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National Safety Council, India
Plot No.98-A, Institutional Area, Sector
15, CBD Belapur,
16 August 2020 Navi Mumbai - 400 614 1
Overview of Indian Standard and Statutes related to
Occupational Health & Safety Audit
Anil Sawant,
National Safety Council
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Coverage
▪ Statutory provisions for OH&S Audit
▪ The Factories Act,1948
▪ The Maharashtra Factories Rules,1963
▪ The Manufacture, Storage, Import of Hazardous Chemicals
Rules,1989 - amended 1994
▪ The Maharashtra Factories ( Control of Industrial Major
Accident Hazards) Rules,2003
▪ The Maharashtra Factories(Safety Audit) Rules,2014
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Coverage
▪ Standards for OHSMS
▪ IS/ISO 45001: 2018 OH&SMS Requirements with guidance for
use
▪ IS 15793:2007 on “Managing Environment, Occupational
Health & Safety Legal Compliance – Requirements of Good
Practices”
▪ Standard for OH&S Audit
▪ IS 14489:2018 on “Occupational Health and Safety Audit -
Code of Practice ”
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Statutory Provisions - OH&S
Act/Rule Section/ Requirement
Rule
The Factories Act,1948 7A(1) Occupier to ensure OH&S in factory
41B(1) Disclosure of Hazardous Process
Maharashtra Factories 73L(5e) Policy to specify Risk Assessment
Rules,1963 techniques – safety Audit
The MSIHC Rules,1989 10(4) Carry out Safety Audit
Amendment,1994
The Maharashtra Factories 9(2) Internal Safety audit once in a year
(CIMAH) Rules,2003 External Safety audit once in two years
The Maharashtra Factories( 1(2) Hazardous Chemicals/Process
Safety Audit) Rules,2014 More than 250 workers
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Statutory Provisions - OH&S Audit
The Maharashtra Factories( Safety Audit) Rules,2014
Rule Requirement
2(vii) Safety Audit definition
2(viii) Safety Auditor definition
Auditor recognised by the state govt. committee
3 Internal Audit once in a year
External Audit once in 2 years
In case of any change one month before
change
4 Audit as per IS 14489:2018 standard
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IS/ISO 45001:2018 OHSMS Requirements and Guidance
◼ Introduction
1. Scope
2. Normative references
3. Terms and definitions
4. Context of the organization
5. Leadership and worker participation
6. Planning – HIRA, Legal requirements, objectives
7. Support – resources, communication, documentation
8. Operation – management of change, procurement
9. Performance evaluation- monitoring, measurement, analysis, evaluation,
internal audit, management review
10. Improvement- corrective action, continual improvement
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IS 15793:2007
“Managing Environment, Occupational Health & Safety Legal
Compliance –
Requirements of Good Practices”
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Annex A
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Annex B (Clause 4.2.1) Relevant Indian Legislation on EHS
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Annex B (Clause 4.2.1) Relevant Indian Legislation on EHS
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Annex B (Clause 4.2.1) Relevant Indian Legislation on EHS
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Annex C (Clause 4.2.1) Typical Format of Legal Register
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Annex D (Clause 4.6.1)
Typical record of good practices related to EHS
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IS 14489:2018 –
Occupational Health and Safety Audit - Code of Practice
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IS 14489 : OH&S Audit – Code of Practice
◼ First published in 1998
◼ NSC played a major role in developing this standard
◼ Revised in 2018
◼ Significant Revision in elements
◼ Earlier version had 31 elements
◼ Current version has 8 major elements and 76 sub-elements
◼ A guideline for self demonstration of
◼ conformance to major elements of IS / ISO 45001
◼ compliance to IS 15793
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IS 14489:2018
1. Scope
2. Reference
IS 15793:2007 Managing Environment, Occupational Health &
Safety Legal Compliance – Requirements of Good Practices”
IS/ISO 45001:2018 OHSMS Requirements with guidance for use
3. Terminology
3.1 Auditee
3.2 Audit team
3.3 Client
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IS 14489:2018
3.4 Nonconformity-
The non-fulfillment of specified requirement
3.5 Observation-
A statement of fact made in the course of an audit and preferably
substantiated by objective evidence
3.6 Objective Evidence- Qualitative or quantitative information,
records or statements of fact, which is based on observation,
measurement or test and which can be verified.
