When an occupational risk assessment really needs updating

A change of technology or process: different operating parameters, a different sequence of operations, a new medium. Replacing or buying equipment — including when “it is the same machine, just newer”, because newer often means different guarding and a different cleaning routine.

Introducing a new chemical, or a change of supplier under the same trade name. A change in work organisation: night work, lone working, shorter changeovers, a different line takt. A new or modified workstation, and assigning to it a person with special status such as a young worker or a pregnant employee.

An accident, near miss or breakdown at the workstation. Measurement results showing an exceedance or a rising exposure ratio. Findings from an audit, external inspection or safety walk. A change in legal or normative requirements for the agent concerned. Repeated employee reports about the same workstation.

A review is not changing the date on the front page. Work through four areas: the hazard list (has anything appeared or disappeared), the estimate (are likelihood and severity still true), the controls (are they implemented and are they used), and the people exposed (has the team or any special condition changed).

Check separately for controls that exist only on paper. If the record says “use the guard” but the guard comes off at every changeover, the assessment describes a wish, not a fact. That gap is the single most common audit finding.

Record the outcome even when nothing changed. A note saying “reviewed, no changes, rationale” is evidence of oversight; no entry at all looks like neglect, whether or not the review actually took place.

The most effective organisational rule is also the simplest: no technical or process change is closed until someone answers whether it requires a risk assessment update. “No” is an acceptable answer — provided it is written down and signed.

That shifts the burden from the safety specialist's memory onto the process. Instead of reconstructing once a year what happened in the plant, you get a chain of entries tied to changes, events and measurements, each of which either triggered an update or carries the reason why none was needed.

The minimum is the person responsible for safety, the direct supervisor of the workstation, and the employee who works there. Technical hazards bring in maintenance, chemicals bring in whoever manages substances, and harmful agents bring in someone who knows the latest measurement results.

Employee participation is not a formality. It is the only source of information about how the task is really performed on night shift, during a breakdown and under time pressure — which is exactly when events happen.

Occupational risk assessment — in Poland an employer duty under Article 226 of the Labour Code: assess and document workplace risk, apply controls and inform workers. Details are set out in § 39a of the general OHS regulation.

Review vs update — a review checks whether the assessment is still adequate; an update changes the record when the review finds differences. The law sets no fixed “once a year” interval; the assessment must reflect actual working conditions.

Review trigger — an event after which the assessment must be checked: a new or changed workstation, machine, process or chemical, an accident, an occupational disease, a near miss, exposure measurement results or new legislation.

Management of change (MOC) — a procedure in which every planned technical or organisational change is risk-assessed before implementation, not after the first incident.

Risk assessment record — the document for a workstation: task description, hazards, sources and consequences, controls, estimated risk and actions. Workers confirm they have been informed, usually by signature.

Acceptable and residual risk — acceptable risk needs no further action; residual risk is what remains after controls. Both are re-recorded after an update in the occupational risk assessment module.