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John Binns  
#1 Posted : 21 August 2015 10:29:31(UTC)
Rank: New forum user
John Binns

We require a little assistance with the above - without having to call in a 3rd party auditor as suggested during our recent audit. Any ideas on how we can establish procedures to handle this? 4.5.2.1 Consistent with its commitment to compliance [see 4.2c)], the organization shall establish, implement and maintain a procedure(s) for periodically evaluating compliance with applicable legal requirements
Kate  
#2 Posted : 21 August 2015 13:28:32(UTC)
Rank: Super forum user
Kate

I had difficulty identifying this too, then an external auditor helpfully pointed out all the things we were doing that contributed to this. This included inspections, internal audits, health surveillance, incident investigations, fire risk assessments and the like. All the ways in which you can find out that there are breaches (or not). So I wrote a list referring to the specifics of these things and that's our procedure(s).
SBH  
#3 Posted : 21 August 2015 15:00:38(UTC)
Rank: Super forum user
SBH

Are procedures in place for accident investigation ? Do these procedures include clear responsibilities ? Are procedures in place for the reporting of accidents ? Are procedures in place for the reporting of incidents ? Are procedures in place for the initiation and completion of corrective action ? Do these procedures require that all proposed + corrective and preventive actions are reviewed through the risk assessment process prior to implementation ? Are changes to documented procedures resulting from corrective and / or preventive action documented ? Do the investigation procedures state the level of authority of the persons involved ? Do the reporting procedures take into account damage to property ? Do the procedures clearly define the course of action to be taken following non-conformances identified ? Do procedures exist for immediate action to be taken upon observation or reporting of non-conformances ? Are such procedures linked to emergency plans ? How are accident reports documented ? Do procedures exist for the storage of such records / Do these procedures state responsibility for such storage? Do accident investigation procedures state who is to carry out the investigation? Do they include definition of the root cause of any non-conformance? Do they include the arrangements for witness interviews ? Are outstanding or overdue corrective or preventive actions reported to senior management ? Is accident & incident data analysed on a regular basis? Is accident frequency and severity ratings calculated in accordance with accepted practice ? Are regular accident frequency reports issued to management? Do accident report forms include reportable or lost time injury, location of accident, part of body injured, property damage, direct and root cause ? Is such data included within analysis reports? Are records of property damage / repair reviewed ? Are reporting and investigation procedures assessed for effectiveness ? Is such monitoring reported to management ? Is such monitoring included within the overall H&S review process ? Are the investigations of non conformances / accidents / incidents applied to the organisation as a whole ? SBH
boblewis  
#4 Posted : 23 August 2015 10:12:45(UTC)
Rank: Super forum user
boblewis

There are actually two requirements buried in the wording of this clause a) The need to evaluate the level of compliance and b) To evaluate you are aware of all relevant legislation etc. What has been stated above deals with (a) but you need a process monitor (b) also.
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