Mechanism 3.0 - Identification, Assessment and Nomination of Entities

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Abu Dhabi Occupational Safety and
Health System Framework
(ADOSH-SF)
Mechanisms
Mechanism 3.0 – Identification, Assessment and
Nomination of Entities
Version 4.0
July 2024

ADOSH-SF – Mechanisms
Mechanism 3.0 – Identification, Assessment and Nomination of Entities
Version 4.0 – 15 th July 2024
Page 2 of 17
Table of Contents
1. Introduction ...................................................................................................................................................... 3
2. Identification, Nomination and Notification of Entities................................................................... 4
2.1 Sector Regulatory Authority Entity Identification Process .................................................. 4
2.2 Identification of Entities with Multi Activities ........................................................................... 4
2.3 Entity Risk Classification Process ................................................................................................... 5
2.4 Entity Risk Classification Outcomes .............................................................................................. 6
2.5 Entity Approval ...................................................................................................................................... 6
2.6 Sector Regulatory Authority Entity Register. ............................................................................ 8
2.7 Nomination or Notification of Entities Process ......................................................................... 8
2.8 Timeframes for Compliance .............................................................................................................. 9
2.9 Monitoring Progress........................................................................................................................... 10
2.10 Providing Information on Entities with Approved OSHMS .................................................. 10
2.11 Entities Required to Develop a Safety Case ............................................................................. 10
3. ADOSH-SF - Standard Forms .................................................................................................................... 13
4. Document Amendment Record ............................................................................................................... 14
Appendix 1: Entity Identification, Assessment and Nomination/Notification Flowchart .......... 15

ADOSH-SF – Mechanisms
Mechanism 3.0 – Identification, Assessment and Nomination of Entities
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1. Introduction
This mechanism is designed to define the standard processes for Sector Regulatory
Authorities (SRA’s) in identifying, classifying and nominating or notifying the entities
within their concerned Sectors.
This mechanism includes the key SRA requirements of:
•
Identifying entities to be included in their concerned sector under the ADOSH-SF
•
assessing the risk level of sector entities to classify them in terms of OSH
management requirements;
•
identifying entities to be nominated to develop a fully compliant OSHMS within
their concerned Sector
•
identifying entities to be notified to comply with the medium risk entity
requirements within their concerned Sector;
•
identifying and notifying entities classified as low risk within their concerned
Sector; and
•
gaining official approval from ADPHC to notify or nominate specific entities within
their concerned Sectors.
This mechanism has been designed to ensure fair, transparent and consistent
implementation of the
ADOSH-SF.

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2. Identification, Nomination and Notification of Entities
(a) Each SRA shall develop, document, implement and maintain a procedure for the
identification, risk classification, nomination or notification and registration of entities
that are operating within their sector.
(b) The identification, assessment and nomination / notification process is shown in
Appendix 1.
2.1 Sector Regulatory Authority Entity Identification Process
(a) Each concerned SRA shall identify entities known to be licensed and operating within
their concerned sector.
(b) Each SRA shall then undertake a risk classification, using the criteria set within Section
2.3 of this document to determine the risk ranking of the identified entity.
(c) For entities that have been identified as having multiple activities across different
sectors, the process set within section 2.2 of this document shall be used to identify
the sector that the entity should be nominated / notified within.
2.2 Identification of Entities with Multi Activities
(a) The following aspects and process shall be considered when identifying entities that
have multi activities.
2.2.1 Aspects to be considered for identification of Entities with Multi
Activities
(a) Trade License: In the case of entities having similar names (e.g., if belonging to the
same owner) but operating through separate trade licenses (i.e., each has its own legal
identity), each entity must be nominated / notified by the SRA relevant to its primary
activity that is stated in its trade license and subject to the
ADOSH-SF.
(b) Other Licenses: Ideally, the entity must be nominated / notified by the SRA having
legal power on the entity’s operations (i.e., can withdraw the entity’s operational
license if needed, with consequent withdrawal of its trade license).
(c) Main activity: The entity must be nominated / notified by the SRA that can best
regulate its main primary operational activities subject to the
ADOSH-SF and to asses
and manage risks from such activities (regardless of the other activities that may
appear on its trade license) since risk management is a founding principle of the
ADOSH-SF.

