ISO 45001 Audit Preparation: How to Ready Your OH&S Management System (DSTU ISO 45001:2019) for Certification with Ekontrol

In Ukrainian industry, the phrase "occupational safety audit" gets used for two completely different processes, and confusing them derails companies preparing for international certification. The first process is a traditional statutory compliance check modeled on a state labor inspection. The reviewer sits in the safety engineer's office and checks appointment orders, signatures in induction and periodic briefing logbooks, job-specific safety instructions, and closeout of previous regulatory citations. The second process is a systemic engineering audit against ISO 45001:2018 (adopted in Ukraine as DSTU ISO 45001:2019), which evaluates a living Occupational Health and Safety Management System (OHSMS, or СУОП in Ukrainian).

Why does a factory that keeps spotless paper logbooks for inspectors from the State Labour Service of Ukraine (Derzhpratsi) regularly stumble during its first DSTU ISO 45001:2019 certification audit? Because a state inspector checks static adherence to national rules, whereas a certification auditor tests whether your system proactively spots hazards before someone gets hurt, involves shop-floor workers in safety decisions, controls engineering changes, supervises contractors on site, and eliminates the root causes of near-misses.

Article 13 of the Law of Ukraine "On Occupational Safety" No. 2694-XII obliges every employer to establish and maintain a functioning occupational safety management system. Yet the statute itself doesn't provide an engineering blueprint for connecting risk assessment, procurement, contractor control, and executive management review into a closed PDCA loop. That operational blueprint comes from DSTU ISO 45001:2019, which builds on international safety principles from the International Labour Organization (ILO) and workplace risk research from the European Agency for Safety and Health at Work (EU-OSHA).

If your company is still at the starting line of designing its safety architecture, read our complete guide to ISO 45001 certification and our engineering breakdown of how to build an occupational health and safety management system (SUOP). In this guide, we focus squarely on the audit itself: what happens during Stage 1 and Stage 2, what evidence auditors look for in every clause, and how to prepare your facility to pass on the first attempt.

In industrial health and safety management, the word "audit" covers four distinct verification formats, each governed by its own rules, auditor qualifications, and commercial consequences.

1. Internal OHSMS audit (First-Party Audit)

Conducted by your own trained internal auditors (drawn from engineering and operational departments) or by contracted specialists under Clause 9.2 of DSTU ISO 45001:2019 and the auditing guidelines of ISO 19011. Its purpose is to uncover blind spots, missing records, and shop-floor hazards before external auditors arrive, feeding real findings into your corrective action (CAPA) system.

2. Customer or general contractor HSE audit (Second-Party Audit)

Conducted by the Health, Safety, and Environment (HSE) team of a major enterprise buyer, international lender, agricultural commodity trader, energy operator, or construction general contractor. Second-party audits combine ISO 45001 clauses with strict client-specific protocols (such as Lockout/Tagout verification, work-at-height harnesses, confined-space entry, and fire protection). Passing determines whether your company is cleared to bid or bring crews onto the client's site.

3. Initial certification audit (Third-Party Audit: Stage 1 + Stage 2)

Conducted by an independent Conformity Assessment Body accredited under ISO/IEC 17021-1 by the National Accreditation Agency of Ukraine (NAAU) or an international accreditation body listed in IAF CertSearch. The certification audit always runs in two sequential stages: a documentation and statutory readiness review (Stage 1) followed by an on-site operational audit across your active workshops and shifts (Stage 2). Passing both stages earns your 3-year DSTU ISO 45001:2019 (ISO 45001:2018) certificate.

4. Annual surveillance and 3-year recertification audits

Certification is an ongoing 3-year cycle. At month 12 and month 24 after initial certification, the certification body conducts mandatory surveillance audits to verify that your OHSMS hasn't turned into shelfware. Before month 36 expires, a full recertification audit renews the certificate for the next three-year period.

Under ISO/IEC 17021-1 and the mandatory international OH&S auditing standard IAF MD 22, initial certification is split into Stage 1 and Stage 2. Stage 1 evaluates your documented OHSMS design, verifies how you track statutory labor safety compliance, and confirms whether your sites are ready for Stage 2 inspection.

