Global Community

 

Last week, we looked at Clause 5.3: Organizational roles, responsibilities, and authorities.. This week, we shall look at Clause 5.4: Consultation and Participation

Clause 5.4: Consultation and Participation

Consultation means seeking views before making a decision, which implies two-way communication. On the other hand, participation means active involvement in the decision-making process itself. Having made a distinction between consultation and participation, let's delve into clause 5.4 proper.

The organization shall establish, implement and maintain a process(es) 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.

 

This means that the organization must implement processes to clarify how worker consultation and participation from all levels of the organization (from the top level down) are integrated into the OH&S management system. Specifically, worker consultation and participation are required throughout the development, planning, implementation, performance evaluation, and continual improvement phases of the OH&S management system.

We shall look at it point by point

The organization shall:

1. Provide mechanisms, time, training, and resources necessary for consultation and participation

NOTE 1: Worker's representation can be a mechanism for consultation and participation

The organization must provide opportunities for worker consultation and participation. If this requires taking time off for training or reviewing specific procedures as part of a committee, it must be provided. Worker representatives are a classic mechanism for consultation and participation, serving as a voice for the workforce. 

2. Provide timely access to clear, understandable and relevant information about the OH&S management system.

To effectively consult and participate, workers require access to relevant information regarding the OH&S management system. This information enables them to contribute meaningfully to the decision-making process. However, meaningful involvement requires dedicated time. 

3. Determine and remove obstacles and barriers to participation and minimize those that cannot be removed

NOTE 2: obstacles and barriers can include failure to respond to worker inputs or suggestions, language or literacy barrier, reprisals  and policies or practices that discourage or penalize workers participation.

This means the organization must put everything necessary in place to make sure workers are consulted and they participate in decision making regarding the OH&S management system regardless of any barrier e.g. language, education etc. and worker should not be afraid to express their opinion for fear of being penalized for speaking up.

4. Emphasize the consultation of non managerial workers on the following:

For emphasis on non managerial workers in terms of consultation.

 

1. Determining the needs and expectations of interested parties (Clause 4.2): 

 

When determining the needs and expectations of internal and external interested parties, non-managerial workers must be consulted.

 

2. Establishing the OH&S policy (Clause 5.2): 

 

In establishing the OH&S policy, processes and procedures must be put in place to ensure non-managerial workers are consulted.

 

3. Assigning organizational roles, responsibilities, and authorities (Clause 5.3): 

 

When assigning responsibilities across all organizational levels, non-managerial workers must be consulted. For example, a worker's level of knowledge, experience, and education must be evaluated before assigning specific responsibilities, ensuring skilled roles are not given to unskilled personnel.

4. Determining how to fulfill legal requirements and other requirements (Clause 6.1.3): 

 

Non-managerial workers must be consulted to determine how to fulfill international laws, local regulations, collective agreements, and contractual terms. This will be covered in detail under Clause 6.

 

5. Establishing OH&S objectives and planning to achieve them (Clause 6.2): 

 

When setting safety objectives, targets, and Key Performance Indicators (KPIs)-as well as the action plans to achieve them-consultation with non-managerial workers is required. As the primary workforce executing these plans, their input is vital. This will be expanded upon in Clause 6.

 

6. Determining applicable controls for outsourcing, procurement, and contractors (Clause 8.1.4):

 

 While an organization may outsource activities due to a lack of internal resources, non-managerial workers must be consulted during procurement. This ensures they are aware of how to control the risks and hazards associated with outsourced services and contractors.

 

7. Determining what needs to be monitored, measured, and evaluated (Clause 9.1): 

 

During inspections and performance evaluations, non-managerial workers must be consulted so they understand what is being measured, how it will be monitored, and the evaluation criteria. This will be examined in Clause 9.

 

8. Planning, establishing, implementing, and maintaining an audit programme (Clause 9.2.2): 

 

When developing an internal audit programme, non-managerial workers must be consulted regarding the audit methodology, frequency, and team selection. This will be detailed further in Clause 9.

 

9. Ensuring continual improvement (Clause 10.3): 

 

Non-managerial workers must be consulted when reviewing safety performance against established targets and KPIs, as well as when determining corrective actions for continual improvement. Clause 10 will cover this in detail.

 

The ISO 45001 standard explicitly simplifies the requirements, allowing us to identify the specific areas to focus on regarding the consultation of non-managerial workers. This clarity will be highly beneficial during an audit.

5. Emphasize the participation of non managerial workers in the following:

For emphasis on non managerial workers in terms of participation

1. Determining the Mechanism for Consultation and Participation (Clause 5.4)

This involves developing a formal process for the participation of non-managerial workers in the Occupational Health and Safety (OH&S) management system. Various methods must be established to guarantee active worker engagement and consultation across all organizational levels. 

2. Identifying Hazards and Assessing Risks and Opportunities (Clauses 6.1.1 & 6.1.2)

This requires non-managerial workers to actively participate in the risk assessment process. Because these employees perform frontline tasks on a daily basis, they possess the critical, hands-on information necessary to accurately identify workplace hazards. 

3. Determining Actions to Eliminate Hazards and Reduce OH&S Risks (Clause 6.1.4)

The participation of non-managerial workers is crucial when determining effective control measures to address identified hazards and risks. Frontline insight ensures that the chosen mitigation strategies are practical and effective. The technical specifics of these control measures will be addressed comprehensively in Clause 6. 

4. Determining Competence Requirements, Training Needs, and Evaluating Training (Clause 7.2)

Allowing employees to participate in the OH&S management system provides management with critical information regarding worker competence. This collaborative approach applies equally to identifying specific training gaps and evaluating the overall effectiveness of completed training programs. 

5. Determining What to Communicate and How to Communicate It (Clause 7.4)

Non-managerial worker input is necessary when shaping communication protocols. Management must assess workers' existing communication styles and literacy levels to ensure that safety information is transmitted effectively, accessibly, and transparently. 

6. Determining Control Measures and Their Effective Implementation and Use (Clauses 8.1, 8.1.3 & 8.2)

The entirety of Clause 8 focuses on operationalizing the foundational planning established in preceding sections. Non-managerial worker participation serves as an integral asset during this implementation phase, ensuring safety controls are integrated into daily workflows. These operational details will be explored further in Clause 8. 

7. Investigating Incidents, Non-Conformities, and Determining Corrective Actions (Clause 10.2)

The involvement of non-managerial workers is essential when conducting thorough incident investigations, addressing organizational non-conformities, and determining sustainable corrective actions. Their firsthand views are critical to uncovering root causes and preventing future reoccurrences. Detailed procedures will be outlined in Clause 10

The standard further clarified with the below notes:

NOTE 3: emphasizing the consultation and participation of no managerial workers is intended to apply to persons carrying out the work activities , but it is not intended to exclude, for example , managers who are impacted by work activities or other factors in the organization

NOTE4: It is recognised that the provision of training at no cost to workers and the provision of training during working hours, where possible, can remove significant barriers to worker participation.

We have come to the end of Clause 5. Next week, we shall begin the study of Clause 6: Planning.

Thank you! I appreciate your warm wishes and look forward to hearing your thoughts.

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Nosakhare Aisagbonhi Irabor
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