Risk management strategies
Risk Management has become an integral part of WHS Management. This has been driven by the need to meet legislative requirements and the recognition that risk management is good practice. An effective WHS Management program is an integral part of any successful organisation. It ensures that the health and safety needs of your workers are properly addressed and can provide a range of benefits including:
- Reduced injuries and illnesses,
- Compliance with WHS legislation,
- Reduced workers compensation costs,
- Reduced employee turnover and improved morale,
- Improved operational efficiency,
- Better corporate governance,
- Increased stakeholder confidence
WHS risks within the Disability Sector are common with some other sectors such as aged care, HACC programs and a range of industrial sectors depending on the Disability Enterprise activities. What is unique for the Disability Sector is the potential need for a particular organisation to be able to address WHS obligations across such a range of industry types which often include uncontrolled environments whilst working with service users who may have unforeseen or unpredictable functional restrictions or behaviours. The Disability Sector also has to address the potential mismatch between risk minimisation and the person’s desire to take risks.
Risk can be defined as the chance of something happening that will impact upon objectives. Risk is inherent in life. Everything we do involves risk. Risk may have positive or negative outcomes, resulting in either an opportunity or a loss for a business.
Risk management is the way in which adverse effects from risk are managed and potential opportunities are realised. The potential cascade effect of a failure to address a safety issue may affect the level or type of risk experienced in all areas of the organisation. It is essential that all your risk management processes and systems compliment one another, fit within your organisation’s culture and work in synergy towards the same goals. See attached risk management policy for a basis for your risk management manual.
Good risk management means ensuring that you have a good match between an applicant or worker and the job they will undertake. A Job Dictionary has been developed for the Sector. The Job Dictionary breaks down key generic roles into the physical demands whilst considering key environmental and psychological issues. It can be modified to suit your organisational roles and sent to applicants, doctors undertaking pre-employment medicals and doctors treating workers with work related injuries.
Risk is the likelihood that a hazard will cause harm.
Clause 34 of the Work Health and Safety(WHS) Regulations requires the Person Conducting a Business or Undertaking(PCBU) to identifyreasonably foreseeable hazards that could give rise to risks to health and safetyand eliminate risks so far as is reasonably practicable or if not reasonably practicable minimise those risks as far as is reasonably practicable.
If, as an employer, you have identified a hazard and you do not know how to control it immediately you must assess how dangerous it is. You ask yourself: how likely is it that an injury or illness will occur and how seriously could someone be affected? This is risk assessment.
The level of significance of the risk will determine the priority assigned to activities required to eliminate the risk, or, if that is not practicable, control the risk of harm occurring.
Hazard identification strategies generally fall into two categories – planned and incidental.
Planned hazard ID
- Workplace inspection – internal or external parts of own premises 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. A group home inspection checklist is also available.
- 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.
There are many types of hazards and the methods for identifying them will differ.
Some of the ways it can be done by:
- reviewing all available health and safety information relevant to the hazard (for example, information from the supplier of plant, material safety data sheets, labels, registers of installed asbestos, referring bodies, carers etc for information on client behaviour and abilities/restrictions, previous incident, injury or illness reports);
- identifying factors that contribute to the hazard (for example, layout and condition of working environment; capability, skill, experience and age of people ordinarily doing the work as well as the client receiving assistance; systems of work being used and reasonably foreseeable abnormal conditions);
- identifying actions necessary to eliminate or control the risk; and
- identifying any records necessary to be kept to ensure that risks are eliminated or controlled (including how long they should be kept).
The types of hazard identification and risk assessment methods commonly utilised in the disability sector include:
- Client initial intake assessments
- Client risk profiles
- Client home assessments
- Workplace inspections - internal and external
- Venue assessments
- Activity assessments
- Task analysis or risk assessment for equipment and jobs undertaken in Disability Enterprises
Risk Assessment if undertaken Based on the above information for each hazard identified you should:
- judge the severity of any harm. Consider if it could cause:
- permanent disability, ill health or death;
- long term illness or serious injury;
- require medical attention with someone off work for several days; or
- someone to require first aid.
2.judge the likelihood of the harm occurring:
- very likely - (could happen any time)
- likely - (could happen sometime)
- unlikely - (could happen but very rarely)
- very unlikely - (could happen but probably never will)
The Hazpak Matrix developed by WorkCover is one means of rating the risk so that the lower the number, the higher the risk and the more important it is to implement controls. There are other rating systems in existence and you should choose the one that your employees are most likely to understand.
Eliminate or control the level of risk
It is not enough to identify hazards. Action must be taken to do something to fix (ie eliminate or control) the hazard before it has the chance to cause injury and illness. This is risk control and the following hierarchy helps us to determine the control strategies most suitable based on the risk ranking calculated.
The first priority of the PCBU is to try to eliminate the risk altogether. (Clause 35(a) of the WHS Regulation). If this is not reasonably practicable, the employer must take action to control the risk. (Clause 35(b).
A PCBU must also make sure that all measures taken to eliminate or control risks to health and safety are properly used and maintained. (Clause 37).
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..
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.
