Document: ISO/PC 283/N
28 71
Our ref
Secretariat of ISO/PC 283
Date:
22 October 2013
To the Members of
ISO/PC 283
Occupational health and safety management systems – Requirements
Comments received on document ISO/PC 283/N21 Draft "Design Specification" for the development of the ISO OH&S MS standard
with agreed decisions
Please find the comments from N28 and N40 below.
These were reviewed at the Open Forum session held on 22 October 2013, and decisions agreed against each comment, as indicated in the 3rd column.
Yours sincerely
Charles Corrie
For the BSI Secretariat of
ISO/PC 283
charles.corrie@bsigroup.com
1
ISO/PC283/N71
Template for comments and secretariat observations
MB/
NC1
Line
number
Clause/
Subclause
(e.g. 17)
(e.g. 3.1)
Paragraph/
Figure/
Table/
(e.g. Table 1)
Type of
comment2
Document: ISO/PC 283/N 71
Date: 2013-09-18
Comments
Project: ISO OH&S MS
Proposed change
Observations of
the secretariat
General Comments
AR
General
a) Comments on the draft
b) Recommendations

It should be written as a requirements
document. For example: “The new
standard shall…”

Reformat sections 2 and 4 under the
shape of requirements (“The standard
shall….”).

Only sections 2 and 4 contain
requirements. The other sections
provide general and historical
information on the new standard that not
necessarily is needed for the verification
process.

Include that the standard shall be
auditable and be translatable.

Move sections 3, 5 and 6 to the annexes
section of the document.
Not accepted
CO
General
We agree on the design specification
Noted
ILO
General
ILO is offering the following comments, based on our responsibilities set out in the Agreement
between ISO and ILO, seeking to ensure that ISO standards are consistent with international labour
standards. The purpose of the Agreement is to align the private industry minimum with the public
minimum thresholds agreed by the 185 ILO Member States for their use, which significantly influence
the national law and regulations on OSH shaping how companies approach OSH in a given country.
This coherence with the public policy international standard will help users of the ISO standard, and
likely assist in recognition and take up of the ISO standard. The Agreement between ISO and ILO
recognizes that ILS should be treated as authoritative instruments with which the ISO standard would
be consistent and which would prevail over any inconsistent industry standard, in order to ensure the
success of the standard being developed. See also N22 and N 23 comments.
Noted
2
ISO/PC283/N71
Specific Comments
NL
1
ILO
1
Our reaction to the secretariat note in the
introduction about if supporting application
guidelines are needed (page 2): ‘Guidance on –
broadly accepted and applied – performance
indicators (lagging/trailing indicators) for
occupational health and safety (including uniform
definitions for incidents, accidents, illnesses,
employees, contractors, ires, visitors) would
give more clarity about OHS-performance and
lead to better mutual understanding in OHSdiscussions and OHS-cooperation between
organizations (beneficial in internationally
operating companies and organizations, in
international cooperation and benchmarking
etc.). A non-mandatory ISO-document/guideline
on performance indicators accompanying this
ISO standard would be sufficient.’
3
Noted – passed to WG1
1. Principles and general expectations for the
development of the International Standard
2
Occupation health and safety management
systems – Requirements
ILO would suggest using the more common
phrase “Occupational safety and health”, which is
also used in ILO standards. It is a small change,
but may facilitate acceptance and usage since it
harmonizes with ILO terminology on OSH.
4
There is no fixed list of specific items or
requirements to be considered in the
standard.
Where minimum levels of safety and health, and
related methods of compliance, have already
been determined by international labour
standards, such requirements should be included
in the list. This will help to avoid ISO standards
being set lower than other important reference
points for companies.
3
Noted
ISO/PC283/N71
SE
1
US
1
3rd
paragraph,
Secretariat
note
ge
It is preferable to keep the standard tight with its
requirements, and to have the guidelines
separate in the same way as OHSAS 18002. It
will also be easier to recognise the approach if it
is the same as for 18001/18002. Another
advantage is that the development of the
guidelines do not need to delay the standard
itself.
