As defined in EA 3/13 M: 2016 – G 9.2.1.3:
“Once the scope is defined, the OH&SMS shall include activities, products and services within the organization’s control or influence that can impact the organization’s OH&SMS performance.
Temporary sites, for example construction sites, shall be covered by the OH&SMS of the organization that has control of these sites, irrespective of where they are located. The need to visit such sites and the extent of sampling shall be based on an evaluation of the risks of failure of the management system to control the OH&S risks associated with the client’s operations (see clause B.9 of Appendix B)”.
Question: Considering the same importance and dignity of all the workers of an organization, that can affect the organization’s OH&SMS performance, is it mandatory to include into the scope of the certificate all the sites of the organization? In other words, can an organization decide to certify only a part of the organization, excluding some sites?
Example: An organization has 1 headquarter and a network of 10 sites. The organization applies the OH&SMS only in the headquarters and in 5 sites. Is it acceptable, or the company has to apply for the certification of the OH&SMS of the full organization? In this case, it could be acceptable that the organization establishes a plan in order to certify all sites.
March 2017
Clause G 9.2.1.3 of EA-3/13 relates to audit scope not scope of certification. EA-3/13 does not make any reference to whether or not all sites shall be included in the scope of certification. The core requirement is Clause 8.3.4 (g) of ISO/IEC 17021-1 which states that that the certified client ‘does not imply that the certification applies to activities and sites that are outside the scope of certification’. The existence of this requirement accepts that it is possible that not all sites are covered by the scope of certification. EA-3/13 provides no additional guidance to clause 8.3.4 of ISO/IEC 1702-11, therefore, it is acceptable that some sites could be excluded from the scope of certification.
The CB should report on the rationale/justification for not including all sites.