3.7 OH&S Audit - A systematic, objective, documented and
independent evaluation to determine whether , the activities
conform to the requirements of OHS systems and procedures
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IS 14489:2018
3. Terminology
3.8 OH&S System - The organizational structure, responsibilities,
procedures, processes and resources specified by top
management of an organization as required for implementing
occupational health and safety objectives
(Annex A – elements of OH&S system)
3.9 Organization
3.10 Recommendation- Suggestion made by the audit team in the
course of audit for improvement in the OH&S system
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Annex A (Clause 3.8 & 5.2.4)
Elements of OH &S Systems
• A-1 OH & S MANAGEMENT
• A-2 PHYSICAL HAZARD
• A-3 CHEMICAL HAZARD
• A-4 FIRE AND EXPLOSION HAZARD
• A-5 INDUSTRIAL HYGIENE / OCCUPATIONAL HEALTH
• A-6 ACCIDENT / INCIDENT REPORTING, INVESTIGATION AND
ANALYSIS
• A-7 EMERGENCY PREPAREDNESS (ON- SITE / OFF SITE)
• A-8 SAFETY INSPECTION
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IS 14489:2018
4. Audit Goals, Objectives, Roles and Responsibilities
4.1 Audit Goals
- Provide the auditee with an opportunity to assess its own
OH&S System against standard & identify areas for
improvement
- To determine the conformity of the implemented OH&S
system with specified requirements & identify areas of
improvement
- To meet regulatory requirements
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IS 14489:2018
4.2 Audit Objectives
- To carry out a systematic , critical appraisal of all potential
hazards involving personnel, plant, services and operation
method
- To ensure that OH&S system fully satisfies the legal
requirements and those of the company’s written safety
policies, objectives and program.
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IS 14489:2018
4.3 Roles & Responsibilities
4.3.1 Auditors
[Link] Audit team,
[Link] Lead Auditor ‘s Responsibilities
[Link] Auditor’s Responsibilities
[Link] Auditors’ duties
[Link] Attributes of auditors
4.3.2 Client
4.3.3 Auditee
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[Link] Lead Auditor’s Responsibilities
◼ Selecting the audit team members;
◼ Preparing the audit plan; Planning the field visit;
◼ Defining the requirements of each audit assignment;
◼ Communicating with client, auditee and other auditors regarding
audit requirements;
◼ Briefing the audit team and guide the auditors to prepare the
working document;
◼ Reporting critical nonconformities resulting in imminent danger to
the auditee immediately;
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[Link] Lead Auditor’s Responsibilities
◼ Interacting with the client and auditee’s management;
◼ Reporting any major obstacles encountered in performing the
audit;
◼ Maintaining agreed time schedule.
◼ Preparing audit report with the help of auditors;
◼ Reporting the audit results objectively, clearly, conclusively
and without delay.
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[Link] Auditor’s Responsibilities
• Complying with the applicable audit requirements
• Scheduling and carrying out assigned responsibilities effectively and
efficiently.
• Preparing additional checklist if required;
• Documenting the observations;
• Reporting the audit findings;
• Verifying the effectiveness of corrective actions taken as a result of
the earlier audits;
• Retaining and safeguarding documents pertaining to the audit
ensuring such documents remain confidential and treating privileged
information with discretion.
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[Link] Auditor’s Duties
◼ Remain within the audit scope;
◼ Exercise objectivity;
◼ Collect and analyse evidence that is relevant and sufficient to
permit the drawing of conclusions regarding the audited OH & S
safety system;
◼ Remain alert to any indications of evidence that can influence the
audit results and possibly require more extensive auditing;
◼ be able to answer such questions as presented by the auditee
with respect to the relevance of the auditor’s queries;
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[Link] Auditor’s Duties
◼ Should be able to convince the auditee about any apprehension, if any,
regarding audit findings;
◼ Ensure that the procedures, documents and other information specifying
requirements of the OH & S system are known, available, understood and
used by the auditee’s personnel;
◼ Ensure that all the documents and other information used to describe the
safety system are adequate to achieve the required OH & S objectives; and
Act in an ethical manner at all times.