Ge
We support the development and use of a
Design Specification setting out principles and
general expectations for the ISO OHSMS
standard, provided it is developed in accordance
with S.L.8.2.2 of Annex SL.
Keep the same structure as OHSAS 18001
and 18002.
Disagreed
Noted
We look forward to an opportunity to review and
comment on a more fully developed draft
document after the initial meeting of PC283. It is
our expectation that this draft document will be
expanded during the meeting to contain
information about the standard development
timeframe and overall format of the standard to
be developed. Once this information is added it
will be a useful guide to the participants.
US
1
Ge
To guide the work of PC283, it would be
advisable to include the approved scope of the
standard as well as the constraints placed of this
standard development activity as set out in the
NWIP. For example, the approval of the NWIP
by the ISO Member Bodies was for the
development of a type A ISO MSS.
US
1
te
The first sentence of the Introduction states that
the Design Specification provides principles for
the development of the OHSMS standard. It
would be helpful to add OHSMS principles to the
Design Specification to assist in the development
of this standard. A possible list of OHSMS
principles is set out.
Agreed
Consider adding following list of OHSMS
principles to the Design Specification:
Worker Health and Safety Principles
1.
Health and Safety Focus
Worker health and well-being is an
important organizational resource to be
protected through the prevention of injury
and ill health.
2.
Leadership Commitment
Top management needs to provide the
4
ISO/PC283/N71
Agree to include
principles
leadership and resources necessary to
instill a culture through all levels of the
organization focused on identifying,
reducing and managing OHS risks and
improving OH&S performance on a
proactive basis
3.
Worker Engagement
Workers need to have the information,
opportunities and accountability necessary
for them to actively participate in ensuring
their own safety
4.
Factual Approach to Risk
Assessment
The recognition of hazards and
assessment of associated risks should, to
the extent feasible, be based on the
analysis of factual information
5.
Prevention Instead of Reaction
Establishing systematic processes and
appropriate metrics to proactively identify
and address OH&S risks is more effective
than waiting until after an incident has
occurred to react
7.
Supply Chain Accountability
Organizations need to act ethically when
transferring OH&S risks to others in their
supply chain
8. Interested Party Communication
5
1.
Occupational
health and
safety focus
2.
Leadership
Commitment
3.
Worker
Participation
4.
Risk
assessment
5.
Hierarchy of
controls
6.
Proactive
approach
7.
Supply chain
management
8.
Management of
internal and
external
communication
Prioritization of Controls
Workplace equipment , processes and
facilities should be designed for safety.
Hazards should be controlled using
process, equipment and facility controls
before administrative controls and personal
protective equipment are utilized
6.
Principles include the
following (not an
exhaustive list):
ISO/PC283/N71
Organizations should consider the interests
and issues of relevant external interested
parties in establishing and maintaining
their OHSMS
SE
US
2
2
2nd indent
ed
te
Adopt the general terms from ISO 31000
regarding risk management.
To help those developing the standard perform
their work in a timely fashion, a clear and more
concise purpose statement is needed.
We need to be careful about not confusing the
purpose of the standard with the purpose of an
OHSMS. As an example… the standard by itself
will not “Enable organizations to control OH&S
risks and improve OH&S performance”.
However, an effective OHSMS that is skillfully
designed implemented and maintained in
conformance with the OHSMS standard will.
Information about the intended users of the
standard (e.g. bullet point 3) should be moved to
the target audience section (Section 3).
Information relative to the purpose of an OHSMS
content of the standard was included in the
OHSMS Principles.
6
Change “to control OH&S risks” to
Superseded by edit
“to manage OH&S risks”
The overall primary purposes of this
International Standard is to provide
requirements for occupational health and
safety management systems that will:
-
-
Specify what is needed for the
development, implementation,
maintenance and improvement
the essential components of an
OH&S management system
Can be used as auditable criteria
for conducting conformity
assessments of an organization’s
OH&S management system.
