Occupational health and safety division of responsibility: A conceptual model for the implementation of the OHSAS 18001:2007 standard 1

2.1 Considerations on responsibility in OHS management systems

OHS events are under a lot of scrutiny from both internal and external stakeholders, having significant impacts on reputation, employees’ morale, relation to regulative bodies, not to mention legal consequences.

Under most legal frameworks, accountability lies with the head of the organization [7, 10–16], but the distance between senior and frontline management, makes it impossible for an appropriate monitoring of the system [14]. As shown by [17], authors voiced the confusion of top, middle and front-line managers in Finnish public sector service organizations regarding their responsibilities and their duties, whereas the research presented in [18] that has been developed in the case of construction industry, has shown the contextual influences on safety leadership and pointed that the issue of who is responsible for safety is perceived as acutely needing an answer. Understanding the framework in which each level must operate for the common goal of safety is a resource facilitating decision-making and action.

Employees engagement is an important aspect is safety management. Thus, important findings on this behaviour dimension were presented through the study of the role that trust plays in moderating the relation between employee engagement and fairness, in service enterprises in [19] and by [20] where research findings demonstrate the importance of workplace well-being in promoting work engagement.

Furthermore, the guidelines for the Australian mining industry presented by [11] proposed a Safety Culture Maturity Model which considers the importance of frontline staff and develops personal responsibility. These findings are echoed by the works presented in [21] who showed that the less mature the OHS organization, the smaller the part played by employees and line-managers and less attention is given to it by top-management, as stated also, by [4]. The research presented by [22], focused on the chain of responsibility at a macro, i.e. national, level and in the context of Chinese regulation and underlined the complexity of the governmental chain of responsibility. If upper management clearly bears the legal responsibility for OHS (CEO, chairman, OHS-managing director), lower-level managers and OHS officers are concerned with managerial aspects of OHS (planning, organizing, directing, control and coordination). It is fascinating to note that in Chinese Law (Trade Union Law of the People’s Republic of China’s, 3rd April 1992, amended on 27th October 2001), trade unions are bearers of the crucial role of both technical and scientific training. Equally, specific safeguards have been ordered by the Chinese law under the form of separate in-company safety-inspectorates, without a link to production or management.

The division of responsibilities throughout the organization has a three-fold purpose: accountability in case of OHS occurrence, empowering employees to be OHS actors in their work environment and continuously improved risk management.

Rules represent a fundamental building-block of Occupational Health and Safety management as they “provide accountability and predictability by defining responsibilities for tasks and help in achieving a common understanding by developing an agreement between organizational actors” [23]. Rules can take the form of legal requirements, as defined by international or national frameworks, international conventions, European directives or regulations (in the European Union), national laws, decrees, codes [24], sectorial laws and conventions. These sets of texts mainly refer to the duty of care shared between the employer (as primary repository) and the employees. Secondly come internal policies, which are defined internally by the organization, and which, although do not have an initial legally binding character by themselves, are mandatory for application in the organization. They cannot contain dispositions opposite to legal requirements, but in case of accident or incident, the courts can consider such documents as proof of implementation of OHS. Finally, frameworks or guidelines are documents written by external bodies (with or without the input of the organization and the implementation of which is subject to the will of top management). Conformity to such documents can give a competitive advantage [25] and when adopted and implemented, they become part of company policies and therefore adopt the characteristics of these rules. Moreover, rules represent an ever-changing body, in constant search of the balance between too many and too few rules as between blind application of the rules and workers’ common sense. Thus, a viable OHS system requires the participation of the entire organization because of the intricate relationship between those who generate risk and those who are exposed to it. In this respect, the research presented in [25] proposed, in the case of the production environment, a macro-ventilation of a series of roles and responsibilities between top-management, production manager, hierarchical strata, employees, OHS delegate and employee constituted OHS committees. This proposal remains, a starting point for considering OHS roles, especially as the item “structure and responsibilities” is pinned under top management.

Other studies [11, 26–29] proposed changing the rules to match reality and considering that the workforce is an important part of the expertise of the organization, thus researchers proposed a classification of rules in action rules (small granularity procedure), process rules (decision-making models) and goal rules (defining desired states, not practices) [4, 30]. The OHSAS 18001-2007 is an example of goal-setting rules, which has achieved consensus from numerous certification institutions, national bodies and expertise bodies. The document is a framework for OHS management systems that set out several requirements and best practice for organizations that were grouped in six themes: general requirements, OHS policy, planning, implementation, and operation, checking and management review. The OHSAS 18001:2007 implementation is a voluntary approach to OHS which needs to be tailored to the organization [27].