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[Link] Attributes of Auditors
• Ethical that is fair, truthful, sincere, honest and discreet;
• Open-minded, that is willing to consider alternative ideas or
points of view;
• Diplomatic that is tactful in dealing with people;
• Observant, that is, actively aware of physical surroundings
and activities;
• Perceptive, that is instinctively aware of and able to understand
situations;
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[Link] Attributes of Auditors
• Versatile that is adjusts readily to different situations
• Tenacious that is, persistent, focused on achieving objectives;
• Decisive, that is, reaches timely conclusions based on logical
reasoning and analysis;
• Self reliant that is acts and functions independently while
interacting effectively with others
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4.3.2 Client or Head of Organization
◼ Determine the need for and the purpose of the OH & S audit and
initiate the process;
◼ Select the auditing organization;
◼ Agree in consultation with the lead auditor the general scope of
the audit such as what OH & S system standard or document is to
be selected as reference and the time schedule;
◼ Define the audit reporting requirements;
◼ State specific confidentiality requirements, if any;
◼ Receive the audit report;
◼ Determine follow-up action to be taken in consultation with the
auditee.
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4.3.3 Auditee ( or Safety Department)
◼ Inform relevant officials and staff about the objectives and scope of
the audit;
◼ Appoint one or two officials to coordinate / liaise with audit team;
◼ Provide all resources needed for the audit team in order to ensure
an effective and efficient audit process;
◼ Provide access to the facilities and evidential material as requested
by the auditors;
◼ Co-operate with the auditors to facilitate achievements of audit
objectives;
◼ review of the audit results
◼ Ensure implementation of corrective actions based on the audit
report
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IS 14489:2018
5. Audit Methodology
5.1 Initiating the OH&S Audit:
5.1.1 Scope
5.1.2 Audit Frequency
5.1.3 Preliminary Review of Auditee’s Requirements of OH&S System
5.2 Preparing the OH&S Audit
5.2.1 Audit Plan
5.2.2 Audit Team Assignments
5.2.3 Working Documents of the Audit Team
5.2.4 Questionnaire of preliminary information
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5. Audit Methodology
5.3 Executing the OH&S Audit
5.3.1 Opening Meeting
5.3.2 Presentation by Auditee
5.3.3 Examination of Records (Annex B – Types of
records to be examined)
5.3.4 Field Visit(Annex C–Safety Audit Questionnaire)
5.3.5 Interviews
5.3.6 Audit Observations
5.3.7 Audit Recommendations
5.3.8 Closing Meeting with Auditee
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IS 14489:2018
5.4 OH&S Audit Documents:
5.4.1 Audit Report Preparation
5.4.2 Report Content
5.4.3 Report Distribution
5.4.4 Record Retention
6. OH&S Audit Completion
7. Action for Implementation of OH&S Audit Report
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Annex A (Clause 3.8 & 5.2.4)
Elements of OH &S Systems
• A-1 OH & S MANAGEMENT
• A-2 PHYSICAL HAZARD
• A-3 CHEMICAL HAZARD
• A-4 FIRE AND EXPLOSION HAZARD
• A-5 INDUSTRIAL HYGIENE / OCCUPATIONAL HEALTH
• A-6 ACCIDENT / INCIDENT REPORTING, INVESTIGATION AND
ANALYSIS
• A-7 EMERGENCY PREPAREDNESS (ON- SITE / OFF SITE)
• A-8 SAFETY INSPECTION
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A-1 OH & S MANAGEMENT
a) OH & S Policy b) OH & S organizational set-up
c) Safety manual d) Standard Operating Procedures (SOP)
e) Plant modification procedure f) Work permit system
g) Contractors’ safety system h) Plant design and layout
j) Medical management of accidents k) Management of emergencies (natural /
man-made)
m) Employee selection and n) Safety culture
placement
p) Statutory licenses, approvals and q) Motivational and promotional
records measures for OH & S
r) Hazard identification and job safety s) Product safety
analysis
t) Safety training u) Change management 38
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A-2 PHYSICAL HAZARD
a) Housekeeping b) Machine and general area guarding
c) Material handling d) Electrical safeguarding
e) Safety in storage and warehousing f) Hazard assessment of new
equipment
g) Hazards from radiation sources h) Control measures for specialized
industrial hazards like work at height
and work in confined space
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A-3 CHEMICAL HAZARD
a) Transportation of hazardous b) Handling of hazardous substances
substances
c) Storage of hazardous substances d) Spill control measures
e) Material Safety Data Sheet (MSDS) f) Gas cylinders
g) Labeling and colour coding h) Hazardous waste management
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A-4 FIRE AND EXPLOSION HAZARD
