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Equipment, PPE and workforce compliance in an OH&S management system, clause by clause
How GearTracker helps you meet ISO 45001
ISO 45001 never sets an inspection interval. It requires you to identify the ones your law imposes, prove you meet them, and make that proof available where the work happens. That is exactly what GearTracker produces.
ISO 45001 in brief
ISO 45001 is the international standard for occupational health and safety management systems. Published in 2018, it replaced OHSAS 18001 and has become the third most certified management system standard in the world: 542,527 valid certificates covering 941,546 sites in 2024, behind only ISO 9001 and ISO 14001.
Like every recent management system standard, it follows the common high-level structure of 10 clauses, organized around the Plan-Do-Check-Act cycle. The first three are introductory; the seven that follow carry the auditable requirements:
| Clause | Title | What it requires |
|---|---|---|
| 4 | Context of the organization | Understand your environment and interested parties, define the scope of the system |
| 5 | Leadership and worker participation | Top management commitment, OH&S policy, and effective consultation of workers |
| 6 | Planning | Hazards, risks, applicable legal requirements, measurable OH&S objectives |
| 7 | Support | Resources, competence, awareness, communication, documented information |
| 8 | Operation | Operational control, hierarchy of controls, change, procurement, emergencies |
| 9 | Performance evaluation | Monitoring and measurement, evaluation of compliance, internal audit, management review |
| 10 | Improvement | Incidents, nonconformity and corrective action, continual improvement |
A few markers before you start:
- Certification is issued by an accredited certification body, not by ISO itself.
- The cycle runs three years: a two-stage initial audit, then annual surveillance audits, then a recertification audit.
- The audit combines document review, observation of work as it is actually done, and interviews with workers at every level.
- Findings are classified as major or minor nonconformities; a major blocks certification until it is closed out with a verified corrective action.
- The standard is generic: it applies to any organization of any size in any sector. That is its strength, and the reason it will never tell you how often to inspect a harness.
note
ISO 45001 adoption in the United States is still modest — around 2,400 certificates, ranking the country 20th worldwide — but it is climbing fast, driven by multinational parent companies, by owner-client prequalification, and by organizations that want a system rather than a compliance checklist. This page covers the requirements of such a system that come down to evidence: equipment and PPE, worker competence and medical surveillance, incidents and corrective actions. That is what GearTracker covers, and among the most time-consuming parts to prepare.
What the standard actually requires about equipment
Open ISO 45001 looking for “annual PPE inspection” and you will find nothing. It is disconcerting the first time, and it is also the key to the whole subject.
ISO 45001 is a management system standard. It prescribes no technical rule; it organizes how you will identify your obligations, meet them, and prove it. For an equipment inventory, that plays out in three requirements that chain together.
- Clause 6.1.3 — You must know what the law requires of you. The standard requires you to determine the legal requirements applicable to your hazards and to understand how they apply. Translation: the inspection interval for every item you own must be identified, justified and documented. Your national and state law sets it, not the standard.
- Clause 9.1.2 — You must prove you meet them. This is the direct counterpart to 6.1.3: evaluate compliance with those requirements at a defined frequency, evaluate the results and retain the documented information. A register of obligations with no evidence of execution is a nonconformity, not a system.
- Clause 7.5.3 — The evidence must be where the work happens. This is the most underestimated requirement of all: documented information must be available and suitable for use where and when it is needed. A manufacturer’s manual perfectly filed at headquarters, but unreachable by the technician at the top of a tower, does not satisfy it.
ISO 45001 does not ask you to inspect your PPE every twelve months. It asks you to know who requires it, to prove you do it, and to make that proof reachable at the point of work.
Where PPE sits in the hierarchy: better to own it
Clause 8.1.2 requires you to apply a hierarchy of controls, in this order: eliminate the hazard, substitute it, use engineering controls and reorganization of work, use administrative controls including training, and finally use adequate personal protective equipment. PPE comes last because it protects one individual instead of removing the risk at source.
So let us be blunt: GearTracker eliminates no hazard and substitutes nothing. An auditor seeing an action plan resting entirely on PPE would immediately record that clause 8.1.2 is not being applied — and they would be right.
