Work Health And Safety (WHS) Management System And Policy Proposal

Obligations

Management is firmly committed to a policy enabling all work activities to be carried out safely, and with all possible measures taken to remove (or at least reduce) risks to the health, safety and welfare of workers, contractors, authorised visitors, and anyone else who may be affected by our operations.

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The company should be committed to ensuring we comply with the Work Health and Safety Act 2012, the Work Health and Safety Regulations 2012 and applicable Codes of Practice and Australian Standards as far as possible (Hughes and Ferrett 2015).

This policy:

  • shows the commitment of (your business name)’s management and workers to health and safety
  • aims to remove or reduce the risks to the health, safety and welfare of all workers, contractors and visitors, and anyone else who may be affected by our business operations
  • aims to ensure all work activities are done safely (Reese 2015) 

Management: 

Will provide and maintain as far as possible:

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  • a safe working environment
  • safe systems of work
  • plant and substances in safe condition
  • facilities for the welfare of workers
  • information, instruction, training and supervision that is reasonably necessary to ensure that each worker is safe from injury and risks to health
  • a commitment to consult and co-operate with workers in all matters relating to health and safety in the workplace
  • a commitment to continually improve our performance through effective safety management.

Workers: 

Each worker has an obligation to:

  • comply with safe work practices, with the intent of avoiding injury to themselves and others and damage to plant and equipment
  • take reasonable care of the health and safety of themselves and others
  • wear personal protective equipment and clothing where necessary
  • comply with any direction given by management for health and safety
  • not misuse or interfere with anything provided for health and safety
  • report all accidents and incidents on the job immediately, no matter how trivial
  • report all known or observed hazards to their supervisor or manager (Dau-Schmidt, Finkin, and Covington 2016)
  • Application of this policy 

The company seeks the co-operation of all workers, customers and other persons. We encourage suggestions for realising our health and safety objectives to create a safe working environment with a zero accident rate. 

This policy applies to all business operations and functions, including those situations where workers are required to work off-site (Friend and Kohn 2014). 

The purpose of the Work Health and Safety Management System is to:

  • Ensure all faculties and divisions of Charles Sturt University (the University) are able to translate their ‘duty of care’ under the Work Health and Safety (WHS) legislation into the management of risk;
  • Identify and prioritise realistic goals for each area;
  • Determine budgetary needs for short and long term WHS goals;
  • Provide a written commitment to all staff to improve WHS performance;
  • Provide a focus for current and future areas or issues for improvement;
  • Encourage active participation from all staff and to allocate responsibility and accountability to all involved; and
  • Provide for legislative awareness and compliance.

Senior Management Commitment- This element is about defining the contractor’s policies, objectives, responsibilities and commitments to WHS, as well as identifying and providing the resources needed for implementation and verification. Responsibility for the system starts at the senior management level, with a corporate WHS policy that applies to all projects. 

WHS Communication and Consultation- This element is about establishing the process for sharing relevant WHS information with workers and other contractorssuch as subcontractors and consultants in the supply chain, providing them with an opportunity to express their views on WHS issues and allocating adequate time to resolving such issues.

Managing Subcontractors and Consultants- This element is about selecting and managing subcontractors and consultants, defining measures to assess the capacity of all subcontractors and consultants in the supply chain to comply with specified WHS standards and monitoring their compliance.

Design- This element is about defining a process to identify and eliminate (or at least minimise) WHS risk relating to design at any stage of a Project. The elimination of risks at the design or planning stage is often easier and cheaper to achieve than making changes later when the risks become real hazards in the workplace.

Risk Management- This element is about defining a process to identify WHS hazards, assess risks and plan work processes to control those risks. It also covers Safe Work Method Statements and hazardous management processes. For effective WHS management, company must establish procedures for:

  • Identifying work site and work activity WHS hazards
  • Assessing risks associated with these hazards and devising ways to eliminate or minimise the risks
  • Implementing and prioritising control measures following risk assessment and monitoring risk control measures
  • Reviewing the adequacy of the risk assessment and the effectiveness of the control measures

Goals

Training- This element is about establishing the procedures and allocating resources to identify and provide for the training needs of workers. A properly designed training program will consider the training needs for each stage of a construction process. It will allow for regular and ongoing WHS communication, for example through ‘toolbox’ meetings. It will facilitate the delivery of appropriate training by appropriately qualified personnel.

