Introduction

After an organization has planned risk controls, management-of-change controls, emergency response, and other controls on the basis of hazard identification and risk assessment, it measures, monitors, analyzes, and evaluates OH&S performance and carries out management review. Nonconforming OH&S performance and incidents must be corrected and followed by planned corrective action. For conforming OH&S performance or measures, the organization should use those same performance-evaluation and management-review processes to find opportunities to improve the OH&S management system. This is the “A” step of PDCA.

In light of this, ISO 45001 separates improvement into “incidents, nonconformities and corrective action” and “continual improvement,” and gives different guidance for each. I follow that structure below.

Incidents, Nonconformities, and Corrective Action

In ISO 45001, an “incident” is an occurrence arising out of, or in the course of, work that results in or could result in injury or ill health. An incident that actually causes harm may be called an “accident.”

An incident that does not cause injury or ill health but could have done so is commonly called a “near miss.” Accidents and near misses therefore both fall within ISO 45001’s definition of an incident.

A “nonconformity” is a matter discovered through performance evaluation that does not meet ISO 45001 or the requirements set by the OH&S management system.

Although incidents often result from one or more nonconformities, an incident can also occur where no nonconformity is present.

For incidents and nonconformities, ISO 45001 recommends corrective action to eliminate the cause and prevent recurrence.

When an incident or nonconformity occurs, the organization must respond in a timely way, take action to control or correct it, and deal with its consequences.

In my view, whether an incident or a nonconformity occurs, an incident investigation should first be conducted. Where multiple incidents or nonconformities occur, practical guidance[1] recommends considering the consequences of the events, their frequency, and their potential consequences when establishing and conducting the investigation. The organization should seek the causes, examine possible contributing factors, and simultaneously review its existing assessment of OH&S and other risks.

ISO 45001 calls for organizations to involve workers and relevant interested parties in incident investigations. In my view, organizations should provide a way for workers to take part in discussing investigations and corrective action. How an individual worker participates still depends on their role, the organization’s arrangements, and applicable law.

The organization should then determine the corrective action to be implemented according to the hierarchy of controls and management of change, assess any new OH&S risks that may arise before implementation, evaluate the effectiveness of the corrective action afterwards, and retain documented information on the action taken and the effectiveness evaluation.

Continual Improvement

The significance of following PDCA in an OH&S management system is not only to correct incidents and nonconformities through OH&S performance evaluation. It is also to identify opportunities to improve the management system and raise it progressively.

For this purpose, ISO 45001 suggests continual improvement through the following: (1) improving OH&S performance; (2) promoting a culture that supports the OH&S management system; (3) promoting worker participation in implementing continual-improvement actions; (4) communicating the results of continual improvement with workers or their representatives; and (5) maintaining and retaining documented information as evidence of continual improvement.

In practice, this can be achieved by improving technology, broadly incorporating proposals and suggestions from interested parties, and learning new OH&S knowledge.

Conclusion

This ISO 45001 series has finally reached its last article! I am deeply moved. After publishing so many articles in a single week, my brain is nearly dry as well.

I hope the audience for these articles will be people who are currently working in occupational health and safety, want to put ISO 45001 into practice in their workplaces, but do not know where to begin—partners and friends alike.

Many readers may think an ISO 45001 control system is just paperwork or a way to obtain certification. In reality, that is not how it works.

You may also question my credentials. I am only a graduate of an environmental health program (not occupational health XD—though they have now merged), with a law graduate degree and a master’s thesis, and little practical experience; yet here I am writing at length about ISO 45001 as if I were an “expert.”

Well, I am not an expert. But perhaps you can call me “a navigator on the sea of ISO 45001” or “a land clearer in the jungle of OH&S management systems” (wink).

I first wanted to write about these matters in my master’s thesis because one of my published articles advanced the view that an OH&S management system can be a way to reduce the burden of proof in litigation (I will not link it here, or it would really look like product placement XD).

Once that view had been raised, how could I avoid explaining what a qualified OH&S management system is?

ISO 45001 is the current OH&S management-system standard, but many of its provisions are genuinely abstract and provide only conceptual, framework-level principles, which makes concrete implementation difficult.

Since I had learned law for the thesis and had graduated from public health, why not use that background together with current legal requirements to build these ideas into practical methods that can apply across organizations of many sizes without becoming empty, while better meeting ISO 45001 requirements?

That is how this whole section was born in my master’s thesis. The original motivation was simply personal: to tell the thesis story well and tell it completely.

Still, as someone who cares about marketing and SEO, these articles are undoubtedly unsuccessful. Thesis content is hard to write in a way that fits SEO rules. I provided a corresponding structure and tried to write plainly with frequent paragraph breaks, but the material remains difficult to make truly easy to understand. That is the greater regret.

I hope this article helps readers, even if only a little. To everyone who has read this far, thank you very much for your support : D.

For anyone who would really like to criticize my lack of practical experience: I am currently between jobs, so if you would like to offer relevant practical work that lets me train, gain experience, and become more than a cloud player, you are also very welcome! You can email me through the link below : D!

I am Wakame. OH&S management systems are only one part of my expertise; if you would like to know the others, please see the other articles on my website. See you in another article if our paths cross again (wave).

References

[1] Industrial Development Bureau, Ministry of Economic Affairs. Practical Handbook for Promoting Occupational Health and Safety Management Systems in Manufacturing—ISO 45001, 2019, p. 114.