Core documentation verified during Stage 1

During Stage 1, the lead auditor reviews a mandatory set of documented information:

1. OHSMS Scope (Clause 4.3): the exact list of operational activities, physical plants, warehouses, field branches, and total headcount (including civil-contract staff and permanent on-site subcontractors). The auditor checks to make sure the company hasn't artificially excluded a high-hazard foundry, boiler house, or chemical storage area from its scope.
2. OH&S Policy and measurable objectives (Clauses 5.2 and 6.2): a signed OH&S Policy containing explicit commitments to prevent work-related injury and ill health, eliminate hazards, reduce OH&S risks, comply with legal requirements, and consult workers.
3. Hazard Identification and Risk Assessment methodology and live register (Clause 6.1.2): proof that your risk register covers all workstations, routine and non-routine tasks, and emergency scenarios rather than a generic five-row table.
4. Completed Internal Audit cycle (Clause 9.2) and Management Review minutes (Clause 9.3): if you haven't audited all clauses internally and held a formal executive Management Review, you cannot advance to Stage 2.

Verifying statutory compliance obligations in Ukraine (Clauses 6.1.3 and 9.1.2)

You cannot pass an accredited DSTU ISO 45001:2019 audit while violating national occupational safety law. Under Clauses 6.1.3 and 9.1.2, auditors verify objective evidence that your company fulfills the Law of Ukraine "On Occupational Safety" No. 2694-XII and applicable national safety regulations (Npaop):

• High-hazard work permits and declarations: valid permits issued by the State Labour Service of Ukraine (Derzhpratsi) or registered declarations of material and technical base compliance for high-hazard work and high-risk machinery (under Cabinet of Ministers Decree No. 1107).
• Workplace attestation by working conditions: laboratory measurement protocols for workplace air quality, noise, vibration, dust, microclimate, and lighting (under Cabinet of Ministers Decree No. 442), which determine statutory hazard pay, extra leave, and medical checkup schedules.
• Mandatory employee medical examinations: signed final medical commission acts confirming pre-employment and periodic medical clearance for staff performing heavy work, work in harmful conditions, work at height, or equipment operation.
• Statutory technical inspections (PTO / ChTO): current inspection certificates and logbooks for overhead cranes, forklifts, pressure vessels, steam boilers, elevators, and gas distribution systems.

How audit duration is calculated under IAF MD 5 and IAF MD 22

During Stage 1, the lead auditor also validates the calculation of Stage 2 audit duration in auditor-days. Accredited certification bodies calculate audit time strictly from the mandatory tables of IAF MD 5 and IAF MD 22 using two engineering inputs:

• Effective Personnel headcount: this includes full-time employees on payroll plus seasonal workers, civil-contract workers, and permanent subcontractor crews working on your premises under your operational direction.
• OH&S Risk Complexity Category (High, Medium, Low): heavy manufacturing, metal fabrication, chemical processing, grain elevators, construction, mining, and energy operations fall into the High Complexity category, requiring significantly more on-site audit time for a 100-person plant than an office or warehousing company of the same size.

Stage 1 concludes with a written report listing any Areas of Concern. You use the 2-to-6-week window between Stage 1 and Stage 2 to close every flagged gap before the audit team walks onto your shop floor.

Stage 2 takes place on the ground across your production halls, maintenance shops, boiler rooms, chemical stores, construction sites, and laboratories. Under IAF MD 22 rules, if your facility runs two or three shifts, the audit plan must include coverage of evening or night shifts, where supervision is typically lighter and procedural shortcuts happen more often. Furthermore, if your company operates multiple branches or active construction/installation sites (Temporary Sites), the certification body selects a representative sample using the square-root sampling rule ($y = \sqrt{x}$) and inspects live work on site.

How the auditor inspects the shop floor

During the physical walkthrough, the auditor traces evidence backward from the workstation to the records:

1. Physical guarding and workplace engineering controls: the auditor checks machine guards and interlock switches on presses and conveyors, pedestrian-forklift separation lanes, grounding connections, local exhaust ventilation above welding bays, safety signage, emergency eyewash stations, and fire extinguishers.
2. Actual PPE use and behavioral compliance: if a sign at the workshop entrance mandates hearing protection and safety glasses, yet three machinists are grinding steel with their face shields flipped up or wearing sneakers instead of steel-toe boots, the auditor records an operational control failure under Clause 8.1.
3. Live inspection of active Permits-to-Work: whenever the auditor spots a maintenance crew welding on a catwalk or a contractor repairing a roof, they walk straight to the work zone, ask to see the open high-hazard Permit-to-Work (наряд-допуск), match the names written on the permit against the workers standing on the scaffold, and check their high-hazard training cards.
4. Chemical safety and Safety Data Sheets (SDS): in chemical storage rooms, fuel depots, and paint shops, the auditor checks secondary spill containment bunds, chemical compatibility segregation, secondary container labeling, and point-of-use availability of up-to-date Ukrainian Safety Data Sheets.

