Key takeaways
  • Worker consultation and participation is an explicit, auditable requirement, not a cultural aspiration.
  • Hazard identification must be ongoing and proactive, covering routine and non-routine activities, emergencies, and human factors.
  • The hierarchy of controls is mandatory in the standard: elimination first, PPE last.
The requirement with real teeth
Consultation and participation of workers

Clause 5.4 requires organisations to consult non-managerial workers on specific matters and to remove obstacles to participation. Auditors ask workers directly. A safety committee that meets without minutes or without non-managerial representation is a straightforward finding.

Hazard identification versus risk assessment

Identification asks what could cause harm. Assessment asks how likely and how severe, and whether current controls are adequate. Systems that jump straight to a risk matrix tend to assess only the hazards someone already thought of, which is why the identification step must be systematic and ongoing.

What must be covered

  • Routine and non-routine activities and situations.
  • Emergency situations.
  • People, including workers, contractors, visitors and others who could be affected.
  • Design of work areas, processes, equipment, and work organisation.
  • Human factors: workload, working hours, fatigue, harassment and bullying.
  • Changes in knowledge about hazards, and actual incidents including those elsewhere in the industry.

The hierarchy of controls

  • Eliminate the hazard.
  • Substitute with something less hazardous.
  • Engineering controls and reorganisation of work.
  • Administrative controls including training.
  • Personal protective equipment.

The standard requires controls to be applied in this order. Jumping to PPE and training because they are cheap and fast is the most common weakness, and it is visible in a risk assessment where every control is a rule or a glove.

Incident investigation and corrective action

Incidents and nonconformities must be investigated to determine causes and to evaluate whether similar ones exist or could occur. That last clause is what turns a single incident into an organisational improvement, and it is routinely left unanswered.

What auditors examine

  • Evidence that workers were consulted, with names and topics, not just a policy statement.
  • Risk assessments that show the hierarchy applied, with justification when a higher control was not feasible.
  • Competence records matched to the actual hazards people face.
  • Emergency drills performed and reviewed.
  • Corrective actions from incidents verified for effectiveness, not just closed.