2.2 Considerations on responsibility and organizational stakeholders

The mere existence of OHS rules is not equivalent to an efficient OHS management system; knowledge, tailoring and understanding of OHS rules are pre-requisites to their implementation. As these prerequisites are intertwined, one of the main difficulties in tailoring an OHS management system is managerial failure to know all OHS obligations and subsequent changes [31]. What is more, the implementation of voluntary management systems such as the OHSAS 18001 can induce unexpected risks within the organization [32]. Consequently, “the sustainable prevention of worker’s health should take into account: management responsibility, workers responsibility [ ...  ] clear roles for stakeholders” [32].

From the perspective of rulemaking, in [12] is stated that organizational safety compliance means that legal and/or regulatory requirements are met through practices and procedures that the safety leaders define, and the others enact. On the other hand [23], proposes that from an organizational perspective, “rules made at the top level can be written less strictly, covering only the minimally required safety level. Sub-divisions of the organization can then be authorized to issue stricter rules in their specific tasks, or its context requires them” This is reinforced through examples of practices in Norway oil and gas industry where the internal control of regulations is part of the line organization, “i.e. everyone at his/her level has a particular responsibility to improve and safeguard the OHS quality of the workplace. The overall responsibility, however, rests with the employer, who will seek support both form his professional staff and from the participants in the OHS organization” [26].

When rules are modified, generally middle-managers and team-leaders are consulted on the modification before implementation. The expected gain is that the rule makers can filter the new rule through an operational lens which is beneficial for eliminating mistakes and facilitates future implementation [23].

Empowering employees to be actors of OHS in their work environment is a crucial task that relies on direct management [14] who must be trained accordingly [33] and finally, on the employees themselves [13]. Employees are the first who can help risk identification, minimization and/or elimination becoming the first beneficiaries of the implemented measures. For this to occur, any employee must have appropriate training for the work to accomplish but also relative to the operating environment. To this end, for instance, front-line supervisors in construction industries, as described in [33], are considered motors for recognizing safe work behaviour, and thus the minimal legal training requirements seem insufficient compared to the real OHS needs of their work environment.

Literature still debates middle-managers’ role in OHS on account of their proximity to information, their capacity to make financial decisions in safety issues, their role in motivating personnel [13] within a limited action span [29, 35]. Their role in OHS has been less researched. Parallelly, employees are viewed as a group of stakeholders that have essential knowledge of the workplace and the risks related to it and consequently, are considered as having a paramount role in hazard mitigation.

Within the EU Framework Directive 89/31, Article 11, it is specified that all discussions regarding safety and health at work should involve either workers or their representatives. In the research study [35] is re-examined the modern role of the safety representative (on a general basis) and three categories of them are defined: safety committee with representation from all parties, safety representatives elected by the employees and safety experts representing the management. Regardless of the form, the safety representative’s functions include representation of the employees on OHS matters with the employer and the enforcing authorities, with the objective of complying with OHS requirements and protecting employee interest. This can be achieved through the investigation of hazards or complaints, inspections, attendance in committees and specific training. If the employee representatives are partial participators to OHS as the final decision lies with the employer, the latest research tends to confirm the need for a more precise definition of their rights and duties. The consensus among managers and safety representatives’ points to satisfaction with the legal and regulatory framework but dissatisfaction with its operational application. Building on these findings, we can infer that the managerial job needs support in dealing with the bulk of information, and such a transversal aid could be the safety representative.

As emphasised by [36], in an integrated safety culture organization, top-down and bottom-up approaches coexist among management strata: upper management decisions are efficient for rapid implementation and change, but procedure maintaining should be a bottom-up approach in which lower management and workers can voice their own conclusions. The responsibilities of middle and frontline managers include implementing relevant safety training, establishment and dissemination of experience feedback (including analysis of incidents and accidents), communicating safety rules, checking subsequent application, proposing discussions on rule formalizing, implementing and finally, arbitrating on contradictions [8].

All in all, research on a holistic approach of stakeholder responsibility in the field of OHS remains scarce, approaches focusing on specific industries and/or legal contexts. If leadership, roles, culture are discussed, the matter of responsibility is mainly dealt within the context of a legal framework and with an important focus on the responsibilities of top management. One of the few attempts linking voluntary management systems to the leader-follower dyad is that presented in [12], who coupled leader practices for safety and aligned them to macro requirements of the OHSAS 18001:2007. Among the reviewed studies, none had a holistic approach regarding all the items of the OHSAS 18001, while through the sampled population, the focus was on the front-line supervisors and workers, and thus safety compliance was oriented on implementation [37].

