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TMB / NWIP

TO THE ISO MEMBER BODIES

2013-03-12

New work item proposal – Occupational health and safety management systems Requirements
Dear Sir or Madam,
Please find attached a new work item proposal submitted by BSI (UK) on Occupational
health and safety management systems - Requirements. It should be noted that, if the
NWIP is approved, the work is proposed to be carried out in a Project Committee.
In addition to the NWIP and corresponding information received from BSI, you will findattached a letter from Rob Steele, ISO Secretary General, adressing the right and abilityof ISO and its members to deal with the subject area, as well as a letter from theInternational Labour Organization (ILO) on this proposal.
You are kindly invited to complete the ballot form (Form 05) which can be downloaded atwww.iso.org/forms and send it, preferably in Word format, to the Secretariat of the ISO
Technical Management Board at tmb@iso.org before 11 June 2013.
Yours faithfully,

Sophie Clivio
Secretary to the Technical Management Board
Encl: Letter from Rob Steele (ISO Secretary General)
Letter from the ILO
Letter from BSI
NWIP (Form 04)
OHSAS Justification Study
2011 OHSAS Standards and Certificates Survey results data (see separate Excel file)
OHSAS 18001
OHSAS 18001 - Proof of concept draft

BCL/TMB_NWIP_CL

ISO Central Secretariat
1, ch. de la Voie-Creuse
Case postale 56
CH - 1211 Genève 20
Switzerland
Telephone
Fax
E-mailWeb+ 41 22 749 02 17+ 41 22 733 34 30
central@iso.org
www.iso.org

Rob Steele
Secretary-General

TO THE ISO MEMBER BODIESTMB/NWIP

2013-03-122

New work item proposal – Occupational health and safety management
systems - Requirements

Dear Sir or Madam,
A New Work Item Proposal (NWIP) from BSI on "Occupational Health and Safety(OH&S) Management Systems – Requirements" has been circulated today to ISO
members for vote (see attached).
This letter does not express any view on the merits of the NWIP, inst ead I would liketo address the right and ability of ISO and its members to deal with the subject area.
The idea of an ISO standard on this subject is not new. However, it is being proposed
again as BSI feel the landscape for OH&S standards has evolved over the last few
years. For example, ISO has since successfully developed ISO 26000 : 2010
"Guidance on social responsibility", there have been a number of national
developments on OH&S standards, and ISO has now adopted a common framework
for management system standards. Given high stakeholder interest in the subject, youwill no doubt be contacted by parties that oppose and those that support the proposal.
That is good and what the ISO process is all about.
Attached you will find a letter from the International Labour Organization (ILO) dated
26 February 2013 expressing its concern with the proposal. Their comments areincluded to support greater collaboration with the ILO, and to inform ISO members
about the ILO's views. However these are ILO's opinions only, and it's important toclarify a number of issues related to the role of ISO in this field, specifically:
Is ISO "undermining the role of governments" by developing such a standard?
Put another way, is ISO compromising the role of governments by developing
standards in areas that are the subject of national regulation, such as health andsafety of workers? Only governments can decide on regulations. This includes
whether a voluntary ISO standard is referenced or used as a basis for regulations.
ISO has no role or intent to develop standards that confuse or compromise regulations
or public policy. This objective is clearly stated in Annex SO of ISO's Directives on"Principles for developing ISO and IEC Standards related to or supporting public
policy initiatives". ISO has already successfully developed International Standards inhighly regulated areas (e.g., food safety, medical devices) and experience has shownthat the ISO standard has added value to the role of governments and theirregulations, rather than having been a hindrance.

2013-03-11
Page 2

Does ISO have the competence to address labour and social issues?
The ILO is a specialized agency of the United Nations that brings together
representatives of governments, employers and workers to jointly develop standards,
policies and programmes promoting decent work for all. The ILO's international labour
standards (ILS) are a means of achieving its objectives, including through ratificationin its member States. One of ISO's strengths is the ability of its members to mobilize
national stakeholders with expertise and interest in the standards that it develops, andto connect with the most relevant international organizations on a subject. In addition,
ISO's audience is not States, but rather organizations. As new fields are proposed,
ISO's network is triggered to ensure that the right individuals are engaged in its
projects. ISO's competence is assured through its development procedures and its
network of national members that involve the required expertise and stakeholderinterests. A recent example is the successful development of ISO 26000 involving 6
categories of stakeholders including but not limited to industry, labour andgovernment.
Can ISO decide to pursue work if ILO disagrees?
In 2007, the ILO Governing Body (the organization's Board) requested that ISO refrainfrom developing an International Standard on occupational health and safety
management systems. In 2011, the ILO expressed concern and disappointment about
ISO's decision to proceed with the field of human resources. In 2013, in reply to theattached BSI NWIP, ILO suggests again that this field is not within the competence ofISO. It's important to note that ISO is an independent international organization with
its own structures and accountabilities. Therefore it is only ISO members that can
decide to pursue a new field of activity. It would also go against ISO's own processes
to prevent the circulation of new work on the basis of an external organization's
disagreement.
I'm hoping that the justification in the NWIP, along with ILO's letter and this letter, help
to clarify the issues as you consult stakeholders on this proposal. I encourage you tolisten and engage with all relevant interests in your country, to challenge any
unfounded claims for or against the proposal and to develop your position accordingly.
Yours truly,

Rob Steele

6 February 2013
Mr. Rob Steele
ISO Secretary General
Dear Rob
New work item proposal on Occupational health and safety management
On behalf of BSI, and with the support of both the national stakeholders and the OHSAS
Project Group, I am delighted to submit this new work item proposal for the development ofan International Standard on ‘Occupational health and safety management systems –Requirements’.
The need for organizations worldwide to improve their OH&S performance cannot be
underestimated; the statistics for health and safety incidents, accidents and their related
costs (to the individual, to organizations and to society) continue to be horrific.
Good health and safety management enables an organization to achieve effective
management of its business and OH&S risks; the protection of those doing work under its
control (direct employees as well as contractors); the protection of those affected by its
activities (visitors, neighbours, people passing the organization’s work sites); and the ability
to respond to the challenges of the global environment.
There is a clearly documented market need for standardization in this field. Guidelines in
the field of Occupational health and safety are not suitable to be used for demonstration ofconformity. This had led to a number of national and consortia standards being developed
to meet this need, and has resulted in their use internationally. The OHSAS "Standards andCertificates Survey" has shown a rapid rise in the rate of use of OHSAS 18001 andequivalent standards over the past 10 years. More importantly, it has shown that thestandards are now being used in 127 countries around the world, which strongly suggeststhat there would be value to seeking to harmonize OH&S management practices into
International Standards, and to share best practices. Using the common structure, this new
International standard will be easily integrated into the existing series of ISO Management
System Standards thereby significantly facilitating its implementation.
If the proposal is approved, BSI would like to offer to host the first meeting in September
2013 in order to progress this very important area.
Yours sincerely
Amanda Richardson,
Head of International Policy, BSINEW WORK ITEM PROPOSAL
Closing date for voting

