ISO 45001: Thinking about practice, too!
The upgrade to the new ISO 45001 standard (occupational safety) is imminent. This is intended to implement many ISO innovations such as high-level structure, stakeholder analysis and other useful features for the topic area of "occupational safety". Without conscientious practical implementation, however, this standard will remain nothing more than a paper tiger.
- Figure 1: Structure of the standard requirements of ISO 45001.Source: SQS, 2017
Companies are eagerly awaiting the repeatedly postponed appearance of ISO 45001. This new standard is intended to make it possible to re-describe occupational safety management systems that were previously certified in accordance with OHSAS 18001 or followed an EKAS industry solution, and to harmonize them with other management systems (ISO 9001, ISO 14001). The detailed structure of the requirements of the standards is known and in Figure 1 pictured on the right.
But what do standard requirements such as "6.1.2 Identification of hazards and assessment of risks" or "8.1.2 Eliminate hazards; reduce A&GS risks" or "7.4.2 Internal communication" mean? The answer to this question is - depending on the situation - "product sheet", "safety data sheet", "operating or work instructions". These documents, which tend to go unnoticed but are important for the implementation of the management system, provide employees with information on the correct procedure to follow when carrying out dangerous work or handling dangerous goods.
What are dangerous works?
Hazardous work is that which is specified in EKAS Guideline 6508 under Annex I "special hazards". Among them we find a whole series such as construction site work, construction cleaning, assembly work, "work with substances hazardous to health", etc.
The question arises in such work as to how the duty to provide information as an employer is to be implemented, for example at a machine such as a punch or when decanting acids? Is it sufficient to simply provide employees with the operating instructions or the safety data sheet?
What does the law say about this?
If the standard requirement "6.1.3 Determination of legal regulations" is met and the duty to provide information is pursued further, then the EKAS guideline 6512 "Work equipment" comes into contact. This guideline regulates how protection goals for employees are achieved and when instruction or training is required. These are based on the Ordinance on the Prevention of Accidents and Occupational Diseases (VUV) and Ordinance 3 to the Labor Act. There, it is required that the employer ensures that all employees working in his company, including employees from other companies working there, are informed about the hazards that occur during their activities and are instructed about the measures to prevent them.
When implementing these requirements, uncertainty and interpretation begin there - what does "sufficient" mean and what is "appropriate"? Here the legislator gives free room for maneuver and personal responsibility to act according to the state of the art, appropriate to the circumstances and necessary according to experience. So it's a matter of finding out and asking around how the requirements are currently being implemented and ultimately dealing with the following questions:
- Are the employees instructed appropriately?
- Can employees perform hazardous work safely with their level of knowledge?
- Do the employees understand the operating instructions or the safety data sheet?
Are the operating instructions or the safety data sheet sufficient?
Whether foundries, construction companies or hospitals, you increasingly see an information sheet in the form of an A4 page, also called operating instructions, in the factories, which gives advice on how to behave in the hazardous area.
An operating instruction for the operation of a machine makes sense; but what about a hazardous substance? Our German neighbor defines this type of instruction quite clearly in TRGS 555 "Technical Rules for Hazardous Substances". Whereby in the conversation about these instructions for chemicals, the word hazardous substance instruction or the so-called compressed safety data sheet tends to come up.
However, drawing up these instructions requires safety-specific expertise. The German regulation "Technical Rules for Hazardous Substances" (TRGS 555) provides good guidance for the content and structure.
It breaks down the instruction into six areas:
- Scope;
- Dangers to people and the environment;
- Protective measures and rules of conduct;
- Behavior in case of danger and malfunctions;
- First Aid;
- Proper disposal (waste).
The contents for these six points can be taken from the operating instructions according to the Machinery Directive or the EC safety data sheet for hazardous substances.
The important thing here is to supplement this with information specific to the company and the workplace. And this is the main sticking point when there is no experience or uncertainty. But this can be countered with a suitable hazard identification. When creating a hazardous substance instruction, care should be taken to work with symbols and graphics in order to facilitate faster comprehension and to provide good information to employees speaking foreign languages. An example of an operating instruction is given in Figure 3 pictured.
Procedure for hazardous substances
For a chemical, find the appropriate phrases from the MSDS. A suitable suggestion is given in Figure 2 presented. When inserting the sentences, it is important that they are clear, short and concise and in the language used by the employees. Sentences that do not apply can also be omitted, such as: "P102 Must not get into the hands of children.", as there are usually no children in a company.
Procedure for machines
In the case of instructions for machines, it is important that the person preparing the instructions discusses the work process with the employees and describes the most important work steps and the potential hazards in the instructions. Subsequently, the necessary protective measures and rules of conduct are defined.
If the instructions are drawn up together with the persons concerned, acceptance increases in the majority of cases and hidden weak points are often identified; in addition, employees are made aware of dangerous habitual activities and new persons in the company can be instructed quickly. When drawing up such instructions, it is important to find the right balance and it may be sufficient to list only the most important instructions.
Once the instructions have been created, the question is often asked, "Do I need to post the documents on site in printed form, or is it enough to save them digitally?" Legislation requires that documents must be accessible to personnel at all times. Provided this is implemented by a technical device, such as a computer, there is therefore no problem. However, it should be clarified whether the documents would also have to be available in the event of a power failure, which speaks in favor of a print version.
Conclusion
The safety-related content of instructions for hazardous work is determined by the requirements of the regulations and important instructions provided by the manufacturer. The instructions must contain all information necessary for the safe operation of machines, systems, equipment or for the safe handling of hazardous substances. In this way, the requirements of A&GS management, which often seem somewhat theoretical, are brought to life.
Instruction - Instruction: What is an operating instruction?
According to TRGS 555 Art. 3.1: In contrast to an operating manual, an operating instruction is a document which is intended exclusively to point out hazards and to indicate protective measures. Operating instructions are workplace and activity-related, binding written instructions and rules of conduct issued by the employer to employees for the protection against accident and health hazards as well as fire and explosion hazards and for the protection of the environment during activities involving hazardous substances.
