• Sarah Bond
    62
    Hi Safety People,

    It's been a while since I've posted in here; however, I regularly check-in and appreciated the 'hive mind' information sharing.

    Background: A few months ago a client of mine had a TELARC audit. They passed and found the auditor professional, thorough and good at sharing information to make their system even better.

    Issue: The client was asked to re-write their SMS to match the ISO 450001 format. This is where I lost it. Their SMS has been a decade in the making, it's written in their language and everyone knows how to use it. For example, team leaders know that if they have a worker returning to work from an injury, they need to check Section 6 Rehabilitation and talk through the return to work form.

    Question: What would you do? Re-write the system to keep the auditor happy (anecdotally I've heard that consultants all over the country are charging a lot of money to do this). Or, push back, add in the 'appropriate language' where necessary?

    Keen to hear what everyone else thinks,

    Stay safe,

    SB
  • Sheri Greenwell
    340
    That's preposterous!!

    I would create a navigational guide that can assist the auditor to find what they are looking for. I always say the auditor doesn't live here, but YOU do.

    It's absolutely vital that the system is set up to support the business, not just to make life easy for the auditors - we pay auditors to think, apply, interpret, probe and verify against the criteria, not to dictate the structure.

    I like to think of the organisation's management system as a single building with multiple entrances; you can provide different stakeholders with different navigational strategies that all link into the same management system that is already established and proven effective.

    In the past, I have used hyperlinked documents to assist auditing. You could also set up a page on the intranet that links to your existing management system but is organised with links that relate to the relevant standard for ease of auditing.

    It's also an important consideration that different auditors have different perspectives and hobby horses. What's to say if you set the system up to suit one auditor that it would necessarily suit a different auditor at a different time??

    At the end of the day, if we start shaping our systems for passing audits instead of what works for the organisation, we are headed down a slippery slope.
  • Craig Marriott
    206
    Well said, Sheri.
    Push back. Push back. Then push back some more.
  • Steve H
    308
    I would create a navigational guide that can assist the auditor to find what they are looking for. I always say the auditor doesn't live here, but YOU do.

    It's absolutely vital that the system is set up to support the business, not just to make life easy for the auditors - we pay auditors to think, apply, interpret, probe and verify against the criteria, not to dictate the structure.
    Sheri Greenwell

    Your final sentence sums it up very nicely, Sheri, and ditto with Craig, if the system currently in existence is being used correctly and is understood by the users it's intended to protect, adjust the auditor not the system
  • Jono Johnson
    57
    Surprising to hear that and a little disappointed, particularly as I've had dealings with Telarc on a number of occasions & their auditors were pretty damn good.

    As long as your system covers off what's required in 450001 then tell them to shove it.
  • Garth Forsberg
    34
    I agree with Sherri and Craig as well.
    I've always provided an appendix look up table between the manual and different standards that it covers - especially true for QMS manuals that have had to cover off ISO, CCC (China), UL (USA) and other standards and keep multiple different auditors happy. They just had to look up the cross reference to get to the correct chapter.
    Don't go fixing it if it ain't broke.
    There's nothing in the standard saying how the manual has to be laid out.
  • Aaron Marshall
    118
    To be honest, I wouldn't even bother to push back.
    If you've passed the audit, then I'd ignore the request, or at most respond with "thank-you for the suggestion, we have investigated it and found that it is not suitable for our requirements."
    As Garth has said, a cross-reference is useful and is something I include in all of my manuals, particularly when various requirements are met within one manual.
  • Andrew
    395
    Time to push back on these leeches. All they seem to do is create extra work at extra cost with zero actual benefit to on the ground safety. While lining their own moral free pockets at the same time.

    (Confirms my basic operating principle that the more you write down the more you will get tripped up on)
  • Tony Walton
    129
    The paradox of our times is that we have more degrees, but less sense; more knowledge, but less judgement; more experts, but less solutions. Just saying!
  • Cathy Faulkner
    11
    Agree with comments above - push back.

