Management system guidance
5.0 Leadership and Worker Participation
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5.4 Consultation and participation of workers
Clause 5.4 is one of the most distinctive requirements of ISO 45001. The organization must establish, implement and maintain one or more processes for consulting workers, and enabling them to participate, at all applicable levels and functions. Where workers’ representatives exist, they must also be involved. Consultation and participation must cover the development, planning, implementation, performance evaluation and improvement of the OH&S management system.
The involvement of workers is a key factor in effective OH&S management because the people who do the work usually know best where the hazards are, and their input enables the organization to make better-informed decisions. Workers are also more likely to support controls they helped to design.
Consultation versus participation
ISO 45001 treats these as different things (see 3 Terms and definitions):
- Consultation means seeking workers’ views before making a decision. It is two-way: workers receive timely information, give informed feedback, and the organization considers that feedback before deciding.
- Participation means involving workers in the decision-making itself, for example jointly carrying out a risk assessment and agreeing the actions.
What the organization must provide
- The mechanisms, time, training and resources needed for consultation and participation. Worker representation can be one such mechanism;
- Timely access for workers to OH&S management system information that is clear, relevant and easy to understand;
- Identification and removal of obstacles or barriers to participation, and minimization of those that cannot be removed;
- Emphasis on consulting non-managerial workers on specified topics (listed below);
- Emphasis on the participation of non-managerial workers in specified activities (listed below).
Barriers can include failing to respond to worker suggestions, language or literacy difficulties, reprisals or the threat of them, and any policy or practice that discourages or penalizes participation. The standard recognizes that providing training free of charge and during working hours, where possible, removes significant barriers. The emphasis on non-managerial workers targets the people carrying out the work activities, but does not exclude managers who are affected by them.
Topics on which non-managerial workers must be consulted
- Determining the needs and expectations of interested parties;
- Establishing the OH&S policy;
- Assigning roles, responsibilities and authorities, as applicable;
- Determining how to fulfil legal requirements and other requirements;
- Establishing OH&S objectives and planning to achieve them;
- Determining applicable controls for outsourcing, procurement and contractors (see 8.1.4);
- Determining what needs to be monitored, measured and evaluated;
- Planning, establishing, implementing and maintaining the audit programme;
- Ensuring continual improvement.
Activities in which non-managerial workers must participate
- Deciding the mechanisms for their own consultation and participation;
- Hazard identification and the assessment of risks and opportunities (see 6.1.1 and 6.1.2);
- Deciding the actions needed to eliminate hazards and reduce OH&S risks (see 6.1.4);
- Determining competence requirements and training needs, delivering training and evaluating it (see 7.2);
- Deciding what needs to be communicated and how (see 7.4);
- Determining control measures and how they are implemented and used (see 8.1, 8.1.3 and 8.2);
- Investigating incidents and nonconformities and determining corrective actions (see 10.2).
Choosing mechanisms
It is up to your organization to decide the best way of ensuring effective consultation and participation, and whether it needs formal mechanisms such as a health and safety committee (which top management must support under 5.1). For small organizations it can be effective to include all workers in discussions and decisions, whilst larger organizations may find it more effective to have one or more workers’ representatives. Other mechanisms include toolbox talks, focused team meetings, workshops, worker surveys, suggestion schemes and inviting workers onto risk assessment and incident investigation teams. Any participation arrangements must take account of applicable legal requirements on worker consultation.
Contractors and others working under your control
Your consultation and participation processes should, where relevant, include contractors and other people carrying out work under the organization’s control. This can include, for example, consulting contractors on hazards that might be new or unfamiliar to them, or that their work introduces to your own workers.
When to consult
Beyond the topics listed above, consult workers whenever planned changes could affect their health and safety (see 8.1.3 Management of change), such as:
- New or unfamiliar hazards, including those introduced by contractors;
- Reorganization or changes in staffing levels;
- New processes, procedures or work patterns;
- The construction, modification or change of use of buildings and facilities;
- The introduction of new or modified equipment;
- New or amended controls;
- The use of new chemicals or materials;
- Changes in emergency arrangements;
- Changes in legal requirements and other requirements.
Your organization should encourage active and ongoing consultation and participation in the development and review of OH&S practices and of the OH&S management system as a whole. Feedback on the system depends on worker participation, and suggestions flow more freely when workers have no fear of dismissal, disciplinary action or other reprisals.
You should seek and record evidence that a consultation and participation process exists and works in practice: for example, committee minutes, consultation records on the policy, objectives and audit programme, risk assessments and incident investigations showing named non-managerial participants, records of time and training given to representatives, actions taken to remove barriers, and feedback given to workers on their suggestions. Interview non-managerial workers to confirm they know how to raise OH&S matters, have been consulted, and have seen their input acted on.
More information on PDCA
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