Systematic HMS work means that you work in a planned and regular way on health, environment and safety. You do not wait until something goes wrong. The requirement is in section 3-1 of the Working Environment Act (arbeidsmiljøloven), and it is set out in more detail in the Internal Control Regulations (internkontrollforskriften), in full the regulations on systematic health, environment and safety work in enterprises.
Who must do this?
All businesses covered by the law. This also applies to small businesses with few employees. The system must fit the business's size, nature, activities and risks. A sole proprietorship with two employees does not need the same system as a factory, but both must work systematically.
What does section 3-1 say?
The employer must make sure that systematic HMS work is carried out at all levels of the business. The work must be done in cooperation with the employees and their representatives. So you cannot do it alone behind a closed door.
What the Internal Control Regulations require
The regulations (section 5) say that you must put in place measures that together make up internal control. In short, you must:
- set goals for the HMS work,
- have an overview of the organisation: who has responsibility, tasks and authority,
- make sure that the laws and rules that apply to you are available, and that the employees have enough knowledge and skills,
- make sure that the employees take part,
- identify dangers and problems, assess risk and make plans and measures (lesson 3),
- have routines to detect, correct and prevent breaches of the requirements, including through reporting of non-conformities (avvik),
- follow up and review the system regularly, and improve it where needed.
Do not read this list as a series of one-off jobs. It is a cycle: plan, do, check, improve.
Documentation
You must be able to show how your HMS work functions. The regulations (section 5) say that internal control must be documented in the form and to the extent necessary given the nature, activities, risks and size of the business. Some parts must always be in writing, even in small businesses: the goals of the HMS work, who has responsibility and tasks, the survey and risk assessment with plans and measures, the routines for finding and correcting breaches, and the review of internal control. You do not need a thick folder. A short, up-to-date document can be enough in a small business with low risk.
Non-conformities and improvement
A non-conformity (avvik) is something that is not as it should be, for example an accident, a near miss, a safety routine that is not followed or a complaint from an employee. Good routines mean that:
- everyone knows how to report,
- reporting is not met with threats or sanctions,
- you find the cause and put things right, not just find someone to blame,
- you learn and change the routines when needed.
Review
You must regularly assess whether the HMS work is working. The law sets no fixed deadline, but many businesses carry out a review at least once a year, and always when something changes: a new machine, a new department, a reorganisation, an accident.
Remember
- Systematic HMS work applies to all businesses, adapted to size and risk.
- It must be done in cooperation with the employees.
- The documentation must be adapted to the business, and the most important parts must be in writing.
- Non-conformities are valuable information. Make it safe to report.