A. Review Issues and Questions

1.	Publication date.	1996.
2.	Status: final, draft, other.	Final.
3.	Pending revisions.	No.
4.	Publishing Organization type.	Government - state.
5.	Type of OHSMS.	State 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 both shall and should statements.
9.	Is it a management system?	Yes. Closed system. Missing open system variables.
10.	Are there technical appendices?	No.
11.	Is there a companion audit guidance document?	Yes. Cal-OSHA provides a guide to develop and inspect OHS programs.
12.	Are there stated limitations of use?	Yes. Does not apply to workplaces with fewer than 25 employees.

B. Review Comments

As allowed by the United States’ Occupational Safety and Health Act of 1970, individual states are allowed to form a state-run occupational health and safety administration. California has elected to form such an agency. The document analyzed originated in a State Senate bill, SB 198, which required the development and implementation of an OHS program in organizations that contain greater than 25 employees.

The analysis conducted revealed that this is a closed system. Key open system variables are not present; these are continual improvement, integration, and management review.

 Other variables not present include:

- regulatory compliance and OHSMS conformance

- performance measures

- process design

- hazardous agent management

- documentation and record management system

- medical program and surveillance

Some of these OHSMS variables maybe present in other portions of the regulation.

C. Outline

a. Scope and application

b. Employer duties

1. Written safety and health program

2. Safe work practices

3. Periodic inspections

4. Safety and health training

D. Analysis Checklist

	Management System Variable		Notes
1.0	Management Commitment and Resources	x
1.1	Reg. Compliance and OHSMS Conformance
1.2	Accountability, Responsibility, and Authority	x
2.0	Employee Participation	x
3.0	Occupational Health & Safety Policy	x
4.0	Goals and Objectives	x
5.0	Performance Measures
6.0	System Planning and Development	x
6.1	Baseline Eval. and Hazard/Risk Assessment	x
7.0	OHSMS Manual and Procedures	x
8.0	Training System	x
8.1	Technical Expertise and Personnel Qualifications	x
9.0	Hazard Control System	x
9.1	Process Design
9.2	Emergency Response	x
9.3	Hazardous Agent Management
10.0	Preventive and Corrective Action	x
11.0	Procurement and Contractor Selection	x
12.0	Communication System	x
12.1	Document and Record Management System
13.0	Evaluation System	x
13.1	Auditing and Self-Inspection	x	Does not make the distinction between audits and self-inspection.
13.2	Incident Investigation and Root Cause Analysis	x
13.3	Medical Program and Surveillance
14.0	Continual Improvement
15.0	Integration
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.