Baseline, Issue Based and Task Based Risk Assessments

8 October 2026 by ASC Team

Ask a South African SHEQ officer for the risk assessment and you will usually be handed one document: the baseline, written by a consultant some years ago, two hundred lines long, rated medium almost everywhere. Ask an inspector or an auditor the same question and they mean several documents: the baseline, yes, but also the task based assessments for the jobs that hurt people, the issue based assessments for the things that changed, and the regulation specific assessments that the Hazardous Chemical Agents, Ergonomics, Noise Exposure and Physical Agents Regulations each require on their own clock. Section 8(2)(d) of the Occupational Health and Safety Act 85 of 1993 requires every employer to establish the hazards and the precautionary measures. The regulations say how often, and for what. This guide sets out the three kinds, what each is for, which the law requires, and why a 212 line baseline from 2021 does not answer the question.

What does the law require, and how often?

The general duty is section 8(2)(d): to establish, as far as is reasonably practicable, what hazards to health or safety are attached to the work, the articles and substances used and the plant, and what precautionary measures should be taken, and to provide the means to apply them. The section does not say “baseline” or “task based” and sets no interval. It is the duty every other assessment serves.

The regulations then name specific assessments with their own triggers and intervals.

Regulation	What must be assessed	When, and how often
Regulations for Hazardous Chemical Agents (GN R280 of 2021), regulation 5	Whether any employee may be exposed to a hazardous chemical agent by any route, considering the agent, its effects, where and in what form it is present, the route and extent of exposure, and the work process, including control failure	Immediately, and at intervals not exceeding two years; reviewed immediately if it may no longer be valid or the process, methods, equipment or procedures change; after consulting the representative or committee
Ergonomics Regulations, 2019, regulation 6	An ergonomic risk assessment by a competent person: complete hazard identification, everyone who may be affected, how, analysis and evaluation, prioritisation	Before work that may expose employees to ergonomic risk, and at intervals not exceeding two years; reviewed when no longer valid, when controls fail, when work or equipment changes, or after an incident or medical finding
Physical Agents Regulations, 2024, regulation 6	A risk assessment for all tasks involving cold stress, heat stress, illumination, indoor air quality, vibration and non-ionising radiation, recorded	Reviewed at least every 24 months, earlier if circumstances change
Noise Exposure Regulations, 2024, regulation 7	A noise exposure risk assessment, followed by monitoring, medical screening and surveillance, noise zones and hearing protectors under the regulations that follow it	As the 2024 regulations set out; they replaced the 2003 regulations on 6 September 2026
Regulations for Hazardous Biological Agents, 2022, regulation 6	A documented risk assessment by a competent person, where the regulations apply	Reviewed at intervals of no more than 24 months, and sooner after changes, incidents or adverse medical findings
Construction Regulations, 2014, regulation 5	The client’s baseline risk assessment and site specific health and safety specification for building work it commissions	Before the work, given to the designer and included in the tender

Two things follow. A site with cleaning chemicals, packing lines, a cold store and a noisy hall owes at least four regulation specific assessments on two year clocks, whatever its baseline says. And none of them is satisfied by a baseline line that says “chemicals: medium: PPE”: regulation 5 of the chemical regulations wants the agent, the route and the extent of exposure, and regulation 6 of the ergonomics regulations wants a competent person.

What are the three kinds, and what is each for?

The baseline is the map. It covers the whole site, every activity and area, at a level that shows where the significant risks are and in what order to deal with them. It is done once, properly, and then kept current: reviewed when the site changes and when an incident shows it was wrong. It tells you where to look next. It cannot tell you how to do a job safely, because it does not describe the job.

The issue based assessment is for a change or a question. A new line, a new chemical, a project, a change in shift pattern, a new piece of equipment, an incident that showed a gap, a regulation that came into force. It takes the one issue and assesses it in the depth the baseline could not. Construction Regulation 5 makes the client’s assessment for a building project a legal requirement; the chemical regulations’ regulation 5(5) review after a change in process or equipment is another. ISO 45001 clause 8.1.3 calls the same thing management of change.