External (governments, NGOs, work inspectors, work doctors, audit organizations) and internal (top, middle and front-line managers, employees, trade unions) gravitate around OHS, and consent seems to be achieved on the role played by top management (as an employer) who define policies in coherence with the strategy of the company, and bear the accountability for OHS, middle management (as representatives of the employer) who ensure follow-up and regular application of company policy, but without any clear responsibility associated, yet having decisional capacity, front-line managers (as representatives of the employer) who ensure the day-to-day implementation of OHS policies, governments (as a legislator) who define the minimum legal OHS requirements and standards-issuing/audit organizations (as control organizations), who can exercise a form of control on the way in which OHS is implemented [30, 38].

Main divergence of opinion occurs around the following stakeholders: employees, targeted by the OHS policies and the core of its application and trade unions (as representatives of employees), the existence of which seems to depend on statutory and historical inputs [8, 30].

In conclusion, the few studies tackling responsibility and OHS deal with high-risk industries or specific legal frameworks and do not bridge the gap of how the internal chain of responsibility can be implemented in the organization. If national legal frameworks seem to agree on the general duties of the employer and consequent legal accountability, the way in which subsequent responsibility is cascaded within the organization and among the internal stakeholders remains an understudied field.

Based on the literature review and ILO Guidelines (2001), Table 1 summarizes the stakeholders that influence OHS responsibility (considered also the synthesis of relevant studies as [10, 40]).

Coronavirus (COVID-19) infection disease was reported in Wuhan (China) on December 31st, 2019, and subsequently spread around the world within the next few months. Currently, there are more than 200 countries that are confronting this pandemic. Compared to the Severe Acute Respiratory Syndrome (SARS), COVID-19 is more contagious, which has indicated a different fatality rate. The recent emergence of COVID-19 has devastated not only countries’ economies but also tarnished the image of health mechanisms among advanced and developing countries. The industries are confronted with the severe challenge of corona pandemic and face severe challenges of OHS Management Systems implementation. The primary objective of the OHSAS 18001 standard is to establish the business managerial measures relative to OHS [17]. A secondary objective of OHSAS 18001 implementation relates to its contribution to sustainable development through the preservation of human life and of the environment.

Occupational injuries and frequency of accidents can wreck both the organizational structure and employees’ perception. Occupational injuries are one of the foremost by-products of organizations and economies alike [41]. A staggering number of people faces preventable occupational injuries and fatalities around the globe. Occupational injuries are particularly perceived as an unintended event which affect working abilities of the workforce, damage equipment and interruption in daily activities [42]. To the staggering figures relative to employee safety [43], new concerns are added due to the physiological and psychological impacts of COVID-19 on workers. In this situation, both employers and employees should play their role to prevent the spread of the disease. The current situation is more challenging for organizations from moral, economic, and legal stand points. It is the responsibility of the organization to ensure a strict and efficient implementation of the OHSAS-18001 during the current pandemic situation. The importance of infection control plan can be neglected in the present scenario. Organizations can implement several measures in the workplace such as providing hand sanitizers/washing facilities, proper ventilation systems and cleaning those objects that are commonly touched. Occupational health and safety measures should be monitored and checked regularly [44].

The implementation of OHS within organizations must also consider current conditions. The implications of OHS and COVID-19 are presented in Table 2 (as a synthesis of [45–47]). An evaluation of the basic conditions related to OHS in the COVID-19 conditions was performed, followed by an attribution of responsibility for OHS directions to specific stakeholders.

From a historical perspective, the OHS directions in COVID-19 environment are neither new nor innovative measures, but specific OHS issues that are derived from more global OHS considerations. The particularity of the COVID-19 work environment is that is shifts focus on specific preventive behaviours of more global OHS themes. For example, the OHS direction “Proper collection of hazardous waste for employees and the environment” is derived from the chapter “4.4.6 Operational control” of the OHSAS 18001(as supported also by [43, 48–50]).

In conclusion, the COVID-19 work environment makes OHS considerations more stringent and reinforce the need of a clear definition of OHS responsibility.

4.1 The research method

The present chapter shall present the method for the implementation of the proposed OHS Responsibility Multilevel Model with respect to the OHSAS 18001:2007.

