communication process may seem obvious and basic, but consider the form(s) of communication between the implementation team members and others in the organization. How often will face‐to‐face meetings be held? How often will senior management be briefed? Will electronic mail be used extensively? How will documents be tracked as they are being developed and modified? Consider early the form of the progress report that will document the progression of the project from beginning to end.
Maintaining Momentum. Consideration should be given to the way that support and focus will be maintained throughout the implementation process. Full implementation in a large organization may take well over a year. Well‐defined communication mechanisms and intervals will assist in maintaining focus. Consider informal ways that support can be maintained. An example maybe through occasional informal discussions with senior managers, or lunch debriefs.
Anticipating and Responding to Breakdowns. At the earliest point in the implementation process, think about things that can go wrong or events that might occur that would threaten the implementation process, or challenge momentum. Consider early how breakdowns will be addressed and morale maintained through the implementation process. Discuss plans to deal with such roadblocks proactively with supporting stakeholders that will be needed during such times, such as senior managers.
7.7 Evaluation and Continual Improvement
Following the implementation of an OHSMS, regular evaluations of it are done by design. The goal of these ongoing evaluations is to ensure the proper functioning of the system and to identify ways to improve it. Evaluation is essential for the proper functioning of the system and to maintain its ongoing relevance to the organization. Evaluations include self‐inspections, internal audits, external audits, and management review.
Industrial hygienists and OH&S professionals may be uneasy with the term “continual improvement.” There is a sense that a point may be reached where actions are taken in an inefficient manner simply as a means to fulfill continual improvement requirements. This is not the case. The point is that the organization should be alert for ways to improve its OH&S performance and aspects of the management system. OHSMSs do not dictate how an organization should define its continual improvement activities, but rather, that there is a structured process whereby such definition is generated that is specific to the organization. As such, an organization wants to carefully think through how it will demonstrate its continual improvement, especially if certification will be sought.
7.8 John Kotter's “Leading Change” Body‐of‐Work
In the late 1990s, John Kotter at Harvard University published a seminal article from which evolved an eight‐step “process for successful change” (77). A presentation of the eight‐step process was done through a fable in Our Iceberg is Melting – Changing and Succeeding Under any Conditions (78). The approach's eight steps are presented in Table 2 and provides a perspective that can assist with OHSMS development and implementation.
While all eight steps are important in a successful change initiative, possibly the most important one for industrial hygienists and OH&S professionals to master is Step 4 on “communicating for understanding and buy in.” This step points to the importance of communication skills, such as dialogue, listening, and building a compelling case for a decision or change.
8 AUDITING
Whether in noun or verb form, the term “audit” is historically associated with regulatory compliance determination(s), and more recently, in the MS space, it is associated determining conformance to a standard such as ISO 45001 or ANSI Z10. This term is also associated performance assessment, monitoring, and measurement, by some. As addressed earlier, it is common for OHSMS standards to have internal auditing requirements. Internal auditing is a familiar activity in organizations, and in larger organizations, it is common to have a dedicated internal audit function. OH&S functions are as well familiar with auditing, primarily from regulatory compliance perspective.
TABLE 2 The eight‐step process of successful change.
| Set the stage |
| 1. Create a sense of urgency |
| Help others see the need for change and the importance of acting immediately |
| 2. Pull together the guiding team |
| Make sure that there is a powerful group guiding the change – one with leadership skills, credibility, communications ability, authority, analytical skills, and a sense of urgency |
| Decide what to do |
| 3. Developing the change vision and strategy |
| Clarify how the future will be different from the past, and how you can make that future a reality |
| Make it happen |
| 4. Communicate for understanding and buy in |
| Make sure as many others as possible understand and accept the vision and strategy |
| 5. Empower others to act |
| Remove as many barriers as possible so that those who want to make the vision a reality can do so |
| 6. Produce short‐term wins |
| Create some visible, unambiguous successes as soon as possible |
| 7. Don't let up |
| Press harder and faster after the first successes. Be relentless with initiating change after change until the vision is a reality |
| Make it stick |
| 8. Create a new culture |
| Hold on to the new ways of behaving, and make sure they succeed, until they become strong enough to replace old traditions |
It is important that industrial hygienists and OH&S professionals performing management system audits have training in this type of auditing since it requires an expanded skillset beyond traditional compliance auditing. For example, there is greater emphasis on conducting interviews and interpretation of documents that require the auditor to make assessments and judgments that go beyond simply following a checklist or doing air sampling.
Audit guidelines unique to ISO 9001:1987 were first published in 1990 and 1991 and focused on auditing quality systems. ISO published guidelines for auditing EMS in 1996 when it also published ISO 14001. In 2002, ISO consolidated its quality and environmental audit documents into a consolidated auditing standard (ISO 19011). This standard has subsequently been revised in 2011 and 2018. Industrial hygienists and OH&S professionals can use ISO 19011:2018 (68) to support OHSMS auditing activities.
8.1 Audit Types
In addition to the audit type (regulatory compliance or MS conformance), another consideration is who (party) conducts an (the) audit.
8.1.1 First Party – Internal Audits
First‐party audits refer to audits that are conducted within an organization by members of that organization. Many organizations have robust internal audit programs that assess both