WHS Management Systems

WHS Management Systems

To ensure compliance with WHS legislation a planned, systematic and coordinated approach to WHS Management is required.  Whilst systems developed need to reflect the environment a service provider is working within there are some generally accepted principles which should apply to any workplace.  Assistance with managing your WHS management system is available from an online system known as NDSonlineWHS available on a yearly licence fee basis.

Disability Services Providers must operate under the Work Health and Safety Legislation in individual states and territories as well as a range of Disability related legislation.

Work Health and Safety(WHS) Legislation consists of a WHS Act and WHS Regulation as well as a number of approved Codes of Practice.  Disability Service providers are regarded as Persons Conducting a Business or Undertaking (PCBU).  The PCBU has responsibility for the general duty to ensure the health, safety and wellbeing of workers and others as far as is reasonably practicable.  Workers include employees, volunteers, contractors and sub-contractors and their employees, agency staff, students and any others who undertake any form of work for the PCBU.  A workplace is anywhere where work is undertaken and includes offices, workshops, vehicles, client's homes and community venues.  A posiitve duty known as due diligence to ensure that the PCBU meets its obligations under the legislation is placed on Officers of the PCBU.  Officers include CEO level and Board members but may include anyone else who makes decisions which affects more than 50% of the organisation.  Individual organisations need to identify who woudl be classified as Officers within their organisations and ensure that they meet their due diligence obligations - management commitment for more informaiton.

The PCBU must consult effectively with all workers and with other PCBUs.  Consultation is the cornerstone of all parts of the legislation.  Mechanisms for consultation are determined by the PCBU in consultation with workers but the legislation provides informaiton on Health and Safety Representative (HSR) elections and Helath and Safety Committee formation - see consultaiton section for more information.

A number of Codes of Practice have been approved and a number of others are to be introduced over time.Copies of the Codes of Practice are available on the Safe Work Australia Website www.safeworkaustralia.gov.au;  Summaries in the form of factsheets are available for the following Codes of Practice relevant to the Disability Sector:

There is also a factsheert on PCBUs, RCDs and PPE.  There is also a sanple factsheet which can be given to volunteers to explain their WHS obligations.

The ideal way to implement the WHS legislation is through a planned, systematic and coordinated approach.  Models for such an approach are available and how they are implemented is dependent upon the type of service being offered.  However there are some generally accepted principles which should apply to any workplace.  Adoption of these practices should reduce the risk of injury and the risk of non-compliance with legislative requirements.

A checklist has been developed to assist organisations to review their WHS Management systems.

NDSonlineWHS is an online tool customised for the disability sector which allows you to record and manage your WHS management system in one spot.

 Management Commitment and Active Involvement

Commitment should be demonstrated through the publication of an Work Health and Safety (WHS) Policy and associated procedures.  The Policy Statement should outline the goals and objectives of management, specific responsibility of all involved in the organisation and resources which will be provided to achieve the goals and objectives.

Commitment can be further demonstrated through development of an WHS Plan for the year, inclusion of WHS responsibilities in job descriptions and key performance indicators for all staff and the inclusion of WHS as a regular agenda item at staff meetings. 

The Management Board should regularly review the performance of the WHS Management System to ensure that it is effective and complying with legislative requirements.  The Boardsafe material can be used to provide advice to Board members on the requirements of the WHS Management system as well as a checklist and action plan to ensure good governance of the WHS system.

 Consultation Strategy

All persons conducting a business or undertaking (PCBU) are required to consult with workers including volunteers and contractors on any issues which may affect their health and safety.  The Work Health and Safety legislation allows three consultation mechanisms:

  • Health and Safety Committee – where there are 5 or more workers request the establishment of a Committee, or management or the Regulator determine a committee is required.
  • H&S Representative – where at least one employee requests election of an H&S Representative or where Management or the Regulator determine that an H&S Representative is required.
  • Other Agreed Arrangements – must be agreed to by the majority of workers and can include the discussion of WHS issues at staff meetings and/or the formation of an WHS Committee which does not meet the legislative requirements of a Committee e.g. composed of mainly management reps.

The choice of consultation strategy should consider the nature and size of the workforce and the current communication strategies in place.  The strategy is best recorded in a Consultation Statement or procedure and reviewed on a regular basis (e.g. every 2 years).