But the last rung is still a rung, and the standard asks for adequate PPE. A harness whose inspection has expired, a fall arrester issued to someone without the matching authorization, an item past its service life still in circulation: none of those is adequate PPE. Preventing precisely that is what the tool does.
warning
What ISO 45001 does NOT require. It mandates no software, no document format, no numeric interval, and no particular inspection provider. Any vendor selling you an “ISO 45001 requirement” to buy their tool is telling you a story. The interval obligation comes from OSHA, ANSI and your manufacturers; the standard only requires you to know it, meet it and be able to prove it.
Clause by clause: the GearTracker answer
Clause numbers below refer to ISO 45001:2018. Requirements are paraphrased, never quoted: the text of the standard is copyrighted and must be purchased from ISO or ANSI.
Clause 6 — Planning
Legal requirements, hazards and objectives
This is the foundation, and the most widely misunderstood part: ISO 45001 sets no inspection interval whatsoever. It requires you to go find the ones your law imposes, then prove you meet them. Without a reliable equipment inventory, this clause is unmanageable.
6.1.3
Determine the legal requirements and other requirements applicable to your hazards, understand how they apply, and maintain that information as documented information kept up to date.
Covered
The inspection interval is set item by item — statutory where one exists, taken from the manufacturer's instructions otherwise. Your legal requirements register stops being a theoretical spreadsheet: it becomes a property carried by every item in the inventory, verifiable on demand.
6.1.2
Identify hazards on an ongoing basis, taking into account equipment, materials and the actual conditions in which they are used.
Partially covered
The complete, current, named inventory feeds that identification: who carries what, in what condition, since when, until what end-of-life date. It is the input, not the analysis itself — that remains your work.
6.2.1 · 6.2.2
Establish measurable OH&S objectives consistent with the policy, and plan how to achieve them: what, who, when, with what resources, and how results will be evaluated.
Covered
"Reach 98% compliant equipment and zero overdue inspections by 31 December" is a measurable objective whose value is permanently visible on the dashboard. Most OH&S objectives fail audit for not being measurable; this one is measurable mechanically.
Clause 7 — Support
Competence and documented information
Clause 7 holds the most underestimated requirement in the standard for anyone managing equipment: 7.5.3, which requires documented information to be available and suitable for use where and when it is needed. Not in the office. At the point of work.
7.5.3
Control documented information so it is available and suitable for use where and when it is needed, adequately protected, and managed for distribution, storage, change control and retention.
Covered
This is where scanning pays off: an NFC tag or QR code on the item, a phone, and the record opens with the manufacturer's instructions, the certificate and the last inspection. On site, in front of the auditor, with no binder to carry. The public record even lets a phone with no account view it.
7.2
Determine the competence needed by workers who can affect OH&S performance, ensure they are competent, and retain documented information as evidence.
Covered
Training is recorded with its certificates, authorizations with their own catalog and renewal period, and an alert goes out before each due date (two months for a training, 30 days for an authorization). An authorization can be linked to the training that justifies it: if the training expires, the authorization is flagged too. The per-person compliance status combines their training, authorizations, medical checks and the equipment they hold.
7.4 · 7.5.3
Communicate information relevant to OH&S internally, and control the distribution, access and versions of documented information.
Covered
Risk assessment, procedures, safety data sheets: organization documents are published to a folder or to everyone, versioned, and each recipient acknowledges reading them. Every new version asks for that acknowledgement again. You know who read which version, and you can show it.
7.3
Ensure workers are aware of the policy, of the hazards and risks relevant to them, and of the implications of not conforming to requirements.
Partially covered
Users are unlimited, so every wearer can see their own equipment, its instructions and its due dates, and finds their own training, medical checks and authorizations under "My tracking". The tool makes awareness verifiable in the field, but it replaces neither your onboarding nor your toolbox talks.
Clause 8 — Operation
Operational control, hierarchy of controls and procurement
This is where the standard explicitly names PPE — at the bottom of the hierarchy of controls. Better to own it: GearTracker eliminates no hazard. It ensures the last line of defense is serviceable, current and provable.
8.1.1
Establish criteria for processes, implement control in accordance with those criteria, and maintain and retain documented information to have confidence that processes have been carried out as planned.
