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I hear this a lot when auditing...

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Published: 25 Apr 2024

How can an organisation demonstrate that it has communicated its quality, environment, and health and safety policies to all employees? Lead Auditor Andy Lau explains.

I hear this a lot when auditing – does it sound familiar to anyone else?

Auditor: Can you tell me if you have communicated the company’s policies on quality, environment, and occupational health and safety to your staff?

Auditee: I have, during last month’s staff assembly.

Auditor: I have spoken to (let us call them) Paul, John, Ringo and George about their understanding of the company’s policies, but none of them could tell me what the policies actually is.

Auditee: But I did tell them – look! (Shows the auditor a photo of the assembly on the auditee’s phone) But I’m sure if you had interviewed the managers, they would be able to tell you the policies.

Auditor: But all staff does not just mean the managers; it means everyone working in the company.

Auditee (getting angry): Well, I have told the team, and I am standing by that!

If you have encountered a similar experience, then, like me, you will probably skip asking this question on your audit checklist because, more often than not, the above conversation will be the response.

"When asked, staff should be able to explain that what they do not only guarantees ethical business success, but also the opportunity to grow their skill sets and improve their livelihoods."

Andy Lau, Lead Auditor.

What the standards say

I am sure we are all familiar with what is stated in ISO 9001:2015 Quality management systems – Requirements:

7.3 Awareness

The organisation shall ensure that persons doing work under the organisation’s control are aware of: a) the quality policy

AND 5.2.2 Communicating the quality policy The quality policy shall: b) be communicated, understood and applied within the organisation.

The story is the same with ISO 14001: 2015 Environmental management systems – Requirements with guidance for use:

7.3 Awareness The organisation shall ensure that persons doing work under the organisation’s control are aware of: a) the environmental policy

AND 5.2 Environmental Policy The environmental policy shall: — be communicated within the organisation.

Again, similar wording appears in ISO 45001: 2018 Occupational health and safety management systems – Requirements with guidance for use:

7.3 Awareness Workers shall be made aware of: a) the OH&S policy

AND 5.2 OH&S Policy The OH&S policy shall: — be communicated within the organisation.

Importance of awareness

As an impartial and objective auditor, I would probably give Clauses 5.2.2 of ISO 9001, 5.2 of ISO 14001 and 5.2 of ISO 45001 as conformance.

This should be supported by evidence (not, as in the case above, simply by a photo shown by the auditee) that there is a recording of the contents of the communication by the auditee to the staff, which contains the contents of the policy related to quality, environment and OH&S.

However, in the scenario I have outlined, I cannot give Clause 7.3 for all three standards as a conformance because, based on the interview with Paul, John, Ringo and George, none of them could tell me that they are aware of, or understand, the policy.

When given a task, an employee will seldom ask why, and most managers are too busy to explain the reason and purpose behind every task. Awareness, as referenced in Clause 7.3, is about understanding one’s role as an employee and, perhaps more fundamentally, the wider business needs.

It is about why the business needs to do what it does well for its customers (ISO 9001), why the business must consider the impact of its activities on the environment (ISO 14001), and why everyone at the organisation is able to get safely through the working day (ISO 45001).

Ensuring awareness

When carrying out such an audit, I am looking, during interviews, for evidence that staff know their roles and responsibilities well. This may seem obvious, but I need to see this demonstrated – not only during normal times, but also during situations such as a slow-down in the economy or a complaint from a big customer. When the business is facing a setback, how does it adapt?

Employees should be able to explain how they follow procedures when executing their everyday tasks, because they know, if they don’t, the risk of failure in the organisation will increase. When asked, staff should be able to explain that what they do not only guarantees ethical business success, but also the opportunity to grow their skill sets and improve their livelihoods.

To ensure that organisations are able to meet the criteria for Clause 7.3 in all three of the standards mentioned earlier, leadership by example is key.

Managers must take the time to talk to staff and really understand how they can help employees to be better in their job. Doing this can ensure that employees’ jobs are not just about being paid well, but rather about making a meaningful contribution to society, in products and services produced, by caring for the environment and ensuring the wellbeing of themselves and others.

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