OHSAS 18001 Is Dead — What Now?
OHSAS 18001 was officially withdrawn on 31 March 2021. Any organisation still referencing OHSAS 18001 certification is operating with an expired, unrecognised credential.
Key Changes You Must Address
1. Annex SL High-Level Structure
ISO 45001 follows the same structure as ISO 9001:2015 and ISO 14001:2015, making integration straightforward.
2. Context of the Organisation (New Requirement)
You must now formally identify:
- Internal issues: organisational culture, governance, capabilities
- External issues: economic conditions, legislation, technology
- Interested parties: workers, unions, regulators, contractors, communities
3. Enhanced Leadership Requirements
ISO 45001 requires top management personal accountability — cannot be fully delegated.
4. Risk-Based Thinking
Expanded from hazard identification to include OH&S risks, system risks, and opportunities.
5. Worker Participation (Not Just Consultation)
Workers must actively participate in hazard identification, risk assessment, control determination, and incident investigation.
Migration Gap Analysis Checklist
Context and Interested Parties
- [ ] Internal and external issues documented
- [ ] Interested parties identified with needs and expectations
- [ ] Scope statement updated to reflect ISO 45001
Leadership
- [ ] Top management demonstrates personal commitment
- [ ] OH&S policy updated to ISO 45001 wording
- [ ] Worker participation mechanisms established
Planning
- [ ] Risk and opportunity assessment beyond traditional HIRA
- [ ] Legal register updated to include "other requirements"
- [ ] OH&S objectives SMART and measurable
Support
- [ ] Competence framework established
- [ ] Awareness requirements expanded
- [ ] Communication process documented
Operation
- [ ] Hierarchy of controls explicitly referenced
- [ ] Management of change process documented
- [ ] Outsourcing and procurement controls established
Performance Evaluation
- [ ] Compliance evaluation process formalised
- [ ] Internal audit programme competency-based
- [ ] Management review agenda updated
Migration Timeline
| Phase | Duration | Key Activities |
|---|---|---|
| Gap Analysis | 2-3 weeks | Assess current system against ISO 45001 |
| Update Documentation | 4-8 weeks | Revise manual, procedures, records |
| Implement Changes | 6-12 weeks | Context analysis, worker participation |
| Internal Audit | 2 weeks | Full system audit against ISO 45001 |
| Management Review | 1 week | Updated agenda and outputs |
| Certification Audit | 2-3 weeks | Stage 1 and Stage 2 |
Total: 4-6 months for organisations with established systems.
Common Migration Pitfalls
Pitfall 1: Treating it as a documentation exercise ISO 45001 requires genuine cultural change around leadership and worker participation.
Pitfall 2: Ignoring context analysis Clause 4 requires genuine strategic thinking. Auditors will test this.
Pitfall 3: Inadequate worker participation evidence Consultation ≠ participation. You need evidence of active worker contribution.
Pitfall 4: Not updating internal auditor competency Auditors must understand ISO 45001's new requirements.
The Cost of Not Migrating
| Risk | Potential Impact |
|---|---|
| Lost tenders | R500,000 - R50M+ per contract |
| Insurance premium increase | 10-25% uplift |
| Regulatory scrutiny | Improvement/prohibition notices |
| Client audits | Failed supplier assessments |
Training for Successful Migration
OHS Compliance Group offers targeted migration training:
- ISO 45001 Migration Workshop (2 days)
- ISO 45001 Internal Auditor (3 days)
- ISO 45001 Lead Implementer (5 days)
- Management Briefing (half day)
- NEBOSH IGC for foundational competency
Request a free migration consultation or view our ISO 45001 training.
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