8 min read
How do you audit an internal audit programme under ISO 45001?
How to check that internal audits are planned from risk, carried out by impartial auditors, reported to the right people and followed through.
3FOLD Training is a CQI IRCA Approved Training Partner (ATP 6039853) · Licensed by KHDA, Dubai
An internal audit programme is how an organization checks its own OH&S management system. When it works, problems are found early and fixed. When it does not, audits become a yearly tick-box and weaknesses stay hidden. An external or lead auditor therefore looks at the programme itself, not only at what the audits found. 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.
To audit an internal audit programme under ISO 45001, check that audits happen at planned intervals, that the programme considers the importance of processes and the results of earlier audits, and that criteria and scope are defined for each audit. Then check that auditors are objective and impartial, that results reach relevant managers and workers, that nonconformities lead to action, and that documented information is kept. Clause 9.2 of ISO 45001:2018 sets these requirements.
| Standard audited | ISO 45001:2018, Occupational health and safety management systems |
| Clause | 9.2, Internal audit |
| Purpose | Show whether the system conforms and is effectively implemented and maintained |
| Frequency | At planned intervals set by the organization |
| Key tests | Risk-based planning, impartial auditors, reporting, follow-up |
| Related course | ISO 45001 Lead Auditor · PR357 · CQI and IRCA |
What does ISO 45001 require for internal audit?
It requires the organization to conduct internal audits at planned intervals and to run an audit programme.
Clause 9.2.1 of ISO 45001:2018 says the audits provide information on whether the OH&S management system conforms to the organization’s own requirements and to the standard, and whether it is effectively implemented and maintained. Clause 9.2.2 then describes the audit programme and what it must contain. Always check the exact wording in the current standard. Our guide to how an ISO 45001 audit works from start to finish shows the audit process, and our guide to auditing management review in ISO 45001 shows where audit results go next.
What should an internal audit programme contain?
It should contain the frequency, methods, responsibilities, consultation, planning needs and reporting for the audits.
The table below turns the requirements into audit questions. Use it to check the programme, not only the audits.
| Requirement | What the auditor asks |
|---|---|
| Frequency and methods | Is there a plan, and was it followed? |
| Importance of processes and earlier results | Did risky areas and past findings shape the plan? |
| Criteria and scope | Is each audit’s scope and criteria defined? |
| Objective and impartial auditors | Does anyone audit their own work? |
| Reporting to managers | Did the results reach the relevant managers? |
| Reporting to workers | Were relevant results shared with workers and their representatives? |
| Action and improvement | Were nonconformities fixed and OH&S performance improved? |
| Documented information | Is there evidence of the programme and the results? |
An audit programme that never changes is not responding to risk.
Want to practice auditing a real process? The course includes editable audit working documents and a case study.
Why do you audit the audit programme itself?
Because weak internal audits leave real problems unfound and give top management false comfort.
If internal audits only visit easy areas, or the same person audits their own department, the results say little about the system. An auditor does not re-do every internal audit. The task is to judge whether the programme is a sound way to learn about the system. Look for signs of real challenge, such as findings, observations and changes to the plan based on what was learned.
How do you plan an audit of the audit programme?
Ask for the programme, the schedule, recent audit reports and auditor records, and plan to meet the programme owner.
Request the audit programme for the current and last cycle, along with reports, finding logs and auditor competence records. Pick two or three completed audits to examine in depth, choosing at least one in a high-risk area. Plan to interview the person who manages the programme and one of the internal auditors. Our ISO 45001 audit plan and checklist guide shows how to build this into your checklist, and our guide to ISO 45001 audit reports shows what good reporting looks like.
What evidence should you collect?
