9. Performance Evaluation
9.1 Monitoring, Measurement, Analysis and Performance Evaluation
9.1.1 General
Performance evaluation is the data layer of the system. Defined measures, defined methods, defined frequencies — feeding analysis that tells the organisation whether the OH&S system is actually working. Without measurement, "we have a good safety system" is an opinion.
Determination of Monitoring and Measurement
Five questions, answered up front:
a
What gets monitored and measured:
- How well legal duties and other obligations are being met
- Activities tied to identified hazards, risks and opportunities
- Progress against OH&S objectives
- Whether operational controls are doing what they were designed to do
b
Methods that produce valid, repeatable results — not anecdote
c
Performance criteria — the thresholds that separate acceptable from not
d
Frequency — how often each measure is taken
e
Reporting cadence — when results are analysed, evaluated and communicated
Leading vs Lagging Indicators:
Leading Indicators (Proactive):
- Safety inspections completed on schedule
- Hazard reports submitted by workers
- Near-miss reporting rates
- Safety training completion rates
- Safety observations and behavioral audits
- Risk assessments conducted
- Corrective actions closed on time
- Worker participation in safety committees
- Preventive maintenance completion
Lagging Indicators (Reactive):
- Lost Time Injury Frequency Rate (LTIFR)
- Total Recordable Injury Frequency Rate (TRIFR)
- Days away from work
- Fatalities and serious injuries
- Occupational illnesses
- Workers' compensation claims
- Incident severity rates
Don't run on lagging indicators alone:
LTIFR and TRIFR tell you what's already gone wrong. Leading indicators — inspection completion, near-miss reporting rate, training currency, action close-out — tell you whether the conditions for failure are building. A dashboard that only watches lagging measures is reading yesterday's news.
LTIFR and TRIFR tell you what's already gone wrong. Leading indicators — inspection completion, near-miss reporting rate, training currency, action close-out — tell you whether the conditions for failure are building. A dashboard that only watches lagging measures is reading yesterday's news.
Monitoring and Measurement Methods
OH&S Monitoring and Measurement Activities:
- Workplace Inspections: Regular safety inspections and walkthroughs
- Exposure Monitoring: Air quality, noise levels, chemical exposures, ergonomic assessments
- Health Surveillance: Medical examinations, health monitoring programs
- Equipment Testing: Safety equipment testing, calibration, maintenance verification
- Behavioral Observations: Safe/unsafe behavior observations
- Incident Tracking: Incidents, near-misses, first aid cases
- Compliance Checks: Permit-to-work compliance, procedure adherence
- Performance Metrics: KPI tracking, objective achievement monitoring
- Worker Feedback: Safety surveys, suggestion schemes, consultation outcomes
Equipment Calibration and Maintenance
Monitoring and measurement equipment — gas detectors, sound level meters, dosimeters, pressure gauges — is calibrated or verified to a defined schedule
Equipment is used within its specification and maintained between uses
Calibration certificates and measurement records are retained as evidence of valid results
Analysis and Performance Evaluation
Raw data is analysed for trend, pattern and outlier — not just reported as monthly totals
The analysis evaluates both OH&S performance (are workers safer) and system effectiveness (is the management system delivering)
Results are documented and retained as part of the evidence base for management review
Performance Analysis Questions:
- Are we achieving our OH&S objectives?
- Are our controls effective in eliminating hazards and reducing risks?
- Are we complying with legal and other requirements?
- What are the trends in our OH&S performance?
- Are there areas of concern requiring additional focus?
- What are the root causes of incidents and near-misses?
- How does our performance compare to industry benchmarks?
- Are workers actively participating in OH&S activities?
9.1.2 Evaluation of Compliance
The organisation has to actively check itself against legal duties and other obligations — not wait for a regulator visit or an incident to find out where compliance has slipped. Compliance evaluation is the deliberate, scheduled test of where the operation stands against its full obligation set.
