ISO 45001 - also think of the practice!

Companies are eagerly awaiting the repeatedly postponed publication of ISO 45001, a new standard that should make it possible to re-describe occupational safety management systems that were previously certified in accordance with OHSAS 18001 or followed an EKAS industry solution, and to harmonize them with other management systems (ISO 9001, ISO 14001). But what do standard requirements such as "6.1.2 Identification of hazards and assessment of risks" or "8.1.2 Eliminate hazards; reduce A&GS risks" or "7.4.2 Internal communication" mean? The answer to this question is - depending on the situation - "product sheet", "safety data sheet", "operating or work instructions". These documents, which tend to go unnoticed but are important for the implementation of the management system, provide employees with information on the correct procedure to follow when carrying out dangerous work or handling dangerous goods. The detailed structure of the requirements of the standards is well known and is shown in Figure 1.

What is dangerous work?
Dangerous work is that which is specified in EKAS Guideline 6508 under Annex I "Special hazards". Among these we find a whole series, such as construction site work, construction cleaning, assembly work, "work with substances hazardous to health", etc.

In such work, the question arises as to how the employer's duty to provide information is to be implemented, for example on a machine such as a press or when decanting acids? Is it sufficient to simply provide employees with the operating instructions or the safety data sheet?

What does the law say?
If the standard requirement "6.1.3 Determination of the legal regulations" is met and the duty to provide information is pursued further, the EKAS guideline 6512 "Work equipment" comes into contact. This guideline regulates how protection goals for employees are achieved. These are based on the Ordinance on the Prevention of Accidents and Occupational Diseases (VUV) and Ordinance 3 to the Labour Act. These require employers to ensure that all employees working in their company, including those working in other companies, are informed about the hazards arising from their activities and are instructed in the measures to be taken to prevent them.

When implementing these requirements, the uncertainty and interpretation begins: what does "sufficient" mean and what is "appropriate"? Here, the legislator gives free room for manoeuvre and personal responsibility to act according to the state of the art, appropriate to the circumstances and necessary according to experience. So it is important to find out and ask around how the requirements are currently being implemented and ultimately to deal with the following questions:

1. are the employees instructed appropriately?

2. are employees able to carry out dangerous work safely with their level of knowledge?

3. do the employees understand the operating instructions or the safety data sheet?

Are the operating instructions or the safety data sheet sufficient?
Whether in foundries, construction companies or hospitals, you will increasingly see an information sheet in the form of an A4 page, also known as an operating manual, which gives instructions on how to behave in the danger zone.

An operating instruction for the operation of a machine makes sense, but what about a hazardous substance? Our German neighbour clearly defines this type of instruction in TRGS 555 "Technical Rules for Hazardous Substances". However, when talking about these instructions for chemicals, the word "hazardous substance instruction" or the so-called "condensed safety data sheet" is more commonly used. The German regulation "Technical Rules for Hazardous Substances" (TRGS 555) provides good guidance on the content and structure in six areas:

1.Scope of application

2. dangers for humans and the environment

3. protective measures and rules of conduct

4. behaviour in case of danger and malfunctions

5.first aid

6.proper disposal (waste)

The contents of these six points can be taken from the operating instructions in accordance with the Machinery Directive or the EC safety data sheet for hazardous substances. It is important to supplement these with operational and workplace-related information. The contents of these six points can be taken from the operating instructions in accordance with the Machinery Directive or the EC Safety Data Sheet for Hazardous Substances. It is important to supplement these with information relating to the operation and the workplace. And here lies the essential sticking point, if no experience or uncertainties are available.

Procedure for hazardous substances
In the case of a chemical, the appropriate sentences must be selected from the safety data sheet. When inserting the sentences, it is important that they are unambiguous, short and concise and in the language used by the employees. Phrases that do not apply, such as "P102 Keep out of the reach of children", can also be omitted, as there are usually no children in a company.

Procedure for machines
In the case of instructions for machines, it is important that the person preparing the instructions discusses the work process with the employees and describes the most important steps and the potential hazards in the instructions. The necessary protective measures and rules of conduct are then defined. If it is drawn up together with the persons concerned, acceptance increases in the majority of cases. Incidentally, the legislator requires that the documents be accessible to the personnel at all times.

Conclusion
The safety-related content of instructions for hazardous work is determined by the requirements of the regulations and important information supplied by the manufacturer. The instructions must contain all information necessary for the safe operation of machines, systems, equipment or for the safe handling of hazardous substances. In this way, the requirements of A&GS management, which are often somewhat theoretical, are brought to life.