The PCBU must also review and revise control measures if they are not effective, before a change which may alter the risk, if a new hazard or risk is identified, consultation identifies the need for a review or a HSR requests a review.(clause 38)
To ensure that the review and monitoring phase are implemented any risks which are not eliminated should be placed in a risk register which can include a review date for specific risks.
The Code of Practice ranks control strategies from the most effective to the least effective strategy – known as the hierarchy of control. The PCBU must consider actions in the order specified to minimise the risk to the lowest possible level.
Lets consider a report of toxic fumes from an oven cleaner
(Remember that the service provider should only be using this list if they have not been able to eliminate the hazard): so you should first consider if you should be cleaning the oven in the first place but if it is not practicable to not clean the oven you need to look at the hierarchy to minimise the risk using one or more of the following:.
- substitute the hazard with a hazard that poses a lower risk of harm eg less hazardous chemical
- isolate the hazard from the person put at risk eg. Self cleaning oven
- minimise the risk by engineering means eg. Use a pump system for handling the chemical or ventilation hood to capture fumes
If there is still a risk after implementing one or more of the above:
- use administrative means to minimise the risk eg. safe work methods, training,
and if a risk still remains
- use personal protective equipment (PPE) eg gloves, mask and overalls.
If one of these measures is not enough to minimise the risk to the lowest possible level a combination is required..
Standardised risk control practices
There are a number of other risk control practices which a Disability Sector employer should have in place and these include:
- Recruitment practices including the conduct of Pre-employment Functional Assessments to ensure the suitability of the applicant to the job;
- Access to counselling services for staff exposed to traumatic events or having difficulty with the demands of the job in conjunction with their personal lives
- Training and development including induction and task specific training
- Competency assessments
- Safe use of chemicals
- Safe use of plant and equipment including the development and training of staff in safe work procedures. Safe work procedures (known as safe work method statements also) are a common administrative control where the hazard cannot be eliminated and the task etc creating the hazard must be undertaken e.g. manual handling of a client, home care activities. Guidelines for writing statements and a sample template and sample completed statement are attached. Generic safe work procedures for kitchen and laundry tasks are available.
- Electrical tagging or inspections and provision of RCDs
- Asbestos registers if appropriate
Many of the above points have information available under the Hazards/risks buttons on this website.
Part 3 of the WHS Act requires the regulator to be notified of serious workplace incidents and for the site of these incidents to be preserved until an inspector arrives or directs otherwise.
A notifiable incidnet includes:
- the death of a person
- a 'serious injury or illness' or
- a 'dangerous incident'.
Serious injury or illness requires immediate treatment as an in-patient in a hospital for any duration inlcuding treatment for amputation of any part of the body, a serious head injury, a serious eye injury, a serious burn, separation of the skin from an underlying tissue e.g. degloving or scalping, loss of bodily function (not including a faint); serious laceration causing muscle, tendon, nerve or blood vessel damage or permanent impairment as well as deep or extensive cuts or tears of wounds to the flesh or tissues. Medical treatment within 48 hours of exposure to a substance e.g. blood borne patogens or micro-organisms and prescribed occupational zoonoses.
Dangerous incidents is an incident that exposes a worker or any other person to a serious risk to a person's health or safety as a result of uncontrolled escape, spillage or leakage of a substance, uncontrolled implosion, esplosion or fie, uncontrolled escape of gas or steam, uncontrolled escape of a pressurised substance, electric shock (not minor), fall or release froma height of any plant, substance or thing, collapse, overturning, failure or malfunction of, or damage to, any plant that is required to be design or item registered under the WHS reulatiosn, collapse or partial collapse of a structure, collapse or failure of an excavation or shoring supporting an excavation, inrus of water, mud or gas in workings, in an underground excavation or tunnel, or interruption of the main systme of ventilation in an underground excavation or tunnel.
Only work related incidents are notifiable e.g. not journey accients, heart attacks or epileptic seizures when not related to work.
An important risk management activity is an accident investigation. Investigations should be undertaken whenever an accident results in physical harm or property damage though the extent of the investigation may vary depending on your organisation and known hazards within your service. Details on the acccident investigation process have been provided.
Emergency procedures and first aid
Some basic management systems can also reduce the risk of workplace injury e.g. emergency procedures and first aid. Where workers are working outdoors either on community participation or grounds maintenance crews a sun protection policy is required.
A Fire Standards Factsheet has been developed to cover key requirements.
For children's services the same risk management principles apply with some specific hazards related to working with children. Known hazards include lifting and moving children and equipment, storing equipment, materials and toys, bending, kneeling and squatting, working in the kitchen, fire emergencies, intruders, excursions, chemicals, infectious diseases, working in the kitchen and bullying, harassment and stress. The attached poster and toolbox talk discuss some solutions to some of these hazards. Organisations need to review their service to identify other hazards and/or possible solutions. You should also review the WorkSafe Victoria document "Children's services - occupational health and safety compliance kit: How to control the risks from the most common hazardous tasks in the children's services sector".
Safe Work Australia Code of Practice - How to Manage Work Health and Safety Risks