Compliance Evaluation Requirements
1
Defined frequency and method for compliance evaluation — the more material the duty, the more frequent the check
2
Action when a gap is found — short-term containment plus root-cause correction
3
A current, defensible view of the compliance status across all applicable requirements
4
Records of the evaluation results, retained as evidence
Compliance Evaluation Methods:
- Compliance Audits: Systematic evaluation against legal requirements
- Regulatory Inspections: Government inspector visits and findings
- Self-Assessments: Internal checks against compliance requirements
- Expert Reviews: External legal or technical expert evaluations
- Document Reviews: Verification of permits, licenses, certifications
- Testing and Monitoring: Environmental monitoring, exposure testing against limits
- Checklist Verification: Systematic checks against compliance checklists
Common Legal Compliance Areas:
- Workplace safety regulations and standards
- Hazardous substance management requirements
- Equipment safety standards and inspections
- Noise, vibration and exposure limits
- Working time and rest break requirements
- Worker training and competency requirements
- Incident reporting and notification obligations
- Health surveillance and medical examination requirements
- Emergency preparedness requirements
- Record keeping and documentation requirements
The compliance register pays for itself:
A live register listing every applicable requirement, the responsible person, the evaluation method, the last check date and the status — that's the artefact that holds compliance together. Without it, evaluation becomes ad hoc and gaps go unnoticed until the inspector arrives.
A live register listing every applicable requirement, the responsible person, the evaluation method, the last check date and the status — that's the artefact that holds compliance together. Without it, evaluation becomes ad hoc and gaps go unnoticed until the inspector arrives.
Non-Compliance Actions
Containment first — stop the immediate exposure or operational deviation
Root cause investigation — why did the system allow the gap
Corrective action that prevents recurrence, not just patches the symptom
Mandatory regulator notification where the law requires it (section 24 of the OHS Act, section 11(5) of the MHSA, COIDA reporting thresholds)
Records of the finding, the response and verification that the correction held
9.2 Internal Audit
9.2.1 General
Internal audit answers two questions: does the OH&S system match what ISO 45001 requires, and does it match what the organisation's own procedures say it should do — in practice, not just on paper. Audits run at planned intervals across the full clause set over a defined cycle.
9.2.2 Internal Audit Programme
An audit programme covers:
a
Frequency, methods, responsibilities, planning rules and reporting structure
b
Audit criteria and scope defined for each individual audit — not a generic template
c
Auditor selection that protects objectivity — auditors don't audit work they're responsible for
d
Reporting flow: relevant managers receive results; workers and their representatives see the findings that affect them; other interested parties are kept informed where appropriate
e
Action on nonconformities — closed out and verified, not parked
f
Records of the audit programme and individual audit results retained as evidence
Internal Audit Programme Planning:
When planning the audit programme, consider:
- Importance of Processes: Audit high-risk areas more frequently
- Changes: Audit areas where changes have occurred
- Previous Audit Results: Follow up on areas with previous non-conformances
- Incident History: Focus on areas with incident trends
- Legal Changes: Audit compliance with new regulations
- Coverage: Ensure all areas and requirements audited over the audit cycle
Audit Criteria and Scope
Typical Audit Areas:
- Conformity to ISO 45001 requirements
- Implementation of OH&S policy and objectives
- Hazard identification and risk assessment processes
- Legal compliance and other requirements
- Operational controls effectiveness
- Worker consultation and participation
- Competence, training and awareness
- Communication processes
- Documentation and record keeping
- Emergency preparedness and response
- Incident investigation and corrective actions
- Monitoring, measurement and analysis
- Management review
Auditor Selection and Competence
Auditor competence covers OH&S subject knowledge, audit technique and the ISO 45001 requirements being tested
Independence of the auditor from the area being audited — no auditing your own work
Cross-functional teams where the audit scope spans multiple disciplines
Ongoing auditor development through training, calibration sessions and shared findings
Audit Process Steps:
1Plan the audit (scope, criteria, schedule, team)
2Notify auditees of upcoming audit
3Conduct opening meeting
4Gather audit evidence (interviews, observations, document reviews)
5Analyze findings against criteria
6Classify findings (conformance, non-conformance, opportunities for improvement)
7Conduct closing meeting
8Prepare and distribute audit report
9Follow up on corrective actions
10Verify effectiveness of corrective actions
Workers in the audit loop:
Worker representatives feed into audit programme planning — what gets audited, when, and against what. They also see relevant findings from completed audits. That transparency is what stops audit findings from being treated as internal management information disconnected from the workforce.