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2.2.2 Process for Identifying Entities with Multi-Activities
(a) In case the entity has multiple activities listed on its trade license and these activities
may fall under more than one SRA, the SRA should identify the main activity(s) of the
entity that are subject to the
ADOSH-SF by using
ADOSH-SF – Form A1 – Identification
of Entity Main Operation Activity.
(b) The SRA shall nominate / notify the entity within its sector if its main operational
activities fall under the SRA, as per
ADOSH-SF requirements (regardless of the other
activities that may appear on its trade license).
(c) When there are several main operational activities that are overlapping with other
sector/s, the SRA shall raise the issue to ADPHC for consideration, along with a
completed
ADOSH-SF – Form A1.
(d) ADPHC will call for a meeting with all concerned SRAs to agree on the sector that will
nominate / notify the entity, within a maximum time frame of two weeks from
receiving a duly filled
OSHD-SF – Form A1.
(e) Following that ADPHC will approve the identification within a specific sector and
inform other related SRAs by sending a signed copy of
ADOSH-SF– Form A1.
2.3 Entity Risk Classification Process
(a) Each Sector Regulatory Authority shall perform a risk classification exercise on
entities that have been identified within its concerned sector. The risk classification
process shall be documented.
(b) The entity risk classification process shall be approved by ADPHC and include the
following as a minimum:
(i) complexity / nature and frequency of operations and activities performed;
(ii) number of employees;
(iii) contractor Management – use of contractors to undertake high risk activities;
(iv) use, storage and/or emission of hazardous materials; and
(v) proximity to residential or sensitive communities (schools, hospitals, etc.).
Note: refer to section 2.11 for additional requirements related to Major Hazard Facilities.
Note: the SRA has the authority to set the risk classification of its entities.
(c) Each SRA shall review the entity risk classification process at least every three years.
The review of the classification process shall be documented.

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2.4 Entity Risk Classification Outcomes
(a) Each SRA shall classify entities identified within its concerned sector based upon the
process described in section 2.3 of this document.
(b) The risk classification outcome shall be:
(i) High Risk: If an entity is classified as a High Risk Entity it shall:
1. develop a full OSH MS in compliance with the requirements of the
ADOSH-
SF and submit it for the concerned SRA for approval.
2. Employ, as a minimum, one OSH Senior Practitioner as defined by
ADOSH-
SF – Mechanism 7.0 –Occupational Safety and Health Practitioner and
Service Provider Registration.
(ii) Medium Risk: If an entity is classified as a Medium Risk Entity it shall:
1. implement the requirements of
ADOSH-SF – Mechanism 5.0 – OSH
Requirements for Medium Risk Entities.
2. If over 100 persons are employed by the entity, they shall employ, as a
minimum, one OSH General Practitioner as defined by
ADOSH-SF –
Mechanism 7.0 –Occupational Safety and Health Practitioner and Service
Provider Registration.
(iii) Low Risk: If an entity is classified as a Low Risk Entity, it will be monitored by
the SRA in line with the requirements of section 2.7.3 of this document.
(c) All entities regardless of the risk classification assigned, shall comply with the
mandatory technical requirements specified within the
ADOSH-SF – Codes of Practice
that are applicable to their activities / business undertakings.
Note: SRA’s may request entities to comply with additional requirements related to their activities as
per their innate power as a competent authority within their field.
(d) Each SRA shall review the risk classification assigned to its entities at least every
three years.
2.5 Entity Approval
(a) Each concerned SRA shall identify entities to be nominated or notified for
development and implementation of
ADOSH-SF requirements under their Sector,
based upon the risk classification process described in sections 2.3 & 2.4 of this
document.
(b) An entity must demonstrate a certain minimum level of risk within its sector for it to
be targeted for control under the
ADOSH-SF.
(c) Each concerned SRA shall officially submit proposed entity nominations or
notifications to ADPHC for assessment and approval prior to informing the entity of
the requirements to comply with
ADOSH-SF.
(d) The decision of ADPHC shall be final with regards to the approval of entity nomination
or notification.

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(e) The SRA shall notify ADPHC of any changes to the list of nominated / notified entities
(e.g. those that cease trading or operation).

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2.6 Sector Regulatory Authority Entity Register.
(a) Each concerned SRA shall develop, document, implement and maintain a register of all
its identified entities.
(b) Identified entities are those that have been classified for risk as per the requirements
of sections 2.3 & 2.4 of this document.
(c) The register shall contain the following information as a minimum:
(i) entity name;
(ii) main undertaking;
(iii) single disciplinary or multi-disciplinary (if identified as Multi Activity Entity, the
register shall also contain information regarding other operating criteria);
(iv) risk classification - High, Medium or Low;
(v) stage of registration (OSHMS approved / Under development); and
(vi) entity classification code (as per the classification codes proposed by the
concerned SRA and approved by ADPHC) and registration number.
2.7 Nomination or Notification of Entities Process
2.7.1 Nomination and Registration of High Risk Entities
(a) Entities that have been classified as high risk shall be nominated to develop,
implement and maintain an operational OSH MS to manage the OSH hazards and risks
of their operations in compliance with the
ADOSH-SF.
Note: refer to section 2.11 for additional requirements related to Major Hazard Facilities.
(b) The concerned SRA shall officially inform the subject entity and provide it with a
copy of
ADOSH-SF – Form A. The entity shall be required to complete Form A and
register with the SRA to develop an OSHMS in compliance with the requirements of
the
ADOSH-SF.
(c) The concerned SRA shall set the entity a timescale to complete the registration and
return
ADOSH-SF- Form A, this timescale shall be no longer than 30 calendar days.
(d)
ADOSH-SF – Form B is to be used to update or modify the nominated entity’s
information, including proposed changes to OSH MS development and
implementation timelines.
2.7.2 Notification of Medium Risk Entities
(a) The concerned SRA shall officially notify an entity that has been classified as medium
risk of the requirement to comply with
ADOSH-SF – Mechanism 5.0 – OSH
Requirements for Medium Risk Entities.
(b) The concerned SRA shall perform an OSH compliance inspection within 6 months of
notification to ensure compliance. The concerned SRA shall record the outcome of the
inspection (e.g. Inspection Checklist).

