OHS Documents Versus Records

Government Regulation No. 50 of 2012 on the Implementation of the Occupational Safety and Health Management System (PP 50/2012) requires employers to document all OHS activities, and Article 13(3) lists at least 11 things that must be documented: OHS laws and standards, OHS performance indicators, work permits, the results of hazard identification, risk assessment and risk control, OHS training, inspection, calibration and maintenance, monitoring data records, accident reviews and their follow-up, product identification including composition, information on suppliers and contractors, and SMK3 audits and reviews (Pemerintah Republik Indonesia, 2012). In the audit, Annex II assesses element 4, document control, through 7 criteria and element 10, collection and use of data, through 6 criteria, while criteria on records also appear in several other elements.

On site, these two kinds of information are often mixed up. Procedures, work instructions and blank forms are documents, meant to be revised. Completed forms, inspection results and minutes are records, which serve as evidence and should not change once made. ISO 45001:2018 brings both under one term, documented information, and separates them through its verbs (International Organization for Standardization [ISO], 2018). We analyse how PP 50/2012 and ISO 45001 clause 7.5 treat documents and records, compare them, and draw out the compliance implications. We read PP 50/2012 from a copy of the regulation and its annexes; our account of the ISO clauses is a summary, not a quotation, and should be checked against a licensed copy.

Documents Are Not Records

The distinction that follows is our own frame for reading both sources. A document answers the question of what must be done and how. Its content changes when processes, equipment or rules change, so what needs controlling is its version. A record answers the question of what was done, when and by whom. Its value lies in staying fixed, so what needs controlling is its integrity, storage and retention.

The wording of PP 50/2012 fits that frame. Annex I asks that documents be reviewed periodically and revised where needed, approved by authorised personnel before issue, available in their latest version wherever they are needed, and removed once obsolete (Pemerintah Republik Indonesia, 2012). For records, criterion 10.1.1 in Annex II uses different verbs: identifying, collecting, archiving, maintaining, storing and replacing OHS records. The work permit is the clearest example. The blank form is a document with a revision number, while the form filled in and signed for one job is a record kept as evidence.

What PP 50 Requires

Element 4 by Level

Sub-element 4.1, on approval, issue and control of documents, has four criteria: OHS documents show their status, authority, date of issue and date of modification (4.1.1); the distribution recipients are listed in the document (4.1.2); the latest editions are stored systematically in a designated place (4.1.3); and obsolete documents are withdrawn promptly, while obsolete documents kept for a specific purpose carry a special mark (4.1.4). Sub-element 4.2, on changes and modifications, contains three: a system exists for making and approving changes (4.2.1), the reason for a change is stated in the document or its attachment and communicated to those concerned (4.2.2), and a document control procedure or a list of all documents showing the status of each is in place to prevent use of obsolete documents (4.2.3) (Pemerintah Republik Indonesia, 2012).

Table 1 of Annex II stages these criteria. The initial level, with 64 criteria, includes only 4.1.1. The transitional level, with 122 criteria, adds 4.1.2 and 4.2.1. The other four are assessed only at the advanced level of 166 criteria (Pemerintah Republik Indonesia, 2012). In our view this is easy to misread. A company aiming for the initial level is still bound by the documentation guidance in Annex I, so the staging should not be read as permission to postpone a master document list.

Records Across Elements

Sub-element 10.1, on OHS records, has four criteria: a procedure for identifying through to replacing records (10.1.1), OHS laws, standards and guidelines kept within easy reach (10.1.2), a confidentiality procedure (10.1.3), and records of accident compensation and health rehabilitation (10.1.4). Sub-element 10.2 asks for current data to be analysed and routine performance reports circulated. No element 10 criterion sits at the initial level: 10.1.1, 10.1.2, 10.2.1 and 10.2.2 apply from the transitional level, and 10.1.3 and 10.1.4 at the advanced level (Pemerintah Republik Indonesia, 2012).

Other record criteria sit outside element 10, including records of contract reviews (3.2.4), detailed records of inspection, maintenance, repair and modification of production equipment (6.5.2), records of workers' health surveillance made in line with the relevant regulations (7.4.5), and records of all training (12.1.6). Annex I also asks that inspection, testing and measurement records be maintained and available to management, workers and the contractors concerned (Pemerintah Republik Indonesia, 2012). On our reading, PP 50/2012 sets no retention periods; where they exist, they come from subject-specific regulations, as criterion 7.4.5 implies.

How Findings Are Weighted

Annex II sorts findings into three categories. A critical finding is one that results in a fatality. A major finding covers failure to comply with laws and regulations, failure to apply one of the SMK3 principles, and a minor finding against one audit criterion at several locations. A minor finding is an inconsistency in meeting requirements. A company with a critical or major finding is judged not yet to have implemented SMK3 successfully, whatever its percentage score (Pemerintah Republik Indonesia, 2012). For document control, one outdated procedure posted in one area may be minor, but the same pattern at several locations can be read as major.