Covered
Reusable inspection checklists per equipment family are those criteria: two inspectors check the same things, and every answer is retained. The timestamped, attributed history is the documented information proving the process actually ran.
8.1.2 (e)
Apply the hierarchy of controls — eliminate the hazard, substitute, use engineering controls and reorganization of work, use administrative controls including training, and finally use adequate personal protective equipment.
Partially covered
GearTracker operates only at the last rung, and says so: it neither eliminates nor substitutes any hazard. But an expired, uninspected or wrongly assigned item is not adequate PPE — and preventing exactly that is what the tool does.
8.1.3
Control temporary and permanent changes that affect OH&S performance, and review the consequences of unintended changes.
Partially covered
Reassignment, change of wearer, retirement, removal from service: every movement is traced, dated and attributed. The management-of-change process itself still needs formalizing on your side — the tool supplies the equipment substance, not the procedure.
8.1.4.1 · 8.1.4.2
Control the procurement of products and services to ensure conformity with the system, and coordinate requirements with contractors, including hazards arising from their activities.
Covered
Contractor and temporary-worker equipment lives in the same inventory, with the same due dates and the same evidence. Folders and labels let you isolate one contractor, one site or one job and produce its compliance status on a client's request — the same export that satisfies an ISN or Avetta review.
Clause 9 — Performance evaluation
Monitoring, compliance evaluation and internal audit
Clause 9.1.2 is the counterpart to 6.1.3: having identified your legal obligations, you must prove you meet them, at a defined frequency, and retain the record. This is where organizations burn the most time preparing for audit.
9.1.2
Plan and implement the evaluation of compliance with legal and other requirements, determine its frequency, evaluate the results and retain documented information on them.
Covered
The compliance rate is calculated continuously: items in date, overdue, at end of life, out of service. The dated PDF or CSV export is your compliance-evaluation record for the equipment side — produced in one click, not reconstructed the night before the audit.
9.1.2 (workers)
Also evaluate compliance with the legal requirements that apply to workers themselves: health surveillance, fitness for work, mandatory authorizations and training.
Covered
Medical checks are tracked by type and interval, with the fitness opinion and any restrictions, never the medical reason. An unfit opinion makes the person non-compliant immediately. Authorizations and training carry their renewal date. An alert goes out before each due date and again once it has passed, and the per-person compliance status shows at a glance who is up to date. An employee's occupational health record can be generated on demand, with no health data in it.
9.1.1
Determine what needs to be monitored and measured, the methods, the evaluation criteria, when to measure and when to analyze, then retain appropriate documented information.
Covered
Compliance rate, overdue inspections, items to inspect or replace, breakdown by status: the metrics are produced mechanically from inventory data, with no manual recount and no intermediate spreadsheet. The compliance dashboard adds training, authorizations, medical checks and incidents, by folder, with their trend over 30 days, 90 days or 12 months.
9.2
Conduct internal audits at planned intervals to verify conformity with the organization's own requirements and with those of the standard.
Partially covered
GearTracker feeds your internal audits with reliable equipment data and serves as a support during field walkthroughs, but it replaces neither your audit programme nor your internal auditors.
Clause 10 — Improvement
Nonconformity and corrective action
10.2
React to incidents and nonconformities, evaluate their causes, implement the actions needed, review their effectiveness, and retain documented information on their nature and on the actions taken.
Covered
An item moved to "to repair" or "discarded" with a comment, a photo and an author is a nonconformity record, and its return to "safe for use", dated and attributed, the evidence of closure. Events follow the same logic: hazardous situations, near misses and damage can be reported by any worker, then followed through to closure with corrective actions and due dates. The clause 10.2 loop closes with no parallel register to maintain.
