I consider this requirement to be a key factor in the success of your OH&S/WHS system.
Before we get started, it is important to note that there are three important definitions in this standard that are pertinent to this clause:
Worker – A person performing work or work-related activities that are under the control of the organization (3.1). This could occur under various arrangements; paid or unpaid, regularly or temporarily, intermittently or seasonally, casually or on a part-time basis. Workers also include top management (3.12), managerial and non-managerial persons. Workers may be employed by the organization, of external providers, contractors, individuals, or agency workers.
Participation - Involvement in decision-making. Participation includes engaging health and safety committees and workers’ representatives, where they exist.
Consultation - seeking views before making a decision. Consultation includes engaging health and safety committees and workers’ representatives
The requirements of this standard demand the following:
Your organization has to establish, implement and maintain a process for consultation and participation of workers at all applicable levels and functions and, where they exist, workers’ representatives, in the development, planning, implementation, performance evaluation and actions for improvement of the OH&S management system.
Your organization has to:
1. Provide mechanisms, time, training and resources necessary for consultation and participation. Such as safety meetings, toolbox talks, and safety committee meetings.
**Worker representation can be a mechanism for consultation and participation**
2. Provide timely access to clear, understandable and relevant information about the OH&S management system.
3. Determine and remove obstacles or barriers to participation and minimize those that cannot be removed.
** Obstacles and barriers can include failure to respond to worker inputs or suggestions, language or literacy barriers, reprisals or threats of reprisals and policies or practices that discourage or penalize worker participation**
4. Emphasize the consultation of non-managerial workers on the following:
Determining the needs and expectations of interested parties (see 4.2)
Establishing the OH&S policy (see 5.2)
Assigning organizational roles, responsibilities and authorities, as applicable (see 5.3)
Determining how to fulfill legal requirements and other requirements (see 6.1.3 of ISO 45001)
Establishing OH&S objectives and planning to achieve them (see 6.2 of ISO 45001)
Determining applicable controls for outsourcing, procurement and contractors (see 8.1.4 of ISO 45001)
Determining what needs to be monitored, measured and evaluated (see 9.1)
Planning, establishing, implementing and maintaining an audit programme(s) (see 9.2.2 of ISO 45001)
Ensuring continual improvement (see 10.3 of ISO 45001)
5. Emphasize the participation of non-managerial workers in the following:
Determining the mechanisms for their consultation and participation.
Identifying hazards and assessing risks and opportunities (see 6.1.1 and 6.1.2 of ISO 45001)
Determining actions to eliminate hazards and reduce OH&S risks (see 6.1.4 of ISO 45001)
Determining competence requirements, training needs, training and evaluating training (see 7.2 of ISO 45001)
Determining what needs to be communicated and how this will be done (see 7.4 of ISO 4500)
Determining control measures and their effective implementation and use (see 8.1, 8.1.3 and 8.2 of ISO 45001)
Investigating incidents and nonconformities and determining corrective actions (see 10.2 of ISO 45001)
My blogs over the next few weeks will go into more depth on these ideas.
Emphasizing the consultation and participation of non-managerial workers is intended to apply to persons carrying out the work activities, but is not intended to exclude, for example, managers who are impacted by work activities or other factors in the organization.
It is recognized that the provision of training at no cost to workers and the provision of training during work hours, where possible, can remove significant barriers to worker participation. You could even get some workers involved in the audit process.
I have included three examples of useful documentation related to this blog, which you can find here:
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