The new ammonia freezer and the missing risk assessment
A lead auditor is conducting a stage 2 ISO 45001 audit of a bakery employing 180 people over two 12-hour shifts. The audit criteria are ISO 45001 and the organisation's legal register. During document review, the auditor finds 42 task-based risk assessments; nine are dated more than 30 months ago. A new spiral freezer using ammonia refrigeration was commissioned four months ago, but it does not appear in the risk assessment register. The maintenance planner says the manufacturer's operating manual is 'the risk assessment' and that no management-of-change form was raised. The legal register was last updated 14 months ago and does not mention a local ammonia refrigeration code issued 10 months ago. Two cleaning staff say they enter the freezer to clean it and rely on the ammonia alarm, but they have not been consulted on the new task. The audit has one day left and three production areas still to cover.
1. Explain how you would determine whether hazard identification, risk assessment and legal requirements conform, including what you would sample and why.
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Start from the audit criteria, not the register. I would sample high-risk and changed activities: the new freezer, cleaning inside it, ammonia detection and maintenance, plus a sample of overdue assessments chosen by risk, shift and task. For each, trace hazard identification to risk assessment, controls, legal requirements and worker consultation. Check the management-of-change record for the freezer, commissioning and alarm testing, and whether the legal register update process identifies new ammonia requirements. Interview the maintenance planner, freezer operators, cleaners and the HSE coordinator; observe the task and alarm response; review training and emergency arrangements. I would not sample all 42 assessments; I would document the rationale and use the results to decide whether any gap is isolated or systemic. The key judgement is whether the organisation has a process that identifies new hazards and legal changes, not merely whether one document exists.
2. The maintenance planner insists the manufacturer manual satisfies risk assessment. Evaluate this claim and decide what finding, if any, you would raise, with reasoning.
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The manual is manufacturer information, not a site-specific risk assessment. It cannot by itself satisfy ISO 45001 6.1.2 because it does not consider the bakery's layout, cleaning method, shift patterns, competence, ammonia detection, emergency response, or interaction with other tasks. The absence of a management-of-change form strengthens the concern: a new ammonia system is a significant change. I would check whether any assessment covers the freezer at all and whether controls are effective. If no suitable assessment exists and workers enter the freezer relying on an alarm that may not be tested, this is likely a major nonconformity because it is a systemic failure in hazard identification for a high-consequence hazard, not an isolated document error. If an equivalent assessment exists under another title and is current, I would verify it before raising a finding. The finding should cite the requirement, evidence and risk consequence, not merely say 'no risk assessment'.
3. What interview and observation evidence would you seek from the cleaning staff, and how would you avoid leading them?
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Use open questions first: 'Walk me through the last time you cleaned the freezer' and 'What tells you it is safe to enter?' Avoid asking 'You rely on the alarm, don't you?' because that suggests the answer. Ask separately about training, alarm tests, what they do if the alarm sounds, who authorises entry, and whether they were asked about the new task. Observe the entry route, signage, alarm test log and any permit. Compare their account with the supervisor's and with records. Interview at least one cleaner per shift and check whether consultation was recorded. If accounts diverge, report the divergence as evidence and seek corroboration rather than choosing the most convenient version. Stop or escalate if there is an immediate danger, such as an untested alarm or unventilated entry.