Your legal register in the United States
Clause 6.1.3 obliges you to identify the applicable rules; clause 9.1.2 to prove you meet them. Here is what that covers in practice under US law for an equipment inventory, and what the tool does with it.
| Rule | What it requires | What GearTracker does with it |
|---|---|---|
| 29 CFR 1910.132(d) | A workplace hazard assessment, verified by a written certification identifying the workplace evaluated, the person certifying, the date(s), and the document as a certification of hazard assessment | The assessment stays yours, but the inventory gives it a factual basis: what is deployed, where, on whom, and in what condition |
| 29 CFR 1910.132(e) | “Defective or damaged personal protective equipment shall not be used.” The shortest sentence in the standard, and the one that makes inspection unavoidable | An item marked “to repair”, “missing” or “discarded” is visibly out of service until it returns to “safe for use”. The status is carried by the item, not by someone’s memory |
| 29 CFR 1910.132(f) | Training on PPE use, verified by a written certification naming each employee trained, the date(s), and the subject | The training register records each training with its supporting document, its date and its refresher due date, per user |
| 29 CFR 1910.134 | Written respiratory protection program: fit testing, medical evaluation, cleaning, inspection and maintenance records. Note that the 1910.132(d) and (f) certifications do not apply here — 1910.134 carries its own, stricter requirements | Respirators, cartridges and filters are tracked with their own intervals and their own history, including expiry-driven replacement of consumables |
| ANSI/ASSP Z359.2 and 29 CFR 1910.140 | For fall protection: a pre-use inspection before every shift and a documented inspection by a competent person at least annually, with immediate removal from service on failure | 12-month interval, alert 45 days before the due date, and an inspection history naming the competent person who performed it — the record Z359.2 asks for and that spreadsheets never hold |
| Manufacturer’s instructions | Wherever no rule sets an interval, the manufacturer’s instructions govern — and where OSHA, ANSI and the manufacturer differ, the most stringent wins | Interval configurable item by item; the built-in catalog pre-fills instructions for major brands (Petzl, Beal, 3M, CAMP, Edelrid and others) |
note
This table covers the United States, and federal OSHA only: about half of the states run their own OSHA-approved State Plans, which must be at least as effective and are sometimes stricter. ISO 45001 being international, each site must build its own register — the French, German, Spanish and Italian versions of this page cite the rules of their own markets. That is a real watch point for multi-country groups: one ISO 45001 system has to absorb as many legal registers as it has countries.
The 6 pieces of evidence an auditor will sample
An ISO 45001 auditor does not read your whole inventory. They pull two or three items in the field and walk the evidence chain backwards. If a link is missing, that is a finding — and the next sample will be wider.
| Evidence expected | Clause | Where to get it in GearTracker |
|---|---|---|
| The register of legal requirements applicable to your equipment, with the intervals they drive | 6.1.3 | The interval carried by each item, exported with the inventory |
| The record of inspections performed: date, author, result | 9.1.2 | Item history, with checklist answers retained |
| Documented information available at the point of work | 7.5.3 | Item record reachable by NFC or QR scan, instructions and certificate included |
| Evidence that the wearer is competent and authorized for the equipment they use | 7.2 | Per-person compliance status: training, authorizations, medical checks, due dates, equipment held |
| The documented handling of a finding, through to closure | 10.2 | ”To repair” / “missing” / “discarded” statuses with comment, then a dated return to “safe for use”; for an incident, its follow-up through to closure and its corrective actions |
| Monitoring and measurement results, quantified and tracked over time | 9.1.1 | Dashboard and dated PDF or CSV export |
The whole evidence chain on one screen, reachable by scanning the item: identification, inspection timeline with who performed each one, applied interval and end of life. This is what clauses 7.5.3 and 9.1.2 are asking for.
Clause 10.2: the finding, the incident, the corrective action, the closure
Clause 10 is the one organizations document worst, because it means keeping a record of your own failures. The standard requires, for every nonconformity, that you react, evaluate the causes, take the actions needed, review their effectiveness, and retain documented information about them.
For an equipment inventory, the good news is that this loop already exists, provided it is tooled. An item switched to “to repair” during an inspection, with comment, photo and author, is a nonconformity record. It stays visible on the dashboard until it is brought back into compliance. Its return to “safe for use”, dated and attributed, is the evidence that the corrective action was taken and verified.
The same loop applies to events. A hazardous situation, a near miss or damage can be reported from the app by any user, or without an account by scanning the site’s QR poster, anonymously if needed. Admins are notified by email and follow the report through to closure: people involved, immediate actions, timeline, testimonies, corrective actions with due dates. The original report is never altered, which is exactly what retained documented information should look like. Root-cause analysis remains your job.
What an auditor is looking for at that point is not an inventory without findings — an inventory with no findings at all is suspicious, exactly like an internal audit report with no nonconformities. What they are looking for is the elapsed time between detection and closure, and evidence that nobody kept using the item in between.
