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How Do You Audit Management of Change in ISO 45001?

October 31, 2026 Posted by Varshini Natarajan ISO 45001 No comments
ISO 45001:2018 Lead Auditor · CQI and IRCA · PR357
9 min read

How Do You Audit Management of Change in ISO 45001?

How to check that changes to equipment, processes, people and requirements are assessed for new hazards before they go live, and that temporary changes do not become permanent.

3FOLD Training is a CQI IRCA Approved Training Partner (ATP 6039853) · Licensed by KHDA, Dubai

In this guide
  1. Where does it sit in the standard?
  2. Which changes should you look for?
  3. What does a sound process look like?
  4. How should you prepare?
  5. Which records prove it works?
  6. What should you ask people?
  7. Where do processes break down?
  8. Change simulation
  9. FAQs

A workplace can be safe on Monday and unsafe on Tuesday because something changed. A new machine arrived, a shift pattern was altered, a guard was removed for a repair or a supplier swapped a material. Management of change is the part of an occupational health and safety (OH&S) management system that stops these changes from creating new hazards unnoticed. An auditor therefore looks at how changes are spotted, assessed and controlled before they take effect. This guide is for auditors working to ISO 45001:2018 and for anyone preparing for the CQI (Chartered Quality Institute) and IRCA (International Register of Certificated Auditors) ISO 45001 Lead Auditor course.

Quick answer

To audit management of change in ISO 45001, check that the organization has processes for the implementation and control of planned temporary and permanent changes that affect OH&S performance. These include new or changed products, services and processes, workplace locations, work organization, working conditions, equipment and workforce, changes to legal and other requirements, changes in knowledge about hazards and risks, and developments in knowledge and technology. Also check that the consequences of unintended changes are reviewed and that action is taken to reduce harm. Clause 8.1.3 of ISO 45001:2018 sets these requirements.

Standard auditedISO 45001:2018, Occupational health and safety management systems
Clause8.1.3, Management of change
PurposeStop planned and unplanned changes creating new hazards unnoticed
Key testsChanges spotted, risks assessed before start, temporary changes controlled, unintended changes reviewed
Evidence to useChange requests, risk assessments, approvals, training records and interviews
Related courseISO 45001 Lead Auditor · PR357 · CQI and IRCA
ISO 45001 Lead Auditor · PR357CQI IRCA Approved Training Partner40 hours, VILTFirst exam attempt included

See course details →

Where does management of change sit in ISO 45001?

It requires processes to implement and control planned temporary and permanent changes that affect OH&S performance.

Clause 8.1.3 of ISO 45001:2018 asks the organization to establish processes for planned temporary and permanent changes that affect OH&S performance, and to review the consequences of unintended changes, taking action to mitigate adverse effects as necessary. The hazards and risks that a change brings are assessed as part of the planning requirements, so the two parts work together. Always check the exact wording in the current standard. Our guide to how an ISO 45001 audit works shows where this check sits in an audit, and our guide to the role of top management in ISO 45001 explains who is accountable.

Which kinds of change should an auditor look for?

Changes to products, processes, places, people, equipment, requirements and knowledge all count.

Type of changeExamples
New or changed processes and productsA new production line or a changed method
Workplace and surroundingsA new location, layout or neighboring activity
Work organization and conditionsNew shift patterns or staffing levels
EquipmentNew machines or modified guards
WorkforceNew starters, agency staff or reduced numbers
Legal and other requirementsA new or revised legal limit
Knowledge and technologyNew information about a hazard or a better control

The riskiest change is the one nobody recorded as a change.

Want to practice auditing a real process? The course includes editable audit working documents and a case study.

See what’s included

What does a sound change process look like step by step?

Good change control spots the change, assesses the risks before start, approves it, informs people and checks the result.

The table turns the requirement into audit questions. Use it to follow one change from request to review.

