What does the resolution regulate?
Resolution 0312 of 2019 from the Colombian Ministry of Labor defines basic requirements for the operation of the Occupational Health and Safety Management System ( SG-SST). It is integrated with Decree 1072 of 2015 and does not replace it. Its purpose is to verify minimum prevention capabilities, activities, and results through criteria and verification methods established in the regulation itself.
Meeting a checklist does not equate to demonstrating that all risks are under control. The company must implement the preventive measures corresponding to its activities, identify hazards, and execute controls. Standards provide a verification framework; their interpretation requires understanding the organization’s size, risk classification, and actual conditions.
Requirements groups
The resolution distinguishes between companies with ten or fewer employees classified as risk levels I, II, or III; companies with eleven to fifty employees in those same categories; and companies with more than fifty employees. Companies with fifty or fewer employees in risk levels IV or V must comply with the broader regulations outlined in Chapter III.
Therefore, a small workforce does not automatically allow for the selection of the shortest list. The number of workers and the risk classification must be checked together. The standard also contains specific provisions for agricultural production units and certain application scenarios. Before evaluating, it is advisable to document why a particular set of requirements is being used.
Responsibilities and competencies
The assignment of the person who designs or implements the system depends on the regulated scenario. The resolution establishes profiles of training, experience, licensing, and qualifications that should not be confused with one another. Passing a fifty-hour course does not, in itself, make a person a professional qualified to design any occupational health and safety management system (OHSMS) or perform any specialized activity.
The employer retains its organizational and resource responsibilities even while receiving advice. The occupational risk insurer can provide support within its scope of functions, but the company must carry out its own responsibilities. It is helpful to distinguish who advises, who makes decisions, who performs each task, and who maintains the records of compliance.
Self-assessment and evidence
The self-assessment must compare each applicable requirement with sufficient and up-to-date evidence. A file with the expected name is not enough. A plan needs content and implementation; a committee needs to be formed and operational; training must address needs and have supporting documentation. The evidence must correspond to the period and organization being evaluated.
The resolution includes provisions for annual self-assessment and its connection to the improvement plan and the annual work plan of the Occupational Health and Safety Management System (OHSMS). Registration channels and schedules should be checked in the official instructions for the corresponding campaign. Dates from previous years’ communications should not be automatically carried over to the new year.
Rating and improvement plan
Article 28 distinguishes between a critical rating when the result is below 60%, a moderately acceptable rating between 60% and 85%, and an acceptable rating when it exceeds 85%. Each situation has improvement and follow-up actions. The rating must be calculated using the table and rules of applicability, without altering denominators or excluding requirements for convenience.
The improvement plan must specify activities, responsible parties, deadlines, resources, and evidence of its effectiveness. An acceptable score does not eliminate pending improvements or legal obligations. It is advisable to link the findings to operational decisions, especially when a documentation deficiency reveals that necessary preventive action to protect workers has not been taken.
Practical example
In a hypothetical example, a company with eight employees belongs to risk class IV. When preparing its self-assessment, it discovers that it was using a shortened list based solely on size. It corrects the group selection and reviews the requirements of Chapter III. This check prevents it from submitting a favorable rating based on an incorrect scope.
The review identifies outstanding actions in training, task controls, and follow-up. The employer assigns responsibilities and resources and schedules the verification of the measures. The useful outcome is not just a new score: the company gains a more accurate diagnosis and concrete actions to close gaps that were not previously identified in the form.
Integration with daily management
Standards should be linked to the system’s routine activities. The results of inspections, investigations, monitoring, and participation inform planning. The Joint Occupational Health and Safety Committee (COPASST) or its equivalent body intervenes within its functions, while management reviews resources and performance. Documentation should serve to coordinate and verify preventive work.
A digital record can facilitate tracking deadlines, responsible parties, and traceability, provided it preserves the source and context of each piece of evidence. Automation should not automatically equate compliance simply because a file is uploaded. It is necessary to assess whether the document is relevant, whether it reflects an action taken, and whether its content fulfills the requirement it is intended to demonstrate.
Common mistakes and review
Common mistakes include using the wrong risk class, copying evidence from another company, and confusing hiring an advisor with implementing the system. It is also inappropriate to complete the self-assessment only at the end of the period without prior follow-up. Ongoing preparation allows for the detection of non-compliance while there is still time to correct it.
Compliance with occupational health and safety regulations requires reviewing changes in activity, staffing, and regulations. The resolution should be consulted in conjunction with the current framework and official instructions applicable to registration. Self-assessment is most useful when it honestly reflects existing conditions and leads to verifiable improvements in the workplace.