-
Enable organizations to control
OH&S risks and improve OH&S
performance
-
Enable organizations of any size
to integrate an effective OH&S
management system with other
management systems to achieve
OH&S and economic objectives
-
Take account of the changes in
OH&S practices since the last
editions of OHSAS 18001, the ILO
OSH Guidelines, ANSI Z10,
AS/NZ 4801 and GB/T 28001, etc.
were published
-
Reflect changes in the
increasingly complex, demanding
and dynamic environments in
which organizations operate
-
Ensure the standard is adequate
to provide confidence in those
ISO/PC283/N71
The purpose of this
International Standard is
to provide requirements
for occupational health
and safety management
systems that
-
Specify the
essential
components of
an OH&S
management
system
Enable
organizations to
demonstrate
conformity to the
requirements
organizations meeting the
standard’s requirements
-
US
2
Items listed are not purposes of the standard.
Some are issues that should be taken into
account in developing the standard.
The following should also be taken into
account in developing this International
Standard:
Since this is the first ISO OHSMS standard not a
revision, the points regarding taking into account
changes are not appropriate.

The standard should enable
organizations of any size, including
small enterprises (SMEs) as well as
large, globally diverse organizations, to
utilize the standard to identity, assess
and control OH&S risks and improve
OH&S performance.

The standard should promote the
integration of an effective OH&S
management system within the
organization’s overall management
system to achieve OH&S objectives.
Other points are too vague to be requirements for
this standard development process. They are not
clearly achievable and/or measurable as is
needed to provide a basis for verification that the
final standard has meant the intent of the
standard development activity.
ILO
2
ILO
2
B3
Ge
Enable organizations to
demonstrate conformity to the
requirements
Agreed
The ILO OSH-MS Guidelines recognize on the
one hand the need for all organizations,
regardless of size, to promote occupational
safety and health; and on the other, the
challenges faced by smaller organizations with
simpler management structures, more limited
resources, and less dedicated and specialized
staff. Our experience—at the international and
national levels, and working with employers’
organizations, which represent SMEs across a
range of sectors—may be useful for helping to
get the right balance in the ISO standard. We
look forward to sharing this experience as part of
the Project committee when issues arise which
may pose particular challenges for SMEs.
Noted
It would be helpful to add to the top of the list the
broader objective of an OSH management
system:
Noted, subsumed by US
comment “essential
characteristics”
The purpose of this standard is to contribute to
the protection of workers from hazards and to the
elimination of work-related injuries, ill health,
7
ISO/PC283/N71
diseases, incidents and deaths (See: Guidelines
on occupational safety and health management
systems, ILO-OSH 2001, para. 1.1.)
ILO
2
B4
It is indeed important to take account of changes
in practices. However, these changes should
build on, and be consistent with, existing
international instruments, in particular ILS, to
ensure that changes advance safety and health
rather than erode established good practice.
Should we have any concerns with changes in
OSH practices which may not be consistent with
ILS and the ILO OSH Guidelines, we will discuss
them during the drafting, to ensure the ISO
standard is fully in accord with ILO instruments.
Noted
ILO
2
B7
A key element of demonstrating conformity
should include involvement of the workers
including through their freely-chosen
representatives, who have both rights and duties
under international labour standards and the
majority of national OSH legal frameworks.
Noted
(The ILO’s Committee of Experts on the
Application of Conventions and
Recommendations noted in its most recent
survey of government law and practice on OSH
that “Safety and Health Committee, or similar
arrangements whereby appointed or elected
workers’ delegates or representatives play an
important role in ensuring dialogue between
workers and the employer in this area, is a
common feature of national OSH legislation.”
See, ILO standards on occupational safety and
health: Promoting a safe and healthy working
environment, ILO 2009, page 66.)
