Work Health and Safety Management Systems and Auditing Guidelines

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1 Work Health and Safety Management Systems and Auditing Guidelines 5th edition, September 2013 (Updated May 2014)

2 Work Health and Safety Management Systems and Auditing Guidelines These Guidelines are a key element of the Procurement Policy Framework of the NSW Government. They are available from the NSW Government Procurement website The document shall be updated on an ongoing basis by the Office of Finance & Services to reflect changes to government policy and procedures. To ensure accurate and up to date information, agencies are advised to access the latest version directly from the website. Further information on these Guidelines should be addressed to: NSW Procurement Client Support Centre: Telephone: nswbuy@finance.nsw.gov.au Issue log Issue 1. Release date Details 2. December November 1998 Revised to apply to projects over $20M Revised to apply to projects over $3M 4. June 2004 Revised to include requirements of OHS Act 2000 and OHS Regulation 2001 Revised to apply to projects over $1M 5. September 2013 December 2013 March 2014 May 2014 Revised to include requirements of the WHS Act 2011, WHS Regulations 2011 and Codes of Practice applicable in NSW Removed reference to requirement for agency accreditation of Work Health and Management Systems Clarification of OHS Auditor requirements (p4). Clarification of certificate requirements (p4). Principal Contractor requirements (p5) updated to remove reference to accreditation address updated Added Evidence of Implementation to Checklist Work Health and Safety Management Systems and Auditing Guidelines May 2014

3 WORK HEALTH AND SAFETY MANAGEMENT SYSTEMS AND AUDITING GUIDELINES SUMMARY... 1 Purpose of the Guidelines...1 Better WHS management performance...1 Other changes...1 Scope...1 Definitions APPLICATION OF THE GUIDELINES... 3 Contract requirements...3 Acceptance and Certification of WHS Management Systems...4 Legal obligations...4 Principal Contractor requirements...5 Government agency requirements WHAT IS A WHS MANAGEMENT SYSTEM?... 7 Corporate WHS Management System...7 Project WHS Management Plan...7 WHS Management Plan...7 Safe Work Method Statements DOCUMENTING A CORPORATE WHS MANAGEMENT SYSTEM... 8 Documenting the system AUDITING PROJECT WHS MANAGEMENT PLANS... 9 Responsibilities of the parties...10 Government agency...10 Audit teams...10 Task and responsibilities for auditing...11 iii

4 6. WHS MANAGEMENT SYSTEM ELEMENTS Senior Management Commitment WHS Communication and Consultation Managing Subcontractors and Consultants Design Risk Management Training Inspection, Testing and Servicing Incident Management and Corrective Action Purchasing, Handling, Storage, Packaging and Delivery Client Reporting and Project Performance Measurement Internal Reviews Documentation and Records WHS MANAGEMENT PLANS Risk Management People with health and safety responsibilities Communication and consultation Managing incidents Site Safety Rules WHS training Safe Work Method Statements...37 APPENDIX A iv

5 1. Summary Purpose of the Guidelines The Guidelines have been developed to enable NSW government agencies which undertake construction and infrastructure projects to work with the construction industry in a manner that: Improves safety outcomes for all construction industry participants; Provides a consistent minimum standard across all NSW government construction projects that construction industry participants must meet; Facilitates a safety management systems approach by construction contractors; Increases productivity and efficiency by improving planning and reducing accidents; Supports NSW government agencies in demonstrating they are meeting their obligations under Work Health and Safety laws. Better WHS management performance The 4th edition of the Guidelines has been revised to ensure the following requirements of the WHS Act 2011 and WHS Regulations 2011 and Codes of Practice applicable in NSW are included: Change of terminology to include the new terms defining Person Conducting a Business or Undertaking (PCBU), worker and officer The principle of ensuring safety so far as is reasonably practicable Due diligence obligations of officers New duties for designers New requirements for the PCBU who commissions construction work to provide information to the designer New requirements for PCBUs who commission construction work to provide complete and up to date asbestos registers for contractors undertaking refurbishment and demolition work Revised requirements for safe work method statements Access to asbestos registers for all workers Other changes Since the 4th Edition there has been increased recognition by construction industry clients and contractors of the pivotal importance of safety leadership in building a sustainable safety culture and improved safety performance in the construction industry. The Guidelines have been revised to reinforce further the importance of safety leadership, including senior management commitment, and the importance of analysing project safety management performance and client reporting. Scope These WHS Management Systems and Auditing Guidelines apply to all NSW government construction projects, and provide the framework for applying a systematic approach to the management of WHS. The NSW Government Construction Agencies have agreed that: Their construction contractors will be required to develop and implement WHS Management Systems and plans consistent with these Guidelines The contract value threshold which the contractors must have an accredited Corporate WHS Management System is $1m These requirements will apply for tenders invited from 1 October 2013 and subsequent contracts Implementation will be managed as part of the business activities of the NSW Government Construction Agencies The effectiveness of the Guidelines will be reviewed and assessed in 2018 Work Health and Safety Management Systems 1 and Auditing Guidelines - May 2014

