OHS Management Systems

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.  The ideal way to implement the OHS 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.

Management Commitment and Active Involvement

Commitment should be demonstrated through the publication of an Occupational Health and Safety (OHS) 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 OHS Plan for the year, inclusion of OHS responsibilities in job descriptions and key performance indicators for all staff and the inclusion of OHS as a regular agenda item at staff meetings. 

The Management Board should regularly review the performance of the OHS 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 OHS Management system as well as a checklist and action plan to ensure good governance of the OHS 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:

• WHS 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 OHS 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 employees 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 must be recorded in a Consultation Statement and reviewed on a regular basis (e.g. every 2 years).

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. 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 OHS legislation.  You are also required to report incidents to staff which are significant to WorkCover ie. Life threatening and report incidents to others – including volunteers, contractors and clients resulting from work activities (does not include client health related incidents) which result in the person being unable to perform their normal activities for seven days or more.  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.  First aid kits are required at every workplace and a workplace is defined as any location where an employee is working.  First aid training is required where there are more than 25 people at a workplace or where warranted by a First aid risk assessment and documented in a first aid plan.  Refer to the first aid management guide for further information.
• Emergency procedures – own premises and external premises.  Emergency procedures may include evacuation, lockdown, medical emergencybomb threat etc and should be documented.
• Behaviour support plans.  Developed for clients with identified challenging behaviours.
• Care plans.  Developed for all clients and should detail any specific OHS 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.
• 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.
• 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.
• Working at heights.  Legislative requirements for use of fall restraint devices when working over 2 metres above ground level as well as general guidelines for any staff member working above floor level including safe use of ladders etc.
• 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.

Training and supervision based on assessment of competence

The OHS 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 OHS 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 OHS 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 OHS 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 OHS audit of your system.  This audit can be conducted by an external OHS 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 OHS Management system calendar which can be used to check off that the main OHS activities are completed as required.

OHS Manual

The above issues can be documented in the form of policies and procedures which would form the basis of an OHS 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