Demonstrating conformity may also pose
particular challenges for enterprises with more
limited resources, especially enterprises in
developing countries where access to assistance
for demonstrating conformity may be more
8
ISO/PC283/N71
difficult to obtain. The design specification
should flag this concern for the drafters.
US
3
ILO
3
te
There are other interested parties.
Add the following –
- Workers, and contractors and their
designated representatives who may
participate in the setting of OH&S
policies and practices within an
organization
- Those providing technical or
professional assistance to an
organization to assist it in reducing
OH&S risks and improving OH&S
Performance (for example, OH&S
Professionals OH&S management
system service providers, including
national standards bodies and
independent certification
bodies,consultants responsible for
assisting with implementing and
assessing OH&S management systems
for organizations; training organizations
offering training in implementing OH&S
management systems
- Those charged with developing,
reviewing and assessing the
sustainability reports of organizations
(e.g. financial reporting and rating
agencies and investors)
The design specification should flag for drafters
that both management and workers have
responsibilities concerning OSH, and should be
involved in developing an OSH policy and
overseeing its implementation through workplace
OSH committees involving both management
and worker representatives (See: ILO OSH
Guidelines, 2001, sections 3.1 and 3.2. ). This
guidance draws on the Occupational Safety and
Health Convention, 1981 (No. 155), Article 20(e)
which recognizes that co-operation between
management and workers and/or their
representatives within the undertaking is an
“essential element” of a national policy on
9
Agreed
Noted
ISO/PC283/N71
promoting OSH.
Another target audience is employers’
organizations who train their members in OSHMS and its underlying national and international
legal frameworks, and can play a critical role in
supporting SMEs to make use of the ISO
standard.
US
ILO
4
te
Although supportive of the need for compatibility
and alignment between the ISO management
system standards, that desire cannot supersede
the obligation of PC283 to develop a clear and
understandable standard that is useful for
establishing, implementing and maintaining an
OH&S management system. The directions to
PC283 in the Design Specification need to be
consistent with the directions provided by the
TMB regarding the use of Annex SL text and
ability to deviate from that text when justified (set
out in JTCG N348 2013-08-06)
The Design Specification should reference
the entire Directives, rather than only
selected sections, as well as pertinent ISO
guides and provide information on where
these documents can be accessed by
members of PC 283 for their review. This
will allow participants to review and
understand the ISO requirements in
preparation for in-person discussions of
the standard.
Discussion of the use of Annex SL text
needs to be consistent with TMB direction.
This section should re-emphasize that the
standard will fully reflect and be consistent with
relevant ILS and related ILO action within the
meaning of the ILO-ISO MoU.
4
Note with URL to the
Directives, other guides,
to be added
Comment withdrawn by
ILO
As to requirements listed:
US
4
te
-
second bullet: “capable of being applied to
the widest possible range of
organizations” We suggest to add at the
end “…, including in relation to access to the
Standard and to conformity services and
related training services, ensuring against
discriminatory impact as to type or size”
-
for the reference to Annex B, see comments
below
As set out in ANSI’s comments on the NWIP, PC
283 should consider the establishment of
appropriate processes and the use of technology
10
This section should include the direction
that PC 283 will consider and to the
maximum extent possible utilize processes
ISO/PC283/N71
Accepted in principle
tools to ensure meaningful and cost-effective
participation by a broad range of relevant
stakeholders.
UK
and technologies to ensure meaningful and
cost-effective participation by relevant
stakeholders. This may be accomplished
through the use of electronic
teleconferences and web-based
collaboration tools.
Add bullet from 2
Agreed
Acount will be taken of
the changes in OH&S
practices since the last
editions of OHSAS
18001, the ILO OSH
Guidelines, ANSI Z10,
AS/NZ 4801 and GB/T
28001, etc. were
published
+ the publication of
ISO31000
SE
5
SE
5
US
5.
te
4th
paragraph
Since the publication of OHSAS 18001:2007, ISO
31000 was published in 2009. It established a
generic framework for risk management. The
new ISO OH&S standard needs to be aligned
with ISO 31000 to reduce the number of different
descriptions of risk management process. It
could in the work be considered to what extent an
alignment should take place.
