Monitoring, Measurement and Performance Evaluation Under ISO 45001

ISO 45001 Clause 9.1

If you cannot measure it, you cannot manage it - and the standard wants to see what you are measuring.

ISO 45001 Clause 9.1 - Monitoring, Measurement, Analysis and Performance Evaluation

ISO 45001 Clause 9.1 covers two related but distinct duties: 9.1.1 sets out general requirements for monitoring and measuring OH&S performance, and 9.1.2 specifically requires the organisation to evaluate compliance with legal and other requirements.

Monitoring and measurement is what tells the organisation whether the management system is delivering. Without it, you can claim the system works but cannot show it. UK organisations also have to demonstrate ongoing compliance with HASAWA and the relevant sets of regulations - 9.1.2 is the formal mechanism for doing that within the management system.

What Clause 9.1.1 Asks For

The organisation must establish, implement and maintain processes for monitoring, measurement, analysis and performance evaluation. The standard expects you to determine:

What needs to be monitored and measured - including the extent to which legal and other requirements are met, activities and operations linked to identified hazards and risks, progress towards OH&S objectives, and the effectiveness of operational and other controls
The methods to use, so the results are valid
The criteria against which OH&S performance will be evaluated
When monitoring and measurement will be done
When the results will be analysed, evaluated and communicated

Monitoring and measuring equipment must be calibrated or verified as applicable, and used and maintained as applicable. Documented information must be maintained on the results and on calibration and verification records.

What Clause 9.1.2 Asks For - Evaluation of Compliance

9.1.2 is a separate, specific duty: establish, implement and maintain a process to evaluate compliance with legal requirements and other requirements. The organisation must determine the frequency and method, evaluate compliance and act if anything needs addressing, retain knowledge and understanding of its compliance status, and keep documented information of the evaluation results. UK organisations typically meet this through periodic compliance audits using a legal register and the relevant sets of regulations.

Practical Compliance Guidance

alphaZ document	How to use it
ISO 45001 Toolkit	Complete document set for an ISO 45001 management system, including the legal register, audit schedule and audit checklist listed below.
ER9 Legal Register	The central record of legal and other requirements that apply to the organisation. Used as the basis for compliance evaluation under 9.1.2 - one row per requirement, the assessed compliance position, and any actions needed.
ER11 Audit Schedule	The forward audit programme that schedules monitoring activities, internal audits and compliance audits across the year. Provides the "when" the standard asks for.
A-C ISO 45001 Internal Audit Checklist	The clause-by-clause checklist used during internal and compliance audits. Generates the documented evidence the standard requires for both 9.1.1 and 9.1.2.

For more on these documents see the ISO 45001 Toolkit.

The simplest way to evidence performance evaluation is keeping accident, incident and near-miss statistics. A spike in slips and trips after a change of shift pattern is information you can act on.

Calibration is where this clause often catches people out. If you rely on a sound level meter, a gas detector, an air quality monitor or any other measuring device for OH&S decisions, the standard expects calibration certificates to be on file and retrievable. Build calibration dates into the equipment register so they cannot be missed.

For 9.1.2 - compliance evaluation - the legal register does most of the work, but the register on its own is not enough. You need documented evidence of an actual evaluation against each requirement, on a defined frequency.

I look for results, not just a plan. Show me your monitoring records, the calibration certificates for any equipment used, and the compliance evaluation against the legal register. If the evaluation has surfaced any non-compliance, show me the action that was taken.

What to Monitor and Measure

The standard does not give a fixed list - it depends on the organisation. Common items include leading indicators (training delivered, audits completed, inspections done, near-misses reported, toolbox talks given) and lagging indicators (accidents, RIDDOR-reportable incidents, lost time injuries, occupational ill-health cases, days lost). The HSE leading and lagging indicator framework in HSG65 is a useful starting point. Pick a manageable set, measure them consistently, and use the results in management review.

Compliance Evaluation - How Often?

The standard says the organisation must determine the frequency. For most UK organisations, an annual compliance audit against the legal register is a reasonable baseline, with more frequent reviews on requirements that change often or carry the highest risk - for example DSEAR-related controls, asbestos arrangements, or activities under enforcement notice. The frequency should be set out in the audit schedule.

Frequently Asked Questions

What is the difference between monitoring and measurement?

Monitoring is observing or checking - inspections, behavioural observations, audit findings, training completion. Measurement is the use of an instrument or numerical method - sound levels, exposure readings, accident frequency rates, lost time. The standard wants both, used together to give an honest picture of OH&S performance.

Does all monitoring equipment need calibration certificates?

Equipment relied on for OH&S decisions needs calibration or verification appropriate to its use - the standard says "as applicable". Sound level meters, exposure monitors, gas detectors and air quality instruments typically need formal calibration to manufacturer or industry-standard intervals. Indicative tools used for awareness only do not need the same level.

Is the legal register the same as the compliance evaluation?

No. The legal register is the list of requirements. The compliance evaluation is the documented review against the register that says whether each requirement is being met. Many organisations combine the two - the register has columns for "compliance status" and "date last evaluated" - but they are conceptually distinct duties under 6.1.3 and 9.1.2.

What if a compliance evaluation shows non-compliance?

The clause requires action where needed. A non-compliance found through 9.1.2 is treated like any other nonconformity - logged, root cause investigated, corrective action taken, and effectiveness checked. For serious legal non-compliance, especially anything reportable, it may also trigger external reporting duties under RIDDOR or other regulations.

UK Legislation

UK organisations have specific monitoring and reporting duties on top of the standard.

Further Resources