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OHSAS 18001 - legal requirements, risk and relevance
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Posted By rstewart
I have been asked to update a very old partially completed risk and relevance matrix which forms part of the legal register for my organisation's external accreditation to OHSAS 18001. In my opinion the legal register is very good and comprehensive however the risk relevance matrix linked to it is way too complicated.
I'd very much appreciate if someone else would be able to advise me on how to make it simpler. I have to take into account (if possible) the numbers of employees, the activities they undertake and therefore the likelihood of harm and the relevance all this has to the legislation. We have to do this to demonstrate to our external accreditor that we are complying with OHSAS 18001.
Bearing in mind my organisation is a local government body with thousands of employees in a wide variety of disciplines.
I hope I have made my request clear! Any pointers or advice would be very much appreciated. Thank you.
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Posted By rstewart
Re my query above basically I'm looking for anyone who has interpreted 'evaluated for applicability' so that it meets the OHSAS standard 4.3.2 legal & other requirements in relation the legal register:
'the organization should have a structured approach to ensure that the legal & other requirements can be identified, EVALUATED FOR APPLICABILITY, accessed, communicated and be kept up-to-date'
Thanks
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Posted By bereznikov
Hi rstewart
"Evaluated for Applicability" basically means checking whether the piece of legislation is relevant to your organisation.
For example, the Management of Health and Safety at Work Regulations would be relevant to your organisation, whereas the Ionising Radiation Regulations won't be unless you use such equipment.
There are a lot of update services available that send you email/mail giving a brief summary of any new/amended legislation for you to check if it will apply to your organisation. Just as good (and how i do it) is basically to check the HSE website, OPSI, DEFRA etc for any upcoming legislative changes/introductions then evaluate if they will apply to my organisation.
Once you have identified which laws apply, it is then basically about producing a matrix table to contain it for your records. I would also recommend keeping e-copies of the actual legislation itself, as i have been asked once whether the company has quick access to the H&S legislation that applies to it.
I hope this helps?
bereznikov
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Posted By rstewart
Hi Bereznikov
Thanks for your reply. It does help in that it confirms what we are doing already is correct. I think though that it is felt we should go that extra mile by interpeting the phrase 'structured approach' to this by undertaking a risk and relevancy matrix to show how we have evaluated the applicability of the legislation.
We already have access to Barbour, HSE news alerts etc and by in large know what's applicable to our organisation. In my opinion our legal register is really good. I'm just wondering whether or not we are going way over the top with this when trying to anticipate the findings of the fast approaching external audit.
Thanks again.
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Posted By Jay Joshi
Or could for each piece of applicable legilations have additional information/assessment with the follwing headings:-
Intent & Scope of the Legislation
List of Approved Codes of Practice and Guidance etc
Impact on the organisation--need not be risk matrix based --your choice?
Actions, Communication & Training required
Measures to monitor the effectiveness of the Actions/requirements (could be inspections, audits i.e leading indicators)
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Posted By MLong
Told you you would get answers on here Rob!...If it is Rob??? :o)
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Posted By rstewart
Hi Jay Joshi
Thanks for the reply and I will certainly consider your suggestions. They have definitely given me food for thought and it appears to be much easier to do it this way than the ridiculously over complicated relevancy matrix we are doing at the moment.
Thanks
Hi Mandy
It is me!! See I do listen to you sometimes!
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Posted By David Balkwell
Hi R Stewart
Try this it might help
Legal Management
Best of luck
David Balkwell
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Posted By Steve Clark
Hi, i had a very interesting conversation with an overseas 18001 auditor recently, it went something like this:
Me: putting together a legal register is a lengthy process
Him: why are you doing that, you don't need one. All you need is to be able to demonstrate that you have a system in place that knows the law, interprets in in light of your organisation and can produce work instructions or guidance to ensure your organisation complies with it.
Me: oh - really
Him: yes really, any auditor who insists on one is making it up; but unfortunately a lot of audits ask for it
Food for thought eh? I know my auditor asks for it.
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Posted By David Balkwell
Hi Steve
A couple of things - the point is quite accurate no list list or register is required (its a relic of BS7750) however many organisations prefer that level of control as it provides clear evidence of what has been established as applicable and whats not - add that H&S stuff (not forgetting other) and all the environmental stuff to the task it becomes very difficult to demonstrate whats new and coming through and whats applicable and how it is incorporated through the risk assessment process in determinance of significance of the risk
Finally the way in which this information is managed and ultimately used for Evaluation of Compliance is key to embracing an holistic and meaningful system and not a minimalist meaningless system
Have fun
David Balkwell
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Posted By Safety officer
Agreed.
How are you going to show that you have identified all your applicable legislation if you cannot show that in some form or another?
A list or matrix would do the job wouldn't it? and some people may even call this a register ;-)
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