A. Review Issues and Questions

1.	Publication date.	1997.
2.	Status: final, draft, other.	Yes.
3.	Pending revisions.	Not known.
4.	Publishing Organization type.	Professional association.
5.	Type of OHSMS.	Professional association best-practice.
6.	Is it used by regulatory agencies to achieve agency mandate?	Not known.
7.	Is it meant to be an auditable standard?	No.
8.	Is it used as an auditable standard?	Can be. Contains a mix of should and shall statements.
9.	Is it a management system?	Borderline. Many system variables missing. Weak input and open system variables.
10.	Are there technical appendices?	No.
11.	Is there a companion audit guidance document?	Not known.
12.	Are there stated limitations of use?	Not clear. Appears to be written for manufacturing industry only.

B. Review Comments

Published by the Japan Industrial Safety & Health Association (JISHA). These OHSMS Guidelines are drawn up to help employers establish and develop an OHSMS that is widely expected to function as the system for ensuring the safety and health of workers with a definite corporate policy and efficient programs created on the employer’s responsibility.

Five fundamental concepts are addressed in this system.

1. Self-regulatory OHS Management by Employers

2. The Guarantee of Implementation and the Maintenance of Records

3. Twenty Areas of OHS Management

4. The Clarification of Role Assignment

5. An Emphasis on Communication Process

There is strong emphasis on medical surveillance, as partially demonstrated by the requirement for an industrial doctor.

Many of the 27 system variables are missing. There is weak to non-existent mention of management commitment and resources. There are activities specified that management must do or perform. But it is not explicitly stated that management commitment to OHS is required or recommended. There is no mention of the need for goals, objectives, or performance measures.

Variables included that are not part of the evaluation criteria are:

D. Analysis Checklist

	Management System Variable		Notes
1.0	Management Commitment and Resources	x	By inference...weak.
1.1	Reg. Compliance and OHSMS Conformance
1.2	Accountability, Responsibility, and Authority	x	Management rep. required.
2.0	Employee Participation	x	via Health and Safety Committees.
3.0	Occupational Health & Safety Policy	x
4.0	Goals and Objectives
5.0	Performance Measures
6.0	System Planning and Development
6.1	Baseline Eval. and Hazard/Risk Assessment
7.0	OHSMS Manual and Procedures	x
8.0	Training System	x
8.1	Technical Expertise and Personnel Qualifications
9.0	Hazard Control System
9.1	Process Design	x
9.2	Emergency Response	x
9.3	Hazardous Agent Management	x
10.0	Preventive and Corrective Action	x
11.0	Procurement and Contractor Selection	x	Contractor management.
12.0	Communication System	x
12.1	Document and Record Management System
13.0	Evaluation System
13.1	Auditing and Self-Inspection	x	By "head" office.
13.2	Incident Investigation and Root Cause Analysis	x
13.3	Medical Program and Surveillance	x	Strong. Industrial doctor required.
14.0	Continual Improvement
15.0	Integration	x
16.0	Management Review

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.