Management system guidance
7.4 Communication
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7.4.1 General
Clause 7.4.1 requires your organization to establish, implement and maintain the process(es) it needs for communicating, both internally and externally, about its OH&S management system. ISO 45001 does not ask for a documented procedure, but you must be able to show that you have decided:
- What you will communicate – e.g. the OH&S policy and objectives, hazards and controls, safe systems of work, incidents and lessons learned, changes, legal updates and emergency arrangements;
- When you will communicate – e.g. at induction, before a task starts, at shift handover, after an incident, monthly or when something changes;
- With whom you will communicate – internally between the different levels and functions of the organization; with contractors and visitors to the workplace; and with other interested parties such as enforcing authorities, emergency services, clients, insurers and neighbours;
- How you will communicate – e.g. toolbox talks, safety committee meetings, notice boards, signage, permits to work, intranet, text alerts, letters or reports.
Further requirements of 7.4.1
When setting up its communication process(es), your organization must also:
- consider diversity when working out its communication needs – for example gender, language, culture, literacy and disability. A briefing delivered only in English to a multilingual workforce, or written instructions given to workers who struggle to read, is unlikely to be understood;
- consider the views of external interested parties when designing the process(es);
- take account of its legal requirements and other requirements (see 6.1.3) – many health and safety laws prescribe what must be communicated, such as the significant findings of risk assessments, statutory notices and the reporting of specified injuries to the enforcing authority;
- make sure the OH&S information it communicates is reliable and consistent with information generated within the OH&S management system – e.g. the accident figures given in a tender match the incident log;
- respond to relevant communications about its OH&S management system;
- keep records (retained documented information) as evidence of its communications, where appropriate.
Build a communication matrix
A simple way to satisfy 7.4.1 is a communication matrix or plan with columns for topic, audience, timing, method, person responsible and the record kept. Typical entries include:
- OH&S policy and objectives – all workers – at induction and when revised – briefing, notice board, intranet – signed induction record;
- Hazards, risk assessments and safe systems of work – affected workers and contractors – before work starts and when changed – toolbox talk, method statement, permit to work – talk register;
- Incidents and investigation outcomes – relevant workers and workers’ representatives – after investigation – safety alert, committee minutes;
- Site rules and emergency arrangements – visitors and contractors – on arrival – signing-in card, induction video – visitor log;
- Statutory notifications – enforcing authority – within legal timescales – online report – copy of the submission.
Contractors and visitors
ISO 45001 specifically names contractors and visitors to the workplace. Make sure they know the site hazards, the rules they must follow, what to do in an emergency and how to report a hazard or incident. Communication must work both ways: contractors should also tell you about hazards they bring onto site, such as hazardous substances, hot work or lifting operations (see 8.1.4 Procurement).
Worker consultation and participation
Communicating is not the same as consulting. Clause 5.4 expects non-managerial workers to be consulted on deciding what needs to be communicated and how it will be done. Involve workers and, where they exist, workers’ representatives when you draw up the communication matrix, choose the methods and review whether messages are actually being received and understood. Lack of communication remains one of the main root causes of incidents, so listen first, then ask for feedback.
Managing sensitive external communications
Take particular care with communications from external parties such as enforcing authorities, lawyers/solicitors and insurance companies. In many parts of the world there is an increasing trend towards litigation following workplace injuries, so decide who is authorized to respond, log what is received and sent, and protect personal and medical information.
You should seek and record evidence that your organization has determined what, when, with whom and how it communicates on OH&S matters; that diversity, legal requirements and the views of external interested parties have been taken into account; that the information communicated is reliable and consistent; that relevant communications receive a response; and that suitable records of communications are retained. Interview workers, contractors and visitors to confirm the messages have actually reached them.
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