Part-Time QHSE Manager and ISO 45001: A Plastics SME Case Study

What is this plastics SME’s starting point?

A solid quality system and informal health and safety. This is a composite case study: it brings together situations we encounter in the industrial SMEs we support. The company and its customer are fictitious; no real data is cited.

The company processes plastics in the Casablanca region: injection moulding of technical parts, extrusion blow moulding of bottles and jerrycans for household cleaning product manufacturers, marking and packing. It employs 120 people, with shift teams on the presses. It has been certified to ISO 9001 for several years, to the 2015 edition.

The quality function is held by a quality manager who also runs the laboratory and customer complaints. Health and safety falls “on top” to the maintenance manager. The safety and hygiene committee (comité de sécurité et d’hygiène, or CSH), the joint employer and employee body that the Moroccan Labour Code requires from 50 employees, exists but meets irregularly.

The trigger is commercial. As its contract comes up for renewal, the main customer, an international group, adds ISO 45001 certification to its supplier requirements. On top of that comes a deadline already known: the transition to ISO 9001:2026, to be completed by 30 September 2029 under the Global ACI transition document. Global ACI is the organisation that took over from the International Accreditation Forum (IAF) for accreditation.

Why a part-time QHSE manager rather than a new hire?

Because the need was twofold and uneven over time. Management first considered hiring a senior HSE manager. The gap analysis showed two distinct needs: concentrated expert work to build the system and prepare for certification, then daily work on the shop floor, less specialised but permanent.

It chose a mixed model: a part-time QHSE manager, with a named deputy, for method and steering; an HSE technician hired in-house for the shop floor. The quality manager keeps quality and leads the integration of the documentation. The external presence, heavier at the start, then follows a calendar aligned with committees, audits and the management review. The cost items of this choice are detailed in our article on in-house vs outsourced QHSE manager cost.

What did the gap analysis reveal?

Gaps against the Labour Code before gaps against the standard. This is common: a health and safety system starts with legal compliance, and the certification body checks it. Under the Global ACI document for OH&S certification (Global ACI-TECH-3-016), the company must demonstrate its compliance through its own evaluation, or present a dated action plan to restore it.

The Labour Code is published in Arabic by the ministry in charge of employment, and the Ministry of Justice publishes a consolidated French version: the “requirement” column follows that version. With 120 employees, the company is also required to have an in-house occupational health service (Article 304). In the consolidated version, Article 317 refers to “each workshop where dangerous work is carried out” without referring to an implementing text that would list such work: which workshops are covered is therefore justified by the risk assessment.

How was ISO 45001 built on the ISO 9001 system?

By integrating it, not by adding it. The quality system already had document control, a corrective action process, an internal audit programme and a management review. They became common to both.

• One set of documentation. Work instructions bring together, on the same page, the quality criterion, the prevention measure and what to do in case of an incident, in French and Arabic.
• One action plan. Customer complaints, audit findings and near misses go into the same register, with the same root-cause analysis.
• One internal audit programme, built on risk.
• One management review, which covers accidents, near misses, regulatory compliance and the results of worker consultation.

Two topics remained specific to ISO 45001:2018. The risk assessment was done workstation by workstation, with the operators, across all shifts. Worker consultation and participation relied on the committee, on toolbox talks led by team leaders and on near-miss reporting. Measures followed the hierarchy of controls: eliminate or protect at source before resorting to personal protective equipment.

The transition to ISO 9001:2026 was handled in the same gap analysis, so the documentation was updated only once. Management did not wait for the ISO 45001 revision: the ISO/TC 283 committee does not expect it before 2027, and a system built on the 2018 edition will carry over through a targeted review. The integration method is detailed on our integrated QHSE management system page.

How did the site prepare for ISO 45001 certification?

By proving that the system worked, cycle after cycle. Committees were held on schedule, accidents were analysed, actions were followed through to effectiveness. The monthly report posted in the Inspirra client space gave management a continuous view of progress.

The internal audit programme covered every process. The part-time manager audited those they do not run; their own activities were audited by another auditor, in line with the independence principle of the ISO 19011 guidelines. A management review and a mock audit followed.

Three points were prepared for the certification body:

1. an application describing the main hazards and risks, the hazardous materials used and the applicable legal obligations, as Global ACI-TECH-3-016 requires;
2. the certification body’s accreditation for ISO 45001 in the sector, and for ISO 9001;
3. the option of a combined audit. Under Global ACI-TECH-3-008, the duration of a combined audit takes account of the level of integration, with a reduction capped at 20%. The transition audit to ISO 9001:2026 could only be combined once the body’s accreditation had moved to the 2026 edition, by 30 September 2027 at the latest according to Global ACI.

On audit day, team leaders and operators explained the risk assessment for their own workstations. That is what the auditor comes to check.

What lessons can be drawn from this case?

Three lessons apply beyond plastics. Legal compliance comes before the standard. Part-time management works when internal roles are written down and a relay is present every day. And an integrated system holds better than a second system placed next to the first.

Before launching an ISO 45001 project with a part-time manager, check:

• The legal thresholds that apply to your headcount: safety and hygiene committee, occupational health service, first aiders per workshop.
  
• Written roles: management, part-time manager, internal relay, team leaders.
  
• A risk assessment planned by work unit and by shift, with the operators.
  
• The committee calendar aligned with the presence plan.
  
• Integration into the ISO 9001 system decided: one set of documentation, one action plan, one audit programme.
  
• The transition to ISO 9001:2026 planned in the same gap analysis.
  
• An independent auditor planned for the activities run by the part-time manager.
  
• The certification body consulted on the combined audit and on its own transition.
  

The engagement models and what must stay with the company are detailed in our part-time QHSE manager guide; starting the engagement is covered in our plan for onboarding an outsourced QHSE manager.