2013-06-11

Reference number(to be given by the Secretariat)

Date of circulationN

2013-03-12

ISO/TC

Secretariat

X Proposal for new PC/ SC

A proposal for a new work item within the scope of an existing committee shall be submitted to the secretariat of that committee with a copy to
the Central Secretariat and, in the case of a subcommittee, a copy to the secretariat of the parent technical committee. Proposals not within thescope of an existing committee shall be submitted to the secretariat of the ISO Technical Management Board.
The proposer of a new work item may be a member body of ISO, the secretariat itself, another technical committee or subcommittee, ororganization in liaison, the Technical Management Board or one of the advisory groups, or the Secretary-General.
The proposal will be circulated to the P-members of the technical committee or subcommittee for voting, and to the O-members for information.
IMPORTANT NOTE: Proposals without adequate justification risk rejection or referral to originator.
Guidelines for proposing and justifying a new work item are contained in Annex C of the ISO/IEC Directives, Part 1.

Proposal (to be completed by the proposer)
Title of the proposed deliverable.
(in the case of an amendment, revision or a new part of an existing document, show the reference number and current title)

English title

Occupational health and safety management systems - Requirements

French title

Systèmes de management de la santé et de la sécurité au travail — Exigences(if available)

Scope of the proposed deliverable.

This International Standard specifies requirements for an occupational health and safety (OH&S)
management system, to enable an organization to control its OH&S risks and improve its OH&S
performance. It does not state specific OH&S performance criteria, nor does it give detailed
specifications for the design of a management system.
This International Standard is applicable to any organization that wishes to:a) establish an OH&S management system to eliminate or minimize risks to personnel and otherinterested parties who could be exposed to OH&S hazards associated with its activities;b) implement, maintain and continually improve an OH&S management system;c) assure itself of its conformity with its stated OH&S policy;d) demonstrate conformity with this International Standard.
All the requirements in this International Standard are intended to be incorporated into any OH&S
management system. The extent of the application will depend on such factors as the OH&S policy ofthe organization, the nature of its activities and the risks and complexity of its operations.
This International Standard is intended to address occupational health and safety management systems,
and is not intended to address other health and safety areas such as employee wellbeing/wellness
programmes, product safety, property damage or environmental impacts.

FORM 4 (ISO) v. 2012

Page 1 of 6

New work item proposal

Purpose and justification of the proposal.

Please refer to the supporting Justification Study (provided in accordance with Annex SL to the ISO/IEC
Directives, Procedures Specific to ISO)If a draft is attached to this proposal,:Please select from one of the following options (note that if no option is selected, the default will be the first
option):X Draft document will be registered as new project in the committee's work programme (stage 20.00)
Draft document can be registered as a Working Draft (WD – stage 20.20)
Draft document can be registered as a Committee Draft (CD – stage 30.00)
Draft document can be registered as a Draft International Standard (DIS – stage 40.00)
Is this a Management Systems Standard (MSS)?
X Yes

No

Indication(s) of the preferred type or types of deliverable(s) to be produced under the proposal.
X International Standard

Technical Specification

Proposed development track

1 (24 months)

Publicly Available Specification
X 2 (36 months - default)

Technical Report
3 (48 months)

Known patented items (see ISO/IEC Directives, Part 1 for important guidance)
Yes

X No

FORM 4 (ISO) v. 2012

If "Yes", provide full information as annex

Page 2 of 6

New work item proposal

A statement from the proposer as to how the proposed work may relate to or impact on existing work, especiallyexisting ISO and IEC deliverables. The proposer should explain how the work differs from apparently similar work,
or explain how duplication and conflict will be minimized.

There are currently no generic ISO or IEC deliverables specifically on occupational health and safety
management systems (although some items could be considered related, e.g. ISO 30000:2009 Ships andmarine technology -- Ship recycling management systems -- Specifications for management systems forsafe and environmentally sound ship recycling facilities; or ISO/TR 12885:2008 Nanotechnologies -- Healthand safety practices in occupational settings relevant to nanotechnologies, ISO_DIS 21101 Adventure
Tourism - Safety management systems - Requirements)
There is reference to occupational health and safety management systems in publications such as the ISO
handbook "Guide to the Integrated Use of Management System Standards"
One of the key factors that often leads to the development of a standard is the issue of "safety". This issue
is addressed in many product standards and guidelines for the safe handling and operation of materials,
equipment or processes. Consequently there may need to be wide interaction between the proposed PC
and many existing other ISO TCs (for example ISO/TC 21 Equipment for fire protection and fire fighting;
ISO/TC 92 Fire Safety; ISO/TC 94 Personal safety -- Protective clothing and equipment; ISO/TC 145
Graphical symbols; ISO/TC 199 Safety of machinery). However, the emphasis of the proposed PC’s work
should be on the achievement of good management practices within organizations and not on the individual
technologies addressed in these other committees (A listing of some further examples of TCs and related
standards is given below)
In addition, as the development of a management system standard is being proposed, there will need to beinteraction with other ISO MSS committees and with the ISO/TMB/TAG13-JTCG, to ensure that the
proposed ISO management system standards are aligned.
There is particularly a need for co-ordination with ISO/TC 207, as the function of health and safety is often
combined with the function for environmental management within organizations.
Additionally, there is a need for co-ordination with ISO/TC 176, as often organizations seek to combine their
quality, health and safety, and environmental management systems into an "integrated" management
system.

