6.3 Planning of changes
The draft adds a standalone clause 6.3, Planning of changes, to align with the harmonized structure. The detailed management of change requirements stay where they are, in 8.1.5, so the new clause is a planning duty rather than a second change procedure.
The 2018 edition already required management of change, at 8.1.3. The draft lifts a planning step into Clause 6 and renumbers the operational management of change to 8.1.5. The public summaries describe the content as a modest change, because the substance of change control was already covered by the operational clause.
Read together, 6.3 asks the organization to plan changes to the OH&S management system itself, while 8.1.5 controls planned changes that affect OH&S performance. The practical effect is that a change to the system, such as a new risk assessment method, a new site structure or a new contractor model, should be planned with the same discipline as a change to plant or a process.
The clause number is the trap. A procedure that says see 8.1.3 for management of change will point at Occupational health after the revision, not at change control. The crosswalk in the kit lists every reference to update.
What an auditor is likely to ask for
- A change plan for each system change, with the reason, the owner, the date and the effect on OH&S
- A register that separates system change from operational change and shows which clause applies
- Evidence that the change was assessed before it went live and reviewed after it settled
These are the records this site expects a reader to hold for the new duty. They are our reading, not draft text, and they will be checked against the published standard when it exists.
Where it commonly fails today
- The change procedure still points at 8.1.3
- System changes are made without a plan because they are not seen as safety changes
- Temporary changes are outside the procedure
What to do now, while it is still a draft
Do not rebuild the system around a draft. Do the work that will be right under either edition: name the owner, write the process, keep the record, and put the clause reference on a list to update at publication. If the published text differs, the process survives the wording change.
Read the 2018 requirement it comes from Back to the clause map
Source for draft clause 6.3: the public DIS contents for the clause title, and the named certification-body summaries for the reported direction. The draft requirement text is not public and is not reproduced. Every source.