Management Review Without the Right Inputs

Clause 9.3 requires the management review to consider a defined set of inputs. Missing inputs include:

1. Status of actions from previous management reviews - without this, there is no continuity and no accountability for prior decisions.
2. Changes in external and internal issues relevant to the OH&S MS - including the new working-at-height regulation. Ignoring a legal change is a serious gap; it links to 6.1.3 (legal and other requirements) and 9.1.2 (evaluation of compliance).
3. Changes in the needs and expectations of interested parties - e.g., regulators, clients, workers.
4. Changes in legal and other requirements - the new regulation is a direct 9.3 input.
5. OH&S performance and effectiveness of the OH&S MS, including trends in incidents, nonconformities, corrective actions, monitoring results, and evaluation of compliance - the agenda has only lagging indicators, not control effectiveness.
6. Results of worker consultation and participation (5.4) - absent.
7. Results of internal audits - two findings open for six months, not discussed.
8. Opportunities for continual improvement - absent.
9. Adequacy of resources - not discussed.
10. Relevant communication with interested parties, including complaints - absent.

A strong answer groups these and notes that the review is not a financial meeting with a safety slide; it must cover the full input set to be effective.

Compliance with 9.3 is not satisfied by holding a meeting and signing minutes. The clause requires the review to consider the specified inputs and to produce outputs that include decisions and actions related to:

• opportunities for continual improvement;
• any need for changes to the OH&S MS;
• resource needs;
• integration with other business processes;
• any implications for the organisation's strategic direction.

A review that omits the required inputs cannot produce informed outputs. The 'we minuted it' defence confuses evidence of a meeting with evidence of an effective review. Under 9.1.1, the organisation must evaluate OH&S performance and the effectiveness of the OH&S MS - the review is the top-level forum for that evaluation. Under 10.3, continual improvement requires the review to feed improvement, not just record lagging numbers.

The correct judgement: the review is nonconformant against 9.3 because the inputs were incomplete and the outputs were not demonstrated. The minutes are evidence of a meeting, not of a compliant review.

The firm should close the real gap, not fabricate a record. A model answer distinguishes remediation from retrospective documentation.

1. Hold a supplementary management review now, with the full 9.3 input set: status of previous actions, legal changes (the working-at-height regulation), internal audit findings, worker consultation results, compliance evaluation, and control effectiveness. Document the decisions and actions (outputs), not just attendance.
2. Address the two open internal audit findings - investigate, correct, and verify. This links to 10.2.
3. Evaluate compliance with the new regulation (9.1.2) and update the legal register (6.1.3).
4. Establish a forward schedule so the next review is planned with the full agenda and inputs - this is the systemic fix.
5. Do not backdate or manufacture minutes. The auditor will test whether the review is effective, and a fabricated record is both a nonconformity and an integrity failure.

A strong answer notes that the auditor is likely to sample the management review minutes, cross-check against the input list, and interview the CEO. The best preparation is to make the next review genuinely complete, and to be transparent about the gap and the corrective action taken.