Outside of ISO and the IEC the key document in this field is the ILO-OSH “Guidelines on occupationalsafety and health management systems”. As these are written as guidelines, and not aligned with the other
ISO MSS, it has been found that this presents a barrier to their use by organizations trying to demonstratethat they have adopted good OH&S practices. Additionally, a number of organizations follow the Safety
Checklist Contractor (SCC) scheme (also known as the Safety Certificate Contractor scheme), which
recognizes standards such as ISO 9001 and ISO 14001, but does not require the implementation of a full
OH&S management system
By working in liaison with the various ISO committees, the ILO and the SCC, it is expected that duplicationand conflict will be minimized.
A listing of some pertinent TCs and their standards relating to safety includes:
TC 139/SC9 ISO 4413:2010 Hydraulic fluid power -- General rules and safety requirements for systems andtheir components
TC 199 ISO 12100:2010 Safety of machinery -- General principles for design -- Risk assessment and risk
reduction
TC 72/SC8 ISO 11111-4:2005 Textile machinery -- Safety requirements -- Part 4: Yarn processing, cordage
and rope manufacturing machinery
TC145/SC2 ISO 16069:2004 Graphical symbols -- Safety signs -- Safety way guidance systems (SWGS)
TC20/SC14 ISO 14620-3:2005 Space systems -- Safety requirements -- Part 3: Flight safety systems
TC67/SC6 ISO 10418:2003 Petroleum and natural gas industries -- Offshore production installations -Analysis, design, installation and testing of basic surface process safety systems
TC85/SC5 ISO 14943:2004 Nuclear fuel technology -- Administrative criteria related to nuclear criticality
safetyTC44/SC9 ISO 15012-1:2004 Health and safety in welding and allied processes -- Requirements testing
and marking of equipment for air filtration -- Part 1: Testing of the separation efficiency for welding fume
FORM 4 (ISO) v. 2012

Page 3 of 6

New work item proposal

A listing of relevant existing documents at the international, regional and national levels.

The key documents to be considered include:
The ISO/IEC Directives, Procedures Specific to ISO, Annex SLOHSAS 18001 Occupational health and safety management systems – Requirements
OHSAS 18002 Occupational health and safety management systems – Guidelines for the implementationof OHSAS 18001:2007
GB/T28001Occupational health and safety management systems - Requirements
AS/NZ 4801 Occupational health and safety management systems - Specification with guidance for use
ANSI Z10 Occupational health and safety management systems
ISO 31000 Risk management
ILO-OSH Guidelines on occupational safety and health management systems
In addition to the above documents, a number of other health and safety standards and regulations arelisted in the "OHSAS Standards and Certificates Survey" and will need to be considered during thedevelopment of the proposed standard

FORM 4 (ISO) v. 2012

Page 4 of 6

New work item proposal

A simple and concise statement identifying and describing relevant affected stakeholder categories (including small
and medium sized enterprises) and how they will each benefit from or be impacted by the proposed deliverable(s)Health and safety management guidelines and practices are usually agreed under a tripartite system
involving representation by governments/regulators, industry and labour organizations.
It would be extremely helpful to the development of the proposed standards if a similar tripartite
representation could be achieved amongst the experts participating on the PC, and particularly if
representatives from labour organizations could be encouraged to participate.
In looking at the benefits that each group of stakeholders might achieve:
1) Governments and regulators would have access to international standards that they could require theirnational industries to follow, in lieu of creating new legislation in this field. In comparison to the development
process for such legislation, the development of a standard can be a quicker and more effective process,and can be updated on a more regular basis. In addition governments and regulators would have theknowledge that their industries would not be at a competitive disadvantage when compared to those inother countries when applying such international standards. Further, they could benefit by seeing improved
compliance with regulations by organizations, and reductions in OH&S incidents and accidents.
2) Industry would benefit by knowing that it was working to the most up to date agreed set of international
practices for health and safety management and that national differences would no longer represent abarrier to trade. In addition, as globalization is moving more towards showing concern for issues on social
responsibility and sustainability, industry would be able to take comfort in knowing that its supply chainsaround the world were working to an internationally agreed set of criteria, thus giving their brands a degreeof additional protection. Further, the availability of an aligned OH&S MSS would facilitate the "integration" of
OH&S into organizations' management systems
3) Labour would benefit by knowing that organizations using the standards were being proactive in theirapproach to health and safety management in order to safeguard their workforces, or other persons under
the organizations' control.
4) Visitors, neighbours and people passing the organization’s sites would benefit by knowing that theorganization had considered their health and safety, and should not be putting them at risk.
5) For SMEs: As with other ISO MSS the proposed initial standards would be generic and applicable to alltypes and sizes of organization; consequently a small or medium sized enterprise may be able to employ asimpler OH&S management system than the more complex systems that larger organizations may need touse, as applicable to their needs.
The issue of health and safety in small organizations is known to be a problem that is common to many
countries, with a disproportionate number of incidents and accidents occurring in such organizations. The
promotion of an agreed international standard to such organizations, along with the supporting infrastructureof training courses etc. to support it, may create a level of awareness of health and safety issues in suchorganizations that other programmes have not yet managed to achieve. While this proposal is for a full
OH&S ISO MSS, ISO could look in the future at producing deliverables specifically for smallerorganizations.

FORM 4 (ISO) v. 2012

Page 5 of 6

New work item proposal

Liaisons:

Joint/parallel work:

A listing of relevant external international organizations
or internal parties (other ISO and/or IEC committees) to
be engaged as liaisons in the development of thedeliverable(s).

Possible joint/parallel work with:IEC(please specify committee ID)
CEN(please specify committee ID)
Other(please specify)

ISO/TMB/TAG13- JTCG
ISO/TC 207/SC 1
ISO/TC 176/SC 2
ISO/TC 260
International Labour Organization
World Health Organization
Safety Contractor Certificate

A listing of relevant countries which are not already P-members of the committee.

N/A
Preparatory work (at a minimum an outline should be included with the proposal)
X A draft is attachedAn outline is attachedAn existing document to serve as initial basis

The proposer or the proposer's organization is prepared to undertake the preparatory work required
Proposed Project Leader (name and e-mail address)

Mr Kristian Glaesel
kristian@glaesel-hseq.dk

Yes

No

Name of the Proposer(include contact information)

Amanda Richardson, BSI
Amanda.Richardson@bsigroup.com

Note: Given the scope of this work, we expect there will
be a need to appoint a PC Chairman and Secretary andto establish a Working Group with the Project Leader as
the Convener, a Deputy Convener, a Working Group
Secretary (and potentially a Twinned Working Group
Secretary).
Supplementary information relating to the proposal
X

This proposal relates to a new ISO document;This proposal relates to the amendment of existing ISO document
This proposal is for the revision of an existing ISO document;This proposal relates to the adoption as an active project of an item currently registered as a Preliminary Work Item;
This proposal relates to the re-establishment of a cancelled project as an active project.