Management of the Work Environment

The service provider is required to ensure as far is as reasonably practicable that:

  1. workplace layout and maintenance allow safe movement within and  in and out of the workplace
  2. work areas have sufficient space to work safely
  3. floors and other surfaces are safe
  4. lighting is adequate for safe work, safe movement within the workplace and safe evacuation in an emergency
  5. if vehicles and predestrians are in the same work area that suitable controls are in place to reduce risk
  6. ventilation that allows a worker to work safely
  7. if working in extremes of heat or cold, work is designed to reduce risk
  8. work in relation to or near essential services does not give risk to risk to health and safety.

Adequate facilities for workers including toilets, drinking water, washing facilities and eating facilities must be provided and maintained in good working order and be clean, safe and accessible but give consideration to nature and location of work etc. 

Risk Management

Providers need to have risk management systems to identify hazards to the health and safety of workers,clients and others and control the risks associated with those hazards.  Hazards may arise from the environment in which the work is conducted, the activities being undertaken and the clients receiving assistance.  Hazard identification, risk assessment(if required due tot he control measure not being obvious) and risk control strategies help the PCBU to do everything reasonably practicable to reduce the risk of injury and meet the duty of care requirements imposed by the legislation.  Hazard identification strategies generally fall into two categories – planned and incidental.

 Planned hazard ID

  • Workplace inspection – own or host employer.  Office and work areas should be   inspected on a regular basis to identify any hazards missed through incidental mechanisms.  Disability Enterprise work areas should be inspected on a more regular basis due to the nature of the work being undertaken.  Work areas belonging  to host employers for clients undertaking work experience should be inspected prior  to placement to ensure the safety of the client and any support staff during that placement.
  • Plant/equipment inspections.  Part of the plant maintenance guidelines and would include pre-use as well as regular inspections.
  • Home inspection.  For providers of in-home support or accommodation services an inspection of the home environment and the equipment being used should be undertaken prior to commencing the service and then on a regular basis due to potential changes in condition etc.
  • Venue inspection.  A Community Venue being accessed as part of a Community Support program on a regular basis should undergo a venue assessment.  A pre-use inspection should be undertaken for venues being used on a one-off basis or at the beginning of the visit. Consider if the venue meets the needs of individual clients.
  • Client risk assessment.  An initial intake assessment of the client as well as specific behaviour or manual handling assessments should be undertaken prior to commencing services and regularly thereafter.
  • Activity risk assessment.  Jobs undertaken by Disability Enterprises should be risk assessed to identify any inherent risks and specific staff requirements/skills.  Other organised client activities such as bowling,  swimming etc should also be risk assessed to determine suitability for client group and controls required.
  • Pre-purchase assessments.  Both workplaces, including houses leased or purchased, and equipment leased or purchased should be assessed for suitability and any necessary controls required prior to commencing usage.

Incidental hazard ID

  • Hazard report form.  Used by staff and volunteers to make you aware of new hazards not identified in the above assessments due to client change of status, deterioration of the workplace etc. 
  • Incident report form.  Used by staff and volunteers to report any incident.  You may have a number of incident report forms depending on information you need to capture e.g. client behavioural incidents.  However you are required to record all incidents to staff and others whether they result in an injury or not as well as any first aid provided by WHS legislation.  You should also review your incident register on a regular basis to identify any trends which may identify the presence of a hazard.  You are also required to report serious incidents to the Regulator which require admission as an inpatient.  Staff injuries which may result in the need for time off work and/or medical attention must be reported to your workers compensation insurer within two days of the incident. 
  • Incident investigation.  Any incident resulting from work activities should be formally investigated to identify the root causes and suitable corrective actions.  This investigation must be recorded. 

Hazard control procedures

However, there are a number of risk controls which should be standard practices for Disability Service Providers:

