What changes will need to be made in the occupational health and safety management system

(OHSMS) as a result of the COVID-19 pandemic?

As we adjust to the new normal after a lengthy community quarantine period, organizations need to
reexamine their processes and determine whether any of these need to be modified in light of the
COVID-19 pandemic and future pandemics. Doing so would evince the organization’s commitment to
the intended outcomes of the OHSMS – ensuring the safety and health of workers and other relevant
parties that may be affected by the organization’s operations. Furthermore, since a properly working
OHSMS is linked to ensuring the organization’s compliance to legal requirements and other relevant
requirements, a careful review of the rules and regulations under the new normal and its repercussions
to operations would prove to be beneficial.

For organizations, with OHSMS that are conforming to the requirements of ISO 45001 1 as well as for
those who would want to improve existing processes to improve health and safety performance, the
following are some of the elements of the OHSMS that may need careful review and revision:

Strategic approach to addressing risks

An organization’s approach on how to address its risks will warrant careful review as COVID-19 may
affect all workers (managerial and non-managerial), contractors, visitors, and customers of the
organization. As mentioned in an earlier blog2, organizations tend to overlook low likelihood, high
impact threats such as the pandemic (although we are likely to see more of these in the future), high
intensity earthquakes, and civil unrest. This would be an opportune time for management teams to
review strategies that would help them deal with the next occurrences of the pandemic. Given the
government’s newly crafted rules and regulations surrounding the different types of community
quarantines, top management has to make sure that they have the flexibility and the agility to adapt to
new restrictions and requirements that may be imposed on their organization.

Operational controls

OHS risks also need to be addressed at the operational level. Some would go even further and say that
operational controls are more important than strategies in the prevention of injuries and ill health.
Without operational controls, strategies will just be nice looking charts and nice sounding words that
hold no meaning to workers and relevant parties exposed to hazards.

In the context of the COVID-19 pandemic, the operational controls may be linked to the rules and
regulations imposed by the IATF. For example, many service organizations have been required to place
physical barriers between their personnel and customers when delivering their service and/or to
drastically limit the number of customers that they can serve to allow for social distancing measures. At
the time of writing, this is already being seen as the new normal and the practice may be continued
indefinitely (or hopefully, until an effective vaccine becomes available and properly distributed).
I am happy to have read an article from the World Economic Forum about the use of the hierarchy of
controls when considering taking a flight during the coronavirus pandemic. 4 Organizations can also
adopt this approach and look from the perspective of their workers and customers when thinking of
operational controls.

In addition to a review of the organization’s hazard identification, risk assessment and determining of
controls (HIRAC) processes, it would also be good to develop specific objectives related to health and
safety of workers and relevant parties as related to the pandemic such as those related to use of
personal protective equipment (PPE), testing, number of confirmed cases, and exposure. Since many
service organizations adopted work-from-home strategies during quarantine, it would also be good to
have metrics and objectives related to ergonomics.

Resources and Support Processes

Among the most important resources during this time of the pandemic are PPEs so these will have to be
available, especially to workers that may have greater exposure to the coronavirus. As part of business
continuity planning, stockpiling of PPEs may have to start when the organization sees the impending
threat of a pandemic and may need to have contractual arrangements with critical suppliers during
these times. Ensuring availability of suitable PPEs and accreditation of qualified suppliers would be
mostly the work of the procurement function.

Dissemination of information becomes very important in reducing the impact of the pandemic. This may
include communication of protocols to be adopted under the new normal. As such, the process of
communicating to all relevant parties related to the organization’s health and safety measures related
to the pandemic may have to be reviewed and then implemented.

Other areas that may need review include the minimum competency and awareness of workers and
relevant parties about SARS-CoV-2 and COVID-19 which may include modes of transmission, symptoms,
and prevention of infection.

As a result of the review of processes, organizations may need to revise existing documented
information and may even create new ones as related to the pandemic.

Emergency preparedness and response

Organizations will have to consider their response when workers are confirmed to have COVID-19 and to
ensure that there are non-discriminatory policies in place while taking into account the right to privacy
of their workers. Some emergency response protocols may also need to be reviewed and revised such as
the use of big valve masks (BVM), otherwise known as manual resuscitators, when performing
cardiopulmonary resuscitation.

Performance evaluation and improvement

During the pandemic, organizations may consider adding to their monitoring and measurement
processes metrics and indicators related to COVID-19 such as number of confirmed cases (especially for
front liners), adherence to OHS protocols, availability of suitable PPEs, etc. Frequencies and trends will
have to be analyzed and evaluated against the OHS objectives and/or against guidelines from credible
health organizations. Internal audits and management reviews need to be conducted with the additional
lens of preventing COVID-19 and maintaining health and safety of all relevant parties. The same is true
when detecting nonconformities and developing actions to address them.

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Notes
1
ISO 45001: 2019 Occupational health and safety management systems – Requirements with guidance
for use
2
https://askaconsultant.blogspot.com/2020/05/why-did-risk-assessments-fail-to.html