LRQA Podcast: ISO 45001 Acting Together

ISO 45001: Acting Together to Build a Positive Safety and Health Culture

6 APRIL 2022 09:00 ◦ 21 MINUTES

In this episode, we continue our conversation with Martin Cottam, Chair of the ISO Technical Committee for Occupational Health & Safety Management. In this episode, we’re talking about the importance of worker participation in building a positive safety and health culture.

Can you tell us about the importance of worker participation in OH&S Management, this seems to be a big theme in ISO 45001 and OH&S Management in general?

OH&S has long been seen as an area requiring collaboration in order to secure the best results and I think this applies at various levels. Starting really at the level of public policy where there’s been a long established tripartite approach, meaning that public policy including regulation of OH&S is developed through collaboration and dialogue between government, employer representatives and worker representatives. And then this carries through to individual organisations where collaboration between employers and workers can really play a big part in achieving good OH&S performance.

For a long time you know we’ve recognised the value of involving workers in specific areas of OHS management such as risk assessment. Since its often only workers themselves who know exactly how work is carried out in practice which of course may well be different from the way that work was originally envisaged to be carried out or different from the way that managers imagine work is carried out. So that detailed understanding that workers bring is really needed to accurately understand the risks.

And then beyond that when it comes to controlling those risks worker input is valuable again because it helps ensure that the controls are practicable and that they really and realistically can be applied in practice and in the day to day context. And another factor is what we sometimes describe as not invented here meaning that workers are rather less likely to apply controls and ways of working on which they haven’t been consulted and in which they have had no input. And they’re much more likely to apply controls which they themselves have helped to design and that they have agreed are necessary and appropriate.

Now there has been as I say this long tradition of involving workers in some parts of the OHS management system such as risk assessment but ISO 45001 goes much further because ISO 45001 effectively says that workers should be consulted and/or participate in all aspects of the OHS management system. And this approach counters the risk of workers perceiving the OHS management system as something not invented here and instead encourages them to see it as a system that they can help shape and influence in  order that everyone is better protected. And that requires a willingness on all parts to engage in constructive debate and of course there’s always a degree of compromise as is necessary in the management of really of any business risk.

Worker participation seems to have been more strongly emphasised in ISO 45001 than it was in previous standards, is that the case?

In many ways the area of worker participation and consultation was the one in which ISO 45001 departed furthest from that generic framework for all ISO management system standards known as Annex SL. Because it effectively gave worker participation and consultation an equal status alongside leadership, leadership of course being one of those standard elements in the Annex SL structure and in that respect, it also went further than the predecessor standards such as OHSAS 18001.

And I think the explanation for this difference between ISO 45001 and OSHAS 18001 is partly to do with the different range of stakeholders who contributed to and influenced the content of the two standards. There was a much broader set of stakeholders involved in the ISO process with stronger participation from those representing workers including the International Labour Organisation, the ILO, as a participant in the project committee and many more worker representatives among the participants nominated by national standards bodies. It is in fact one of the real strengths of ISO and its processes that those processes allow for and encourage very wide and diverse participation in shaping the content of standards.

Thinking of the ISO OHS committee today, we have involvement from 100 countries, the vast majority of those are active as participants but some are observers who still can and do comment on our work at any stage. Now that national input is in turn formulated by mirror committees which again bring together a wide diversity of stakeholders and those committees typically vary in size from perhaps a handful of people in some countries to over 100 people in the case of the USA and the UK is somewhere around half that size.

And then beyond that input draft standards are also made available for public comment at least once during their development cycle and sometimes more. So you know from an OHS perspective where the importance of collaboration has long been recognised, the ISO process itself provides excellent opportunities for a real diversity of input. And it requires of course the committees themselves then to work very collaboratively to reach consensus when considering how to address the many sometimes thousands of comments received on each draft of a document.

So I think its interesting to realise that the stronger emphasise on worker participation that we see in ISO 45001 was effectively the result of a wider participation in the development of that standard, so the standard is itself an illustration of the fact that wider consultation and participation produces better results.

And I’ll just digress for one moment to say that why I think it’s so important for users to take the chance to comment on draft standards when they’re available for public comment. Every comment is individually considered by the committee, that is a requirement of the process and those comments really do make a difference to what eventually gets published.

So I’d really encourage people to consider also you know perhaps joining national mirror committees too for an even greater opportunity to influence the content of standards, and an opportunity also to better understand other people’s perspectives on some of the contentious issues.

What does ISO 45001 require regarding worker involvement and does it allow the healthy negotiation between workers and management?

I would argue that ISO 45001 certainly does allow for healthy negotiation because it encourages there to be consultation and participation of workers across all aspects of the OHS management system. And that of course means that those involved are more likely to get to see the whole picture rather than being consulted piecemeal on isolated issues without an awareness of that broader context. So I think it does provide a very sound foundation for healthy negotiation in that respect.

Its also worth highlighting I think that ISO 45001 talks about both consultation and participation meaning two quite different things and actually this was an area where the project committee that was drafting ISO 45001 had considerable difficulty. Because it gradually became clear to us rather painfully that in different parts of the world those two terms consultation and participation are interpreted quite differently.

I mean if I were to ask you which do you think represents a greater level of involvement for workers consultation or participation? Well from a UK perspective we’d tend to answer by saying that we see consultation as being more limited involvement, just simply being asked for ones views on something. And that from a UK perspective participation in decision making represents a higher level of involvement, a greater level.

