Comments on 5.4 "Participation, consultation and representation" in ISO 45001 2nd CD

5.4 Participation, consultation and representation
https://drafts.bsigroup.com/Home/View/3449155?pos=3449155

Comment
This is about Employee Participation: ISO 45001 vs. OHSAS 18001
ISO 45001 weakens the worker’s options compared to what has been achieved in OHSAS 18001:2007, paragraph 4.4.3.2 “Participation and consultation”.

Remedy
Here the employee representatives in the committee probably will have to propose significant changes in order to come to a standard which is acceptable in Europe. My proposal is to at least maintain what has been achieved with OHSAS 18001:2007.
I hope that employee representatives thoroughly compare to the 2nd CD of ISO 45001 what is written about employee participation in OHSAS 18001:2007. Additionally, the differences between OHSAS 18001:1999 and OHSAS 18001:2007 show what had been achieved for the workers thanks to the beneficial competition with the ILO standard. (There also was resistance on the employers’ side against this improvement. I know of a case where a large European company had been certified since 2009 for OHSAS 18001:2007 although they only switched to from :1999 to :2007 in 2013 after complaints by employees to the accreditation authority.) Was OHSAS 18001 too tough on employers? Seemingly the development of ISO 45001 is used by them as a means to revert these achievements.
Unions should check with labour councils how much resistance they met when trying to put 4.4.3.2 of OHSAS 18001:2007 into practise. Support to workers councils by certification auditors may have been negligable too. Employers may want to use the chance provided by a new AMS standard (ISO 45001) to get rid of requirements which gave workes a say in occupational health&safety practises.
Furthermore, the “Certification scheme for occupational health and safety (OHS) management systems according to OHSAS 18001” of the SCCM (Stichting Coördinatie Certificatie Milieu- en arbomanagementsystemen) in the Netherlands is a valuable source for ideas, how workers participation can be put into practice.

 

Comment
There is too much “as applicable” in the draft, e.g. “Effective participation of workers (and, as applicable, their representatives)”. The workers’ representatives need sufficcient competence and clout.

Remedy
The standard should make it an requirement to establish elected workers representations for OH&S matters where no works councils exist yet. Without such representatives you simply can forget about an effective workers participation. One special requirement should be to let the workers’ representatives participate in certification audits and internal audits. These workes should be able to obtain the required qualifications.