A. Review Issues and Questions

1.	Publication date.	1988 revision.
2.	Status: final, draft, other.	Final.
3.	Pending revisions.	Not known.
4.	Publishing Organization type.	Government.
5.	Type of OHSMS.	National regulation.
6.	Is it used by regulatory agencies to achieve agency mandate?	Yes.
7.	Is it meant to be an auditable standard?	Yes.
8.	Is it used as an auditable standard?	Yes. Contains a mix of shall and should statements.
9.	Is it a management system?	Yes.
10.	Are there technical appendices?	No.
11.	Is there a companion audit guidance document?	Not known.
12.	Are there stated limitations of use?	No.

B. Review Comments

This is the cardinal Act on health and safety in India. It is based on the British Factories Act. The Indian Act emphasizes safety and welfare but is lacking a comprehensive approach to occupational hygiene. The central government promulgated the Act while the state governments promulgate rules on each section of the Act. The Act provides guidelines, whereas rules provide specifications.

Safety Committees are required in organisations over 250 people.

The regulation is comprehensive in the area of Emergency and Community Right-to-Know language and requirements.

For a national regulatory standard, it is strong. It has many of the components of a system. By the definition established, it is not as strong as the ISO-based management systems.

System variables missing include:

- goals and objectives

- performance measures

- OHSMS manual and procedures

- preventive and corrective actions

- continual improvement

Variables that are not presently directly or can be made by inference are:

- technical expertise and personnel qualifications

- management review.

C. Outline

D. Analysis Checklist

	Management System Variable		Notes
1.0	Management Commitment and Resources	x
1.1	Reg. Compliance and OHSMS Conformance	x
1.2	Accountability, Responsibility, and Authority	x
2.0	Employee Participation	x	via Health & Safety Committee.
3.0	Occupational Health & Safety Policy	x
4.0	Goals and Objectives
5.0	Performance Measures
6.0	System Planning and Development	x	Must have organizational structures in place to carry out OHS policy.
6.1	Baseline Eval. and Hazard/Risk Assessment	x
7.0	OHSMS Manual and Procedures
8.0	Training System	x
8.1	Technical Expertise and Personnel Qualifications	x
9.0	Hazard Control System	x
9.1	Process Design	x
9.2	Emergency Response	x
9.3	Hazardous Agent Management	x
10.0	Preventive and Corrective Action
11.0	Procurement and Contractor Selection	x	Review contractor performance.
12.0	Communication System	x
12.1	Document and Record Management System
13.0	Evaluation System	x
13.1	Auditing and Self-Inspection	x
13.2	Incident Investigation and Root Cause Analysis
13.3	Medical Program and Surveillance	x	Surveillance and clinic.
14.0	Continual Improvement
15.0	Integration	x
16.0	Management Review	x

IOHA Report to ILO on an International OHSMS - Appendix C [Title page]     [Table of Contents]     Chapters: I II III     Appendices: A B C D E F G

Updated by AS. Approved by EC. Last update: 30.11.2004.