The ISO 45001 Wording

ISO 45001:2018 deals with documented information in clause 7.5. Clause 7.5.1 covers what the standard requires and what the organisation decides it needs, noting that the extent can differ with organisational size, process complexity, the need to show legal compliance, and people's competence. Clause 7.5.2 asks for identification and description, such as a title, date, author or reference number, suitable format and media, and review and approval. Clause 7.5.3 asks that the information be available and suitable where and when it is needed and protected against loss of confidentiality, improper use and loss of integrity. Control covers distribution, access, retrieval and use, storage and preservation of legibility, control of changes, and retention and disposition. Necessary information of external origin must also be identified and controlled, and a note to the clause states that access includes access by workers and workers' representatives (ISO, 2018).

The split between documents and records shows in the verbs. For processes and plans the standard asks the organisation to maintain documented information. For results, such as evidence of competence, monitoring results, implementation of the audit programme, management review results, and incidents and corrective actions, it asks the organisation to retain documented information as evidence (ISO, 2018). ISO 10013:2021, the guidance on documented information for quality management systems, states that it can also support occupational health and safety management systems (ISO, 2021). It sets no requirements but helps when drafting a control procedure.

Overlaps and Gaps

Both share a core of approval before issue, the current version at the point of use, and control of obsolete documents. Comparing the texts, we note these differences:

• PP 50/2012 is more detailed on documents. Distribution recipients must be listed (4.1.2), the reason for a change must be written down (4.2.2), retained obsolete documents must be specially marked (4.1.4), and a master list with status is expected (4.2.3) (Pemerintah Republik Indonesia, 2012).
• ISO 45001 is more detailed on records. It names protection of integrity, preservation of legibility, and retention and disposition, which Annex II does not spell out as clearly (ISO, 2018).
• Both mention confidentiality, but PP 50/2012 assesses it only at the advanced level, through 10.1.3 (Pemerintah Republik Indonesia, 2012).
• Worker access is stated in a note to ISO 45001 (ISO, 2018). PP 50/2012 comes close through Annex I, which asks that inspection records be available to workers and the contractors concerned (Pemerintah Republik Indonesia, 2012).
• External documents, such as a P2K3 committee ratification letter, competence certificates and statutory inspection reports, are explicitly controlled under ISO 45001 (ISO, 2018), while PP 50/2012 assesses them through criteria in other elements.

Our interpretation is that one procedure covering the combined requirements can serve both sources, whereas separate SMK3 and ISO 45001 procedures invite duplication.

Electronic Records

Permits, inspections and training attendance now often live in applications. Article 5(1) of Law No. 11 of 2008 on Electronic Information and Transactions (the ITE Law) states that electronic information, electronic documents and their printouts are valid legal evidence. Article 6 provides that, where a provision requires information to be in written or original form, electronic information is considered valid as long as it can be accessed, displayed, its integrity guaranteed and it can be accounted for (Republik Indonesia, 2008). The law was most recently amended by Law No. 1 of 2024, which among other things revised Article 5 (Republik Indonesia, 2024). We read both articles through copies and secondary commentary and have not checked whether that amendment, or implementing regulations, affect Article 6.

In our view, the integrity condition in the ITE Law sits comfortably with the protection of integrity in ISO 45001 clause 7.5.3 (ISO, 2018). In practice, an electronic records system should log who created or changed data and when, lock a record once it is signed, restrict editing rights, and keep backups that can actually be restored. This section is not legal advice, and questions about evidential weight in a particular dispute belong with an advocate.

When Paperwork Piles Up

Complete documentation is not the same as safe work. Dekker (2014) describes the bureaucratization of safety, which brings standardisation and transparency but also side effects such as shrinking returns from each new safety initiative and numbers games. Rae et al. (2018) name a related problem safety clutter: the accumulation of procedures, documents, roles and activities carried out in the name of safety that do not contribute to the safety of operations. They trace it to duplication, generalisation and over-specification, and link it to cynicism and surface compliance. Rae and Provan (2019) separate safety work, the activity of managing safety, from the safety of work itself. An ethnographic study of safety professionals by Provan et al. (2019) found that little of their work was aimed directly at risks to workers.

Local studies show a similar pattern. In an advanced-level internal audit at a company in Bogor Regency, element 4 met 7 of 7 criteria and element 10 met 6 of 6, while element 6 on safe working met 34 of 41 and element 7 on monitoring met 14 of 17. The overall score was 153 of 166 criteria, or 92.1 percent, yet the researchers still flagged the need to improve personal protective equipment in the workshop (Rakasiwi et al., 2022). At an educational institution, minor findings arose against criteria 1.2.2 and 1.2.5 because appointed staff had not yet been certified or trained, and against 1.4.3 because the P2K3 ratification letter did not yet exist (Ayunita et al., 2021). We read these as two sides of one problem: internal documents can be complete while evidence from field practice or outside bodies is missing.