Inspection, Testing and Servicing- This element is about establishing procedures for planning and conducting WHS inspection, testing and monitoring on work sites and for plant and equipment use, work processes and incoming products. It also covers health surveillance and monitoring and the servicing of plant and equipment. Regular inspection and testing must be carried out to verify that appropriate WHS management is in place, and that construction work processes are proceeding safely and in accordance with WHS Management Plans and requirements.

Incident Management and Corrective Action- This element is about establishing procedures to manage incidents, to control the use of products and work practices which do not meet WHS requirements and to address appropriately WHS issues through corrective action and injury management procedures.

Purchasing, Handling, Storage, Packaging and Delivery- This element is about making sure that all materials, equipment and plant purchased or hired conform to the required WHS standard and establishing procedures to facilitate compliance with legislative and other requirements for handling, storage, packaging and delivery of products including materials. Employers at a workplace must obtain the necessary information from their suppliers to enable the elimination or control of WHS risks before their installation or use.

Client Reporting and Project Performance Measurement- This element is about establishing procedures for regularly monitoring performance against WHS objectives and targets defined by the contractor at the corporate and project level.  The element defines the process for reporting WHS performance / issues to the Client. Performance measurement is an essential aspect of monitoring and evaluating WHS performance in an enterprise and/or industry. One of the primary objectives of measuring WHS performance is to provide feedback regarding health and safety performance.

Internal Reviews-This element is about establishing procedures for planning and undertaking internal reviews, including audits, to verify the on-site WHS processes and practice match the required plans and procedures. A schedule of internal reviews must be established and implemented to verify that WHS processes and practice match the required plans and procedures, and that the corrective actions resulting from reviews are effective.

Responsibilities

Documentation and Records- This element is about establishing procedures, for the control, approval, dissemination, withdrawal, storage and disposal of WHS documents, data and other records. An important factor for the success of construction projects is accurate and detailed documents such as plans, specifications, Standards and Codes. These include documents dealing with WHS work practices (Lundgren and McMakin 2013).

Traditionally, safety management has been reactive; with a business only taking action after something has gone wrong. A WHS management system will provide the opportunity for a business to take a proactive approach to safety by adopting risk management principles which allow hazards to be identified and controlled before they cause harm. A WHS management system will ensure a coordinated approach to health and safety instead of trying to deal with potentially conflicting information and instructions which lead to confusion among managers and employees and expose the business to unacceptable risk (Pink et al. 2016). A WHS Management system will allow mechanisms for involving your staff in health and safety at the workplace. Employee involvement is one of the principles of good management practice and providing opportunity for input to the people who are doing the work and who know what the problems are, can only benefit the business. A WHS management system will provide a process for review which will permit you to take an “under the hood” look at what is happening in your business and allow you to make improvements where required. While many may see the implementation of a WHS management system in their business as just too hard or too prescriptive, it cannot be denied that there are significant advantages to the systematic management of safety. Business improvements, reduction in risk, and operating cost reductions all flow from a successfully implemented WHS management system (Lundgren and McMakin 2013).

  • Identifying hazards and managing risks 

The company will systematically identify hazards and assess risks before the project starts by using the hierarchy of control in conjunction with:

  • DevelopingSafe Work Method Statements (SWMS) to control risks associated with high risk construction work
  • Usinga risk management form to control general construction risks where necessary

The company would also identify risks:

  • before we buy or re-order any chemicals
  • when introducing a new task
  • when new information is received about tasks, procedures, equipment or chemicals.
  • All hazards that are identified throughout the project must be reported immediately to the principal contractor

We will inform our workers of our risk management procedures and ensure they are trained in risk management (Ball-King and Ball 2016).

  • Hierarchy of control

We will control all risks we identify by applying the Hierarchy of Controls as follows:

  • Eliminate
  • Substitute
  • Isolate
  • Engineering controls
  • Administrative controls
  • Personal Protective Equipment

Where possible, we will implement risk controls that are high in the order and will implement multiple controls where necessary (Badri, Gbodossou and Nadeau 2012). 