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(c) Following the initial inspection, the concerned SRA shall ensure that at least one OSH
inspection is undertaken on the entity’s undertakings every three years.
(d) The concerned SRA may increase the frequency of OSH inspections based on risk
assessment, including analysis of the entity’s Occupational Injury Register, and any
submitted serious incidents as per the requirements of
ADOSH-SF - Mechanism 11.0 –
Incident Notification, Investigation and Reporting.
(e) The concerned SRA can at any time re-assess an entity and update their compliance
requirements.
2.7.3 Notification of Low Risk Entities
(a) The concerned SRA shall officially notify an entity that has been classified as low risk
under the requirement of the ADOSH-SF.
(b) Entities that have been classified by the concerned SRA as low risk, shall be managed
by the concerned SRA in a manner relevant to their risk and operation.
(c) The concerned SRA shall ensure that at least one OSH inspection is undertaken on the
entity’s undertakings every three years.
(d) The concerned SRA shall undertake investigations, in line with the requirements of
ADOSH-SF - Mechanism 11.0 – Incident Notification, Investigation and Reporting,
when a fatality is notified to them by a low risk entity.
(e) SRA’s shall ensure that low risk entities are given adequate support, assistance and
advice as required to enable them to comply with the requirements set by the SRA,
including through attendance at SRA organized events, training, workshops and
seminars and release of awareness material.
2.8 Timeframes for Compliance
(a) The SRA shall set each nominated entity a timescale for the development of their OSH
MS.
(b) In setting timeframes for nominated entities, concerned SRA’s shall consider:
(i) level of risk and complexity / nature of operations and activities performed;
(ii) existing internal OSH resources;
(iii) existing level of “OSH Systems / Processes” (e.g. ISO accreditations); and
(iv) SRA’s internal OSH resources.
(c) Maximum timeframes for entities classified as high risk include:
(i) Development of OSH MS: a maximum of 12 months from official nomination
date, however, SRAs may set a shorter timeframe if deemed appropriate;
(ii) Implementation of OSH MS: to start implementation within one month from date
of official OSH MS approval by the SRA;
(iii) Performance Reporting: to start reporting performance in the next quarter
following approval;

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(iv) Incident Notification / Reporting: to start notifying and reporting incidents
immediately following nomination/registration; and
(v) Annual 3 rd Party audit: to be undertaken within one year of approval of the
OSHMS.
(d) Entities classified as medium risk and informed to comply with the requirements of
ADOSH-SF – Mechanism 5.0 – OSH Requirements for Medium Risk Entities shall be
given a maximum of 6 months from official notification to comply with the
requirements.
2.9 Monitoring Progress
(a) The SRA shall ensure that it monitors the progress of all entities nominated and
notified to comply with the requirements of the
ADOSH-SF.
(b) Where an entity fails to meet the timescales set for submission of their OSH MS, the
SRA shall seek official clarification from the entity on the causes behind late
submission and request an action plan from the entity that shall include timescales for
submission. The timescales shall be no longer than one calendar month of the original
submission date.
(c) The SRA shall monitor the progress of entities that have failed to meet the original
submission date.
(d) Where entities fail to meet updated timescales for submission, the SRA shall officially
invite the entity for a meeting to review status and agree timescales with the entity
for submitting their OSH MS. The meeting shall be attended by a member of the
entity’s top management. The review meeting shall be officially recorded.
2.10 Providing Information on Entities with Approved OSHMS
(a) ADPHC will publish the names of all entities with an approved OSH MS.
2.11 Entities Required to Develop a Safety Case
(a) The SRA can request, based on risk assessment, an entity to perform a more detailed,
specialized risk management technique, commonly called a Safety Case. This is an
additional requirement above the entity OSH MS.
(b) Reasons for this may include:
(i) if they consider that there are high risk activities, processes, substances or
materials in use; and/or
(ii) if they consider that a building / facility is a major hazard facility.
Note: A Safety Case can be requested as part of the initial entity risk classification or at any time
through Performance Monitoring outcomes.