Other:
Annex(es) are included with this proposal (give details)

1

Justification study (in accordance with Annex SL)

22011 OHSAS Standards and Certificates Survey results data

FORM 4 (ISO) v. 2012

Page 6 of 6

Justification Study
for an ISO International Standard on

Occupational health and safety (OH&S)
management systems - Requirements
February 20131

Contents
1. Overview, Purpose and Scope of the MSS

3

2. Principle 1 - Market Relevance7

3. Principle 2 - Compatibility

14

4. Principle 3 - Topic coverage

16

5. Principle 4 - Flexibility

17

6. Principle 5 - Free Trade18

7. Principle 6 - Applicability of Conformity

19

8. Principle 7 - Exclusions

20

9. Principle 8 - Ease of Use

20

2

1. Overview, Purpose and Scope of the MSS
1.1. Purpose and scope
What is the proposed purpose and scope of the MSS? Is the document supposed to be a
guidance document or a document with requirements?
The proposed OH&S ISO MSS would be an International Standard specifying requirements(a “Type A” ISO MSS)The International Standard is intended to provide organizations with the elements of aneffective occupational health and safety (OH&S) management system that can be integrated
with other management requirements and help organizations achieve OH&S and economic
objectives. This standard, like other International Standards, is not intended to be used tocreate non-tariff trade barriers or to increase or change an organization’s legal obligations.
The overall aim of the International Standard is to support and promote good OH&S
practices, in balance with socio-economic needs.
The International Standard would specify requirements for an OH&S management system toenable an organization to: develop and implement a policy and objectives which take into
account legal requirements and information about OH&S risk, establish processes toachieve the policy commitments, take action as needed to improve its performance, anddemonstrate the conformity of the system to the requirements. It is intended to apply to alltypes and sizes of organizations and to accommodate diverse geographical, cultural andsocial conditions.
Proposed Scope statement:This International Standard specifies requirements for an occupational health andsafety (OH&S) management system, to enable an organization to control its OH&S
risks and improve its OH&S performance. It does not state specific OH&S
performance criteria, nor does it give detailed specifications for the design of amanagement system.
This International Standard is applicable to any organization that wishes to:a) establish an OH&S management system to eliminate or minimize risks topersonnel and other interested parties who could be exposed to OH&S
hazards associated with its activities;b) implement, maintain and continually improve an OH&S management system;c) assure itself of its conformity with its stated OH&S policy;d) demonstrate conformity with this International Standard.
All the requirements in this International Standard are intended to be incorporated
into any OH&S management system. The extent of the application will depend onsuch factors as the OH&S policy of the organization, the nature of its activities andthe risks and complexity of its operations.
This International Standard is intended to address occupational health and safety
management systems, and is not intended to address other health and safety areas
such as employee wellbeing/wellness programmes, product safety, property damage
or environmental impacts.

31.2. Type of product to be produced
Would the proposed MSS work item result in an International Standard (IS), an ISO(/IEC)
Guide, a Technical Specification (TS), a Technical Report (TR), a Publicly Available
Specification (PAS), or an International Workshop Agreement (IWA)?
The proposal would result in an International Standard specifying requirements for an OH&S
management system (a “Type A” ISO MSS).
1.3. Inclusion of product specifications, test methods etc
Does the proposed purpose or scope include product (including service) specifications,product test methods, product performance levels, or other forms of guidance or
requirements directly related to products produced or provided by the implementing
organization?
The proposed purpose or scope of the International Standard does not include any type of
guidance or requirements for products or services produced or provided by an implementing
organization.
1.4. Responsibility for the proposed MSS
Is there one or more existing ISO committee or non-ISO organization that could logicallyhave responsibility for the proposed MSS? If so, identify.
There are no existing ISO committees that could logically have responsibility for the
proposed OH&S ISO MSS.
There is the possibility that either the International Labour Organization (ILO), or the OHSAS
Project Group, could be given such responsibility as non-ISO organizations, though a new
ISO Project Committee dealing with this subject matter is the preferred option.
1.5. Identification of relevant reference materials
Have relevant reference materials been identified, such as existing guidelines or establishedpractices?
Relevant materials have been identified. These include:
•
•
•
•
•
•
•
•
•
•

The ISO/IEC Directives, Procedures Specific to ISO, 2012, Annex SLOHSAS 18001:2007, Occupational health and safety management systems —Requirements
OHSAS 18002:2008, Occupational health and safety management systems —Guidelines for the implementation of OHSAS 18001
GB/T28001, Occupational health and safety management systems - Requirements
AS/NZ 4801 Occupational health and safety management systems - Specification
with guidance for use
ANSI Z10 Occupational health and safety management systems
ISO/IEC Guide 73 Risk management -Vocabulary
ISO 31000 Risk management
International Labour Organization:2001, Guidelines on Occupational Safety and
Health Management Systems (OSH-MS)
ISO 9001 Quality management systems - Requirements4•

ISO 14001 Environmental management systems - Requirements with guidance foruse

In addition there are many national OH&S management system standards, regulations andguidelines available.
1.6. Availability of technical experts to support the standardization work, and theirrepresentation
Are there technical experts available to support the standardization work? Are the technicalexperts direct representatives of the affected parties from the different geographical regions?
During the development of the OHSAS standards, the OHSAS Project Group received direct
input from delegates representing approximately 20 different countries, from many different
geographic regions, with many more contributing through commenting on the drafts (allcontinents were represented).
The proposed standards are generic and could affect all geographic regions.
A critical issue is the need to have representation from governmental interests, industrial
interests, and particularly those representing labour organizations’ interests, in order toreplicate the tripartite system under which many OH&S regulations are developed.
We consider that there would be more than sufficient experts, from all the affected parties,
from all the different geographic regions, available to support the standardization work.
1.7. Efforts required to develop the document/s
What efforts are anticipated as being necessary to develop the document in terms of experts
needed and number/duration of meetings?
We estimate that a working group of approximately 30 experts (from government, industry
and labour) would be needed to develop the document.
We anticipate that the development of the standard would follow the default 3 year track, andwould require 5 face-to-face meetings for the working group, each of 5 days duration, withadditional inter-meeting working by webinars, conference calls and e-mailThis work needs to be closely aligned with the revisions of ISO 9001 and ISO 14001, andmay be subject to delays if those activities encounter any difficulties. Consequently, close
co-ordination will be needed with ISO/TC 176 and with ISO/TC 207.
1.8. Anticipated completion date
What is the anticipated completion date?
Three years of effort is estimated to be required from the time of approval of the project
Given the ISO/IEC Directives, Procedures Specific to ISO, Annex SL for developing MSS
are relatively new (in 2012), we have already developed a Preliminary “Proof of Concept”
Draft (provided with this Justification Study) showing how the requirements of OHSAS 18001
can be migrated into the Annex SL structure, and how they align with the recent ISO/WD2
14001
5

