The time scale for suppliers under the category of “Direct Textiles” to achieve LSAS Level 2 approval has been re-confirmed as the 30 September 2014, which is 18 months from the launch of the framework agreement. For companies who have already achieved LSAS Level 1 the first annual visit has been waived by NHS SC as long as suppliers are working towards the LSAS Level 2 and achieve this prior to the deadline.
There is no contractual requirement at present to go beyond LSAS Level 2, however, should a company decide to progress to level 3 or level 4 then this would be a demonstration that they have a robust system for managing labour standards in line with the International Labour Organisation (ILO) conventions.
The additional requirements and questions to think about, on top of the LSAS Level 1 requirements are as follows:
LSAS Level 2 – Clause 1 (Policy) – Communication of the labour standards policy both internally and externally, in effect is it publicly available? Reviews against business objective and records to support this. Acknowledgment of receipt from suppliers. The policy to be a formal part of the documentation control system in terms of review, approval and updates.
LSAS Level 2 – Clause 2 (Management Representative) – Training and experience the management representative has for this role. Minutes and other evidence of activity to demonstrate involvement and whether or not this is a dedicated role. Is does not have to be dedicated, especially for small companies the management representative would normally wear another “hat.”
LSAS Level 2 – Clause 3 (Labour Standards Status Review) – Have desktop reviews taken place on supplier performance? How has the frequency of reviews been determined, for example has it been from the risk assessment that would have been formulated at Level 1? Have the audits been conducted by qualified and experienced auditors?
LSAS Level 2 – Clause 4 (Legal & Other Requirements) – Who has access to the information on legislation relating to Labour Standards, Contractors, Subcontractors and Suppliers?
LSAS Level 2 – Clause 5 (Objectives, Targets & Programmes) – Is there a plan of action in place and has it been communicated internally and to all interested parties? Has the plan been discussed with the “facilities?”
LSAS Level 2 – Clause 6 (Roles & Responsibilities) – Is there a defined organisation structure relative to Labour Standards as well as defined roles and responsibilities?
LSAS Level 2, Clause 7 (Competence, Training & Awareness) – Has competence been assessed for personnel and training and development needs identified who are directly employed or working on behalf of the organisation in areas where there is contact with Labour Standards issues? Is evidence available to support the assessments?
LSAS Level 2, Clause 8 (Communications) – A procedure is required for this level which addressed internal communications and external communications with interested parties that deals with receipt, response and actions involved to deal with Labour Standards issues.
LSAS Level 2, Clause 9 (Documentation & Records) – There are no requirements within this clause for Level 1. For Level 2 the requirement is to have documents and records to demonstrate conformity with all clauses.
LSAS Level 2, Clause 10 (Operational Control) – The difference between Level 1 and Level 2 for this clause is that procedures are now required for operational control. What will be looked at here is whether the findings of the risk assessment as required at Level 1, under Clause 3 (Labour Standards Review) has been used.
LSAS Level 2, Clause 11 (Supply Chain Management) – This clause for Level 2 has the most additional requirements from those required for Level 1. Evidence that the policy has been communicated “beyond” directly contracted suppliers in the supply chain? Does the supply chain map as required for Level 1 identified Labour Standards risks “beyond” contracted supply, e.g. sub-suppliers, homeworkers, etc? In addition to communication of the policy how does the organisation know id the policy has been understood and the expectations that go with it? Does the organisation’s procedure address what should take place in instances where Labour Standards abuses have been identified within the supply chain?
LSAS Level 2, Clause 12 (Emergency Response) – The Organisation should have documented mitigation action plans in place that relate to significant Labour Standards risks as identified through the risk assessment as required by Level 1, Clause 3 (Labour Standards Review) or by other means. There should be evidence of review to ensure that the mitigation plans are robust, based upon findings and changing circumstances.
LSAS Level 2, Clause 13 (Performance Monitoring & Measurement) – There are no requirements within this clause for Level 1. For Level 2, has the company identified and defined data and performance indicators to monitor and measure performance against its stated objectives and targets, compliance with relevant legislation and any other requirements. Is there a process of internal audits to check conformance with planned arrangements that address critical control points and significant supply chain risks. Although as stated above there was no requirement for this clause at Level 1, this should have been partly addressed by Clause 3 (Labour Standards Review) and the risk assessment.
LSAS Level 2, Clause 14 (Corrective Action – There are no requirements within this clause for Level 1. For Level 2 a procedure is required and needs to address the identification, recording of non-conformities and potential non-conformities. That corrective actions as well as time scales for implementation are agreed and effectively implemented. That corrective and preventive actions are taken and reviewed and that root cause analysis has been undertaken. The requirements of Level 2 for this clause are almost the same as those defined within ISO 9001:2008.
LSAS Level 2, Clause 15 (Management Review) – This is one of the most important activities of any management system and often it is the weakest. For Level 1 there was only a requirement for policies, etc to be formally approved. For this Level there needs to be evidence that top management have reviewed the organisation’s labour standards assurance system at planned intervals to ensure its continuing suitability, adequacy and effectiveness. Records of such reviews would need to be available for the auditor(s).
The original time to achieve LSAS Level 1 was extended, however, the time scale of 18 months from the launch of the framework agreement remain unchanged, therefore, some organisations may not have that long to achieve LSAS Level 2. To assist with this GCL INTL shall be running a series of training courses and workshops throughout 2014. The dates will be published through the web site, www.gcl-intl.com in due course. Anyone interested in attending a training course or workshop on LSAS Level 2 should in the first instance send an email to [email protected]