Every inspection leaves a dated, attributed, commented record. A “to repair” status opens the nonconformity; the return to “safe for use” closes it.
Clauses 9.1 and 6.2: turning compliance rate into an OH&S objective
Clause 6.2 requires OH&S objectives to be measurable — and this is one of the points where management systems get pulled up most often. “Improve safety” is not an objective; “reach 98% compliant equipment and zero overdue inspections by 31 December” is, because it can be measured, monitored and demonstrated.
It is also an objective you do not have to calculate: the compliance rate is produced mechanically and continuously from due dates and statuses. It then feeds clause 9.1.1 (monitoring and measurement), clause 9.1.2 (evaluation of compliance) and the clause 9.3 management review, without a single line being recounted by hand.
Compliance rate, overdue due dates, items to inspect or replace: the value of your OH&S objectives, permanently available rather than reconstructed before the management review.
What GearTracker does not do
ISO 45001 is a complete management system: GearTracker provides its evidence (equipment, workforce competence, incidents), not its governance or its safety leadership. Better to know that before the certification audit.
Out of scope
ISO 45001 requirements to handle by other means
4 · 5.1 · 5.2 · 5.3
Context of the organization, interested parties, scope of the system, leadership and commitment, OH&S policy, roles and responsibilities.
Outside the tool's scope
These are governance documents and decisions. GearTracker plays no part, other than supplying hard equipment numbers to your objectives.
5.4
Consultation and participation of workers and their representatives at all levels, with barriers to that participation removed. This is the requirement that most distinguishes ISO 45001 from other management system standards.
Partially covered
GearTracker supports only one aspect of it: any worker can report a hazardous situation, with or without an account (QR poster), and anonymously if they wish. Consultation itself rests on your safety committees, your worker representatives and your day-to-day safety culture.
8.2
Emergency preparedness and response: planning, periodic testing, drills, communication to interested parties.
Outside the tool's scope
GearTracker ensures rescue and emergency equipment is inspected and available, but it writes neither your emergency plans nor your drill scenarios.
10.2 (investigation) · 9.3
Incident investigation and root cause analysis, internal audit programme, management review, continual improvement of the system as a whole.
Outside the tool's scope
The tool records events, testimonies and corrective actions, and provides inputs to management review, but the analysis, the audit and the review remain human processes. Be wary of any vendor promising "turnkey ISO 45001 certification".
The ISO 45001:2027 revision is coming
ISO 45001 has been under revision since 2024. The draft has reached DIS stage (Draft International Standard) and publication of ISO 45001:2027 is expected around the middle of 2027, with a transition period likely to be about three years — matching those set for ISO 9001:2026 and ISO 14001:2026, the latter published on 15 April 2026.
The announced themes broaden the scope of the standard noticeably:
- Worker well-being, not only health and safety in the narrow sense.
- New ways of working, including remote and hybrid arrangements.
- Workforce diversity — gender, age, disability — in hazard identification.
- Climate change, formally integrated into requirements as in the other recent management system standards.
- Emerging technology, with specific attention to artificial intelligence.
- Return to work after injury or illness, and control of externally provided services.
Should you wait? No. None of these themes changes the mechanics of documented information about equipment: you will still have to identify your legal obligations, prove you meet them and make the proof reachable at the point of work. An inventory structured today will cross the transition without rework, and you will have three years to align the rest of the system.
note
One timing point does deserve attention: if your recertification audit falls after publication, your certification body will expect you to be aligned with the new version. Better to lay down now the building blocks that will not move.
Getting the equipment side of your ISO 45001 audit ready in 6 steps
The order matters: each step makes the next one cheaper.
1
Build the legal requirements register for your equipment
This is clause 6.1.3, and it is the mandatory starting point. For each equipment family, note the applicable rule and the interval it drives: OSHA 29 CFR 1910.132 and 1910.134, ANSI/ASSP Z359.2 for fall protection, and the manufacturer's instructions everywhere else. Until this register exists, nothing is auditable.