Confidential interviews with non-managerial workers

A strict requirement of IAF MD 22 and Clause 5.4 of ISO 45001 is that the auditor must interview shop-floor workers (machine operators, welders, electricians, warehouse forklift drivers) without managers or the safety officer present.

Here are the 5 questions an auditor almost always asks a worker at their workstation:

• What are the main hazards at your workstation and what controls keep you safe?
• What do you do if you notice a damaged cable, a missing guard, or an unsafe condition?
• Do you have the authority to stop work immediately if you see an imminent danger to life, without fear of getting fined or punished by your supervisor?
• How do you report a near-miss or suggest a safety improvement on your line?
• What do you do when the emergency siren sounds, and where is your exterior assembly point?

When an operator answers plainly in their own words, points to the QR hazard-reporting poster on the wall, and names the assembly point in the yard, the auditor sees a living OHSMS.

Nearly 60% of all audit nonconformities under DSTU ISO 45001:2019 cluster around two clauses: Clause 5.4 (Consultation and participation of workers) and Clause 6.1.2 (Hazard identification and assessment of risks and opportunities). Let's unpack what auditors expect in both areas.

Clause 5.4. Consultation and participation of non-managerial workers

Unlike ISO 9001 or ISO 14001, ISO 45001 explicitly mandates involving non-managerial workers in safety governance. The standard separates two active mechanisms:

• Consultation: seeking worker views and feedback before management makes a decision (for instance, when updating the OH&S policy, planning training schedules, designing organizational controls, or setting up the audit program).
• Participation: involving shop-floor workers directly in joint decision-making (specifically: having operators participate in hazard identification and risk assessment for their own machines, joining incident and near-miss investigation teams, and field-testing different models of respirators, safety boots, and welding helmets before procurement buys in bulk).

Auditors also check Clause 5.4 d): what obstacles or barriers to participation did you remove, and how do you protect workers from retaliation when they report hazards or exercise Stop Work Authority? In practice, we help companies set up joint safety committees, deploy 30-second mobile QR bots so workers can snap a photo of a hazard without filling out paper forms, and issue a formal non-retaliation policy signed by the CEO.

Clause 6.1.2. Comprehensive hazard identification and risk assessment

The most common flaw in a company's risk register is listing only routine machine operations (such as "lathe operation: flying metal chips") while ignoring everything else. Opening Clause 6.1.2.1 of DSTU ISO 45001:2019, the auditor checks whether your risk matrix covers:

1. Routine and non-routine activities: planned maintenance overhauls, emergency breakdown repairs, confined-space cleaning inside silos or tanks, equipment commissioning, and night-shift operations.
2. Human factors: operator fatigue during 12-hour shifts, repetitive motion, awkward ergonomic postures, and manual handling loads.
3. Psychosocial hazards: aligned with EU-OSHA guidelines and ISO 45003, this includes chronic workplace stress, operating under air-raid alerts and wartime security threats in Ukraine, burnout, shift harassment, and excessive production pressure.
4. Off-site and vicinity hazards: road safety risks for field service technicians and sales drivers, plus hazards originating from neighboring industrial facilities.
5. Management of Change (MoC, Clause 8.1.3): mandatory risk assessment before installing a new production line, introducing a new chemical solvent, or reorganizing warehouse racking.

In Clause 8, the auditor moves from reviewing risk tables to verifying the physical barriers that keep people alive on the shop floor.

Enforcing the Hierarchy of Controls (Clause 8.1.2)

Clause 8.1.2 requires you to apply risk controls in a strict priority order from most reliable to least reliable, following the universal safety pyramid endorsed by the ILO:

1. Elimination: completely removing the hazard. For example, replacing high-altitude manual window washing from suspended cradles with ground-level telescopic water-fed poles.
2. Substitution: replacing a hazardous substance or process with a safer alternative. For example, switching from solvent-based toxic paints to water-borne coatings, or replacing 220V corded grinders in damp areas with 24V battery or pneumatic tools.
3. Engineering controls: physically isolating people from the energy source. Examples include two-hand press controls, photoelectric light curtains, interlocked safety gates that cut power when opened, local exhaust ventilation, acoustic enclosures, and fall-arrest anchor rails.
4. Administrative controls: safe work procedures, high-hazard Permits-to-Work, Lockout/Tagout (LOTO) energy isolation padlocks and tags during maintenance, shift rotation in high-noise zones, warning signs, and safety training.
5. Personal Protective Equipment (PPE): hard hats, respirators, safety glasses, arc-flash suits, and ear defenders. PPE sits at the very bottom of the hierarchy because it doesn't remove the hazard; it only serves as the last line of defense when higher barriers fail.

