Programme on Safety and Health at Work and the Environment (SafeWork)International Labour OrganizationRoute des Morillons 4CH -1211 Geneva 22Switzerland

TeL. + 41 22 7996715Fax + 41 22 7996878

e-mail : safework @ ilo.org www.ilo.org / safework

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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: pubdroit@ilo.org. 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.

ILO Cataloguing in Publication Data

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The responsibility for opinions expressed in signed articles, studies and other contributions rests solely with their authors, and publication does not constitute an endorsement by the International Labour Office of the opinions expressed in them.

Reference to names of firms and commercial products and processes does not imply their endorsement by the International Labour Office, and any failure to mention a particular firm, commercial product or process is not a sign of disapproval.

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Photocomposed in Switzerland JMBPrinted by the International Labour Office, Switzerland

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.

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.

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

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

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

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.

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.

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.

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.

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.

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.

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