Your company has completed the SMK3 audit, and the results are presented as a single percentage figure and a category label. The question that arises afterward is simple but rarely answered clearly: compared to what is that figure, and why is the neighboring company assessed with 166 criteria while you are assessed with 64?
Three categories, one tiered list
Regulation of the Minister of Manpower Number 26 of 2014 Article 20 paragraph (1) divides the assessment of SMK3 implementation through external audits into three categories: initial level with compliance to 64 criteria, transition level with 122 criteria, and advanced level with 166 criteria.
These are not three separate lists, but rather one tiered list. Appendix II of Government Regulation Number 50 of 2012 organizes all criteria in Column Table 1. The initial level uses column 3, the transition level uses columns 3 and 4, and the advanced level uses columns 3, 4, and 5. This means that the 122 criteria already include all 64 criteria of the initial level, and the 166 criteria encompass everything. Advancing categories means adding criteria, not replacing them.
The duration of the examination also adjusts accordingly. Appendix of Minister of Manpower Regulation 26/2014 stipulates that the audit day must cover at least 40 percent of Table 1 for the initial level, 60 percent for the transition level, and 80 percent for the advanced level.
Regardless of the category, the criteria are grouped into 12 elements as stated in Government Regulation 50/2012 Article 16 paragraph (3), ranging from commitment building, documentation of K3 plans, document control, procurement, work safety, monitoring standards, material management, to skill development.
The meaning of the percentage figure
Minister of Manpower Regulation 26/2014 Article 30 paragraph (1) uses three value bands, and these bands are the same for all three categories:
- 0 to 59 percent: insufficient implementation assessment level
- 60 to 84 percent: good implementation assessment level
- 85 to 100 percent: satisfactory implementation assessment level
For insufficient results, the Director General may take legal action against companies that are required to be audited, or take coaching actions for companies that voluntarily apply. For good results, the award is a silver certificate. For satisfactory results, a gold certificate. Both apply to initial, transition, and advanced categories.
The flags are different. The silver and gold flags are only awarded to companies in the advanced category. An initial level company that achieves 90 percent still receives a gold certificate, but does not receive a flag. All awards are valid for a maximum of 3 years.
Minor findings can elevate your level without you realizing it
The final score does not drop due to a single major finding. Articles 25 to 28 categorize findings into three categories. Critical findings are those related to equipment, work methods, work environment, or work processes that can cause loss of life, and must be corrected no later than 1x24 hours. Major findings include non-compliance with K3 regulations or failure to implement one of the SMK3 principles, with a correction deadline of no later than 1 month. Minor findings are inconsistencies in meeting regulatory, standard, or guideline requirements.
What is often overlooked is in Article 27 paragraph (3): minor findings on the same criterion found in 3 different locations are counted as major findings. Small recurring disorganization at many points is therefore more detrimental than a standalone negligence.
If the company does not accept the results, Article 29 opens a channel for objection to the Director General. Document examination and field verification are conducted no later than 7 working days, and the decision is established no later than 2 working days thereafter.
A single figure that is often misquoted
Many summaries state that the SMK3 audit must be conducted at least once every three years. This provision comes from Minister of Manpower Regulation Number PER.05/MEN/1996, which has been revoked by Minister of Manpower Regulation 26/2014 along with Minister of Manpower and Transmigration Regulation Number PER.18/MEN/XI/2008 and Minister of Manpower Decree Number KEP.19/MEN/1997.
What is currently applicable are two different things. First, the validity period of the certificate and flag is a maximum of 3 years, so the three-year cycle arises from the expiration of the award, not from the audit obligation. Second, for internal audits, Appendix I of Government Regulation 50/2012 states that the frequency is determined based on the review of previous audit results and evidence of hazards obtained in the workplace. Companies with a history of recurring findings should audit themselves more frequently, not wait three years.
The basic obligation itself has not changed: Government Regulation 50/2012 Article 5 paragraph (2) mandates the implementation of SMK3 for companies employing at least 100 people or having a high potential for hazards.
Sources
- Government Regulation Number 50 of 2012 on the Implementation of Occupational Safety and Health Management System, JDIH Ministry of Manpower (Article 5, Article 16, Appendix I, Appendix II)
- Minister of Manpower Regulation Number 26 of 2014 on the Implementation Assessment of SMK3, JDIH Ministry of Manpower (Article 20, Article 25 to 30, Appendix III)
- Minister of Manpower No. 26 of 2014, status and list of revoked regulations, Regulation Database JDIH BPK
- Minister of Manpower Regulation Number 26 of 2014, JDIH Ministry of Manpower (status Valid)