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How to implement Clause 4 of ISO 45001? (Context of the Organisation)

Since the publication of ISO 45001: 2018 Standard in March 2018, there have been lots of forums, sharing sessions, seminars, etc taken place in the country. QuESH Consultants have also conducted a few sharing sessions such as "Coffee Break" with our clients, highlighting the changes and requirement. In some instances, we were also invited by organisations to share some insights on the practical approach of migrating BS OHSAS 18001 requirement to ISO 45001 requirement.

Today, we will share the requirement of Clause 4 basing on our combined years of practical experiences as Management Systems Practitioner, Certification Bodies Auditor and Management Systems Consultant. 

Clause 4 - Context of the Organisation

As we know, context of the Organisation is a new clause in ISO 45001. There are 4 sub-clauses under this, i.e. 4.1 Understanding the organization and its context; 4.2 Understanding the needs and expectations of workers and other interested parties; 4.3 Determining the scope of the OH&S management system; and 4.4 OH&S management system. Requirement of sub-clauses 4.3. & 4.4 are already stipulated in the BS OHSAS 18001, either directly or indirectly. As for clause 4.1 & 4.2, it is something new and we need to demonstrate the conformance accordingly. Let's elaborate these 2 new sub-clauses.

In business perspective, clause 4.1 & 4.2 are essential looking into the development of any business. Even a small start up company will look into this but in an informal approach. E.g. before starting any venture, business owners will usually look at few areas such as market forces, unique selling point, target clients, competitors, pricing, etc. to determine where they "stand" basing on gut feeling. Experienced business owners will probably adopt a more structured approach using analysis tools such as SWOT, PESTEL, STEEPLE... to name a few. 

ISO Standards are developed with the intention to provide solutions and achieve benefits for almost all sectors of activity. In a way, once an organisation successfully adopted any ISO Standard, it should improve / maintain its business operations meeting internationally recognised benchmark. With the inclusion of these 2 new sub-clauses, organisations are required to have a more holistic mindset re-looking into their entire OHSMS in relation to their business activities. With the OHSMS already established basing on BS OHSAS 18001, it should already have some practices in place to manage the OHS risks. So now, organisations will just need to review its OHSMS looking for possible missing pieces with respect to its business activities.

The following diagram shows the expected outputs of clause 4. As you can see, you will need to show some form of documented information demonstrating that you have determined the possible / foreseeable / reasonable issues (positive or negative) that your organisation is facing internally and externally that could affect your OHSMS. For small organisation, this could be quite straightforward with the inputs directly from the boss. However, for bigger organisation which are having complex business operations, it would requires more time and efforts to get the outputs.

Also, you will need to determine your interested parties and what are their expectations. In ISO 45001, it emphasised heavily on the involvement of workers, as such, it specifically included workers as one of your interested parties.

Generally, these 2 sub-clauses requirement can be considered inter-related, e.g. the determined "issues" could be from the determined "interested parties"; "expectations" of "interested parties" could cause an "issue"; etc. Some organisations which we encountered have nicely integrated the determination process and presented a valid inter-relationship between the 2 sub-clauses requirement. See below illustrated matrix.

This exercise of addressing the context is just like a Reflection. People reflect the way they do things so as to seek opportunity for improvement. Similarly, when we implementing the 2 sub-clauses, we are like reflecting our current way of carrying out business activities taking into consideration of our current internal / external issues and interested parties & their needs. Through this, organisations are able to understand their weaknesses and strength so that required follow up actions could be introduced. Ultimately is for the purpose of minimising risks and seeking for opportunities (which is related to Clause 6).

One thing to note is that, the requirement for these 2 sub-clauses is to "determine", as such, there is no need to establish comprehensive analysis criteria on how you "determine". Having said that, it would be good to follow some structured approaches as mentioned earlier.

Preferably, a team or committee comprises of different stakeholders should be established to address clause 4.1 and 4.2 of ISO 45001. Moreover, one of the Top Management Representatives should be the Chairman leading the team or committee looking into the context of the organisation. Annex A of ISO 45001 Standard provides a good reference for organisation to kick start the process (refer to A.4.1 and A.4.2). To have a good analysis, the team or committee should gather necessary and relevant information such as types of cultural workforce; political stability index of a country; age group of workforce; suppliers performance; business activity of neigbouring organisations; etc. to help them on the determination process.

Once the context of the organisation is addressed, it should be reviewed regularly as business situation may change. The regular review is also important as the information of the context of the organisation is required to be considered when determining the organisation's risk and opportunities (Clause 6).

Hope the above provide some insights to kick start your migration process. Remember to subscribe to our newsletter for more articles!

References: ISO 45001: 2018

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