Collect the plan, completed audit records, auditor competence records, reports and proof of follow-up.
| Check | Records | Interview or observation |
|---|---|---|
| Plan followed | Programme and completed audit reports | Ask why any audit was moved |
| Risk-based planning | Risk register, incident data and earlier findings | Ask how risky areas were prioritized |
| Auditors impartial | Audit allocation and auditor records | Ask who audited which area |
| Auditors competent | Training and experience records | Ask an auditor how they plan an audit |
| Results reported | Reports, review minutes and worker briefings | Ask workers what they heard |
| Action taken | Corrective action log with closure evidence | Check one closed action on site |
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.
How do you interview the programme owner and the internal auditors?
Ask open questions about how the programme was planned and what the audits have changed.
- Ask the programme owner how the schedule was set and what drove the priorities.
- Ask for an example of a plan change made because of an incident or an audit finding.
- Ask an internal auditor how they were selected, trained and kept independent.
- Trace one finding from the audit report to the action and to evidence that it worked.
- Ask workers or their representatives what they were told about audit results.
Our guide to competence and training in ISO 45001 explains what auditor competence should look like, and our guide to the skills to become an ISO 45001 auditor lists the abilities an auditor needs.
Not sure whether to start as an internal or lead auditor? Compare the two roles in our guide.
What gaps do auditors commonly find in audit programmes?
Common gaps are a fixed yearly schedule, auditors checking their own work, no worker feedback and findings left open.
- Calendar, not risk. The same areas are audited in the same order every year.
- Self-audit. People audit the process they manage.
- Untrained auditors. Nobody can show how an internal auditor was prepared.
- No worker feedback. Results reach managers but not the workforce.
- Open findings. Nonconformities stay open past their dates with no explanation.
Treat these as prompts, not conclusions, and confirm each one with evidence before you raise a finding. Our guide to verifying corrective action after an ISO 45001 audit covers how to follow actions through. For the ISO 14001 side, see our guide to internal audit in ISO 14001:2026.
Audit programme 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.
1 scenario answered: 1 of 1 correct
Preloaded example: Situation 1 is already answered. A programme that repeats the same schedule each year is not using risk or earlier results to plan.
Frequently asked questions
What does ISO 45001 clause 9.2 require?
Clause 9.2 of ISO 45001:2018 requires the organization to conduct internal audits at planned intervals. The audits must show whether the OH&S management system conforms to the organization’s own requirements and to ISO 45001, and whether it is effectively implemented and maintained.
What must an ISO 45001 internal audit programme include?
An ISO 45001 internal audit programme must include the frequency, methods, responsibilities, consultation, planning requirements and reporting of the audits. It must take into account the importance of the processes concerned and the results of previous audits.
How often must ISO 45001 internal audits take place?
ISO 45001:2018 requires internal audits at planned intervals but does not set a fixed frequency. The organization decides the interval, and an auditor checks that it reflects the importance of the processes and the results of earlier audits.
Who can carry out an ISO 45001 internal audit?
Auditors must be selected so that the audit process is objective and impartial. This means people should not audit their own work, and an auditor checks how the organization made sure of this and how the auditors were prepared.
Must ISO 45001 internal audit results be reported to workers?
Yes. Clause 9.2 of ISO 45001:2018 requires relevant audit results to be reported to relevant managers and also to workers and, where they exist, workers’ representatives. Auditors check how this was done.
What evidence shows that an ISO 45001 internal audit programme works?
Evidence includes the programme and its schedule, completed audit reports, auditor competence records, findings with actions and closure evidence, and records of results shared with managers and workers. Interviews with the programme owner and auditors confirm what the records show.
What is the difference between an ISO 45001 internal audit and a certification audit?
An internal audit is carried out by the organization or on its behalf to check its own system. A certification audit is carried out by an independent certification body. 3FOLD Training prepares you to audit; certification is done by independent certification bodies.
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.
UAE mobile and WhatsApp: +971 50 481 9989
India mobile: +91 91762 57536
Chennai: Plot No: 1342, HIG, TNHB Main Road, Sithalapakkam, Chennai 600126
Monday to Friday 9:00 am to 5:00 pm, Saturday 9:00 am to 2:00 pm. See the 3FOLD Training contact page for all details.



Leave a reply