Roles and responsibilities:

All workers are responsible for:

  • taking reasonable care of their own health and safety
  • taking reasonable care that their conduct does not adversely affect others 

The principal employer is responsible for:

  • preparing, updating and implementing this WHS Management Plan, including all associated procedures
  • identifying and observing all legal WHS requirements
  • ensuring that all works are conducted in a manner without risk to workers
  • planning to do all work safely
  • participating in the planning and design stages of trade activities
  • identifying WHS training required for an activity
  • ensuring workers undertake identified WHS training

WHS management system

Emergency and incident response:

To ensure we are prepared for an emergency we:

  • show all workers and subcontractors the emergency point as part of their induction (this is included in our induction checklist)
  • display emergency procedures in the site office or other visible location
  • check and mark fire extinguishers at the beginning of the project and six-monthly after that

If an incident occurs at the workplace the procedure is:

  • immediately notify the principal contractor
  • do not interfere with the scene of the incident

Depending on the nature and severity of the injury, the principal contractor will notify Workplace Standards.

This induction will outline:

  • the expectations outlined in this WHS Management Plan, including all policies and procedures
  • the emergency meeting point
  • the site rules
  • the facilities
  • any site specific hazards
  • high risk construction work activities (Tompa et al. 2016)

The worker training would

  • ensure workers are trained and competent for the work to be carried out
  • ensure workers are trained to deal with any risks associated with the work and understand the control measures in place
  • ensure all workers have had relevant white card training (or other appropriate training from another jurisdiction)
  • ensure on-site training and supervision is provided (Foster and Barnetson, 2016)

We will consult with all workers and contractors on WHS issues for this project:

  • at toolbox meetings where anyone can raise issues for discussion
  • informally during the planning of activities or the development of Safe Work Method Statements
  • when changes to workplace arrangements could affect the health and safety of workers
  • during investigations into any incident to establish details of the incident or to formulate corrective action to prevent the incident re-occurring (Manuele 2013)

We will ensure our workers and other contractors are aware of WHS requirements by providing them with this WHS Management Plan before starting work on the project. Contractors are expected to make their workers aware of all WHS requirements.

We will communicate relevant WHS information to everyone involved in this project by:

  • induction
  • pre-work meetings
  • toolbox meetings
  • incident reports and outcomes
  • distributing safety alerts or guidance material about industry specific hazards/incidents (Walters and Nichols 2009)

We will manage the risks associated with falls from heights by:

Ensuring that where practicable, any work involving the risk of a fall is undertaken on the ground or on a solid construction (such as an elevated work platform). We will ensure, where reasonably practical, that that no-one comes within an unsafe distance of an overhead or underground power line. We will maintain an in-service inspection and test regime for all portable electrical leads, tools and earth leakage devices. We will ensure that all plant is regularly maintained, inspected and tested by a relevant competent person (Urquhart, 2011).

Workers must:

  • not use incomplete scaffolding
  • report any scaffolding issues to the principal contractor
  • comply with the directions of any tags attached to the scaffold (Chen and Le 2014)

The metrics reported for the health and safety performance are: Lost Time Injury Frequency Rate (LTIFR). This is the number of lost time injuries per million hours worked. • Total Injury Frequency Rate (TIFR). This is the number of injuries per million hours worked. • Number of Lost Time Injuries (LTI). • Number of all Injuries inclusive of first aid, medical treatment, and lost time • Number of near Hits.

Incident Frequency Rate:  The organisation wide incident frequency rate for both lost time injuries and all reported injuries is relatively stable. This is largely due to the averaging effect of the calculation when taken over a twelve month period, combined with the limited set of data. The staff TIFR is showing a steady downward trend. This reflects in the overall reduction in the frequency of injuries over the last 12 months. This trend is offset by a steady increase in the number of contractor incidents reported over the last 12 months giving a total Organisation downward trend.

Total Incidents: Based on the information currently available, the number of Lost Time Incidents is averaging around 2.5 per month peaking at 7 for March. The 7 LTIs in March were all as a result of injuries sustained by Auckland Transport Staff (3 ankle sprains, two assaults, a slip, trip, and fall, and a strained leg). • Total reported incidents for staff are highly variable month to month with no obvious seasonal pattern. • The contract workforce is providing a good level of near hit reporting. Information as to the nature and cause of the near hit is not collected currently and, as such, no trend analysis is possible. An initiative to improve staff near hit reporting will be rolled out in conjunction with the new reporting tool.

Outline of plan containing outcomes of consultation

A review of the current Health and Safety Risk Register for the organisation has been completed. The identified risks and the assessment and treatment of those risks does not appear to accurately reflect the actual organisational risk. A series of health and safety risk management workshops is planned that will develop a risk register that identifies and quantifies the critical risks for the organisation. The first of these workshops will focus on public transport operations and will be completed in the first weeks of May. An assessment of the organisation’s “risk appetite” will also need to be completed to ensure the risk assessment process matches the needs of the organisation.