The task based assessment is for a job that people do, step by step. Clearing a jam on the sleeve applicator. Decanting caustic. Entering a kettle for cleaning. It lists the steps, the hazard and the control at each step, and who does what, and it is written with the people who do the job, because they know where the procedure and the practice part company. It is the document a supervisor uses, a new worker is trained on, and an investigation checks the sequence of events against. The Act does not use the term, but section 8(2)(d) and 8(2)(e), the duty to give information, instruction, training and supervision, are what it serves.

What was wrong with Mzansi’s 212 lines?

Mzansi Fresh Meals is the case site in ASC’s courses: a chilled ready meals plant in Kempton Park with 400 people on two shifts and 60 agency workers, a training scenario built from real audit, inspection and incident patterns. No real company is named. Its risk assessment is a 2021 baseline by a consultant, 212 lines, generic, not reviewed since. There are no task based assessments, no issue based assessment for the cold store project planned for 2027, and no hazardous chemical agents assessment since 2021.

Take four lines. “Forklifts, warehouse: struck by: medium: demarcation, speed limit.” In 2025 a forklift struck a picker in the shared aisle and he was off for 14 days; the line was never revisited, and the controls it names are administrative ones that section 8(2)(b), which requires a hazard to be eliminated or reduced before resorting to PPE, puts well down the order. “Chemicals, chemical store: exposure: medium: PPE, SDS.” That line is doing the work of a regulation 5 assessment, and cannot: it names no agent, no route, no extent of exposure, and it was not consulted with a committee that had not met since February. “Ammonia plant: leak: high: procedure, drill.” The leak procedure had never been drilled, no night shift drill had ever been held, and the regulation 5 assessment that would decide whether the four plant operators need medical surveillance under regulation 7 had never been done. “Packing: repetitive work: low.” Noise at the flow wrappers was measured at 86 dB(A) in 2024 and nobody had been tested since; an ergonomic risk assessment by a competent person under regulation 6 does not exist.

When the inspector came in May 2026, the baseline was produced. She asked for the chemical assessment and the surveillance decision, and the baseline was produced again. Her direction named the missing record of the surveillance decision for the hygiene team. The baseline was not wrong, exactly; it was being asked to be four documents it was never written as.

Which mistakes get noticed?

The same ones, on most sites. Rating the hazard instead of the risk, so that every forklift line is “high” and nothing is prioritised. Rating the risk with the controls that are supposed to exist rather than the ones that do, so that a shared padlock scheme counts as lockout. Treating PPE and training as the control that brings the rating down, when section 8(2)(b) and the hierarchy in ISO 45001 clause 8.1.2 put them last. Assessing the day shift and assuming the night shift is the same. Leaving out the people the Act counts: the agency workers, who are the site’s employees because the Act excludes the labour broker from the definition of employer, and the contractors’ workers, to whom the site owes section 9. Never reviewing after an incident, when regulation 6(3) of the ergonomics regulations and regulation 5(5) of the chemical regulations require exactly that and ISO 45001 clause 10.2 asks for it. And doing it without the workers, when regulation 5 of the chemical regulations and regulation 6 of the ergonomics regulations both require consultation with the committee or representatives and clause 5.4 of ISO 45001 emphasises the participation of non-managerial workers in hazard identification.

How do you decide which one to write?

Ask what question you are answering. “Where are our significant risks, across the site” is the baseline, and if yours is years old or predates a serious incident, the baseline reviewed. “What does this change, project or incident mean for risk” is an issue based assessment, and for building work the Construction Regulations make it the client’s duty. “How is this job done safely, step by step” is a task based assessment, with the people who do it. And “does a regulation require an assessment of this hazard by name” is answered by the table above, and the assessment must meet what that regulation lists, by a competent person where it says so, within the interval, after consulting the committee.