2
Inventory every item concerned
Not just PPE: lifting equipment and accessories, ladders and access equipment, fire extinguishers, power tools, vehicles. A management system that stops at PPE leaves a hole the auditor will see on the first question. If you already have a spreadsheet, upload it in the app: the AI assistant imports it for you, after a 10-row trial.
3
Put the interval on each item
Automatic alerts then take over 45 days before the due date: no more expired inspection discovered during the audit.
4
Attach the documented information to each record
Manufacturer's instructions, certificate of conformity, last inspection report. That is clause 7.5.3 — and it is what makes the field audit easy, since everything becomes reachable by scanning the item at the workstation.
5
Standardize inspections with checklists
A reusable checklist per equipment family is exactly the process criteria of clause 8.1.1. It ensures two inspectors check the same things, and that the answers are retained as evidence.
6
Produce your compliance evaluation and your metrics
A dated PDF export of the inventory and its inspections serves as the record required by clause 9.1.2, and supplies the value of your clause 6.2 objectives for management review. You walk into the audit with evidence, not intentions.
Why GearTracker for an ISO 45001 system
- Clause 6.1.3 becomes operational — the interval is no longer a line in a theoretical register; it is carried by the item itself and triggers alerts.
- Clause 9.1.2 comes out in one click — the dated PDF or CSV export of the inventory and its inspections serves as your compliance evaluation record.
- Clause 7.5.3 is satisfied in the field — NFC or QR scan, and the evidence opens where the work happens, even on a phone with no account.
- Clause 10.2 closes natively — the finding, its author, its comment and its closure date, and reported incidents followed through to their corrective actions, with no parallel register to maintain.
- One inventory for everything — PPE, collective protection, lifting gear, access equipment, extinguishers, power tools, vehicles: the scope of the system does not stop at PPE.
- Training, authorizations and medical checks in the same place — each person’s compliance status combines their training, authorizations, medical checks and the equipment they hold.
- Free up to 100 items, with no time limit and no credit card: you can start your inventory today.
For more on the tool itself, see our PPE management software page, or the enterprise offering if you manage several sites.
note
ISO 45001 is a standard published by the International Organization for Standardization. GearTracker is not affiliated with ISO, is not a certification body and is not a consultancy: certification is issued by an accredited certification body. The requirements discussed on this page are paraphrased, not quoted — the text of the standard is copyrighted and must be purchased from ISO or ANSI. Always confirm the applicable version with your certification body.
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FAQ – GearTracker and ISO 45001
Whether large companies or associations, they trust us
Audrey G.
HSE Manager at Capgemini
This tool is a real performance driver for our business. The platform is intuitive, seamless, and particularly easy to use. Quick access to information and the automation of many tasks enable us to save significant time every day while improving the efficiency of our processes.
Thanks to this solution, our teams can focus on higher-value tasks, which directly helps improve our productivity. Reliable, high-performing, and perfectly suited to our needs, this tool brings real added value to any organization looking to optimize its operations and become more efficient. I highly recommend it.
Christian M.
Warehouse Manager at Bonduelle
Since we started using GearTracker last year, our experience has been extremely positive.
The platform has significantly simplified the management of our personal protective equipment (PPE) and other regulated equipment. Features such as deadline alerts, incident tracking, and repair monitoring have allowed us to save valuable time and ensure the safety of our teams.
What truly sets GearTracker apart is the quality of relationships with the founders. Their responsiveness is exemplary. Their personalized support has made all the difference, making the integration of the solution smooth and efficient. We highly recommend GearTracker to any organization looking to optimize their equipment management.
Alexis R.
CAF Annecy
At CAF Annecy, we were looking for a simple and effective solution to manage our PPE. With GearTracker, setup was quick and intuitive. From the very first days, volunteers were able to use the application without any training or user manual. For us, that is proof of well-designed software.
The GearTracker team is another real strength. Our suggestions for improvements are genuinely heard, and several have been incorporated into subsequent updates.
GearTracker is a modern, reliable, and constantly evolving solution. It saves us valuable time in managing our PPE and allows us to focus on what matters most: our activities. We recommend this solution to any association or organization looking to simplify the management of its equipment.
One QHSE tool for your equipment and your people.
Track your PPE and equipment, your teams' training, certifications and medical checks, and your incidents in one place. Plan ahead for deadlines, keep your evidence and prepare your audits.