StepWhat the auditor asks
Spot the changeHow does a change get recorded as a change?
Assess hazards and risksWere new hazards and risks assessed before the change went live?
Approve and planWho authorized it, and what controls were set?
Inform and trainWere workers consulted, told and trained before start?
Control temporary changesIs there an end date, and is it removed or made permanent properly?
Review the resultWas the outcome checked, and were unintended effects handled?

Our guide to auditing the hierarchy of controls shows how the controls for a change should be chosen, and our guide to worker consultation and participation in ISO 45001 explains how workers should be involved.

How should an auditor prepare for the audit?

Ask for the change log, the procedure and recent change records, and pick changes to trace.

Request the change procedure, the change register or log, recent change requests with their risk assessments and approvals, and records of temporary changes. Choose changes of different kinds, such as new equipment, a change in work organization and a temporary change. Plan to visit the area affected and to talk to the people who work there. Our ISO 45001 audit plan and checklist guide shows how to build this into your checklist, and our guide to the documents required for an ISO 45001 audit helps you decide what to read first.

ISO 45001 Lead Auditor · PR357CQI and IRCA certified courseVirtual Instructor Led Training (VILT)Two full mock exams

View the course →

Which records and observations prove the process works?

Collect the change log, risk assessments, approvals, training records and what you see on site.

CheckRecordsInterview or observation
Changes are recordedChange log and requestsAsk how a change is raised and who decides
Risks assessed before startRisk assessments dated before the changeCompare the assessment date with the start date
Approved with controlsApprovals and control measuresAsk who signed it and what controls were added
People informed and trainedTraining and briefing recordsAsk affected workers what they were told
Temporary changes controlledTemporary change register with end datesLook for temporary fixes still in place
Unintended changes reviewedIncident and review recordsAsk what happened when something changed unexpectedly

Remember that a comment is a lead, and you confirm it with a record or an observation. Our guide to how to interview workers in an ISO 45001 audit shows how to ask the questions.

What should you ask workers, supervisors and change owners?

Ask who raises changes, who assesses them and what affected workers were told.

  1. Ask the change owner how a change is raised and what must happen before it starts.
  2. Ask the person who assessed it which hazards were considered and when.
  3. Trace one change from the request to the check after start.
  4. Ask workers in the area what changed, what they were told and what training they had.
  5. Ask for a temporary change and when it ends.

Our guide to auditing contractor management in ISO 45001 covers changes brought by contractors, and our guide to auditing emergency preparedness and response in ISO 45001 shows how changes affect emergency plans.

Not sure whether to start as an internal or lead auditor? Compare the two roles in our guide.

Compare the roles

Where do change processes usually break down?

Common gaps are changes made without assessment, forgotten temporary fixes and untrained workers.

  • Assessed after the fact. The risk assessment is dated after the change went live.
  • Forgotten temporary changes. A temporary fix stays in place for months with no end date.
  • Not seen as a change. Staffing, shift or supplier changes are never logged.
  • Untrained workers. People find out about a change when they meet it.
  • Legal changes missed. New requirements do not trigger a review of controls.

Treat these as prompts, not conclusions, and confirm each one with evidence before you raise a finding. Our guide to auditing evaluation of compliance in ISO 45001 covers how legal changes are tracked, and our guide to auditing management review in ISO 45001 shows where changes should be reviewed.

ISO 45001 Lead Auditor · PR357CQI IRCA Approved Training Partner (ATP 6039853)40 hours, VILTOne year of free retraining

Check upcoming batches →

Change simulation: choose the best auditor action

For practice only. Read each situation and choose the best response. These scenarios were written by 3FOLD Training and are not real exam questions.