Then write all of them into one register, so that the baseline line for the chemical store points to the regulation 5 assessment, the task based assessment for decanting and the issue based assessment for the new transfer pump. That is what an inspector means by “the risk assessment”, and what ISO 45001 clause 6.1.2 means by ongoing and proactive hazard identification.

Frequently asked questions

Does the OHS Act require a baseline risk assessment?

Section 8(2)(d) requires the employer to establish the hazards and the precautionary measures. The Act does not use the word “baseline”. The Construction Regulations, 2014 do: regulation 5 requires the client’s baseline risk assessment for building work.

How often must a risk assessment be reviewed?

The Act sets no interval. The regulations do for their own assessments: not exceeding two years under the chemical and ergonomics regulations, 24 months under the physical agents and biological agents regulations, and sooner after a change, an incident or a medical finding where each regulation says so.

Who may do a risk assessment?

The Act does not say. Several regulations require a competent person for their assessment, defined by knowledge, training, experience and any applicable qualifications for the specific work; the Ergonomics Regulations are one. For the rest, the person who knows the work, with the people who do it.

Must workers take part?

The chemical regulations, regulation 5, require consultation with the representative or committee and give them written notice, time to comment and the results. The ergonomics regulations require consultation before the assessment. ISO 45001 clause 5.4 emphasises the participation of non-managerial workers in hazard identification.

Is a task based assessment the same as a safe work procedure?

No. The assessment identifies the hazard and the control at each step; the procedure tells the worker what to do. The procedure comes from the assessment, and the assessment is checked against how the job is actually done.

Does ISO 45001 change any of this?

It adds to it. Clause 6.1.2.1 requires ongoing and proactive hazard identification and lists the sources to consider, including routine and non-routine activities, past incidents, emergencies and changes. Clause 8.1.3 requires management of change. The legal assessments remain the floor whether or not a site is certified.

Which ASC course teaches the three kinds?

This guide is drawn from Hazard Identification, Risk Assessment and Incident Investigation, FS67, a course for supervisors, representatives, SHEQ officers, engineers and consultants. Lesson 1.1 is the legal duty and the regulations’ clocks, lesson 1.3 is baseline, issue based and task based, and Module 3 does the chemical, ergonomic and physical agents assessments and management of change on the cold store project.

R1 495, in rand, no VAT added. About 5 hours, self paced, lifetime access.

Hazard identification from the sources, the walk, the task analysis and the people; the matrix and its mistakes; controls by the hierarchy.
Incident investigation that finds causes, with section 24, General Administrative Regulations 8 and 9 and clause 10.2.
The HIRA Register and Incident Investigation and Corrective Action tools, loaded with the Mzansi case, and a workshop.
Three knowledge checks, three games, eight scenario checks, three case study assessments and a final, all at 70 percent.

Enrol now and write assessments that stand up. All eight courses and the free guides sit at ISO 45001 and health and safety training. For a team, ask about a group arrangement on WhatsApp ASC.

Sources

Occupational Health and Safety Act 85 of 1993, sections 1, 8 and 9, SAFLII consolidated text, saflii.org
Regulations for Hazardous Chemical Agents (GN R280 of 2021), regulations 5 and 7, lawlibrary.org.za; Ergonomics Regulations, 2019, regulation 6, lawlibrary.org.za; Regulations for Hazardous Biological Agents, 2022, regulation 6; Physical Agents Regulations, 2024 and Noise Exposure Regulations, 2024, Government Gazette 52226, 6 March 2025; Construction Regulations, 2014, regulation 5
ISO 45001:2018, Occupational health and safety management systems: Requirements with guidance for use (ISO), clauses 5.4, 6.1.2, 8.1.2, 8.1.3 and 10.2

This guide is training, not legal advice. ISO 45001 is copyright and is not reproduced here. ASC is not affiliated with ISO. Last updated 8 October 2026.