How to structure health & safety

documentation according to OHSAS

18001
Nobody likes documentation. It is often perceived as a bureaucratic burden that consumes
energy and time with no real added value to the company. OHSAS 18001 documentation
is also perceived in the same manner. And it can be true, depending on how the
documentation is structured and how it is developed. If you develop documents just to
meet the standard requirements, without having a sense of the purpose of each document
and its role in the system, the documentation will be overwhelming and it will make your
OH&SMS (Occupational Health & Safety Management System) inefficient and
ultimately ineffective. How can this common drawback of the management system
documentation be avoided?

Documentation hierarchy

One of the main reasons why the documentation doesn’t work to the company’s
advantage is that the documentation authors don’t have a clear picture of the purpose of
each type of document, and where it belongs in the documentation hierarchy. There are
several types of documents used to establish an OH&SMS: policy, objectives, manual,
procedures, work instructions or SOPs (Standard Operating Procedures), and records and
forms. Each of them has its place and role in the OH&SMS as represented below:

Figure 1 – Documentation hierarchy

People are often puzzled as to which document is the most important, and what document
comes before another. The simplest way to determine the hierarchy is to see who writes
the document: if it is written by the top management, then it goes on the top, if it is filled
in by the employees, it goes on the bottom of the pyramid.

How to structure the documentation

OHSAS 18001 requires certain documentation (for more information, see: Which criteria
to apply when deciding about OHSAS 18001 documentation), and the best way to start
producing a document is to understand its role and purpose before creating and enforcing
it. The documentation for an Occupational Health and Safety Management System should
be structured as follows:

1) OH&S Policy. A policy represents a declarative statement by an organization,

something like a constitution of the system, and all other documents arise from it. The
policy is written by the top management and its purpose is to define the general direction
and aim of the Occupational Health and Safety Management System. The OH&S Policy
also provides a framework for establishing OH&S Objectives. For more information
about the OH&S Policy, see: How to write an OH&S Policy.

2) OH&S Manual. This is not a mandatory document according to OHSAS 18001, but it
is often used to document the scope of the OH&SMS and the main elements of the
OH&S Management System and their interactions, and references to related documents.
Since it is a very common document, it is usually the first document that a certification
body wants to see to get familiar with the system. In the case of a small company or a
company with simple hazards, all procedures can be placed into one OH&S Manual. For
more information about the OH&S Manual, see: Does your organization need a health &
safety manual?.

3) Procedures. OH&S procedures can have different formats and structures. They can be
narrative, i.e., described through text; they can be more structured by using tables; they
can be more illustrative, i.e., using flow charts; or they can be any combination of the
above. Procedures should include title, purpose, scope, responsibilities and authorities,
description of activities, and reference to relevant work instructions, SOPs, and records.

4) Work instructions and SOPs. The most common reason for creating a work
instruction is to avoid nonconformities. It is usually written for those activities within the
process with the highest chance of nonconformity occurrence, or for complex or rarely
conducted activities. Work instructions can be part of a procedure, or they can be
referenced in a procedure. Generally, work instructions have a similar structure to the
procedures and cover the same elements; however, the work instructions include details
of activities that need to be realized, focusing on the sequencing of the steps, tools, and
methods to be used and required accuracy.

5) Records and forms. Finally, there must be some evidence that activities and processes
are conducted in the way prescribed in procedures and work instructions. This is the main
purpose of the records and forms. Most of them are filled in by employees, but some of
them (e.g., Management Review Minutes), are filled in by the top management. The best
way to make them practical is to avoid requiring employees to write essays. Having
records with checkboxes instead of empty rows for employees to write sentences will
ensure that the forms or records are filled in quickly and easily.

Documents should fit your company

If you create documents just to have them on your list, i.e., because the standard requires
that you have them, I have to tell you – you wasted a lot of effort. Even more than that,
you missed the opportunity to set your processes in a managed, i.e., transparent and
controlled way. It is important that documentation is proportional to the level of
complexity, hazards, and risks concerned and is kept to the minimum required for
effectiveness and efficiency.

Having a clear perspective on the purpose and role of each document will help your
organization to establish adequate documentation for its Occupational Health and Safety
Management System, and only the adequate documentation will enable the organization
to meet the requirements of the standard and help in avoiding hazards in the workplace.

Click here to download a free white paper: Checklist of Mandatory Documentation

Required by OHSAS 18001:2007.