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(c) Major hazard facilities (MHF’s) are facilities that produce, store, handle or process
large quantities of hazardous material (e.g. chemicals) and dangerous goods,
including, but not limited to:
(i) petroleum products;
(ii) petrochemical / chemical / gas refineries;
(iii) chemical manufacturing sites;
(iv) gas-processing plants;
(v) liquefied petroleum gas (LPG) facilities;
(vi) specific warehouses and transport depots; and
(vii) facilities of a similar kind to those listed.
(d) Major hazard facilities have to demonstrate their operational safety through a Safety
Case developed specifically for their unique operations and situation.
2.11.1 Process for Notifying Entities to Develop a Safety Case
(a) The concerned SRA shall officially submit proposed entities identified to develop a
Safety case to ADPHC for assessment and approval.
(b) The submission shall be accompanied by an assessment showing scope and risks
posed by the entity and objectives of the Safety Case.
(c) The SRA shall officially inform the entity that they have been requested to develop a
Safety Case, including:
(i) The scope, contents and requirements (in line with
ADOSH-SF – Element 2 - Risk
Management);
(ii) Timescales set by the SRA for submission;
(iii) Review and approval process; and
(iv) Inspection requirements.
(d) The relevant emergency services shall be consulted on emergency plan preparation,
and other relevant authorities shall be consulted on actions required for the safety
of local community members in the event of a major incident.
2.11.2 Review and Approval of a Safety Case
(a) The SRA shall review the Safety case for adequacy and provide official feedback to
the entity.
(b) Where required, the SRA shall liaise with other stakeholders who have an interest in
the Safety Case, such as emergency services etc.
(c) On approval of the safety case, the SRA shall officially inform the entity along with
details of any additional requirements set by the SRA.

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2.11.3 Monitoring of the Safety Case
(a) The SRA shall develop a detailed monitoring plan for each individual safety case
approved within their sector.
(b) The monitoring of the Safety case shall include:
(i) Detailed Inspections, directly related to the Safety Case;
(ii) Testing of control measures implemented for specific scenario’s; and
(iii) Detailed Audits, directly related to the Safety Case.
(c) The SRA shall ensure that any non-compliance with the conditions of the Safety Case
is communicated to the entity and corrective action agreed.
(d) The SRA shall monitor the implementation of any corrective action.

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3. ADOSH-SF - Standard Forms
Form A – Registration for Development of an OSHMS
This form is sent to the nominated entities by the SRA to inform them of the
requirement to develop and implement an OSHMS. It is to be returned to the SRA
acknowledging these requirements and providing entity information including contact
details.
Form A1 - Identification of Entity Main Operation Activity
This form is to be used when the main undertaking of an entity is unclear or the
entity works across a number of Sectors under ADOSH-SF.
Form B – Amendment of Registered Information
This form is to be used to inform of any changes to entity or contact details. This
form is also to be used if an extension to the OSHMS development or implementation
timelines is required.
ADOSH-SF Standard Forms are available at www.ADPHC.gov.ae

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4. Document Amendment Record
Version Revision Date Description of Amendment
Page/s Affected
4.0
15 th July 2024
System acronym updated from OSHAD-SF
to ADOSH-SF to accurately reflect
document title
Throughout
Change from OSHAD to ADPHC
Change of Logo
Clause 2.4 updated to reflect manpower
requirements for OSH.
Appendix 2 (ADOSH-SF Classification
Codes) deleted together with deletion of
reference to this Appendix in Clause
2.6(c)(vi).
Minor editorial changes throughout the
document without changing requirements.

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Appendix 1: Entity Identification, Assessment and Nomination/Notification
Flowchart
Concerned SRA shall identify entities
known to be operating and licensed within
their Sector (by DED and/or SRA)
SRA to gather entity information on
undertakings and risk profile
Does the entity operate across
multiple sectors?
SRA to complete form A1 and
send to ADPHC Yes
ADPHC to meet with
concerned SRA(s) to
decide on the relevant
SRA
Entity assigned to agreed SRA
SRA to undertake entity risk assessment
based on information collected
No
SRA to classify the entity based on the
outcome of the risk classification
Is the entity classified as High Risk
Entity officially notified and
informed of the compliance
requirements No
Approved Entity details added to the SRA
entity Register
Entity officially nominated to comply with
the requirements of ADOSH-SF
Entity asked to register and complete
Form A
SRA to set timescales for the
submission of the entity OSH MS
SRA to monitor progress of
submission
Entity inspection requirements
identified and added to
relevant schedules
Identification, Classification,
Nomination/Notification and
Registration of Entities
Refer to Submission, Review and Approval
of OSH MS
List of entities to be sent to ADPHC for
Approval
IS a safety case required
Yes
Proposal sent to ADPHC for
approval
Yes
Entity Notified of this
Requirement if approved by
ADPHC
No

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