So for us worker involvement is more limited in consultation and more extensive if you participate in decision making but as the project committee discovered in some parts of the world the interpretation of these terms is almost exactly the opposite with consultation representing the higher level of involvement. So you can imagine how difficult and confusing those discussions were in the project committee before we gradually came to understand that it was the understanding of the terms which was not consistent across the team.

And that’s in fact why those two terms are so carefully defined in ISO 45001 and by the way it’s a good example really of why its always useful to look really carefully at the terms and definitions section of a standard, its often the section people gloss over and move quickly on to the meat of the standard but it really is quite an important section at times to refer to.

Now ISO 45001 separately specifies those matters on which workers and their representatives should be consulted and those matters on which workers should participate in decision making. So for example workers should be consulted on the OH&S policy, assignment of OH&S roles and responsibilities and the establishment of objectives on things like the audit programme controls for outsourcing, and procurement, and contractors interestingly. Whereas the list of matters on which there should be worker participation in decision making includes identifying hazards and addressing risks which we spoke about earlier, determining controls, competence requirements, communication requirements and involvement in investigation of incidents and non-conformities.

I know that back at the time when ISO 45001 was being developed some people questioned whether organisations would hesitate to apply the new standard because these requirements for worker involvement seemed to be more extensive. But that discussion really disappeared very quickly when the standard was published, and as we know almost every organisation that had previously adopted OHSAS 18001 migrated to ISO 45001 and also a significant number of organisations which didn’t previously use OHSAS, or any other OH&S management system standard, have adopted ISO 45001.

So I can only conclude that users don’t see these requirements as excessive but rather that they, you know they appreciate how much more effective their OHS management can be when workers are fully involved in shaping the approach and when they fully buy into the system.

We hear a lot about diversity and inclusion these days, how does that impact on worker participation?

Diversity and inclusion is an area really of some concern to us in the ISO OHS Committee as there is some recent ISO research which has indicated that we just haven’t been as successful as we hoped in getting across the message that organisations need to consider and address the needs of all workers and interested parties and that this means addressing the full diversity of individuals within these groups.

So for example gender specific needs including those of women, the needs of pregnant workers and new parents. The needs of workers of different age, taking into account both older workers and younger workers whose needs are quite different and indeed the needs of people with disabilities. And indeed there are other factors to consider as well, you know ethnicity for example is, can be a relevant factor because of the implication that that has in terms for example of different physical body sizes and the OHS implications of that.

Now very often in the early drafts of our standards we’ve included lists of examples exactly like the one I’ve just given you, but often in later iterations of the standards we substituted much more generic wording such as you know the phrases like consider the needs of all workers.

And what the ISO research has told us is that without the prompts provided by such specific examples many  users interpret the requirements more narrowly and fail to consider the full spectrum of needs, needs of workers and interested parties. Because part of the role of those examples was to alert us to things which the reader just might not think of or might be unaware of and where a very specific prompt is necessary, and you know perhaps a good example of that would be the need to consider adjustments to light and noise levels for people with neurodiverse conditions such as autism. You know a generic phrase like ‘consider the needs of all workers’ is never going to prompt somebody who doesn’t have an awareness of those factors around autism to think well this maybe relevant to you know workers within my organisation.

So we’re starting to introduce much more specific wording and examples into the guidance standards that we currently have under development and we’ll need to do the same of course with ISO 45001 when its eventually revised. So the implication for worker consultation and participation is that it needs to be capturing input which reflects the full diversity of worker needs and there needs to be mechanisms to ensure that where individuals and groups are not directly involved themselves in that consultation or participation, those who are involved both can and do fully reflect their needs.

And there must be a connection to the participation and collaboration we’re talking about here and the management of workers psychological health and wellbeing addressed in ISO 45003?

I think the significance of worker participation as a positive contribution to workers psychological health and wellbeing comes out very clearly in ISO 45003 when it identifies the factors in fact that can be harmful to workers psychological health and wellbeing at work. The standard specifically mentions limited input to decision making as a factor that can be harmful to workers psychological health and wellbeing.

But equally significantly pretty much every other factor mentioned in the standard as potentially causing harm to workers psychological health and wellbeing is something where consultation collaboration could help avoid that harm occurring. And I’m thinking of examples such as, and these are the ones cited in the standard, you know lack of necessary tools, equipment and resources, inadequate maintenance and repair of equipment, poor workplace conditions in terms of lighting, heating, ventilation or noise, failure to listen to and act on complaints or suggestions. And another one is role ambiguity or role conflict.

So there’s a really clear connection here you know consultation and participation provide a direct opportunity to address specific concerns that may otherwise cause psychological harm to workers if they’re left unaddressed. But they also provide the means to build a positive culture around OH&S within the organisation, which ultimately enables people to feel valued and included. And that means being able to contribute their ideas without wondering how they’ll be treated as a result, so that people are comfortable to voice concerns within the workplace when that’s necessary.

In other words OH&S management depends on collaboration between organisations and their workers, its really in everybody’s interests to have effective consultation and participation for a number of reasons. Wider input produces better decisions, involving workers in decision making creates buy in for those decisions and that in turn helps with implementation. And then the process of consultation and participation itself positively contributes to the phycological health and wellbeing of the workforce and helps build a positive culture within the organisation.