Add a new paragraph:
Disagreed
ed
OHSAS 18001 defines incident to include
accidents.
Change “accidents and incidents” to
“incidents”
Disagreed
Te
Rather than stating that the PC will consider
guidance in a CEN document and, thereby
making it a mandatory reference document, it
would be better to state what information within
that document should be considered for the
development process. That information would
also be more appropriately placed in section 4.
Delete the 4th paragraph and move
appropriate information to Section 4.
Secretariat: By
resolution 77/2012 the
ISO/TMB has added
the CEN Guide to the
list of “Reference
documents” in the
Directives
“Risk management is an important part of
the OH&S concept. As ISO 31000 has
been published establishing a generic
framework for risk management, the new
ISO OH&S management system standard
shall be aligned with ISO 31000.”
Agreed
US
5
SG
Annex A
Te
Information and directions on liaison with others
should be covered in section 6.
Delete 5th paragraph and move appropriate
information to section 6.
Agreed
We proposed that the following documents be
added to Annex A – List of reference documents
a)
Agreed
11
Singapore Standard SS506: Part 1:
2009, Occupational Safety and Health
ISO/PC283/N71
which may determine the development of the
new standard
(OSH)
Management
Requirements
b)
ILO
System
–
Singapore Standard SS506: Part 2:
2009, Occupational Safety and Health
(OSH)
Management
System
–
Guidelines for implementation of
SS506: Part 1
This list should include the relevant ILO
instruments, a list of which is found annexed to
this document.
Annex A
+ Malaysia standards
+ ISO 26000
+ Japanes standard
JISA
+ Indonesia
Agreed
[Secretariat Note: The listing is not attached.
See instead document PC283/N 31]
These are public instruments adopted in a
transparent, representative process; and the
international labour conventions are binding on
states which ratify them. As such, the Guidelines
and the binding Conventions hold a unique
nature in relation to the industry-based voluntary
standards listed and should be given deference
in case of conflict with the industry standards, to
ensure that the ISO OSH standard will not pose
problems for users vis-à-vis international and
national law.
US
B.1
Td
Some of these points are overly prescriptive and
additional flexibility is needed, while maintaining
the intent expressed in the initial sentence. The
two over-arching themes would appear to be 1)
ensuring the requirements set out in the standard
are clear and 2) ensuring the requirements are
auditable (i.e. usable for conformity assessment
purposes).
Delete existing text and reword as follows:
Bullet points relating to translation issues should
be moved to B.2.
 Cross-referencing will be used as
appropriate to enhance ease of use but
care will be taken to prevent circular
references
Bullet points relating to liaison relations should be
moved to section 5.
ISO/PC 283 shall ensure that the standard
is clear, concise and user-friendly. This
will be accomplished by:
 Using understandable language that is
free from cultural bias and easily
translatable (see B.2 Translation issues)
 Consistent use of terminology will be
maintained while avoiding the excessive
use of jargon
12
ISO/PC283/N71
ISO/PC 283 shall ensure
that the standard is
clear, concise and userfriendly. This will be
accomplished by:
 Using understandable
language that is free
from cultural bias and
easily translatable
(see B.2 Translation
issues)
 Cross-referencing will
be used as
appropriate to
enhance ease of use
but care will be taken
 To the extent possible, terms that cannot
be quantified are to be avoided.
 Sentences will be kept short for ease of
reading, but not so short as to be
ambiguous.