    Personally I've never advocated for accreditation against standards (unless it's a client/customer requirement). You can still have a HSMM designed to align or comply with the standard wihout getting accreditation and plenty of options for independent review of that system to make sure it's actually fit for purpose.
  • Rowly Brown
    59
    In my opinion conformance with the ISO Standards has become too administratively burdensome for businesses with less than 200+ employees and does little to foment good work practices and safe physical work environments. Andrew summed it up pretty well, as has Cathy. As with ACC's WSMP programme, there's very little analysis and insight gained into work practices from those Systems audits. It's more about the scope of the "system", and the practices can be somewhat different i.e."work done vs work imagined". Much better to get an external reviewer / auditor with good industry experience to conduct a "fresh eyes" review of physical conditions and the working environment, observe work being performed, engage in conversation with workers about what, how, and why they do things, and produce a report that explains what appears to be good, what appears to be not so good, and what to do about the "not so good" stuff.
  • Andy Anderson
    11
    I haven't been on here for a few years, but clicked back on the bookmark link and noticed this one. I am a senior Telarc auditor, wouldn't classify myself as a leech though. I'd be happy to receive the feedback offline and feed it back in to our system Sarah.
    There are a few things here that I would say are the basic principles to auditing a management system. Are the areas that the standards require to be maintained as documented information in place, only six areas of those in ISO 45001:2018.
    Are we doing what we say we do, basic internal requirement of the standard and part of your own internal audit program.
    The critical part of the standards, are some of the core words. The organisational shall determine, not the auditor. If the organisation determines how and what it writes and how certain things will be achieved, e.g. what competency means, then auditors must accept this, as long as it meets the standard.
    Documented information can be in whatever format and style the organisation chooses. So if you provide flowcharts, videos, a manual etc. And they cover the basic requirements of the standard, then that is all acceptable.
    The new standards, when used properly, are actually good tools as the amount of the office time and actual documented information has significantly reduced. The new standards require understanding workers levels of engagement, participation, consultation and understanding and this can only really be done by having good on-site conversations and discussions.
    I'd push back on this if it was a specific requirement. If it was a general discussion about having more information documented than is actually needed these days then it can be considered, but must be weighed up against what is best for the client.
  • Andy Anderson
    11
    There is nothing in the standards that requires a manual either. :smile:
  • Garth Forsberg
    34
    Nothing in the ISO standards, but some of the other standards I've had to "work with" and be be audited to listed specific documents that had to exist. The auditor spent their time writing down the reference number of the document without ever reading the contents. They are the guys that need the cross referenced index in a specific manual.
  • Andy Anderson
    11
    I agree. I think unfortunately, as with everything, not all auditors are the same. And the update to standards sometimes leaves people behind as they fail to adjust their style and the requirements. These days it should be risk based auditing, as much as the client maturity allows.
  • Karen
    9
    Hi Sarah. When you say the client was asked to, was it in the form of an observation or OFI? Or a verbal request?
    I'm an auditor and as long as the system covered the requirements of the Standard and complied with NZ legislation, industry etc., I wouldn't ask that of the client, personally. There are some excellent OHS systems out there which have all the relevant information but aren't written to the format of the Standard.
  • Chris Peace
    84
    I agree with pretty much all of the above. And Sheri had it nailed with her comments three weeks ago. However, I draw attention to the following on page viii of ISO45001:
    "This document contains requirements that can be used by an organization to implement an OH&S management system and to assess conformity. An organization that wishes to demonstrate conformity to this document can do so by:
    • making a self-determination and self-declaration, or
    • seeking confirmation of its conformity by parties having an interest in the organization, such as customers, or
    • seeking confirmation of its self-declaration by a party external to the organization, or
    • seeking certification/registration of its OH&S management system by an external organization."
    An external auditor might add value but so might customers, suppliers, sub-contractors, competitors, trade bodies, and other "interested parties". Their comments and feedback might be very illuminating!
    I'm in the middle of a project on developing guidance for a trade body on an aspect of safety using ISO Annex SL (the base framework for all management system standards) for the framework. This means a user will be able to take the content and apply it to any relevant standard, including ISO450001, ISO9001, ISO14001, etc.
  • Jules
    4
    Hi Sarah, good on you for raising this. I am currently doing some work for an SME who are TELARC audited and who had their IMS rewritten by a consultant to match what the auditor wanted to see. It took me sometime to understand why the IMS started at section 4. I am now in the process of unpicking this, maintaining the structure of the 3 ISO standards but ensuring it fits the character of the business. Incidentally there was nothing wrong with their original system. The IMS (or HSE MS) should be written to fit the business (with certification requirements considered of course and application of ISO) not the system written to fit the standards. Those that are familiar with Safety Cases and the addition of concordance tables understand that there is a simple way of providing an auditor a map to navigate a companies system. As HSE consultants we should be aware of the needs of the business we are supporting. If we are doing this right there should be no issues for an energetic auditor to find their way. I would say push back on the re-write but ensure the original management system has a road map to match it's contents to ISO 45001 so the auditor doesn't get lost.........
  • Alex
    22
    We've had contractors submit their HSMS manual for pre-qualification purposes in the past and have had a couple written to match the old ACC WSMP headings. It was clear that the manual had been written to meet audit requirements and not necessarily the business needs so the questions was raised as to whether or not it was actually followed.
  • MattD2
    338
    ...written to meet audit requirements and not necessarily the business needs...Alex
    Oh but it was written to meet their business needs... the "business need" to reduce cost by getting the 20% discount on their ACC levy.
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