Procurement and contractor safety management (Clause 8.1.4)

Industrial accident statistics show that a disproportionate share of severe workplace injuries happen to third-party contractors (construction crews, roofers, equipment installers, cleaning staff) working on a client's premises. Clause 8.1.4.2 requires you to control three risk directions: hazards your facility poses to contractors, hazards contractor work poses to your employees, and hazards contractors pose to anyone else on site.

Auditors check four contractor controls:

• Pre-qualification of contractors before contract award (verifying their Derzhpratsi permits, worker qualifications, and medical clearances);
• Site-specific safety induction and signed co-activity permits (акт-допуск) before work starts;
• Active supervision of contractor LOTO, hot-work permits, and scaffolding on site;
• Clear authority to halt contractor work immediately if safety rules are breached.

Emergency preparedness and response drills (Clause 8.2)

Having a written Emergency Response Plan in a binder satisfies only half of Clause 8.2. Auditors ask for records of live emergency drills covering your realistic scenarios: fire evacuation, air-raid shelter procedures, chemical or fuel spill containment, confined-space or work-at-height rescue, and first aid. Most importantly, the auditor checks the post-drill debriefing report: how many minutes evacuation took, what went wrong (such as a blocked exit door or an inaudible siren inside the press shop), and how the emergency plan was updated afterward.

When an auditor evaluates Clauses 9 and 10, they check how your enterprise measures safety performance and whether you catch warning signs at the base of Bird's accident triangle before a fatal injury occurs.

Lagging and leading safety metrics (LTIFR, TRIR, Near-Miss reporting)

A mature OHSMS tracks both lagging and leading indicators under Clause 9.1:

• Lagging indicators: Lost Time Injury Frequency Rate (LTIFR), calculated per million hours worked: $$\text{LTIFR} = \frac{\text{Number of lost-time injuries} \times 1,000,000}{\text{Total employee hours worked}}$$ alongside Total Recordable Incident Rate (TRIR) and injury severity rates.
• Leading indicators: number of reported and resolved Near-Misses and unsafe conditions, completion rate of behavioral safety walks, percentage of corrective actions closed on time, and LOTO verification audits.

If a manufacturing plant with 250 shop-floor employees shows the auditor an incident register with "0 injuries, 0 first-aid cases, and 0 near-misses" for the entire year, an experienced auditor knows immediately that hazard reporting isn't working or workers are hiding minor incidents.

Incident investigation under Clause 10.2: why blaming the worker triggers a nonconformity

In legacy post-Soviet safety practice, almost every accident report ended with the line "the injured worker violated the instruction due to personal carelessness" followed by an unscheduled briefing. Under DSTU ISO 45001:2019 (Clause 10.2), blaming the human while leaving the physical hazard intact is a textbook nonconformity.

Clause 10.2 requires structured Root Cause Analysis (using 5 Whys, Fault Tree Analysis, or Ishikawa diagrams) with worker participation:

• Why did the operator bypass the guard? Because the solid metal guard blocked visibility of the cutting point and lacked a polycarbonate viewing window.
• Why did the electrician suffer an arc flash? Because the plant lacked individual LOTO padlocks, allowing someone else to flip the breaker back on.

Every completed investigation must feed back into updating the risk assessment (Clause 6.1.2) and verifying that the engineering fix works in practice.

Internal auditing under ISO 19011 (Clause 9.2)

Before scheduling Stage 1 with a certification body, your organization must complete a full internal audit covering every clause of DSTU ISO 45001:2019 across all shifts and sites. We cover the four operational stages of audit planning, checklists, execution, and follow-up in our practical guide to internal management system audits.

Keep the core rule of Clause 9.2.2 in mind: an auditor cannot audit their own work. When the company safety engineer writes the checklist, audits the entire OHSMS alone, and signs off on their own department, the certification auditor will issue a nonconformity for lack of impartiality. Train cross-functional internal auditors (such as the chief technologist, maintenance manager, or quality lead) or bring in Ekontrol specialists to run an independent internal audit.

During a certification or surveillance audit, every finding is graded under ISO/IEC 17021-1 rules as either a Minor Nonconformity or a Major Nonconformity.