1.9. What sort of document?
Is the MSS intended to be a guidance document, contractual specification or regulatory
specification for an organization?
It is intended to be a (Type A) “Requirements” specification

62. Principle 1 - Market Relevance2.1. Identification of all the affected parties
Have all the affected parties been identified? For example:a) organizations (of various types and sizes): the decision-makers within an organization
who approve work to implement and achieve conformance to the MSS;b) customers/end-users, i.e. individuals or parties that pay for or use a product (including
service) from an organization;c) supplier organizations, e.g. producer, distributor, retailer or vendor of a product, or aprovider of a service or information;d) MSS service provider, e.g. MSS certification bodies, accreditation bodies or consultants;e) regulatory bodies;f) non-governmental organizations.
All affected parties have been identified as follows:
1) Organizations of various types and sizes: the decision-makers within an organization
who use standards to improve business processes and accountability. The decision-makers
will be people in the organization who approve work to implement an OH&S management
system and achieve conformance to the future OH&S ISO MSS. Depending on the size andcomplexity of the organization, and the scope of their OH&S management system
implementation, this may include the CEO or equivalent, people with responsibility forcorporate governance, risk management, company/corporate secretary, or any manager
responsible for the general management of an organization or for its specific functions orprogrammes.
2) People under the control of the organization, i.e. direct employees and contractors.
Direct employees and contractors will benefit by having a safer working environment and by
being able to participate in the setting of, and influence, the OH&S policies and practices in
the organization
3) Visitors, neighbours and people passing near the organization’s sites. Visitors,
neighbours and people passing near the organization’s sites will have assurance that theirhealth and safety has been taken into consideration and is not going to be put at risk
4) Customers/end-users, i.e. individuals or parties that pay for or use a product or service
from an organization. Customers of organizations that implement the proposed OH&S ISO
MSS will benefit from effective governance, accountability, responsiveness, and efficient
operations demonstrated by that organization.
5) Supplier organizations. Suppliers that have implemented an OH&S management
system in accordance with the proposed OH&S ISO MSS will be able to demonstrateeffective and accountable business processes and sustainable services to their customers.
This assists in trade and supplier/customer relations. Suppliers may be the producer,
distributor, retailer or vendor of a product, or a provider of a service.
6) OH&S management system service providers. These providers would include national
standards bodies and independent certification bodies providing 3rd party audit orassessment services; consultants with responsibility for implementing an OH&S
management system for organizations or providing in-house assessment; and training
organizations offering training (accredited or otherwise) in implementing an OH&S
7

management system. The providers will benefit by being able to focus their activities on asingle OH&S standard, rather than needing to share resources across a range of them.
7) Governments and regulators would have access to international standards that they
could require their national industries to follow, in lieu of creating new legislation in this field.
In comparison to the development process for such legislation, the development of astandard can be a quicker and more effective process, and can be updated on a moreregular basis. In addition governments and regulators would have the knowledge that theirindustries would not be at a competitive disadvantage when compared to those in othercountries when applying such international standards. Further, they could benefit by seeing
improved compliance with regulations by organizations, and reductions in OH&S incidents
and accidents.
8) Non-governmental organizations. The private sector and the non-profit sector could use
the proposed OH&S ISO MSS to implement an effective OH&S management system,
thereby:- reducing their OH&S incidents and accidents,- reducing disruptions to their operations,- lowering their insurance premiums- providing assurance to their workers, contractors, visitors, neighbours, and people passing
their sites, that their activities are being managed in a safe manner- ensuring their legal compliance- being able to demonstrate to stakeholders that they are applying good OH&S practices(through independent external assessments against the OH&S ISO MSS).
2.2. Need for an MSS
What is the need for this MSS? Does the need exist at a local, national, regional or global
level? Does the need apply to developing countries? Does it apply to developed countries?
What is the added value of having an ISO document (e.g. facilitating communication
between organizations in different countries)?
The OHSAS Standards and Certificates survey has shown that there are a growing numberof OH&S management system standards in different countries (many based on the adoption
or adaption of OHSAS 18001). In addition it shows that such standards are being used in
127 countries.
The need for an OH&S ISO MSS can be identified at a local, national, regional and global
level, and that it applies to both developing and developed countries.
In order to protect their brands, organizations are increasingly demanding information fromtheir suppliers in global supply chains about their OH&S practices. In turn the supplierorganizations are looking for an internationally recognized and independent mechanism todemonstrate that they adhere to good OH&S practices. An OH&S ISO MSS would facilitate
this.
The proposed OH&S ISO MSS is also needed to support a new area of management
systems practice and enable increased compatibility and interoperability of management
systems governance and implementation within an organization.
2.3. Need across sectors
Does the need exist for a number of sectors and is thus generic? If so, which ones? Does
the need exist for small, medium or large organizations?

8

The need for the proposed OH&S ISO MSS is generic. It is needed at global, regional,
national and local levels, by all sectors, and in all organizations, of all sizes.
An organization can implement an OH&S management system to varying levels ofcomplexity, according to its business requirements (i.e. a small or medium sized enterprise
may be able to employ a simpler OH&S management system than the more complex
systems that larger organizations may need to use).
The issue of OH&S in small organizations is known to be a problem that is common to many
countries, with a disproportionate number of incidents and accidents occurring in suchorganizations. The promotion of an agreed international standard to such organizations,along with the supporting infrastructure of training courses etc. to support it, may create alevel of awareness of health and safety issues in such organizations that other programmes
have not yet managed to achieve.
2.4. Importance of the needIs the need important? Will the need continue? If yes, will the target date of completion forthe proposed MSS satisfy this need? Are viable alternatives identified?
The statistics for health and safety incidents and accidents and their related costs continue
to be horrific. For example the UK’s Health and Safety Executive has the following data for2010/11:•