This evidence has limits. Both local studies are single cases assessed with qualitative methods and checklists, and do not describe Indonesian companies in general. The international work is largely conceptual or qualitative, comes from outside Indonesia, and for some of it we relied on abstracts and summaries.

Tidy Before Adding

Both sources ask for versioned documents and trustworthy records. PP 50/2012 is detailed on distribution, reasons for change and obsolete documents, with part of its criteria applying only at higher levels, while ISO 45001 is detailed on integrity, retention and worker access. Repeated small findings can escalate to major, electronic records must keep their integrity to stay usable as evidence, and more documents do not by themselves mean safer work.

Practical steps we suggest:

• Keep a master document list, with status, revision and distribution, separate from a records register that names the owner, storage location, retention period and disposal method for each record.
• Check documents at the point of use, not only in the filing room, because an outdated document in one area that recurs in others can become a major finding.
• Lock records once they are signed, on paper or in an application, and log every correction with its reason and author.
• Control documents of external origin, such as ratification letters, competence certificates and statutory inspection reports, together with their expiry dates.
• Review each form by asking whether its content supports a safety decision, and merge or retire forms that only duplicate others.

Before an external audit, an SMK3 internal audit checks the criteria element by element, including elements 4 and 10, while SOP and technical guideline development and SMK3 and ISO 45001 implementation help build one system that can be assessed against both. The SMK3 Manager application keeps evidence per criterion and document control in one place. The official SMK3 audit is still carried out by an independent audit body appointed by the Minister, and Nusa Safety does not issue certificates.

This article is general information and not legal or professional advice for any specific case.

References

1. Ayunita, D. R., Kurniawan, B., & Widjasena, B. (2021). Analisis ketidaksesuaian penerapan sistem manajemen keselamatan dan kesehatan kerja (SMK3) di institusi pendidikan X berdasarkan hasil audit SMK3 [Analysis of nonconformities in OHS management system implementation at educational institution X based on SMK3 audit results]. Jurnal Riset Kesehatan Masyarakat, 1(1). https://ejournal2.undip.ac.id/index.php/jrkm/article/view/11920
2. Dekker, S. W. A. (2014). The bureaucratization of safety. Safety Science, 70, 348-357. https://doi.org/10.1016/j.ssci.2014.07.015
3. International Organization for Standardization. (2018). ISO 45001:2018 Occupational health and safety management systems: Requirements with guidance for use. https://www.iso.org/standard/63787.html
4. International Organization for Standardization. (2021). ISO 10013:2021 Quality management systems: Guidance for documented information. https://www.iso.org/standard/75736.html
5. Pemerintah Republik Indonesia. (2012). Peraturan Pemerintah Nomor 50 Tahun 2012 tentang Penerapan Sistem Manajemen Keselamatan dan Kesehatan Kerja [Government Regulation No. 50 of 2012 on the Implementation of the Occupational Safety and Health Management System]. Lembaran Negara Republik Indonesia Tahun 2012 Nomor 100. https://peraturan.go.id/files/pp50-2012pjl.pdf
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7. Rae, A., & Provan, D. (2019). Safety work versus the safety of work. Safety Science, 111, 119-127. https://doi.org/10.1016/j.ssci.2018.07.001
8. Rae, A. J., Provan, D. J., Weber, D. E., & Dekker, S. W. A. (2018). Safety clutter: The accumulation and persistence of 'safety' work that does not contribute to operational safety. Policy and Practice in Health and Safety, 16(2), 194-211. https://doi.org/10.1080/14773996.2018.1491147
9. Rakasiwi, A. G., Ginanjar, R., & Listyandini, R. (2022). Audit sistem manajemen keselamatan dan kesehatan kerja di PT Buana Centra Swakarsa di Kabupaten Bogor [OHS management system audit at PT Buana Centra Swakarsa, Bogor Regency]. PROMOTOR Jurnal Mahasiswa Kesehatan Masyarakat, 5(1), 51-58. https://doi.org/10.32832/pro.v5i1.6128
10. Republik Indonesia. (2008). Undang-Undang Nomor 11 Tahun 2008 tentang Informasi dan Transaksi Elektronik [Law No. 11 of 2008 on Electronic Information and Transactions]. Lembaran Negara Republik Indonesia Tahun 2008 Nomor 58. https://peraturan.bpk.go.id/Details/37589/uu-no-11-tahun-2008
11. Republik Indonesia. (2024). Undang-Undang Nomor 1 Tahun 2024 tentang Perubahan Kedua atas Undang-Undang Nomor 11 Tahun 2008 tentang Informasi dan Transaksi Elektronik [Law No. 1 of 2024 on the Second Amendment to Law No. 11 of 2008 on Electronic Information and Transactions]. https://peraturan.bpk.go.id/details/274494/uuno-1-tahun-2024