The original scope and intent of the
standard is to be maintained. This will be
accomplished by:
 Writing the standard so that
requirements for an OH&S management
system are clear and unambiguous (i.e.
can be easily audited)
 Clearly delineating between
requirements and any explanatory
guidance information
 Avoiding redundancy that can create
inconsistencies in what is required
 Reducing ambiguity that would
negatively impact the use of the
standard for conformity assessment
purposes
 Consider opportunities for alignment
with other MMS standards, and ISO
14001 in particular, to enhance the
opportunities for combined
environmental and OH&S management
systems and joint auditing
to prevent circular
references
 Consistent use of
terminology will be
maintained while
avoiding the
excessive use of
jargon
 seeking to ensure
consistency of the
standard with
internationallyrecognized public
terminology, wherever
possible,
 To the extent
possible, terms that
cannot be quantified
are to be avoided.
 Sentences will be kept
short for ease of
reading, but not so
short as to be
ambiguous.
The original scope and
intent of the standard is
to be maintained. This
will be accomplished by:
 Writing the standard
so that requirements
for an OH&S
management system
are clear and
unambiguous (i.e. can
be easily audited)
 Clearly delineating
between requirements
and any explanatory
guidance information
 Avoiding redundancy
that can create
13
ISO/PC283/N71
inconsistencies in
what is required
 Reducing ambiguity
that would negatively
impact the use of the
standard for
conformity
assessment purposes
Consider opportunities
for alignment with
other MMS standards,
and ISO 14001 in
particular, to enhance
the opportunities for
combined
environmental and
OH&S management
systems and joint
auditing
ILO
B.1
This Guidance should seek to ensure
consistency of the standard with internationallyrecognized public terminology, wherever
possible, to avoid confusing the user and
facilitate uptake of the standard.
Noted and agreed
The standard is free from cultural bias
Freedom from cultural bias is another reason to
align the provisions of the ISO OSH-MS standard
with ILO’s OSH-MS Guidelines and the related
Conventions and Recommendations, which
reflect the views of 185 member States, and their
most representative employers’ and workers’
organizations. Is should be noted, however, that
the ILO instruments do recognize that there may
be valid differences in national laws and practice,
which should be taken into consideration in
developing the ISO OSH-MS standard.
(For instance, the ILO OSH-MS Guidelines
section 3.2.4 states: “The employer should
ensure, as appropriate, the establishment and
efficient functioning of a safety and health
committee and the recognition of workers' safety
14
ISO/PC283/N71
and health representatives, in accordance with
national laws and practice.”)
ILO
B.2
Where internationally recognized public
terminology exists, every effort should be made
to achieve consistency between the draft
translations of the Standard and the translations
of that terminology as adopted by the public
organization overseeing the public standard.
Add to end of first
sentence:
207/
sc1
Reference (draft) Guide 82 on sustainability
Disagreed
Bela
rus
First of all we have to create Contents of
Draft Design Specification
Disagreed
Where
internationally
recognized public
terminology
1. Introduction
Include in item 1 the
“Background and guidance on
strategic and other key issues”
and reduce text
2. Target audience
3. Strategic intent and purpose
The main strategic objective of
development International
Standard is to provide
organizations with the effective
institutional mechanism based
on risk management to ensure
the occupational health and
safety of each of employees and
other persons. This is an
important part of the
organization's management to
ensure the sustainable
development of the company
and its continued compliance in
15
ISO/PC283/N71
the increasingly complex,
demanding and dynamic
operational environment.
Besides, it is main reason to
adopt the general terms from
ISO 31000 regarding risk
management and we could to
use risk management to achieve
other purposes not only OH&S.
For example, implementation the
programs OH&S. However, to
calculating the level of OH&S
risk should be used the
definition of risk used OHSAS
18001-2007. If we advise to
integrate systems of
management we must to make
single terminologies base.
4. Principles and general
expectations for the development
5. Requirements for the
development process
Include in item 5 the Annex B
“Guidance on drafting”. Add the
requirement of methodology
PDCA
6. Annex A – List of reference
documents
16
ISO/PC283/N71