Clause 184.108.40.206 on the assessment of OH&S opportunities and other opportunities for the OHSMS requires that you have a process in place to identify opportunities to improve the overall OH&S performance (including hazard reduction) and other opportunities to make the OHSMS better. If you are choosing to not have a procedure for this, you can explain your process to the auditors of how you go about assessing opportunities, and give evidence of how you have acted upon your assessment. For instance, you may have taken actions to make an improvement based on an opportunity (per clause 6.1.4 planning action). You action plan and subsequent implementation would be evidence of your opportunity assessment and what you did about it.
2. Is it mandatory to introduce the format for Management of Change else how to address the clause 8.1.3
As with clause 220.127.116.11 above, if you are not writing a procedure for clause 8.1 .3 on management of change, then you need to explain the process you have for implementing changes to your OHSMS. The whole idea of this clause is to make you consider the impact of any changes you make on the OH&S performance of your company. When there are new or changed products or services, changes in the work environment, changes in legal requirements, changes in risk knowledge or development of technology what does this mean for the OH&S risks and performance in your organization; also including unintended changes. In short, when you make changes what is your plan to mitigate against any adverse effects to your OH&S performance; how do you make changes safely? The standard doesn’t give one way of doing this change management, but you need to know what your method is.