A Programme Under Pressure
You manage the ISO 45001 certification programme for a client holding one certificate covering 14 sites, audited on a rolling multi-site sample. In the last six months: a subcontracted worker died after a fall from height at one site; two internal audits across the sample found the same nonconformity against 9.1.2, where compliance evaluation had not been updated after a legislative change; the auditor who covers the two highest-risk sites has left for another certification body; and the client has acquired three new sites to be added before the next surveillance. The programme budget is fixed for the year, and the client's head of H&S wants the sample reduced to two sites because the system is mature.
1. What must change in the audit programme, and on what basis? Frame your answer around ISO 19011 programme management and risk.
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The programme is risk-based, so four events in six months are four inputs that must be reflected in the programme's objectives, scope, schedule and resourcing - not absorbed silently.
- Fatality at one site: the highest-risk site in the sample must be audited at the next surveillance, and the audit must test the specific controls that failed (work at height, subcontractor management under 8.1.4, incident investigation and corrective action under 10.2). Consider extending the sample of sites with similar activities and consider a special audit now rather than waiting.
- Recurring 9.1.2 finding: the same nonconformity twice is not coincidence, it is a systemic failure of the compliance-evaluation process, and it makes compliance evaluation a mandatory element at every site visited, plus at the central function. Check the central function's own legal register and evaluation process first - that is where a legislative change should be caught.
- Acquisition of three sites: the certificate scope (4.3) is affected. The new sites must be brought into the programme under the certification body's rules for scope extension before they are presented as certified, and their hazard profile assessed for audit time.
- Loss of the high-risk-sector auditor: a competence and resourcing gap affecting the sites that matter most.
Document the revised programme objectives, the changes, the justification and the risk accepted. Report it to the person accountable for the programme.
2. How do you handle the request to reduce the sample to two sites?
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Refuse the basis, not necessarily the number, and be precise about why.
- 'The system is mature' is not a risk criterion. Sample size and site selection must follow the programme's documented rationale: results of previous audits, the significance of hazards at each site, complaints and incidents, regulatory change, changes in organization or process, and the effectiveness of the central function. A fatality and a repeat nonconformity point in exactly the opposite direction.
- Multi-site sampling rules require the central function to be audited every time and the site sample to be justified, part of it selected at random and part selected on risk. A two-site sample for a 14-site certificate with a fatality in the period would not be defensible to an accreditation assessor or to a customer.
- If the fixed budget genuinely cannot fund the required programme, the options are: reduce the scope of certification, defer additions of the new sites, or the client accepts the cost. What is not available is doing the same scope with less evidence. Put the trade-off in writing and let the client choose.
- Record the commercial pressure and the decision. Where pressure could affect impartiality, the certification body's impartiality safeguards must be engaged - this is precisely what the programme-level analysis is for.
3. What are the competence and independence implications, and how do you evaluate whether the programme is delivering?
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Competence. The auditor who covered the highest-risk sites must be replaced by someone with verified sector competence, not by whoever is free. Establish what specifically was lost - construction or work-at-height experience, knowledge of the relevant legal requirements, ability to audit subcontractor controls - then select or develop to fill that gap, using technical experts where the gap is technical rather than audit-related. New team members need a supervised first audit (7.3) before they are relied on.
Independence and performance. The recurring 9.1.2 finding raises a question about audit effectiveness at those two sites: did the previous audit test compliance evaluation properly? Review the relevant reports and consider whether a different team should cover them next cycle. Evaluate auditor performance using the report quality, the traceability of findings, feedback from the client and observation (7.3), and record the outcome.
Programme monitoring. Judge the programme against its own objectives: are findings recurring or reducing, are closure times met, are audits delivered as scheduled, are complaints and incidents trending? If a required element keeps being missed at audit, the fault may be in the programme's design or time allocation, not only in the client's system. Report performance and any need to change the programme to the accountable management, and record the review.