§ Title: OSHMS Compliance Audit – OSHAD Expectations Entity: Abu Dhabi OSH Center - OSHAD Speaker: Alyazia Al Hosani / Adnan Qureshi

Workshop Objectives Clarify OSHAD-SF key requirements; Highlight Improvement Areas; Explain OSHAD expectations on OSHMS Audit; Improve Quality of Audits and Compliance OSHAD Movie

OSHAD SF Overview

Administrative Structure Competent Authority Abu Dhabi OSH Center (OSHAD) Government Entities Delegated by OSHAD to follow up implementation in Sectors (Sector Regulatory Authorities) Government Entities Energy (ADWEA) Transport DOT Tourism & Culture TCA-AD Construction DMA Industry IDB Health HAAD Waste CWM-AD Food ADFCA Education ADEC Commercial DMA Entities

OSHAD SF Structure Elements OSHAD OSH Regulatory Instruments Guidelines (Non-Mandatory Technical Guidance / Advice) OSH Regulatory Instruments (Mandatory Process and Technical Requirements) OSHAD (Mandatory Management System Requirements) Elements Standards Codes of Practice Technical Guidelines OSHAD SF Guidance Documents Mechanisms

OSHMS Compliance Audit Expectations OSHAD SF Requirements (Consistent Gaps Observed)

OSHAD SF Requirements Integrated OSH Policy (Element 09) Policy includes commitment to: prevention of injury, illness and environmental pollution, enhancement of employee health and wellbeing legal compliance, setting, monitoring and reviewing OSH targets and objectives, provision of appropriate OSH resources, Continual improvement Authorised / Signed by top management All requirements not addressed in the audited organisations OSH Policy. No indication or communication

OSHAD SF Requirements Roles & Responsibilities (Element 01) Ensures top management is ultimately responsible for OSH and the OSHMS Ensures appropriate competent OSH resources to implement & maintain the OSHMS Establishes clearly defined and documented OSH roles, responsibilities and delegating authorities for each role within the entity Roles & responsibilities defined by the organisations; however, OSH elements missing from it. No commitments within the OSHMS system to provide adequate resources.

OSHAD SF Requirements Targets and Objectives (Element 07) OSH Targets and Objectives procedure developed OSHAD-SF RF mandatory key performance indicators, as defined in AD OSH RI – Mechanism 6.0 – OSHMS Performance and Incident Reporting Sector specific targets and objectives, if applicable Includes program(s) for achieving the targets and objectives, that include at a minimum, the methods, timeframes, monitoring activities and responsibilities Objectives do not include mandatory KPI (Mech. 6.0) and relevant SRA’s defined requirements. Also management programs not defined for achievement of objectives

OSHAD SF Requirements Legal Compliance (Element 09) Legal compliance procedure developed Identifies and Assesses legislation relevant to entity (e.g Legal Register) Ensures compliance to relevant legal and other requirements when developing OSHMS procedures, processes and programs Ensures communication to stakeholders of legal & other requirements Legal register is not identifying OSHAD SF, applicable laws, regulations requirements or it is not in sufficient details. Reference to the applicable requirements and the processes / procedure in which it is addressed is not mentioned. Review and update of legal requirements not done.

OSHAD SF Requirements Risk Management (Element 02) Risk management procedure developed Defines risk management methodologies and competencies Routine & non-routine activities at the work place risk assessed Supply chain and contractor undertakings Human behavior, Hazards outside the workplace capable of adversely affecting the environment and/or health and safety of employees Review the program on a regular basis All the processes / activities of the organisation are not risk assessed. ALARP not discussed

OSHAD SF Requirements Management of Contractor (Element 03) Management of Contractors procedure developed Incorporates the steps of the "Management of Contractor Process" – assessment of contractor OSH performance through contract life cycle Includes specific "construction work" processes & responsibilities – as per OSH RI – CoP 53.0 – OSH Management during “Construction Work – if applicable OSH Performance of contractors not monitored through ‘contract life cycle’.

OSHAD SF Requirements Emergency Management (Element 06) Emergency Response and Management procedure developed Identification and response to potential emergency situations, specific emergency response & management roles, responsibilities Threat-specific, facility specific, appropriate support / functional plans Provision of appropriate resources (human, equipment, facilities, training) Arrangements for external communications with stake holders, local authorities & emergency services, if applicable Periodic emergency response and management tests and exercises Only considers basic scenarios - fire Emergency response procedure inadequate, does not exists or tested. Emergency response not reviewed for gaps and improvements.

OSHAD SF Requirements Operational Procedures (Element 09) Entity’s operational procedure shall be developed Addresses operations & activities that are associated with identified hazards that require implementation of control measures to manage risk Includes controls related to supply chains (purchase of goods, equipment & services) Includes controls related to contactors and other visitors to the workplace Includes stipulated operating criteria / instructions where their absence could lead to an increase in OSH risk(s) Not aligned to risk assessments Do not consider high / medium risk activities Not all the operational control are documented within the procedures / SoP which are identified within the risk assessments / risk registers.

OSHAD SF Requirements Management of Change (Element 09) Management of Change process developed Ensures that changes in organizational structure, personnel, documentation, processes/procedures does not inadvertently introduce new hazards or increased risk Analyzes changes in operational procedures or processes to identify any required changes in training, documentation or equipment Analyzes changes in location, equipment or operating conditions for potential hazards Ensures that all personnel are made aware of and understand any changes in requirements, procedures & applicable control measures Requirements not clearly understood and/or documented in relevant procedures.

OSHAD SF Requirements OSH Training (Element 05) OSH Training procedure developed Monitoring and measuring of training results, identifying and evaluating OSH training needs (OSH Training Matrix), types of training, refresher training requirements, trainer competency, assessment activities, training records, competency requirements etc. Ensures review of OSH training program Training identified is limited to basics OSH trainings Refresher training requirements not defined in OSHMS. OSH training programs are not periodically reviewed.