The significant health and safety incidents occurred in March:

  • Two TransDev rail workers received minor injuries after their locomotive left the track as it shunted a carriages to the depot in Westfield near Otahuhu on 2 March. The locomotive was pulling an empty four-carriage train south towards the Westfield depot after the Bruce Springsteen concert. The locomotive derailed and ended up on its side while the following two carriages derailed but remained upright. The investigations by TAIC (Transport Accident Investigation Commission), NZTA, KiwiRail and Transdev are still underway.
  • Two Parking Enforcement Officers were assaulted in separate incidents. One of the assaults resulted in hospitalisation of the Officer after he was punched in the head though there was no loss of consciousness. The other assault involved a vehicle being driven onto the foot of an officer. Both incidents have been reported to the Police. A review of the measures for mitigating violence against Parking Enforcement Officers is underway to assess the effectiveness of current measures and to evaluate the potential of other suitable measures. A representative of the Police will be part of the review. The review will be completed by the end of June.

The concerned authority must note:

  1. The trends in the health and safety performance of the organisation and the measures being taken to improve the robustness of the data.
  2. The actions being taken to improve the understanding of health and safety risk across the organisation
  • The three significant health and safety incidents that occurred in March and the update provided on the lost time incident that occurred in December
  1. The progress against the Health and Safety Strategy Work Programme

There is a need of enactment of a new WHS policy, based on Australian Model Law, including:  

  • Extending the ‘Duty of Care’ to Persons Conducting a Business or Undertaking (PCBU), including those in governance roles, in recognition that the traditional employer – employee relationship is only one arrangement
  • Replacing the ‘all practicable steps’ with the AU ‘reasonably practicable’ test (risk control hierarchy)
  • Those in ‘governance roles’ within organisations, such as Directors, assuming a ‘due diligence’ duty

References

Badri, A., Gbodossou, A. and Nadeau, S., 2012. Occupational health and safety risks: Towards the integration into project management. Safety science, 50(2), pp.190-198.

Badri, A., Gbodossou, A. and Nadeau, S., 2012. Occupational health and safety risks: Towards the integration into project management. Safety science, 50(2), pp.190-198.

Ball-King, L.N. and Ball, D.J., 2016. Health and safety and the management of risk. Routledge Handbook of Risk Studies, p.143.

Chen, P. and Li, Y., 2014. Occupational health and safety (pp. 75-94). Wiley-Blackwell.

Dau-Schmidt, K.G., Finkin, M. and Covington, R., 2016. Legal protection for the individual employee. West Academic.

Foster, J. and Barnetson, B. (2016). Health and safety in Canadian workplaces. 1st ed.

Friend, M.A. and Kohn, J.P., 2014. Fundamentals of occupational safety and health. Bernan Press.

Hughes, P. and Ferrett, E., 2015. Introduction to Health and Safety at Work: For the NEBOSH National General Certificate in Occupational Health and Safety. Routledge.

Lundgren, R.E. and McMakin, A.H., 2013. Risk communication: A handbook for communicating environmental, safety, and health risks. John Wiley & Sons.

Manuele, F.A., 2013. On the practice of safety. John Wiley & Sons.

Pink, S., Waterson, P., Dainty, A., Cheyne, A., Haslam, R., Gibb, A., Morgan, J., Hartley, R., Finneran, A. and Bust, P., 2016. Interdisciplinary research for occupational safety and health knowledge. Policy and Practice in Health and Safety, 14(1), pp.22-33.

Reese, C.D., 2015. Occupational health and safety management: a practical approach. CRC press.

Tompa, E., Robson, L., Sarnocinska-Hart, A., Klassen, R., Shevchenko, A., Sharma, S., Hogg-Johnson, S., Amick, B.C., Johnston, D.A., Veltri, A. and Pagell, M., 2016. Managing safety and operations: the effect of joint management system practices on safety and operational outcomes. Journal of Occupational and Environmental Medicine, 58(3), pp.e80-e89.

Urquhart, J. (2011). Workplace health and safety management systems. 1st ed. Bloomington, IN: Balboa Press.

Walters, D. and Nichols, T. (2009). Workplace Health and Safety: International Perspectives on Worker Representation. 1st ed. Palgrave Macmillan Ltd.