a) Organizational setup for fire fighting b) Built in safety in civil design and
construction
c) Built in Safety in Electric Circuits and d) Explosive substances
Equipment
e) Fire safety in handling flammable and f) Fire detection and alarm system
explosive materials
g) Passive and active fire protection system h) Fixed fire extinguishing system
j) Portable Fire Extinguishing System k) Fire fighting equipment and
facilities
m) Fire drill n) Fire fighting training
p) Static electricity and lightning
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A-5 INDUSTRIAL HYGIENE /OCCUPATIONAL
HEALTH
a) Vibration, heat stress, Non-ionizing b) Work place monitoring for
radiations, ventilation, illumination and hazardous chemicals
noise
c) First aid facilities and occupational d) Periodic medical examination
health center (OHC)
e) Personal protective equipment and f) Occupational disease
emergency equipment
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A-6 ACCIDENT / INCIDENT REPORTING,
INVESTIGATION AND ANALYSIS
a) Accident reporting, b) Accident investigation
c) Analysis of accidents d) Implementation of
recommendations
e) Reporting and
investigation of near -miss
incidents
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A-7 EMERGENCY PREPAREDNESS
(ON-SITE / OFF SITE)
a) Site specific details b) Duties and responsibilities of key
personnel
c) Identification of emergencies and d) Declaration and termination of
accident scenario emergency
e) Resources-evacuation / transport f) Communication facilities
g) Medical care h) Updating of emergency plan
j) Periodic drills / exercises k) Training of plant personnel
m) Public awareness programmes n) Mutual-aid programme
p) Emergency control center
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A-8 SAFETY INSPECTION
a) Inspection programme b) Safety Related Deficiency
(SRD) Report
c) Safety inspection records d) Methodology and inspection
team
e) Compliance of
recommendations
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Annex B (Clause 5.3.3) Types of Records to be examined
• OH & S policy;
• Safety organization chart;
• Training records on safety fire and first-aid;
• Record of plant safety inspections;
• Accident investigation reports;
• Accidents, dangerous occurrences and near miss incidents -
statistics and analysis;
• Record of tests and examinations of equipment and structures as
per statutes;
• Standard Operating Procedures (SOP) for various operations;
• Record of work permits;
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Annex B (Clause 5.3.3) Types of Records to be examined
• Record of work environment monitoring (flammable, toxic and explosive
substances);
• Maintenance, testing and calibration records of fire detection and fire fighting
equipment;
• Medical records of employees;
• Records of industrial hygiene surveys, noise, ventilation, illumination, dust
etc.);
• Material Safety Data Sheets (MSDS);
• On-site emergency plans and record of mock drills;
• Records of storage of hazardous solid waste and its disposal;
◼ Records of gaseous emissions and effluent discharges to the environment
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Annex B (Clause 5.3.3) Types of Records to be examined
• Housekeeping inspection records;
• Minutes of safety committee meetings;
• Statutory licences and approvals;
• Records of any modifications carried out in plant or process;
• Maintenance procedure and records;
• Instrumentation and equipment calibration and testing records;
• Planned shutdown maintenance procedures;
• In service inspection manuals, records including that of material handling;
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Annex B (Clause 5.3.3) Types of Records to be examined
• OH & S budget;
• Inspection books and other statutory records;
• Records of previous audits and safety analysis; Procedures for safe
transportation of hazardous substances;
• Calibration records;
• Records for break down of plants during the process of manufacture;
• Records for waste material generated and their disposal;
• SOP for disposal of waste materials;
• Records for issue of PPE items to the personnel working in process building.
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Annex C (Clause 5.3.4)
Safety Audit Questionnaire
▪ Does the organization have OH & S policy?
▪ Who has signed the OH & S policy?
▪ Whether the OH & S policy is per guidelines of the statutory provisions?
▪ When was the OH & S policy declared and adopted?
▪ Whether the OH & S policy reviewed periodically? Whether the OH & S
policy is available in local
▪ language and made known to all?
▪ What was the last date of updation?
▪ Does the policy find a place in the annual report?
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THANK YOU
National Safety Council
…..Your safety is our passion…..
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