Clause 5.4 is one of the most significant and distinctive elements of ISO 45001:2018. Unlike OHSAS 18001, which required only worker representation, ISO 45001 demands meaningful consultation and participation of workers at all applicable levels and functions, including non-managerial workers. This requirement recognizes that workers closest to hazards have the most valuable insights into risks and effective controls.
Consultation vs. Participation
ISO 45001 distinguishes between consultation and participation. Consultation means seeking the views and input of workers before making a decision. Participation means involving workers in the actual decision-making process. Both are required, but they apply to different OHSMS activities.
Workers Must Be Consulted On
- Determining the needs and expectations of interested parties (Clause 4.2)
- Establishing the OH&S policy (Clause 5.2)
- Assigning organizational roles and responsibilities (Clause 5.3)
- Determining how to fulfill legal and other requirements (Clause 6.1.3)
- Establishing OH&S objectives (Clause 6.2)
- Determining applicable controls for outsourcing, procurement, and contractors (Clause 8.1.4)
- Determining what needs to be monitored, measured, and evaluated (Clause 9.1)
- Planning, establishing, and implementing the audit program (Clause 9.2)
- Ensuring continual improvement (Clause 10.3)
Workers Must Participate In
- Determining mechanisms for consultation and participation
- Identifying hazards and assessing risks and opportunities (Clause 6.1.2)
- Determining actions to eliminate hazards and reduce OH&S risks (Clause 6.1.2)
- Determining competence requirements, training needs, and training evaluation (Clause 7.2)
- Determining what needs to be communicated and how (Clause 7.4)
- Investigating incidents and determining corrective actions (Clause 10.2)
Best Practices for Worker Involvement
- Go beyond minimum requirements and create a culture where worker input is valued and acted upon
- Use multiple mechanisms: safety committees, suggestion systems, toolbox talks, safety observations, near-miss reporting apps
- Provide time, training, and resources for workers to participate effectively
- Remove barriers to participation: language differences, shift schedules, literacy levels, fear of reprisal
- Communicate back to workers how their input influenced decisions
- Track worker participation metrics as a leading indicator of OH&S performance
- Include contractors and temporary workers in participation mechanisms


