I’m probably not the best person to comment on this as I did get a referral on my first try (but the second one did the job) but seeing as no one else has posted I may set the ball rolling. You are doing a gap analysis on the company’s policy, and how it should be in regards to the health and safety model that you are using to assess it. Does the policy statement match the model that you are using if not what are the differences, the gaps, in the policy statement? As for practice, say the policy states that regular consultation with safety representatives will take place but this is not apparent then identify this within the gap analysis. This is a policy statement if it is not being done then that should be identified. Hope this helps

Kay It's a good question and in part I suspect you have already answered it. Also good comments from Pete and firestar. As I see the problem you need to know what you are measuring against? For instance, the company H&S Policy, legal standards, 18001, or 'all of the above'. The second question is are you measuring for adherence or the effectiveness of the h&s management system? The former is arguably easier to check and more objective, whereas the latter requires a more intrusive analysis and is clearly more subjective. With say a gap analysis of 18001 the process may identify non-compliance with certain clauses or sub-clauses, but often does not identify the effectiveness of that particular clause. Accident and incident investigation is a typical example. In how good is the reporting process, are are incidents properly investigated by a competent person, appropriate remedial measures identified, implemented in good time and so on.

What I was going to say was along the lines of thank you all for the posts, very useful indeed, and helps reassure me that I'm on the right track. But it's a steep track! My problem with the GA is that as you all can probably guess, the safety management system (part of an Integrated system) isn't so much a 'system' as a long bunch of un-read procedures that regurgitate legal & ISO/OHSAS requirements, and it's totally impractical (indeed, possibly even impossible) to implement. There is no ’process approach’ or at least not what I would call one. Yup, it ticks most of the boxes from a client's/audit's PoV so an adherence GA wouldn't pick up many gaps, but from an effectiveness PoV I personally feel it's pretty useless. NB: Unfortunately whether I like it or not our clients have a lot of sway on it, as being a service providing company they insist on reading, reviewing and picking holes in it on a regular basis - even down to the wording of a sentence here and there. And all clients are different and want different things adding or removing. But how does one explain this 'feeling' in a GA? I can't pinpoint anything specific, I don't have any hard evidence, and the company functions OK, but I just find it really frustrating - I'm sure there are useful, well drawn-up, succinct and effective management systems out there (would love to experience one) but I don't think ours is one of them. I find it a burden. Hence the question about what an IMS actually should be... Perhaps I'm unfairly biased and not seeing the wood for the trees?

You just beat me with your post almost as bad as the timeout feature. I don’t think (IMHO) the procedures should be stand-alone they should interact. For example a general purchasing procedure as part of ISO9001, should at some point refer to a control procedure for purchase and evaluation of chemicals, machinery etc with regard to safety ( and environment). So for chemicals calls for COSHH assessments to be undertaken ( not how to do an assessment – Just one is required by someone trained to do so). In this way most procedures will link with one another. You are right these procedures will not be read very often, but if produced correctly should not need to be. The way I tacked it was not from the requirements of OHSAS18001, but from what was currently done. I recorded the way things were carried out currently an reviewed how well that matched the requirements in the standard. So the procedure I wrote was what they already did, I then only had to discuss any tweaks that needed to be made to get it to link into the whole system. Low impact on the business, so not much whining. To help me (well others really), I produced a large flow chart of how each procedure interacted to form the whole (which was what the company did). I hope this made some sense and was of some help. I think the clue is in the title management system not management set of unrelated procedures and documents. I sympathise with your predicament with Clients, I came from a similar type of company to the one you are in and understand this completely. My only suggestion is fight as much as possible ( it is YOUR Management system ), but I know this is a problem and ultimately the customer can generally have what they want.

I worked lots of unpaid weekend and evenings -which I would not recommend. No loyalty on their part as they made me redundant. I did list out each of the clauses of 18001 on a spreadsheet which may be of help to you, but I'm not sure I have a copy now. If I can find it I will PM you and you can decide if you want to give me your email address for me to forward. In a way it was easy for me as I was responsible for all 3 accreditation's, plus some add on bits. If you deal with Link up for network rail for instance they are a real pain, and feel that you don't work for any other clients.

Kay I have a very useful 18001 checklist which will assist you in your quest - PM if you like.