1.2 million working people were suffering from a work related illness•

175 workers killed at work•

115000 injuries were reported (under RIDDOR)•

200000 reportable injuries (over 3 day absence) occurred•

26.4 million working days were lost due to work related illness and workplace injury•

Workplace injuries and ill health (excluding cancer) cost society an estimated £14
billion (in 2009/10)

Similarly, the figures from the 2005 statistics released at the 17th World Congress on Safety
and Health at Work showed that 2.2 million workers were fatally injured as the result of awork-related accident, which was an increase of 10 % from three years previously. The
figures equate to around 6,000 cases per day.
The need for organizations worldwide to improve their OH&S performance is immediate, andwill definitely continue into the future. Any tool, such as an OH&S management system, that
can help diminish these figures should be supported.
As globalization increases, more consumers (and consequently more customers) aredemanding that organizations operate in ethically acceptable ways, including the manner inwhich they treat their employees. There have been a number of instances whereorganizations’ malpractices have been exposed, leading to significant impact on their brands
and loss of business confidence in those organizations.
The need is important to enable organizations to demonstrate that they have adopted good
OH&S practices, and that this is able to be verified by independent assessments.
9

The need will continue, as there is evidence (from the OHSAS Standards and Certificatessurvey) of a rapidly growing number of organizations establishing formal OH&S
management systems, and as those which have already established such systems pursue
the cycle of continuous improvement.
The alignment of the OH&S ISO MSS with other ISO MSS (through the use of the Annex SL
structure and text) may also encourage organizations to adopt it as part of their overall
integrated management system.
There will also be continuing and increasing demand for standards and related guidelines in
the OH&S domain as organizations are required to respond to regulatory changes andbusiness requirements for evidence and accountability.
2.5. Determination of the importance of the need
Describe how the need and importance were determined. List the affected parties consulted
and the major geographical or economical regions in which they are located.
The need and importance have been voiced since the early 1990s by parties from all
geographical and economic regions; however the 1996 ISO OH&S Workshop concluded that
there was insufficient support at that time to initiate projects in this field. Since then theadvent of the likes of OHSAS 18001, AS/NZ 4801, GBT 28001 have seen a growing numberof standards being developed outside of ISO and yet being used internationally.
The extent of the demand is evidenced by the various OHSAS Project Group “Standards
and Certificates” surveys that have been conducted in more recent years, of which the 2011
results are provided for information.
2.6. Known or expected support for the proposed MSS
Is there known or expected support for the proposed MSS? List those bodies that haveindicated support. Is there known or expected opposition to the proposed MSS? List thosebodies that have indicated opposition.
Even before the 1996 ISO workshop on OH&S there were growing demands for a"Requirements" standard on OH&S management systems, to enable organizations todemonstrate that they had adopted good OH&S practices.
The OHSAS "Standards and Certificates Survey" has shown a rapid rise in the rate of useof OHSAS 18001 and equivalent standards over the past 10 years. More importantly, it
has shown that the standards are now being used in 127 countries around the world,which strongly suggests that there would be value to seeking to harmonize OH&S
management system requirements into an International Standard, and to share bestpractices.
It has been noted that there has been consistent opposition to the development of OH&S
management system standards both in ISO and in CEN since the early 1990s. The main
reason being cited is that each country has its own OH&S regulations, and that is
sufficient. In contrast, a key requirement of OHSAS 18001 is that organizations should
demonstrate legal compliance, which would support such national or regional (e.g. theEU’s SEVESO III) regulations. Additionally, while the regulations may differ from country
to country, the OH&S problems, and their potential solutions, remain the same.

10

The other issue that has consistently been raised in opposition to the development of suchstandards is that the actual balance of participants in the drafting process does not follow
the tripartite approach and would not be adequate. ISO has demonstrated through thedevelopment of deliverables such as ISO 26000 that it is willing to facilitate new
approaches in its drafting processes, and this issue should no longer be considered as avalid barrier.
(The OHSAS survey has shown that there is significant levels of use of OHSAS 18001
occurring even in those states that have previously expressed such opposition)
A copy of the OHSAS "Standards and Certificates Survey" for data up to the end of 2011is provided in order to support this proposal.
2.7. Expected benefits and costs to organizations
What are the expected benefits and costs to organizations, differentiated for small, medium
and large organizations if applicable? Describe how the benefits and the costs were
determined. Provide available information on geographic or economic focus, industry sector
and size of the organization. Provide information on the sources consulted and their basis(e.g. proven practices), premises, assumptions and conditions (e.g. speculative or
theoretical), and other pertinent information.
Health and safety management enables an organization to achieve effective management of
its business and OH&S risks; the protection of those doing work under its control (direct
employees as well as contractors); the protection of those affected by its activities (visitors,
neighbours, people passing the organization’s work sites); and the ability to respond to thechallenges of the global environment.
To this end, the benefits of implementing an OH&S management system for small, medium
and large organizations in any sector include:•

Common governance, policy and practice benchmarks across geographicalboundaries, including different countries, cultures and jurisdictions•

Ability to meet regulatory requirements, including accountability, ethical andcorporate governance requirements; regulatory compliance; and practice audits•

Enables compliance with national and international legislation and codes of conduct•Support of risk management, including emergency planning, and implementation•

Shows a commitment to improved OH&S performance•

Ability to set and assess performance measures for the use of contract service
providers, and for inclusion in commercial contracts•

Significant reductions in the number of OH&S incidents and accidents, including a
reduction in the costs associated with such incidents or accidents•

Significant reductions in the cost of disruptions to operations•

Reduced insurance premiums•

Use of an OH&S MSS that integrates with, and supports other commonly used MSS,
such as ISO 14001 or ISO 9001•

Enables a coordinated, consistent and integrated approach to establishing policy,
objectives, targets and implementation techniques across an organisation; thereby
minimizing duplication, redundancy, and incompatible processes11•

Use of an OH&S management system standard for measuring conformity showscommitment to the wellbeing of workers, neighbours and visitors, as well as toorganisational governance, accountability and integrity•

Scalable use of an internationally accepted system to meet business needs, resource
availability and risk•

Facilitation of communication between different countries on shared issues, and aforum for articulating common principles, minimum and best practice.

