ISO 45001 has become a core requirement for many organizations in the UAE as industries continue strengthening occupational health and safety practices. Auditors frequently identify gaps during certification and surveillance assessments, and many of these issues are repeated across construction, oil and gas, logistics, manufacturing, and facility management firms.
This article explains the most common ISO 45001 non-conformities found in UAE companies, why they occur, and how organizations can address them effectively.
Understanding Non-Conformities in ISO 45001
A non-conformity means the organization’s OH&S practices do not comply with ISO 45001 requirements. They are typically categorized as:
- Major NC: A critical failure impacting the OH&S management system’s ability to achieve intended outcomes.
- Minor NC: A smaller gap that does not significantly affect system performance but still requires correction.
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1. Weak Hazard Identification and Risk Assessment Processes
This is one of the most frequently reported non-conformities in UAE companies. Many organizations rely on outdated assessments, generic templates, or incomplete hazard registers.
Audit Findings Often Include:- Missing documentation for new activities or processes
- Failure to consider chemical, ergonomic, or psychosocial hazards
- Inconsistent risk scoring methods
- No evidence of worker participation during assessments
Fast-paced industries such as construction and logistics often change work conditions rapidly. If assessments are not updated, risks remain unaddressed.
How To Address It:Perform risk evaluations at regular intervals, update registers after incidents or process changes, and ensure workers contribute to hazard identification.
2. Insufficient Control Measures and Poor Hierarchy of Controls
Even if hazards are identified correctly, many companies fail to apply the hierarchy of controls properly. Auditors often find excessive dependence on PPE instead of:
- Elimination
- Substitution
- Engineering controls
- Administrative controls
“Controls do not align with the risk level identified.”
How To Address It:Document decision-making clearly and show why specific controls were selected.
3. Incomplete Legal and Regulatory Compliance Evaluation
UAE companies must comply with:
- Federal Labour Law
- OSHAD SF (for Abu Dhabi)
- Dubai Municipality EHS requirements
- Industry-specific OH&S rules
Non-conformities occur when:
- Legal registers are outdated
- No evidence of compliance evaluation
- Missing records of regulatory inspections
To understand legal obligations clearly, companies must also review the official requirements published under the Abu Dhabi OSHAD Framework
How To Address It:Maintain a structured legal register and review it quarterly. Update documents whenever regulations change.
4. Lack of Worker Consultation and Participation
ISO 45001 places strong emphasis on employee involvement. Auditors frequently note weak engagement, especially in large organizations.
Observed Gaps:- No participation in hazard reviews
- No consultation in incident investigations
- Limited communication on OH&S decisions
Conduct structured meetings, toolbox talks, and feedback sessions, and document participation consistently.
5. Emergency Preparedness Not Fully Implemented or Tested
This appears frequently in logistics warehouses, oil and gas facilities, and multi-site companies.
Typical Non-Conformities:- Emergency plans not updated
- Evacuation maps not visible
- Lack of drill records
- Missing training evidence for new employees
Review the emergency plan annually, conduct drills at scheduled intervals, and keep complete documentation.
6. Training Records and Competency Evaluation Gaps
Auditors look for proof that workers are competent for the tasks they perform. Many UAE companies rely only on basic safety induction.
Auditors Often Report:- Missing competency matrices
- No record of refresher training
- Inconsistent evaluation of contractor training
Develop a training matrix, identify competency needs for each role, and retain clear documentation.
7. Weak Incident Investigation Practices
Many companies only report basic details without performing root-cause analysis.
Common Non-Conformities:- Missing investigation reports
- Poor evidence collection
- No identification of recurring issues
- No follow-up actions
Use structured methods such as the 5-Why approach, document findings, and track corrective actions.
8. Monitoring and Measurement Activities Not Performed Properly
UAE industries often experience gaps in monitoring critical controls.
Audit Findings Include:- Missing calibration records for measurement devices
- No monitoring of noise, heat stress, or air quality
- Incomplete inspection records
Create a monitoring schedule and maintain all measurement records as part of OH&S documentation.
9. Inadequate Management Review Inputs or Outputs
Management review is a core requirement. Non-conformities arise when:
- Not all mandatory inputs are covered
- No clear strategic decisions recorded
- No follow-up on previous action items
To understand legal obligations clearly, companies must also review the official requirements published under the Abu Dhabi OSHAD Framework
How To Address It:Establish a structured agenda aligned with ISO 45001 clause requirements, document minutes, and assign responsibilities.
10. Poor Corrective Action Management
Corrective actions must remove the root cause, not just fix the symptom.
Auditors Often Identify:- Repeated incidents
- No verification of action effectiveness
- Actions closed without evidence
Track each action with responsibility, timeline, and proof of completion. Review effectiveness before closing.
Why These Non-Conformities Appear Frequently in UAE Organizations
Based on trends across various UAE sectors, the root causes often include:
- Rapid expansion of work activities without system updates
- High contractor workforce turnover
- Limited internal auditing capabilities
- Pressure on project deadlines
- Insufficient leadership involvement
Organizations that regularly maintain workplace safety records, update documentation, and engage workers consistently achieve better audit outcomes.
How UAE Companies Can Reduce ISO 45001 Non-Conformities
To strengthen compliance, companies should adopt the following practices:
- Conduct quarterly internal audits
- Keep records digital and centralized
- Provide refresher training for high-risk roles
- Review risk assessments after every change
- Involve workers in OH&S decisions
- Perform management reviews at least once a year
- Document every monitoring and inspection activity
These measures significantly reduce audit issues and support continuous improvement.
Final Thoughts
Understanding common ISO 45001 non-conformities helps UAE companies strengthen their occupational health and safety performance and prepare efficiently for certification and surveillance audits. When organizations maintain updated documentation, engage workers, and monitor processes consistently, they achieve smoother audits and stronger compliance.