Common Non-Conformities in an OHSAS Audit: How to Avoid Them

When undergoing an Occupational Health and Safety Management Systems (OHSMS) audit, non-conformities can emerge, which can hinder an organisation’s ability to maintain a safe and compliant working environment. 

Addressing these common non-conformities proactively is critical to ensuring a safer workplace and passing audits smoothly. Below, we explore some frequent areas of non-conformity and provide insights into how organisations can avoid these pitfalls.

1. Risk assessments: Inadequate identification or incorrect evaluation

One of the most predominant issues during an audit is the improper identification or evaluation of workplace hazards. Risk assessments form the backbone of any OHSMS, so ensuring that hazards are properly identified and assessed is vital.

For instance, in a warehouse setting, people who work in the warehouse could be wearing high-visibility jackets, but they may still be at high risk of injury from equipment like forklifts. Even though personal protective equipment (PPE) like high-visibility clothing is a control measure, the risk of a collision should remain classified as high due to the potential severity of such an incident. The risk assessment must accurately reflect both the likelihood and severity of harm, considering all relevant factors.

Top Tip: Ensure regular and thorough risk assessments are conducted by competent individuals, and always re-evaluate risks when there are changes in the work environment or processes.

2. Non-adherence to Safe Systems of Work

Even with documented procedures and protocols in place, non-compliance with Safe Systems of Work (SSOW) is another common finding during audits. 

A Safe System of Work is a formal procedure that ensures hazardous tasks are carried out safely. However, the issue arises when these procedures are not followed or enforced.

For example, when delivering goods to a site situated on the roadside, the SSOW may specify that deliveries should be made kerbside, rather than on the road itself, to minimise risks. If workers fail to follow these instructions, it opens the door for accidents and non-conformities during an audit.

Top Tip: Check that all employees and contractors are adequately trained on SSOW, and that compliance is regularly monitored. Encouraging a culture of safety and awareness can prevent these lapses.

3. Missed statutory inspections

Another frequent issue is the failure to conduct statutory inspections within the required timeframes. 

This is particularly common with equipment inspections under regulations like the Lifting Operations and Lifting Equipment Regulations (LOLER) and the Provision and Use of Work Equipment Regulations (PUWER). When equipment is not inspected or tested on time, it can continue to be used in unsafe conditions, leading to serious non-compliances.

For example, a forklift may be overdue for its LOLER inspection, yet still be in use. This not only increases the risk of accidents but also results in non-compliance with statutory health and safety requirements.

Top Tip: Implement a robust tracking system for statutory inspections and maintenance schedules to ensure that no equipment is used without having passed the required checks.

4. Incomplete COSHH risk assessments

The Control of Substances Hazardous to Health (COSHH) requirements require thorough risk assessments for any hazardous substances used in the workplace. However, many organisations overlook this, especially when introducing new substances.

For instance, a cleaner might purchase a new cleaning product from a local store and begin using it without a formal COSHH assessment. This could lead to serious health risks, especially if the cleaner is unaware of how the new substance might react if mixed with other chemicals. Furthermore, COSHH assessments should always consider what could happen if substances are used or stored incorrectly.

Top Tip: Train employees on the importance of COSHH risk assessments and ensure that new substances are always evaluated before use. 

5. Contractor controls: Managing third-party risks

Managing contractor safety is another area that frequently sees non-conformities. While many organisations ensure that their own employees are trained and following safety protocols, the same level of attention is not always given to contractors.

Contractors may have their own risk assessments and Safe Systems of Work, but these need to be reviewed and aligned with the organisation's standards. Additionally, general inductions are often provided, but there may not be follow-up refreshers to ensure ongoing compliance. This gap can result in contractors not adhering to the required safety procedures, posing a risk to both the contractor and the organisation's workforce.

Top Tip: Set clear requirements for contractor safety, including the regular review of risk assessments, permits to work, and refresher training where necessary.

Final thoughts

Non-conformities in an OHSAS audit can be costly - not only in terms of potential penalties but also in terms of employee safety and well-being. By addressing these common issues, organisations can ensure that they remain compliant, protect people from harm from the organisation's activities, and create a culture of safety.

Regular audits, continuous training, consultation and diligent risk management practices are essential to maintaining compliance with ISO 45001, applicable legislation, and codes of practice. Remember, the key to avoiding non-conformities is not just to have the right systems in place, but to ensure those systems are consistently followed and updated as necessary.

 Ready to start you OHSAS journey? Contact one of our friendly team today!