In this article, I’m going to cover clause 6.1.4 Planning action which is the final clause under the overarching clause 6 Planning. I’m going to break this clause down and turn it into something you can all understand.
You’ll then be able to apply this to your own organization's system and understand what the requirements will look like for you. No more guessing!
Before we get stuck into the actual clause requirements, I want to point out that this final clause is all about actually doing something with what you’ve learned throughout the rest of clause 6.
In fact, Clause 6.1.4 even references these other clauses to help you to see where the requirements for action will come from. This means the standard ensures that it’s not just all warm and fuzzy stuff, but that you actually have to do something with it.
Clause 6.1.4 starts off by stating
The organization shall plan:
- a) actions to:
- 1) address these risks and opportunities (see 6.1.2.2 and 6.1.2.3)
- 2) address legal requirements and other requirements (see 6.1.3)
- 3) prepare for and respond to emergency situations (see 8.2)
I don’t really have to explain too much here because the clause is already pointing you in the direction of the other clauses to refer to! They’ve made it really easy for you. Basically, what they’re saying is that there would be actions required as a result of meeting the requirements of the clauses:
And actually, just touching on that last one that refers to Clause 8.2, the potential emergency situations could also have been identified as part of Clause 6.1 Actions to address risks and opportunities as well as 6.1.2.1 Hazard identification. That’s my opinion anyway!
Now you just have to come up with a plan on how these actions will be implemented, which leads to the next section of this clause which is point
b) how to:
1) integrate and implement the actions into its OH&S management system processes or other business processes;
2) evaluate the effectiveness of these actions.
I love this! This is saying that your plan and your actions are to be a part of your OH&S management system, its policies, procedures, and processes. Again, this is not something that just sits in the corner, these actions become integrated into your business, and they become ‘just how things are done around here’.
To evaluate the effectiveness of the actions integrated into your OH&S management system, you could use Clause 9.1 Monitoring, measurement, analysis, and evaluation, and even Clause 9.2 Internal audit to monitor and determine the effectiveness. Even if this identifies improvements or nonconformances – that’s what you actually want your system to do! Find where the gaps are and implement corrective action to always be improving.
This clause does also state that:
The organization shall take into account the hierarchy of controls (see 8.1.2) and outputs from the OH&S management system when planning to take action.
Again this clause is pointing you in the direction of the related clause of 8.1.2 Eliminating hazards and reducing OH&S risks. This is stating that when planning your actions and integrating them into your OH&S management system ensure that the actions you take follow the hierarchy of control, prioritizing the more effective controls first and where they can be applied.
And then finally the last sentence of this clause states:
When planning its actions, the organization shall consider best practices, technological options and financial, operational, and business requirements.
The actions that you take should align with what resources and operations the business already has in place. Look at what you already have in processes and systems and integrate your actions within these first.
Also, understand what the ‘normal’ practice is in your industry while also considering your access to technology and your own financial resources.
These actions aren’t meant to send you broke! Your financial, technological, and operational resources will influence the level of action you can take.
Now that I’ve explained all of these requirements, can you see more clearly how you could action and demonstrate this within your management system and what it might look like for your business?
While there is no specific documented information requirement stated for this clause, the requirement of integrating and implementing the actions into other business processes indicates that as an auditor you will find these actions within the system as a whole.
If you are implementing a system, be sure to use what is already created in the system and embed the actions within the system. It may not be necessary to create something brand new!
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