The British Standards Institution (BSI), the United Kingdom’s member body to the International Organization for Standardization (ISO), has submitted a proposal for a new international standard that would specify requirements for an occupational health and safety (OH&S) management system.

According to the proposal, the standard would set down a list of requirements for an OH&S system, with the goal of providing organizations with increased control over OH&S risks, allowing for improved performance in this area. The standard would not establish specific performance criteria for OH&S and would not provide detailed specifications for the design of an OH&S management system.

It is expected that the standard would be applicable to any organization seeking to establish, maintain, or improve an OH&S management system. It would not address product safety, environmental impacts, or other health and safety-related subjects.

Following is a letter from the International Labour Organization (ILO) regarding the proposed standard.

New work item proposal – Occupational health and safety management systems – Requirements

Dear Sir or Madam,

A New Work Item Proposal (NWIP) from BSI on "Occupational Health and Safety (OH&S) Management Systems – Requirements" has been circulated today to ISO members for vote.

This letter does not express any view on the merits of the NWIP, instead I would like to address the right and ability of ISO and its members to deal with the subject area.

The idea of an ISO standard on this subject is not new. However, it is being proposed again as BSI feel the landscape for OH&S standards has evolved over the last few years.

For example, ISO has since successfully developed ISO 26000 : 2010 "Guidance on social responsibility", there have been a number of national developments on OH&S standards, and ISO has now adopted a common framework for management system standards.

Given high stakeholder interest in the subject, you will no doubt be contacted by parties that oppose and those that support the proposal.

That is good and what the ISO process is all about.

Attached you will find a letter from the International Labour Organization (ILO) dated 26 February 2013 expressing its concern with the proposal. Their comments are included to support greater collaboration with the ILO, and to inform ISO members about the ILO's views. However these are ILO's opinions only, and it's important to clarify a number of issues related to the role of ISO in this field, specifically:

Is ISO "undermining the role of governments" by developing such a standard?

Put another way, is ISO compromising the role of governments by developing standards in areas that are the subject of national regulation, such as health and safety of workers? Only governments can decide on regulations. This includes whether a voluntary ISO standard is referenced or used as a basis for regulations.

ISO has no role or intent to develop standards that confuse or compromise regulations or public policy. This objective is clearly stated in Annex SO of ISO's Directives on "Principles for developing ISO and IEC Standards related to or supporting public policy initiatives". ISO has already successfully developed International Standards in highly regulated areas (e.g., food safety, medical devices) and experience has shown that the ISO standard has added value to the role of governments and their regulations, rather than having been a hindrance.

Does ISO have the competence to address labour and social issues?

The ILO is a specialized agency of the United Nations that brings together representatives of governments, employers and workers to jointly develop standards, policies and programmes promoting decent work for all. The ILO's international labour standards (ILS) are a means of achieving its objectives, including through ratification in its member States. One of ISO's strengths is the ability of its members to mobilize national stakeholders with expertise and interest in the standards that it develops, and to connect with the most relevant international organizations on a subject. In addition, ISO's audience is not States, but rather organizations. As new fields are proposed, ISO's network is triggered to ensure that the right individuals are engaged in its projects. ISO's competence is assured through its development procedures and its network of national members that involve the required expertise and stakeholder interests.

A recent example is the successful development of ISO 26000 involving 6 categories of stakeholders including but not limited to industry, labour and government.

Can ISO decide to pursue work if ILO disagrees?

In 2007, the ILO Governing Body (the organization's Board) requested that ISO refrain from developing an International Standard on occupational health and safety management systems.

In 2011, the ILO expressed concern and disappointment about ISO's decision to proceed with the field of human resources.

 In 2013, in reply to the BSI NWIP, ILO suggests again that this field is not within the competence of

ISO. It's important to note that ISO is an independent international organization with its own structures and accountabilities. Therefore it is only ISO members that can decide to pursue a new field of activity. It would also go against ISO's own processes to prevent the circulation of new work on the basis of an external organization's disagreement.

I'm hoping that the justification in the NWIP, along with ILO's letter and this letter, help to clarify the issues as you consult stakeholders on this proposal. I encourage you to listen and engage with all relevant interests in your country, to challenge any unfounded claims for or against the proposal and to develop your position accordingly.

Yours truly,

Rob Steele