Situation 1. A new machine was installed and started last month. The risk assessment is dated after start-up, and operators were trained afterwards. What is the best action?
Model answer: Clause 8.1.3 asks for processes to implement and control changes that affect OH&S performance. Compare the dates, ask how the process is meant to work and look for other changes before you decide.
Situation 2. Night shift staffing was reduced and shift patterns changed. Nobody recorded it as a change. What do you do next?
Model answer: Work organization, working conditions and workforce are listed among the changes the process should cover. Ask how the effects were considered and whether workers took part before you judge.
Situation 3. A guard was removed during a repair and a temporary barrier was put up. Three months later the barrier is still there with no record. What is the best action?
Model answer: The process covers temporary as well as permanent changes. Look at the area, ask for the temporary change record and ask how end dates are set and checked.
Situation 4. A new legal limit on noise took effect this year. The organization has no way to link legal changes to its controls. What is the best action?
Model answer: Changes to legal and other requirements are among the changes the process should cover. Ask how they are tracked, who reviews them and where the evidence is, then judge on that evidence.
Situation 5. A supplier swapped a cleaning chemical without notice and a worker was harmed. What do you do next?
Model answer: The organization must review the consequences of unintended changes and act to mitigate adverse effects. Ask for the incident record and the follow-up, and look at the control of purchased materials.

1 scenario answered: 1 of 1 correct

Preloaded example: Situation 1 is already answered. A machine started before its risk assessment should prompt you to ask how the change process works.

Frequently asked questions

What does ISO 45001 clause 8.1.3 require?

Clause 8.1.3 of ISO 45001:2018 requires the organization to establish processes for the implementation and control of planned temporary and permanent changes that affect OH&S performance, and to review the consequences of unintended changes, taking action to mitigate adverse effects as necessary. Always check the exact wording in the current standard.

How do you audit management of change in ISO 45001?

Ask for the change procedure, the change log, recent change requests, risk assessments, approvals and records of temporary changes. Trace several changes from request to review, compare assessment dates with start dates, and speak to affected workers. Confirm what you hear with records and observation.

What counts as a change in ISO 45001?

Changes include new or changed products, services and processes, workplace locations and surroundings, work organization, working conditions, equipment and workforce, as well as changes to legal and other requirements, changes in knowledge about hazards and risks, and developments in knowledge and technology.

Does ISO 45001 cover temporary changes?

Yes. Clause 8.1.3 refers to planned temporary and permanent changes. An auditor checks that temporary changes are authorized, risk assessed, time-limited and either removed or made permanent through the proper process.

What are unintended changes in ISO 45001?

Unintended changes are changes that were not planned, such as a supplier substituting a material or a gradual drift in how a task is done. ISO 45001 asks the organization to review their consequences and take action to mitigate adverse effects as necessary.

What evidence do auditors look for on ISO 45001 change control?

Auditors look for the change procedure, the change register, risk assessments dated before the change, approvals and control measures, training and briefing records, temporary change records and incident or review records. They also interview change owners and affected workers.

Does the ISO 45001 Lead Auditor course teach management of change audits?

According to the 3FOLD Training course page, the ISO 45001 Lead Auditor course is delivered as 40 hours of Virtual Instructor Led Training (VILT) and teaches the audit method, which you can apply to clauses such as management of change. We prepare you for the exam; CQI and IRCA examine and certify.

Where 3FOLD Training fits

3FOLD Training is a CQI IRCA Approved Training Partner (ATP 6039853), licensed by the Knowledge and Human Development Authority (KHDA) in Dubai. The ISO 45001 Lead Auditor course is delivered as 40 hours of Virtual Instructor Led Training (VILT), with learning management system (LMS) access for class recordings and mock exams, and you can check the next available batch on the course page. We prepare you for the exam; CQI and IRCA examine and certify. Before you book, read what you need in our eligibility guide.

Ready to audit with confidence? Check the next batch and see what the course includes.

Check the next batch

Contact 3FOLD Training
Emailonline@3foldtraining.com
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CQI IRCA Approved Training Partner (ATP 6039853)
3FOLD Training · Licensed by KHDA, Dubai
This guide is for information only. Confirm current requirements in ISO 45001:2018 and your audit program.



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About Varshini Natarajan

Specialized Product Manager handling ISO 9001 QMS, ISO 14001 EMS, ISO 45001 OHSMS Lead Auditor training programs at 3FOLD Training.

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