In this article, we consider the aspects of Clause 9 ‘Performance Evaluation’. This is the ‘check’ aspect of the ‘Plan, Do, Check, Act’ cycle. The organisation must establish, implement and maintain processes for monitoring, measurement, analysis, evaluation of performance and management review of their OHSMS.
A logical start is to determine what actually needs monitoring and measuring, and this should address the action taken in response to the requirements of earlier clauses. What, where, why, when and how? Whatever has been planned and organised in previous clauses will set the criteria.
Monitoring applies to the entire OHSMS. It involves continual checks, inspections, examinations and observations in order to identify deviations from the performance level expected. This extends beyond physical processes and controls, into human factors, behavioural monitoring, safety programmes and health surveillance. Monitoring can move beyond the traditional data gathering of documented information and observations of work being performed into real time data capture, continuous monitoring, wearable monitoring technology and AI tracking.
Measurement can be based on empirical evidence but of course there are aspects of health and safety which require hard, quantitative data. Examples include the measurement of vibration and noise, following defined methodologies to ensure valid results. Equipment for such purposes should be calibrated or verified, used and maintained properly and of course, records kept. Data can be collected on lagging indicators such as near misses, accidents, dangerous occurrences, complaints, and occupationally related ill-health. Data can be collected on leading indicators such as training achievement, health initiatives, control measures, risk assessments, and worker participation.
The measured and monitored data needs to be analysed in order to track, trace and trend and to draw useful conclusions. The data only becomes meaningful if it is analysed and interpreted competently. This can involve statistical analysis to assist in developing action plans and continual improvement.
Performance evaluation determines the extent of compliance of the OHSMS. Internal audits are a familiar method to evaluate the adequacy and effectiveness of systems. Audits at periodic intervals provide valuable information on whether the OHSMS conforms to the organisation’s OH&S policy and objectives and also to the requirements of ISO 45001. Audits should be planned to take into account the full scope of the system and the results of previous audits.
Top management should review the OHSMS to ensure its continuing suitability, adequacy and effectiveness. This goes beyond compliance alone. The review should take into consideration the monitoring, measuring, analysis and evaluation requirements of the clause. The review should also take into account any changes since the last review and compliance with legal and other requirements, so keep abreast of your Red-on-line legal registers and also the extent to which the OH&S policy and the OH&S objectives have been met.
Outcomes of audits and reviews must be documented and shared with relevant managers and workers’ representatives and any other relevant interested parties. They should not end as a presentation of results, but as a strategic evaluation for possible improvement. Non-conformities found during the process must be properly addressed and adequate resources will need to be made available to permit this.