In this article, I’m going to cover clause 6.1.2.1 Hazard identification which falls 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!
This clause has a lot of requirements which are all there to help us to understand what to look for or take into consideration when we are conducting hazard identification. Before we cover these requirements it may be beneficial to get our heads around the definition of a hazard as per ISO 45001. The term hazard is defined as a source with the potential to cause injury and ill health.
So, therefore, this clause, hazard identification is about identifying the source or sources that have the potential to cause injury and ill health.
The leading sentence for clause 6.1.2.1 is:
The organization shall establish, implement and maintain a process(es) for hazard identification that is ongoing and proactive.
Two words stand out here for me – the first word is ongoing. Hazard ID is not something you do once and forget about. Where and how you work is constantly changing so you have to be aware of what has changed and how this may impact the environment you work in or the tools and equipment that you use. Hazard ID is not a project with an end date, it is a constant.
The second word that stands out to me is proactive. I love that! Hazard ID is conducted as a preventive measure. We don’t wait for something to happen to go ‘oh yeah, maybe we should do something about that now’. The point of hazard ID is to identify the hazards that have the potential to cause an incident, whether this is injury or ill health.
The clause then goes on to state
The process(es) shall take into account, but not be limited to:
and then we are provided with a huge list of what to consider when conducting hazard identification, which I will go through each of these with you now.
Point a) states:
how work is organized, social factors (including workload, work hours, victimization, harassment and bullying), leadership and the culture in the organization.
ISO 45001 has used examples here of workload, work hours, victimization, harassment, and bullying and an overarching angle of looking at the leadership and culture within the organization.
So when you are identifying hazards you might be looking at rosters to determine appropriate workloads across all workers as well as varying work hours or shifts (where suitable).
You might also consider the numbers of sick days taken to identify particular areas of the business that may be having an impact on workers either physically or mentally or both of course. You will identify the leadership and cultural elements through interviews with a broad sample of workers.
Then point b) states
routine and non-routine activities and situations, including hazards arising from:
- 1) infrastructure, equipment, materials, substances and the physical conditions of the workplace;
- 2) product and service design, research, development, testing, production, assembly, construction, service delivery, maintenance and disposal;
- 3) human factors
- 4) how the work is performed.
I do love the use of routine and non-routine activities and situations here. It is all too often that we wear blinkers and just look at what we do day in and day out without taking into consideration the exceptions to the rule.
For example, if we are plant operators and our normal day is operating an excavator. Then one-day the excavator breaks down and you’re in the middle of nowhere with no mechanic or field tech on site. So of course, you decide you are going to see if you can troubleshoot and fix the issue. Is this your routine activity? Are there additional or different hazards that you need to be aware of?
Then point c) states:
c) past relevant incidents, internal or external to the organization, including emergencies, and their causes.
We can learn from what’s happened in the past so we have an idea of what the current hazards and risks are. This isn’t just past relevant incidents that have occurred within your business, it’s also what’s happened in your industry.
If it’s happened to others it’s definitely a potential hazard for you too. What a great opportunity you have been given to put some controls in place before it happens (there’s that proactive approach I mentioned earlier).
Then point d) states
potential emergency situations
This makes total sense – as you work through identifying hazards you will also naturally identify potential emergency situations. Those events still may occur even if you have identified the hazard and put controls in place. what to do once you’ve identified potential emergency situations is further explained when you get to clause 8.2 Emergency preparedness and response.
Then point e) states people, including consideration of:
- 1) those with access to the workplace and their activities, including workers, contractors, visitors and other persons;
- 2)those in the vicinity of the workplace who can be affected by the activities of the organization;
- 3)workers at a location not under the direct control of the organization
So, we need to consider not only our own workers (which does include contractors) that access our workplace but also any other workplace (and its workers) that may be impacted by our activities.
I think of a client I audit here that has a warehouse where they operate a forklift. The forklift does unload trucks directly at the door. The trucks do need to use a common driveway so there are times that the coming and going of trucks does impact the other workplaces sharing the same driveway.
The business I audit has to consider this and ensures that another team member is on the driveway as a spotter while also marking the area with traffic cones that support the traffic management plan they have put in place. You can see that they have identified this activity as impacting their neighbour's workplaces and have put in place controls to mitigate any potential risks.
Then point f) goes on to state that other issues, including consideration of:
- 1) the design of work areas, processes, installations, machinery/equipment, operation procedures and work organization, including their adaptation to the needs and capabilities of the workers involved;
- 2) situations occurring in the vicinity of the workplace caused by work-related activities under the control of the organization;
- 3) situations not controlled by the organization and occurring in the vicinity of the workplace that can cause injury and ill health to persons in the workplace
Understanding how work is actually performed including the work areas, processes, equipment, and procedures can identify if OH&S risks are increased or reduced. This can be conducted by observing and discussing hazards with workers.
Observing these activities while discussing the potential hazards with workers it really opens up the potential for your system to not only identify hazards and potential risks, it also includes consultation and participation of your workers. This will assist with the support of the system, including any changes that may need to be implemented.
Then point g) states:
g) actual or proposed changes in organization, operations, processes, activities and the OH&S management system (see 8.1.3)
Hazard identification is not something that you do just once. It is ongoing as changes are made or as incidents or nonconformances occur. Hazard identification is a proactive approach and should be constantly conducted within the organization to pick up any changes.
And finally point h) states:
h) changes in knowledge of, and information about, hazards
It is important to stay up to date with industry knowledge and information specific to the hazards relevant to your industry. Sources of knowledge, information, and a new understanding of hazards can include industry newsletters or articles, OH&S alerts and updates, feedback from workers, and even the review of your own organization's operations.
All of these sources are about providing you with the opportunity to identify new information about hazards and OH&S risks in your business and in your industry.
This again is a proactive approach to staying on top of what has changed or could change, as well as being continually aware of where new knowledge comes from so that it can be implemented in your own system.
Now that I’ve explained all of these requirements, can you see more clearly how you could act and demonstrate these actions in your management system?
This clause is essentially a very handy checklist for you!
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