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There are numerous ways to begin development of an OHSMS within an organization. Regardless of the approach, the characterization of existing business processes and OH&S policies and procedures, as well as the gap analysis described above needs to be done to inform the development steps.

If a formal MS (e.g. ISO 45001) standard is being used or followed, consideration needs to be given to its specific requirements. For instance, ISO 45001, has a focus on process(es) and not just procedures or programs.

One way to begin the development of the OHSMS is to create a grid with the management system elements, or requirements on one axis, and the management system document pyramid (Figure 7) on the other with its four levels. The cells of this grid can then be populated with information about the existing OH&S policies, procedures, and processes. A strategy can then be developed to populate all cells in the grid, as needed for conformance. This approach does not imply that procedures should or need to be developed, rather that if they exist, identifying them is valuable, and if they don't, to consider whether it would be helpful to, or to simply create a simple document that describes a (the) process in play for a particular cell in the grid.

Beyond identifying policies, procedures, and processes, important initial activities include conducting a risk (and opportunities if following ISO 45001) assessment to determine the OH&S risks (and opportunities) and other risks impacting the OHSMS that subsequently establish the foundation from which performance objectives are created and operational controls and actions are put in place.

Organizations typically begin addressing an OHSMS requirements starting with the first section and moving on in a linear fashion, or they begin with an element where there is a current need, or an element where is alignment with other initiatives in the organization. For instance, if there is a need to improve the audit function, the OHSMS checking, evaluation, or corrective action section may be the first place to start. Or if there are leadership initiatives in the organization, OHSMS elements associated with leadership and management commitment may be a fruitful place to begin. What's important to keep in mind is that the elements of an OHSMS are generally interconnected with each other. That is, if starting with leadership, think about aspects of worker engagement, competencies, governance and performance metrics and how that shapes leadership activities.

Regarding auditing, consideration should to be given to how the OHSMS's internal auditing needs (requirements) will interact, be performed, coexist, etc. with existing compliance audit functions. It is common for organizations to integrate the OHSMS and traditional compliance audit functions.