How findings affect your certification decision

• Minor Nonconformity (Minor NC): an isolated lapse or single missing record that doesn't endanger worker life or break the system's capability to control hazards. For example, one out of twelve checked fire extinguishers is two weeks overdue for inspection, or one recently hired technician missed a signature on a training evaluation form. Minor NCs don't block certification: you submit a root-cause analysis and CAPA plan within 2 to 4 weeks, and the auditor verifies physical implementation at next year's surveillance audit.
• Major Nonconformity (Major NC): issued when (1) an entire mandatory clause of DSTU ISO 45001:2019 is absent (for example, no internal audit was conducted or worker consultation under Clause 5.4 doesn't exist); (2) there is a systemic breach of statutory safety law (such as performing high-hazard work without a valid Derzhpratsi permit); or (3) an uncontrolled, immediate life-threatening hazard is observed on site (such as unguarded roof work without fall arrest). A Major NC freezes certificate issuance until you eliminate the root cause and provide objective evidence of closure (typically within a maximum of 90 calendar days, often verified via a follow-up visit).

Because DSTU ISO 45001:2019 shares the Annex SL High-Level Structure, more than 70% of its governance workflows integrate directly with ISO 9001 quality management and ISO 14001 environmental management. Industrial, construction, agricultural, and energy enterprises in Ukraine frequently deploy an Integrated Management System (IMS / QHSE):

• A unified QHSE Policy and context register (Clauses 4 and 5);
• A single risk framework covering quality defects, environmental aspects, and occupational hazards (Clause 6);
• Unified document control, competence matrices, and calibration schedules (Clause 7);
• Integrated contractor pre-qualification and combined industrial/environmental emergency drills (Clause 8);
• Combined internal audits, a single executive Management Review, and one CAPA tracker (Clauses 9 and 10), which cuts combined certification audit man-days and fees by 20% to 30% under IAF MD 11 rules.

10-point readiness checklist 6 to 8 weeks before your ISO 45001 audit

Verify these 10 operational checkpoints before locking in your Stage 1 date:

1. OHSMS Scope (Clauses 4.1-4.3): all physical sites, warehouses, shifts, and operational processes are accurately included in scope.
2. Worker consultation and participation (Clause 5.4): the safety committee or worker representatives are active, a frictionless near-miss reporting channel works on the floor, and operators are involved in risk reviews and PPE trials.
3. Hazard register and risk assessment (Clause 6.1.2): covers routine, non-routine, maintenance, human-factor, and psychosocial hazards, updated after recent changes.
4. Statutory compliance (Clause 6.1.3): valid Derzhpratsi permits and declarations, current workplace attestation protocols, completed periodic medical exams, and valid crane/boiler/pressure-vessel inspections.
5. Competence and high-hazard clearances (Clause 7.2): valid safety and special-work certificates (work at height, electrical safety, confined spaces, forklifts) for 100% of assigned staff.
6. Hierarchy of controls, LOTO, and Permits-to-Work (Clause 8.1.2): machine guards and interlocks are intact, LOTO padlocks are used during maintenance, and high-hazard permits are properly closed.
7. Contractor safety (Clause 8.1.4): subcontractor contracts include HSE clauses, and every outside crew has a co-activity permit and induction record.
8. Emergency preparedness (Clause 8.2): at least one practical evacuation and emergency drill has been executed, timed, and debriefed with action items.
9. Internal audit and Management Review (Clauses 9.2 and 9.3): an impartial internal audit covered all clauses, and executive Management Review minutes record resource decisions.
10. Incident investigation and CAPA (Clause 10.2): near-misses and micro-injuries are logged, 5 Whys root causes are identified, and corrective actions are verified.

How Ekontrol helps you pass ISO 45001 certification on the first attempt

Ekontrol engineers support your team at every step of the certification lifecycle:

• If you already have safety documentation and want an objective check before booking the certification body, we conduct an on-site OHSMS diagnostic audit.
• If you need to build a practical safety system from scratch or upgrade legacy paperwork to DSTU ISO 45001:2019, we lead full ISO 45001 implementation including risk matrices, LOTO procedures, and staff training.
• When your audit is approaching, we provide hands-on certification audit support through Stage 1, Stage 2, and CAPA closure, followed by ongoing annual management system support for surveillance audits.

Reach out via the Ekontrol contact page to discuss your facility's risk profile with a lead auditor and receive a transparent timeline and cost calculation.