Worker representatives feed into audit programme planning — what gets audited, when, and against what. They also see relevant findings from completed audits. That transparency is what stops audit findings from being treated as internal management information disconnected from the workforce.
Audit Documentation:
Annual audit programme and schedule
Audit plans for each audit
Audit checklists and working papers
Audit reports with findings and recommendations
Corrective action plans and follow-up records
Auditor competence and training records
9.3 Management Review
Management review is the executive-level health check on the system — held at defined intervals, attended by top management, evidence-based. It tests whether the OH&S system is still fit for the organisation it serves and whether the resourcing, direction and outcomes still align.
Management Review Requirements
Reviews held at planned intervals — at minimum annually, often more frequently for higher-risk operations
Three tests applied: is the system still suitable, still adequate, still effective
The review takes the wider strategic context and changes in operating environment into account
Workers and their representatives are consulted on the items that go into the review
Management Review Inputs
What goes on the table:
a
Status of actions from the previous review — closed, in progress, or slipping
b
Changes in the external and internal context, including:
- Shifts in interested-party expectations
- New or amended legal duties and other obligations
- New or evolving risks and opportunities
c
Whether the OH&S policy and objectives have been delivered
d
OH&S performance data, including trends in:
- Incidents, nonconformities, corrective actions and improvement activity
- Monitoring and measurement results
- Compliance evaluation outcomes
- Internal audit findings
- Worker consultation and participation activity
- Movements in the risk and opportunity register
e
Whether resources are adequate to keep the system effective
f
Relevant communications with interested parties — regulators, clients, communities
g
Opportunities for continual improvement
Management Review Outputs
What the review has to leave behind:
a
A documented conclusion on whether the OH&S system is still suitable, adequate and effective
b
Identified improvement opportunities
c
Approved changes to the OH&S system where the review has identified gaps
d
Resourcing decisions
e
Specific actions with owners and deadlines
f
Opportunities to integrate OH&S more deeply into other business processes
g
Any implications for the wider business strategy
Effective Management Review Practices:
- Schedule reviews at regular intervals (quarterly or at least annually)
- Prepare comprehensive input reports in advance
- Include senior management and relevant department heads
- Allocate sufficient time for thorough discussion
- Focus on strategic issues, not operational details
- Make clear decisions with assigned responsibilities and deadlines
- Communicate outcomes to all relevant stakeholders
- Track implementation of management review decisions
- Follow up on previous review actions
Tell the workforce what the review decided:
Relevant review outputs are communicated to workers and their representatives. That closes the consultation loop opened in clause 5.4 — workers fed input into the review, and now they see what was done with it. Silence here erodes trust faster than almost anything else.
Relevant review outputs are communicated to workers and their representatives. That closes the consultation loop opened in clause 5.4 — workers fed input into the review, and now they see what was done with it. Silence here erodes trust faster than almost anything else.
Documentation Requirements:
Retain documented information as evidence of the results of management reviews
Document inputs, discussions, decisions and action items
Include dates, attendees, and responsibility assignments
Communicate relevant findings to workers and interested parties
Key Questions for Management Review:
- Is the OH&S management system achieving its intended outcomes?
- Are we meeting our OH&S policy commitments and objectives?
- Is our OH&S performance improving over time?
- Are we complying with all legal and other requirements?
- Are resources adequate for effective OH&S management?
- Are workers actively participating in OH&S?
- What are the emerging risks and opportunities?
- How well integrated is OH&S with business processes?
- What strategic changes are needed to improve OH&S?