The implementation of OHS Management Systems, specifically in the framework of OHSAS 18001:2007 standard, demonstrate a strong organizational commitment to OHS [51]. The literature review brought forward the existence of numerous OHS stakeholders, but also pointed out a real concern regarding the clear definition of their roles and responsibilities in OHS implementation within “the internal responsibility system” [53]. As presented in [50], authors have one of the rare research efforts addressing the research gap of “who is responsible for this OHS dimension within the organization?” through a case study of a growing global organization in the steel industry. Unfortunately, this research is contextualized to a specific moment of the lifecycle of an organization (reorganization following the integration of new units worldwide) [50].

Consequently, the present research explores the question: When constituting an internal chain of responsibility, which organizational stakeholder should be responsible for each item of the OHSAS 18001:2007? In our research vision, the result is a conceptual canvas for attributing internal OHS responsibility, without bias of sectorial or geographical considerations. This internal chain of responsibility is achieved by linking the items of the OHSAS 18001:2007 standard to organizational stakeholders identified through the literature review.

From the methodological perspective, in the first stage, the authors reviewed all the items of the OHSAS 18001:2007 standard to establish if the document specifies whether responsibility for an item is attributed:

Implicitly, i.e. inferred, based on related items that responsibility falls upon a stakeholder;

It was observed that there are few responsibilities that are namely attributed to a hierarchical or functional level, but mainly to the organization. In addition, during this first assessment of the OHSAS 18001:2007 standard, it was observed that items are composed of several individual actions.

Consequently, in the second stage of the approach, all items were decomposed into individual actions, based on the expressions “someone verb something” or “something verb”. If an item included any combination of verbs, the item was divided into as many individual actions as verbs present; for instance, an item including “establish, implement and maintain”, was divided into three separate individual actions: one around “establish”, one around “implement” and one around “maintain”. This decomposition has led to a total of 304 individual actions.

Following, in the context of the third stage of the present research approach, the authors attributed to each of the OHSAS 18001:2007 standard individual actions an internal stakeholder based on the OHS Responsibility Multilevel Model. By integrating these responsibilities in the hierarchical Multilevel Model of the organization, the authors defined an internal chain of OHS responsibility. The purpose of this association was to bridge the gap of responsibility attribution in the implementation of the OHSAS 18001:2007 standard.

4.2 Results and discussions

The present chapter will discuss the practical implications and the utility of the designed Multilevel Model for OHS stakeholders’ responsibility.

The first step of the research consisted in reviewing the OHSAS 18001:2007 standard items with the purpose of identifying the prescribed organizational stakeholder responsible for each item (completed with a quantitative approach). The identification of the responsible stakeholder was based on implicit or explicit designation in the standard, according to the previous methodological explanations.

Three stakeholders were identified for 68 items: the organization, top-management, and management. If the standard clearly attributes responsibility for 10% of its items to top-management, around 89% are attributed to the whole organization without any further detail regarding hierarchy or function (Table 3, Fig. 2, and extended results are shown in Appendix A). This is hypothesised to be due to the wide application spectrum intended for the standard and is coherent with the findings of the literature review, which considered top management as owners of general duty.

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Fig. 2

Implicit and Explicit attribution of responsibility in the OHSAS 18001:2007.

During this first analysis, it was concluded that numerous items of the OHSAS 18001:2007 standard are compounds of several actions. The authors thus considered it appropriate to divide the items into individual actions (according to the methodological approach), which led to the identification of a total of 304 actions. Following, actions were reviewed and associated with an internal stakeholder based on the findings of the literature review. A detailed quantitative synthesis is presented in Table 4 (graphical representation in Fig. 3). Extended results of the association are given in Appendix B.

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Fig. 3

Responsibility attribution according to the OHS Responsibility Multilevel Model.

Regarding the correlation between the literature review and the responsibilities stemming from the OHSAS 18001:2007, it is to be noted that the literature review demonstrated that OHS issues transcend industrial contexts (including healthcare or education) rendering the coupling stakeholder - OHSAS 18001:2007 standard robust to sectorial considerations.

In coherence with the conclusions of the literature review, it was considered that the responsibilities of the employer are transferred upon top management. This hypothesis is based on an organizational perspective and does not include legal considerations which are out of the scope of the present work. Furthermore, this hypothesis is anchored in the conclusions that employer and/or top management responsibilities are mostly the same across countries and industries. Moreover, as the OHSAS 18001:2007 standard requires compliance with minimum legal requirements applicable in the organization’s industrial sector and stemming from the different regulatory frameworks, it is considered that the internal chain of responsibility developed for the OHSAS 18001:2007 respects all external responsibilities.

As the literature review concluded to a decline of the role of trade unions in the OHS problematics, but a more favourable position for the safety representative, the internal Safeguard stakeholder that was considered in this analysis was the safety representative. Considerations regarding the nomination of the safety representative were set aside to favour wide applicability of our findings (across industries or company sizes or legal requirements).