The cost is commensurate with the scope of implementation within each organization and isdetermined by business need and an assessment of risk.
The cost of implementing an OH&S management system can provide both a short-term anda long-term, positive return on investment. Cost containment can be achieved throughintegrated implementation of an OH&S management system with other MSS adopted by anorganization.
Information on benefits was derived from:• Those sources identified in 2.5 above.
•

Anecdotal information from discussions in meetings of the OHSAS Project Group•An ad hoc survey by BSI of users of BS OHSAS 18001

2.8. Benefits and costs to other affected parties
What are the expected benefits and costs to other affected parties (including developing
countries)? Describe how the benefits and the costs were determined. Provide any
information regarding the affected parties indicated.
Affected parties would benefit through:--the establishment of a worldwide body of knowledge on OH&S management systems
the sharing of best practicethe establishment of peer review and other monitoring systems to ensure that theprovision of training, certification and accreditation services are of a reasonable
standard and are universally applied (through the work of organizations such as the
IAF or the IPC)
the establishment of formal complaints handling processes by the certification andaccreditation bodies (through the use of ISO/IEC 17021)

The costs that other affected parties experience would be lower using an OH&S ISO MSS
than they would be in developing and implementing their own standards, which would add
additional development, implementation and training costs in addition to the costs theirindustries would pay for not complying with an international OH&S management standard.
2.9. Expected value to society
What will be the expected value to society?
Ultimately the widespread use of effective OH&S management systems will benefit society• by reducing the number of incidents and accidents;• by reducing disruptions to operational processes

12

•
•
•
•

by reducing the need for emergency medical care provision (both at the workplace
and at hospitals)
by reducing the need for long term care for those unable to return to work following
an accident
by preventing the removal of people from the workforce
by reducing the costs of incidents and accidents or of disruptions.

The OH&S ISO MSS should deliver significant value and performance improvements tousers, including better risk management, transparency, consistency and sustainability.
It should be recognised as a useful tool by regulators to clarify expectations and improveconsensus on requirements for good governance and the optimal way forward in the face of
conflicting requirements (such as short term versus long term goals, cost control, service
delivery and risk management).
For organizations operating in high risk OH&S environments, a joined-up, optimized andsustainable management system is essential as a means of assuring both internal andexternal stakeholders that they are managing their risks appropriately, safely and efficiently.
This is an increasingly important requirement in the current climate of investment concerns,
long term sustainability/ environmental pressures, resource constraints, fast changing
technologies and societal or customer demands.
2.10. Other Risks
Have any other risks been identified (e.g. timeliness or unintended consequences to a
specific business)?
No other risks have been identified or are anticipated.

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3. Principle 2 - Compatibility
3.1. Overlap with other ISO or non-ISO standards
Is there potential overlap or conflict with other existing or planned ISO or non-ISO
international standards, or those at the national or regional level? Are there other public or
private actions, guidance, requirements and regulations that seek to address the identified
need, such as technical papers, proven practices, academic or professional studies, or any
other body of knowledge?
There would be overlap between the proposed OH&S ISO MSS and many existing
international or national standards (e.g. OHSAS 18001, AS/NZ 4801, GB T28001, ANSI
Z10), but no conflicts with them.
There are many other public or private actions, guidance, requirements and regulations that
seek to address the identified need, such as technical papers, proven practices, academic or
professional studies, or any other body of knowledge (e.g. the ILO’s OSH Guidelines
document).
The purpose of the OH&S ISO MSS would be to harmonize such documents and activities
etc. and to share best practices.
3.2. Compatibility with other ISO or non-ISO standards
Is the MSS or the related conformity assessment activities (e.g. audits, certifications) likely to
add to, replace all or parts of, harmonize and simplify, duplicate or repeat, conflict with, ordetract from the existing activities identified above? What steps are being considered toensure compatibility, resolve conflict or avoid duplication?
The proposed OH&S ISO MSS is likely to harmonize, add to, replace, duplicate or repeat(parts of) the existing activities identified in 3.1 above, but would not conflict or detract fromthem.
It is expected that the proposed OH&S ISO MSS would supersede many of the existing
activities, so removing the initial duplication or repetition of them.
Similarly, the related conformity assessment activities would be expected to replace thoseagainst the identified existing activities.
The proposed OH&S ISO MSS would be compatible with, and support, the requirements ofother ISO MSS such as ISO 9000 or ISO 14000 (particularly through the use of the Annex
SL “High Level Structure” and text). It could be implemented as part of an organization’s
overall management system, and/or could be implemented in conjunction with any one ormore other ISO MSS.
Compatibility would be ensured through a process of validation and verification against theexisting MSS’s during the development of the OH&S ISO MSS, and through active liaison
with relevant internal (e.g. ISO/TC 176, ISO/TC 207, ISO/CASCO, the JTCG) and external
parties. This should prevent any conflict and avoid duplication.
3.3. Proliferation of MSS
Is the proposed MSS likely to promote or stem proliferation of MSS at the national orregional level, or by industry sectors?
14

It is likely that the proposed OH&S ISO MSS would stem proliferation of MSS's at thenational or regional level, or by industry sectors.
The proposed OH&S ISO MSS is likely to be adopted as an identical standard (allowing fortranslation differences) in national jurisdictions.
There is no reason for, or advantage to be gained by different jurisdictions or sectors
developing a different OH&S management system standard, although supporting products
could be developed at a regional or national level to aid implementation and to advise on
regional or national regulations.

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4. Principle 3 – Topic coverage
4.1. Application of the MSS for a single specific sector
Is the MSS for a single specific sector?
The proposed OH&S ISO MSS is not intended for any single specific sector. It would beapplicable to all sectors.
4.2. Referencing or incorporating existing ISO MSSWill the MSS reference or incorporate an existing, non-industry-specific ISO MSS (e.g. fromthe ISO 9000 series of quality management standards)? If yes, will the development of the
MSS conform to the ISO/IEC Sector Policy (see 6.8.2 of ISO/IEC Directives, Part 2), and anyother relevant policy and guidance procedures (e.g. those that may be made available by arelevant ISO committee)?
The proposed OH&S ISO MSS is likely to reference (in its Bibliography):• ISO/IEC Directives, Part 1, Procedures Specific to ISO, 2012, Annex SL• ISO 14001 Environmental management systems• ISO 9001 Quality management systems• ISO/IEC Guide 73 Risk management - Vocabulary• ISO 31000 Risk management.- Principles and guidelines• ISO 19011:2011 Guidelines for auditing management systems
The development of the proposed OH&S ISO MSS would conform to the ISO/IEC Sector
Policy (see 6.8.2 of ISO/IEC Directives, Part 2, 2001), and any other relevant policy andguidance procedures such as those provided by a relevant ISO technical committee.
4.3. The need for particular sector-specific deviations from a generic MSS
What steps have been taken to remove or minimize the need for particular sector-specificdeviations from a generic MSS?
The scope of the proposed OH&S ISO MSS is unlikely to require sector-specific deviations
from the generic MSS. However, the ISO PC that is given responsibility for this project
should work through liaison with other internal and external parties to achieve this goal.
Annex SL, Appendix 2 of the Supplement to ISO Directives Part 1 (High level structure,
identical core text and common terms and core definitions for use in Management Systems
Standards) should be used in the development of the proposed OH&S ISO MSS (which isreflected in the supporting preliminary draft).