OSHAD SF Requirements Competency (Element 05) OSH Competency procedure developed Ensures that person(s) under its control performing tasks are competent Identifies and evaluate OSH competency requirements Maintaining and improving competencies Ensures review of OSH competency program Competency requirements are not defined.

OSHAD SF Requirements Hazard, Near Miss, Incident Reporting and Investigation (Element 07) OSH Hazard, Near Miss, Incident Reporting & Investigation procedure developed, in compliance with OSHAD SF Mech. 6(v 2.1); Mech. 11 (v 2.0) Record, investigate and analyze OSH incidents, Ensure investigations are performed by competent person(s) Determine the root causes, corrective and preventative actions, communication of outcomes of OSH incidents, Hierarchies, timetables and responsibilities for reporting, Internal & external OSH performance and incident reporting requirements Annual third party external compliance audit results to the SRA / CA OSH reporting procedure not revised to v 2.1. OSHAD SF defined timelines related to serious incidents & investigation not complied with. Investigations are not conducted on the reported incidents.

OSHAD SF Requirements Communication and Consultation (Element 04) Communication & Consultation procedure developed Internal communication, communication with contractors and other visitors to the workplace, development of an annual OSH performance report Consultation and participation of employees on OSH matters, involvement in risk management activities and OSH incident investigation, consultation with contractors and other external stakeholders Consultation not considered – employee involvement OSH Committee - roles / members – terms of reference not defined

OSHAD SF Requirements Audit and Inspection (Element 08) OSHMS audit, inspection and NC & Corrective action procedure developed Audit program monitoring and review, internal and external reporting requirements, Identification of root cause, corrective action, preventive action. Ensures internal OSHMS auditors are suitably competent to undertake OSHMS audits. Ensures annual external third party compliance audits to be performed by registered (Qudorat) OSHMS Auditing Companies and Auditors Internal Audit Process not effectively implemented NC’s raised during the audit are not effectively closed out.

OSHAD SF Requirements OSHMS Monitoring (Element 07) OSHMS Performance Monitoring procedure developed Description of methodologies and instruments used to monitor, including, calibration requirements and records, monitoring of occupational noise, air and lighting, ergonomic and workplace design factors, wellness programs, hazardous substances, health surveillance, occupational illnesses. Hazards identified in the entity’s risk management program. requirements outlined by relevant SRA / Competent Authorities etc. Monitoring requirements as defined in OSHAD-SF are not complied with.

OSHAD SF Requirements Document Control (Element 09) Document Control procedure developed documents remain legible, traceable and secure relevant version control to ensure unintended use of obsolete documents appropriate review and approval processes appropriate distribution process for OSH documents OSHMS documents are not periodically reviewed to ensure they remain relevant.

OSHAD SF Requirements Record Retention (Element 09) Record Retention procedure developed Maintenance of OSH records as necessary to demonstrate conformity to the requirements Identification, storage, protection retrieval, retention & disposal of records Retention of OSH documents for a period of 5 years Retention medical / occupational health records - period of employment + 30 years Retention period of OSH records do not comply with OSHAD-SF record retention requirements.

OSHAD SF Requirements Management Review (Element 09) Management System Review procedure developed Ensure top management review the entity(s) OSHMS, at planned intervals to ensure its suitability and effectiveness. Ensure management reviews shall include review of the OSHMS by OSH staff, previous review results, results of internal and external audits, OSH performance against targets and objectives, changes to legal and other requirements, relevant communications and complaints, OSH incidents, investigations, non-conformances and corrective actions and recommendations for continual improvement. One full management review per year As a minimum, management review is not conducted once a year.

OSHAD Expectations

OSHAD Expectations OSHAD-SF 3rd Party Compliance Audit Process Define audit scope & criteria. Audit performed by Qudorat registered auditors. Audit Report includes audit findings. NC makes a reference to OSHAD-SF elements, mechanism, CoP etc. Corrective action plan. Form F with Audit Report sent to SRA SRA feedback to entity and OSHAD Investigation and enforcement of corrective action; if complaint received by OSHAD from any stakeholder.

OSHAD Expectations Audits must verify the requirements of latest version of OSHAD-SF as available on OSHAD website www.oshad.ae Audit reports must include the accurate scope of the audit. All the processes / locations of the entities must be included in the scope. Exception is only permitted if authorised in writing by OSHAD / SRA, as applicable. Coverage of the audit must include verification of implementation. Rather then ensuring the documentation of requirements. Representative sample of the activities must be selected to determine true extent of OSHMS implementation.

OSHAD Expectations OSHMS Audits in addition to the corporate office must also verify the extent of OSH implementation and its effectiveness within the operational activities. Audit findings in addition to reporting the weaknesses in the audit report must record ‘positive points’ as well. Positive points must be summarized in the audit matrix (Form F). Standard Definitions of audit findings as used by the auditing company must be included as part of the audit report like Major NC, Minor NC, Observation, OFI etc. NCs shall be cross referred to OSHAD-SF element / mechanism / CoP etc. NC’s shall only be given against the stated requirements of OSHAD-SF. They must not be highlighted by referring to good practices.

OSHAD Expectations Audits must also focus on verifying the implementation of relevant / applicable Regulatory Instruments like Mechanisms, CoPs etc. Implementation of OSHAD-SF Mechanism 2.0 requirements as applicable must be verified during the audit. OSH competence of auditors should be ensured while selecting an audit team. Qudorat Registration is mandatory for OSHAD-SF Auditing Technical specialist must be used if audit team do not have competence of a particular industry / process.

Q & A

Thank you For further information and copy of all OSHAD-SF Documents: www.oshad.ae