The coupling of responsibilities stemming from the OHSAS 18001:2007 standard to organization’s stakeholders allows us to conclude, as presented in Fig. 3, that top management (TM) is responsible for 39% of the identified actions, their responsibilities including policy definition and policy guardianship. Middle managers (MM) and frontline mangers (FLM) are responsible for a total of 29% of the identified actions. The responsibilities of middle managers (17% of identified actions) gravitate around their role as: implementers and communicators. The analysis of the actions for which they are responsible confirms their role as link between top-management as policy establishers and frontline managers as operational implementers on the sharp-edge. Finally, the front-line managers (12% of actions) are responsible for policy implementation and they act as communicators towards workers. They seem to play a small role in policy establishment, which seems coherent with their proximity to employees/workers and being distanced to upper-management strata. Nonetheless, they have a responsibility in signalling incoherencies between the rules established and the real working processes and environment in a bottom-up approach.

Concurrent with the literature review, the application of the OHS Responsibility Multilevel Model shows that the responsibility of the safety representative (SR, 32% of identified actions, Fig. 3), is very complex and widespread, including the traditional prevention role through conformity and hazard analysis and audits, but also policy contributor (he/she contributes to the policies established by top- management as expert on OHS problems), policy maintenance officer (maintains policies established by top-management), training contributor (assesses training needs as regard to OHS problems in the organization) and document guardian (insures the whole process documentation of the OHS system). Thus, the safety representative’s role is extended to that of a transversal manager (outside hierarchical strata) as also accountable for actions in accordance with provisions stipulated by OHSAS 18001:2007 standard, such as:

The participation of workers (under 4.4.3.2 Participation and consultation);

It is to be noted that although the proposed conceptual model considers that employees can have responsibilities ensued from those of frontline managers, no such responsibility was defined among the individual actions identified in the OHSAS 18001:2007. This is also coherent with previous research which showed that employees’ primary responsibility is playing by OHS rules as induced by frontline managers.

Depending on the size of the company, the proposed model can be customized. Due to the fact that within the model different levels of organization have been identified, it is clear that the size of the organization can be from small and medium enterprises to large enterprises (in accordance with the organization of enterprises, depending on the number of employees).

As with operational responsibilities, it can be observed for the OHS chain of responsibilities that was obtained by applying the Multilevel Model to the OHSAS 18001:2007 standard, that there is a diminishment of the number of responsibilities throughout the hierarchical strata, in accordance with the stated hypothesis and findings of the literature review (responsibility is concentrated on top-management and is then cascaded on the lower hierarchical level). Simultaneously, any responsibility hinging on a lower- level is also included in the responsibilities of a superior level. In these regards, the proposed model is a response to performance variability, in which each hierarchical level can compensate or take necessary measures for the improvement or the fluctuation of its lower levels but also point-out anomalies or gaps in the performance of higher-levels, thus engaging a continuous improvement approach for OHS.

From the literature review perspective, in coherence with the results presented in [34] there have been stressed the need for guidelines on management responsibilities which would complete OHS standards, although ultimate legal accountability lies with the employer. Furthermore, the current context of COVID-19 work environments has stressed further the need of clarification regarding OHS responsibilities among organizational stakeholders.

In comparison with other research results or approaches achieved by other authors, most of them do not offer concrete solutions or a framework for defining responsibility in OHS, considering the stakeholders’ management, too. Even the ILO Guidelines in 2001 and other researchers [11, 54] have considered and operate with ideas that OHS accountability lies with the head of the organization (top management), and the hierarchy distance and the defined responsibilities of senior and frontline management and also, of the top, middle and low level managers create an organizational model with an appropriate monitoring of the OHS system. Thus, the proposed OHS Responsibility Multilevel Model together with the discussions on its application have offer a feasible solution for the creation of a practical internal chain of OHS responsibilities. In addition, the creation position of a Safeguard (perceived as an internal or external stakeholder acting in the field of OHS as a “guardian”, depending on the company’s type and stakeholders’ power and interests) is considered an innovative solution for responsibility in OHS (not identified in the literature), supporting the practical application of the OHSAS 18001:2007 standard.

In addition, the presented research is aligned with the conclusions of [15], regarding the middle managers crucial and multiple roles in the OHS management. Despite the research conclusions and debates on the impact and capacity of middle managers (actions and behaviours) supporting safety management into organization, the proposed approach is based on the concept of the diffusion of OHS responsibility by different hierarchy managers and stakeholders. These create the premise of the safety and prevention culture development.