  •  First aid. workers must have access to first aid equipment or facilities and trained first aiders but this is dependent on the nature of the work, vicinity of the work, size of the workpalce etc..  Refer to the first aid management guide for further information.  Red Cross has developed a number of useful resources on first aid and a first aid app.
  • Emergency procedures – own premises and external premises.  Emergency procedures may include evacuation, lockdown, medical emergencybomb threat etc and should be documented and displayed where reaonsably practicable. Review this document about developing emergency procedures for your organisation.
  • Behaviour support plans.  Developed for clients with identified challenging behaviours.
  • Care plans.  Developed for all clients and should detail any specific WHS requirements such as manual handling etc.
  • Communication/security procedures.  Based on the risk assessment you should determine the communication and security needs of staff.  At a minimum this would mean access to a phone or two-way radio whether onsite or offsite and working alone.  Staff may also be provided with duress alarms or procedures to follow such as phoning the office before and after appointments or beginning and end of day.
  • Safe work procedures.  Also known as Safe Work Method Statements this is the documentation of procedures to be followed to ensure staff and client safety whilst performing activities or using specific equipment.  It includes a description of the hazards involved in a task, controls to be implemented and a breakdown of the steps required to be followed to safely complete the task.  See sample format and completed safe work method statement. Generic safe work procedures for kitchen and laundry tasks are available. 
  • Staffing/supervision ratios.  Based on the client and activity/venue risk assessment to ensure safety of staff/volunteers and clients.
  • Plant safety.  Requirements for safe installation, usage and maintenance or repair.
  • Maintenance procedures.  The system for repair and maintenance notification and recording.  Includes planned and unplanned maintenance.
  • Contractor Management procedures.  The system which ensures that contractors, whether used consistently or on a one-off basis, do not cause health and safety risks for themselves or others.
  • Purchasing procedures.  The consideration of OHS issues through a consultation process when purchasing new plant or substances or premises.
  • Food safety practices wether preparing meals for clients at home or for community outings or special events.
  • Infection control procedures to reduce the risk of exposure to biohazards such as infected body fluids, dirty linen etc.  A free online training program is available for healthcare workers.
  • Hazardous substances procedures.  The system for ensuring that the least hazardous substance is utilised and that adequate controls are implemented through correct labelling and compliance with the Material Safety Data Sheet on the substance.
  • Smoke free workplace policy.
  • Electrical safety.  Awareness of specific hazards and procedures for regular inspection and tagging of electrical equipment used in hazardous environments.
  • Vehicle safety.  Consideration of safety requirements during purchase and guidelines for safe usage including safety of clients being transported. A sample vehicle safety policy document is available.
  • Workplace traffic management procedures are in place - see guide developed by Safe Work Australia. Checklists for hazard identification and control are also available.
  • Working at heights. WHS Regulations require the work to be undertaken on ground level or a solid construction whenever reasonably practicable.  If not practicable minimising the risk by providing a fall prevention device, a work positioning system or fall arrest system depending on what is reasonably practicable..
  • Risk Register.  The documentation of known hazards which are not fully controlled so that the controls can be regularly reviewed and monitored for suitability.

 Under the Work Health and Safety Legislation risk assessments are only required if the control measures are not already known or if mandated such as for fall risks.

Think about implementing some health and wellbeing strategies to help workers prevent injuries in the first place.  The Australian Government has a range of resources available on their eat for health website.

Training and supervision based on assessment of competence

The WHS Act requires employers to provide adequate information, training, instruction and supervision.  This can generally be met by:

  • Documented and available policies, procedures, care plans etc.
  • Training plans for induction and skills training for tasks in the workplace
  • Mechanism to assess worker’s use of equipment or work practices where risks are identified in the workplace
  • Regular training on WHS areas such as manual handling, hazard identification, staff and management responsibilities, injury reporting, development of safe work method statements. 

 Document Control and Records Management

The WHS Management System should be readily available to all staff.  This may be in the form of a staff handbook or documentation on an intranet.  The date of the procedure or document, version and review date should be recorded.  All completed forms etc should also be recorded.

 Injury Management and Workers Compensation

Commitment to good workers compensation and injury management practices demonstrates to employees that they are valued team members and also helps to meet legislative requirements and reduce costs.

 Monitoring and Review

Part of your WHS Management System should include the regular review of your policies and procedures to ensure that they are functioning as designed.  This can include a quality assurance regular review of all documented policies and procedures in consultation with relevant staff but can also include an WHS audit of your system.  This audit can be conducted by an external WHS auditor but can also be conducted internally by relevant staff.  Attached is a sample audit form based on the Australian Standard 4801 which can be utilised for internal audits.

Attached is also a sample WHS Management system calendar which can be used to check off that the main WHS activities are completed as required.

 WHS Manual

The above issues can be documented in the form of policies and procedures which would form the basis of an WHS Manual which can be accessible to all staff either on an intranet or in a staff handbook.

References:

Model WHS Act

Model WHS Regulat

AS 4801:2000 – OHS Management Systems – Specification with Guidance for Use

WorkCover – Workplace Safety Kit – A Step by Step Guide for Business