
m
easu
red.
Wor
kers
kne
w
that
the
y w
ere
held
ac
coun
tabl
e, a
nd t
hat
acti
on w
ould
be
take
n if
th
ey f
aile
d to
ful
fil t
heir
ro
le t
o th
e sa
tisf
acti
on o
f m
anag
emen
t.
-
24 Audit Matrix for the ILO Guidelines on Occupational Safety and Health Management Systems
NO
NE
(1
)P
OO
r (
2)
FAIr
(3
)G
OO
D (
4)
ExC
ELL
EN
T (5
)r
ATIN
G
DTh
e en
terp
rise
fai
led
to
defin
e an
d co
mm
unic
ate
the
OS
H s
truc
ture
tha
t w
as in
pla
ce t
o m
anag
e sa
fety
and
hea
lth.
No
one
was
iden
tifie
d as
bei
ng r
espo
nsib
le f
or
OS
H.
OS
H w
as n
ot s
een
as
a lin
e m
anag
emen
t fu
ncti
on, bu
t w
as p
lace
d in
the
han
ds o
f a
safe
ty
offic
er.
Man
agem
ent
was
di
seng
aged
fro
m t
he O
SH
pr
oces
s, a
nd w
orke
rs h
ad
no c
lear
und
erst
andi
ng
of t
heir
dut
ies
or
resp
onsi
bilit
ies.
OS
H w
as s
een
as a
line
m
anag
emen
t fu
ncti
on,
but,
whe
n qu
esti
oned
, su
perv
isor
s cl
aim
ed t
hey
had
no t
ime
to m
anag
e sa
fety
and
hea
lth
issu
es.
OS
H w
as s
een
as a
line
m
anag
emen
t fu
ncti
on,
and
this
was
wel
com
ed
by li
ne s
uper
viso
rs a
nd
man
ager
s.S
enio
r m
anag
emen
t su
ppor
ted
line
man
ager
s,
and
ensu
red
that
line
m
anag
emen
t w
as v
isib
le
and
able
to
iden
tify
w
here
wor
kers
wer
e no
t fu
lfilli
ng t
heir
rol
es o
r re
spon
sibi
litie
s.
OS
H w
as s
een
as a
line
m
anag
emen
t fu
ncti
on,
and
ever
y w
orke
r ha
d a
safe
ty a
nd h
ealt
h ro
le a
nd
resp
onsi
bilit
y.Th
e or
gani
zati
on o
f he
alth
and
saf
ety
had
been
com
mun
icat
ed a
nd
unde
rsto
od b
y al
l, an
d w
orke
rs c
arri
ed o
ut t
heir
du
ties
and
res
pons
ibili
ties
en
thus
iast
ical
ly.
Wor
kers
und
erst
ood
the
stru
ctur
e of
OS
H
man
agem
ent,
and
who
he
ld a
utho
rity
for
dif
fere
nt
elem
ents
of
OS
H.
ETh
e su
perv
isor
s in
the
or
gani
zati
on s
how
ed n
o in
tere
st in
hea
lth
and
safe
ty, an
d fo
cuse
d on
ly
on m
axim
izin
g pr
oduc
tion
an
d pr
oduc
tivi
ty.
Sup
ervi
sors
fel
t lit
tle
resp
onsi
bilit
y fo
r he
alth
an
d sa
fety
, an
d di
d no
t se
e O
SH
as
a lin
e re
spon
sibi
lity.
Sup
ervi
sors
acc
epte
d th
at
they
had
res
pons
ibili
ty
for
OS
H, an
d w
ere
will
ing
to p
erfo
rm t
his
duty
, bu
t la
cked
the
tim
e to
giv
e it
th
e ri
ght
leve
l of
atte
ntio
n.
Sup
ervi
sors
acc
epte
d th
ey h
ad a
dut
y to
pr
otec
t w
orke
rs f
rom
OS
H
haza
rds.
The
y ac
tive
ly
invo
lved
and
enc
oura
ged
wor
kers
in f
ulfil
ling
thei
r O
SH
dut
ies
and
resp
onsi
bilit
ies.
They
sch
edul
ed t
ime
each
w
eek
to o
bser
ve w
orke
rs,
and
to p
rovi
de f
eedb
ack
to w
orke
rs o
n th
eir
perf
orm
ance
.
Sup
ervi
sors
acc
epte
d th
ey
had
a m
ajor
res
pons
ibili
ty
to p
rote
ct w
orke
rs f
rom
he
alth
and
saf
ety
haza
rds.
Sup
ervi
sors
and
man
ager
s sc
hedu
led
tim
e ea
ch d
ay
to c
ondu
ct o
bser
vati
ons,
an
d to
obt
ain
feed
back
fr
om w
orke
rs r
egar
ding
O
SH
issu
es.
-
25Organizing
NO
NE
(1
)P
OO
r (
2)
FAIr
(3
)G
OO
D (
4)
ExC
ELL
EN
T (5
)r
ATIN
G
FTh
e or
gani
zati
on
has
no s
yste
m t
hat
prom
otes
coo
pera
tion
an
d co