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5. Principle 4 – Flexibility
Will the MSS allow an organization competitively to add to, differentiate or encourage
innovation of its management system beyond the standard?
The proposed OH&S ISO MSS would enable an organization to implement an OH&S
management system in a scalable way according to: its regulatory context; its size andcomplexity; the nature of its activities, products and services; its assessment of its risks; or
its organizational culture. This may be the case in particular for small and medium-sizedenterprises.
An organization can choose to go beyond a minimum level of conformance, and reach ahigher level of capability which would improve overall organizational effectiveness anddemonstrate continuous improvement. Implementation can include innovation through:• the use of less hazardous materials, products or processes•

improved design of work processes•

other techniques that result in improved OH&S performance.

The drive for higher conformance and/ or innovation can be for competitive advantage,
market differentiation, or excellence in service delivery – depending on the sector in which
the organization operates.
There are also opportunities for an organization to incorporate contractors, suppliers,
customers or trading partners within the scope of its OH&S management system, thereby
improving supply chain performance, business performance, or customer engagement – anyof which may result in competitive advantage.

17

6. Principle 5 - Free Trade
6.1. How the MSS facilitates or impacts global trade
How would the MSS facilitate or impact global trade? Could the MSS create or prevent atechnical barrier to trade?
By reducing the number of different national OH&S management system programmes, theproposed OH&S ISO MSS could facilitate global trade, and could remove existing barriers totrade.
6.2. Possible technical barrier to trade for small, medium or large organizations
Could the MSS create or prevent a technical barrier to trade for small, medium or largeorganizations?
The proposed OH&S ISO MSS could facilitate trade for organizations of all sizes by
providing:• the implementation benchmark for global or local certification against the OH&S ISOMSS•a qualification framework for tendering, or qualification for preferred provider status.

The proposed OH&S ISO MSS would not create a technical barrier to trade for small,medium or large organizations.
6.3. Possible technical barrier to trade for developing or developed countries
Could the MSS create or prevent a technical barrier to trade for developing or developed
countries?
The proposed OH&S ISO MSS could facilitate trade for developed or developing countries inthe same way as indicated in 6.1 and 6.2 above.
6.4. Use of the proposed MSS in government regulations
If the proposed MSS is intended to be used in government regulations, is it likely to add to,
duplicate, replace, enhance or support existing governmental regulations?
The proposed OH&S ISO MSS is likely to support existing governmental regulations, asmany such regulations now require organizations to establish formal OH&S management
systems. Consequently it could help organizations comply with, and demonstrate theircompliance to, such governmental regulations.
While national legislation for OH&S management usually establishes the requirements andthe body responsible for oversight; the proposed OH&S ISO MSS could provide the basis foran organization’s OH&S policy, principles and implementation techniques.

18

7. Principle 6 - Applicability of Conformity
7.1. Methods of demonstrating conformance
If the intended use is for contractual or regulatory purposes, what are the potential methods
to demonstrate conformance (e.g. first party, second party or third party)? Does the MSS
enable organizations to be flexible in choosing the method of demonstrating conformance,
and to accommodate for changes in its operations, management, physical locations andequipment?
The proposed OH&S ISO MSS:
- could be used for contractual or regulatory purposes in some jurisdictions withinsome countries- would allow for first, second, or third party methods to demonstrate conformance- would enable organizations to be flexible in choosing the method of demonstrating
conformance, and to accommodate for changes in their operations, management,
physical locations and equipment
7.2. Benefits and costs of registration/certification
If third-party registration/certification is a potential option, what are the anticipated benefits
and costs to the organization? Will the MSS facilitate joint audits with other management
system standards or promote parallel assessments?
For the proposed OH&S ISO MSS the primary benefits of third party certification include:--

Increased customer and other stakeholders’ confidence in organizations OH&S
practices, due to the independence of the certification audits
improved communications on OH&S management to customers, contractors,
suppliers and regulators, as more organizations become familiar with the OH&S ISO
MSS
improved efficiency as the global OH&S ISO MSS infrastructure expands, e.g.
through the provision of standardized auditor training courses, the availability ofknowledgeable and experienced consultants, a diversity of certification bodies etc.

The costs of third-party registration/certification include:• employee training• audit preparation costs• audit costs• registration fees.
The liaison arrangements between the OH&S PC and other ISO and IEC technicalcommittees or other external organizations, and the use of the Annex SL “High Level
Structure” and text, will ensure that the proposed OH&S ISO MSS is fully aligned with as
many other MSS as possible (and particularly ISO 14001), to enable joint audits wherever
possible.

19

8. Principle 7 - Exclusions
Does the proposed purpose or scope include product (including service) specifications,product test methods, product performance levels, or other forms of guidance or
requirements directly related to products produced or provided by the implementing
organization?
The proposed purpose or scope of the OH&S ISO MSS does not include any type of
guidance or requirements for products or services produced or provided by an implementing
organization.

9. Principle 8 - Ease of Use
No questions directly refer to the principle 8 "ease of use", but it should guide thedevelopment of the deliverable

Most technical standards require a degree of technical competence in their field tounderstand them, whereas anyone may be appointed as a manager and have to deal with aformal management system; consequently it is essential that the proposed OH&S ISO MSS
be written in a style that is generally understandable to anyone in such a role, and that it canbe translated without loss of any of the concepts underlying its requirements. The ISO PC
given responsibility for this project would need to plan how to achieve the required “ease ofuse” for the proposed OH&S ISO MSS.

20

Withdrawn certificates

Item
5.3.1
5.3.2.

ReasonNumber of withdrawn certificates
89
Organization failed re-certification audit
Organization decided to discontinue
certification because:
5.3.2.1 Return on investment was insufficient40
5.3.2.2 No business advantage resulted
42
5.3.2.3 Other reasons2483
Total 2654