The New Work Item Proposal (NWIP) for development of an ISO Occupational Health and Safety Management System standard has been approved. A new ISO Project Committee, PC 283, has been established to develop the standard. BSI has been appointed as secretariat.
The intent is that this new ISO standard will replace OHSAS 18001:2007.
As I outlined in a prior blog post, there are several issues associated with this standard development activity. The most important of these is that the development of ISO standards must conform with the ISO directives, including the requirements for management system standards set out in Annex SL.
Several interesting aspects to this NWIP –
1. This is a proposal for a Project Committee (PC), not a Technical Committee (TC).
The distinction is that a Project Committee is authorized to develop a single standard. This is the approach that was used for the development of ISO 50001:2011 – the ISO Energy Management System standard. An ISO PC can be converted into a TC in the future but, at least initially, the standard development authority of this ISO committee will be limited solely to the development of the one standard being proposed – an OHSMS requirements document.
2. Given the past controversy that has surrounded the development of an ISO OHSMS standard, this NWIP includes two additional letters.
The first is a letter from the Rob Steele, the ISO Secretary General, addressing the right and ability of ISO to deal with the subject area. The second is a letter from the International Labour Organization (ILO) expressing its concerns with ISO’s decision to proceed with this standard development effort.
3. Any ISO OHSMS standard will be required to meet the requirements for management system standards that are set out in Annex SL of the ISO Directives.
What this means is that an ISO OHSMS will not be based on any of the existing OHSMS standards – including OHSAS 18001 or ANSI Z10. These standards can serve as reference documents but many of the important requirements of an ISO OHSMS will be determined solely by the high-level structure and core common text that are set out in Annex SL.
ANSI is in the process of circulating this proposal to stakeholder groups in the United States. I am confident there will be a great deal of discussion of this NWIP. It is likely that there will be continued disagreement concerning the appropriate venue for developing OH&S standards.
As set out in BSI’s justification document, the world is markedly different today from what it was when an ISO OHSMS standard was last proposed.
Today, protection of workers is as much driven by a complex web of supply chain relationships and sustainability initiatives as it is by governmental decrees and enforcement actions. As show by the success of the certification initiatives that have developed around the handling of electronics waste, publicity and supply chain initiatives can have a greater impact in protecting worker health than governmental rulemaking.
In addition, given the increased use of outsourcing arrangements, many individuals performing work on an organization’s behalf are no longer employees in the traditional labor law sense. By extension, worker safety is no longer solely an employment issue. As explicitly set out in OHSAS 18001, and recognized in several OSHA standards, an organization’s obligation to protect workers extends beyond employees to individuals who are performing work on an organization’s behalf. This can include a range of parties – including contract workers, employees of contractors, volunteers, visitors to the workplace and employees.
Worker safety is no longer simply a labor issue to be addressed through governmental action.
A letter from the International Labour Organization (ILO) dated 26 February 2013 expressed its concern with the proposal. According to ISO, these are ILO's opinions only, and ISO states it is important to clarify a number of issues related to the role of ISO in this field, specifically (these are ISO’s clarifications):
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 six 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 attached 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.
This article originally appeared on Thea’s blog, OHSAS 18001 Expert http://ohsas18001expert.com Thea is one of the country’s leading authorities on occupational health and safety management systems.