Rank: New forum user
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Hello Just a little advice and clarification please We recently had a OHSAS18001 audit where we had a non conformance raised for not having separate DSEAR assessments for paint spraying, welding, FLT battery charging etc. Although our RA's for these activities obviously include the DSEAR hazards and risks i was told that I needed separate DSEAR assessments duplicating the existing RA's but titled DSEAR Assessment.
Is this accurate advice?
Thanks for any advice offered
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Rank: Super forum user
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Hi Mark
Your auditor is wrong!
P
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Rank: Forum user
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Agree, auditor is wrong.
So long as you cover what DSEAR requires in your general RAs, no requirement to have separate RAs.
Can be helpful in more complex DSEAR situations.
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Rank: Super forum user
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This has come up before; external auditors who should know better expecting separate risk assessments under each piece of legislation. This is exactly the sort of rubbish that gives H&S safety a bad name. There has to be a record of the findings of the risks assessment but it is usually possible to combine several types in one procedure for example to include DEAR and COSHH together, depending on the workplace. I suspect that your auditor has a checklist with each type of assessment listed and it is easier for them to check these if they are all separated out for them.
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Rank: New forum user
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I would agree with the last comment, get a new auditor
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Rank: Super forum user
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Ask him/her to show you in the clauses exactly where it specifically asks for that gem. Or you can appeal, you have that right and a decent auditor should have told you that at some point in the audit.
What about combining your DSEAR stuff with the fire risk assessment(s)? All in one nice neat package.
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Rank: Super forum user
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You could argue the case but would it not be easier to note that the assessment is carried out in accordance with the following regs and then just simply list the regs that matter?
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Rank: Super forum user
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Whilst I hear the argument for & against and appreciate some frustrations its only when U get to court that your RA's will be tested [deemed suitable & sufficient or otherwise] so it is a court appearance that U need to be thinking of as they expect depth etc irrespective of what the current fashion for 'less is best' says
I personally cannot see why U cannot undertake separate risk assessments for each law /area and make sure that they are linked together -This linking together is very important - I work this way and have worked this way for >35 years in virtually every employment situation there is
In the many court cases, HSE/EA investigations inclusive of a number of deaths that my style of working with RA's has been present there has not been 1 occasion where my system has been called into question so it works for me. Additionally each area needs to be evaluated properly and I sometimes find that amalgamating areas dose not do justice to the differing subjects therein
Another very important point is that the day to day documents need to be suitable for the day to day staff/ops. This can be easily achieved using the in-depth primary risk assessment to create your day to day areas
This way of working also makes your audits easier
I am not saying that I am right I am just saying that it is another way of working
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Rank: Super forum user
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I agree there is no requirement to do so. Maybe a wiser auditor would have advised you (rather than raising a NC) that seperate DSEAR RAs would be easier to manage & review in the long run.
It (as always) comes down to proportionate response. I've no idea of your work set up but would guess that at least the paint spray activity deserves a seperate RA
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