6 Definitions Client Party inviting and receiving tenders and letting contracts. Consultant Professional party that contracts with a client to provide design, management or other professional services related to construction. Construction All organised activities concerned with demolition, building, landscaping, maintenance, civil engineering work, process engineering, mining and heavy engineering. Construction Consultative Committee The Construction Consultative Committee consists of representatives of key agencies involved in construction procurement and assists the Government in the development of consistent and effective construction procurement practices, and in promoting the application of these practices by agencies. Contractor PCBU that contracts with a client to carry out construction and related services. Government agency NSW government department, authority, corporation or entity established by an Act of the NSW Parliament. The terms government agencies, agency or agencies are used interchangeably in these Guidelines. Notifiable incident An incident involving the death of a person, or serious injury or illness of a person or a dangerous incident, (as defined in the WHS Act 2011) that must be notified to WorkCover NSW Government Construction Agencies Government agencies responsible for construction procurement projects and represented on the Construction Consultative Committee (CCC). Person conducting a business or undertaking (PCBU) May be an individual person or an organisation conducting a business or undertaking (as defined in the WHS Act 2011) and include. Public companies Private companies Partners in a partnership Sole traders and self employed people Government departments and authorities Associations, including not-for profits, if they have one or more workers Local government councils Independent schools Cooperatives Universities. Principal contractor Contractor that contracts with an agency as the client, and is appointed as principal contractor (as defined in WHS Regulation 2011) for nominated work. Project An undertaking with a defined beginning and objective by which completion is defined. A project may be completed using one contract or a number of contracts. Safe design report A report, prepared by the designer of a structure with unusual or atypical design features, which specifies hazards relating to the design, that, so far as the designer is reasonably aware, create a risk during construction work Safe design WHS file One method of recording WHS information for transfer from the designer to the client Service providers Includes principal contractors, contractors, subcontractors, consultants and suppliers. Subcontractor PCBU that contracts with a contractor as the client to carry out construction and related services. Supplier PCBU that contracts with a client to provide a product and/or service.. 2 Work Health and Safety Management Systems and Auditing Guidelines May 2014

7 2. Application of the Guidelines Contract requirements Contracts valued at $1m or more For contracts valued at $1m or more, or lower where the agency otherwise determines, contracts will only be awarded to contractors with an acceptable Corporate WHS Management System. Contracts valued at below $1m For contracts valued at below $1m million, contracts will only be awarded to contractors that are able to prepare and implement an acceptable WHS Management Plan Work Health and Safety Regulation 2011 WHS Management Plan - preparation WHS Regulation 2011 requires a Work Health and Safety Management Plan for all construction projects that involve construction work where the cost of the construction work is $250,000 or more. Work Health and Safety Management Systems 3 and Auditing Guidelines - May 2014

8 Acceptance and Certification of WHS Management Systems The contractor will develop a WHS Management System that meets the requirements of the NSW Government WHS Management Systems and Auditing Guidelines 5th Edition. Corporate WHS Management Systems accredited in accordance with the NSW Government Occupational Health and Safety Management Systems Guidelines Edition 4 will be deemed to be acceptable for three years from the date of accreditation. The contractor will be responsible for engaging an independent OHS Auditor certified by a JAS-ANZ personnel certifier such as RABQSA or equivalent, as a Principal, Lead or Business Improvement OHS Auditor, to provide certification that the contractor's WHS Management System complies with the NSW Government WHS Management Systems and Auditing Guidelines 5th Edition. The OHS Auditor must be independent and not associated with the contractor or any person who developed the Contractor's WHS Management System. An OHS Auditor who is an employee of a registered organisation (under the Fair Work Act or similar) may be engaged to undertake the certification audit. The OHS Auditor will be required to undertake a desk-top audit of the contractor's WHS Management System and, if it complies, to provide certification, on the OHS Auditor's letterhead, that the Contractor's WHS Management System complies with the NSW Government WHS Management Systems and Auditing Guidelines 5th Edition. The certificate should include full details of the contractor and the OHS Auditor including business names, ABN numbers and addresses, and the certificate issue date and expiry date of not longer than 3 years. A copy of the letter of certification, along with a completed and signed copy of the checklist (at Appendix A of these Guidelines) used to verify compliance, should be maintained by the contractor and provided to any NSW government agency, upon request. Accreditation under the Australian Government Building and Construction OHS Accreditation Scheme (Office of the Federal Safety Commission) is deemed to comply with the requirements of the NSW Government WHS Management System Guidelines, Edition 5. Withdrawal of WHS Management System acceptance Failure by a contractor or its service providers to implement properly a Project WHS Management Plan or WHS Management Plan, or repeated safety breaches, may constitute grounds for withdrawal of acceptance of the contractor s WHS Management System. Audits of a contractor s and its service providers implementation of Project WHS Management Plans and WHS Management Plans will be taken into account when an agency determines whether or not the contractor s WHS Management System continues to be acceptable. The contractor and its service provider will be given an opportunity to comment on any such audits and the agency must properly consider these comments before withdrawing acceptance of the contractor s WHS Management System Agencies may (but are not obliged to) withdraw acceptance of a contractor s WHS Management System without further review if it is withdrawn by another NSW Government Construction Agency. Legal obligations These Guidelines, any associated guidelines or any previous guidelines do not in any way relieve service providers of their legal obligations. Service providers are and remain responsible for meeting their obligations under WHS laws. 4 Work Health and Safety Management Systems and Auditing Guidelines May 2014

9 Principal Contractor requirements Contract category At tender stage Before work begins During contract Contracts valued at $1m or more OR Where the government agency otherwise determines Provide evidence of a WHS Management System that meets the requirements of the NSW Government WHS Management Systems and Auditing Guidelines 5th Edition (see sections 3 and 4) and previous satisfactory WHS management performance. Submit a Project WHS Management Plan. Implement Project WHS Management Plan Submit WHS Management Monthly Reports Report WHS incidents Contracts valued at below $1m Provide evidence of previous satisfactory WHS Management performance. Submit a WHS Management Plan Implement WHS Management Plan Submit WHS Management Monthly Reports Report WHS incidents Work Health and Safety Management Systems 5 and Auditing Guidelines - May 2014

10 Government agency requirements Contract category Preparing the tender During tender review Post award of contract - before work begins During contract Design consultancy Include safety risks relating to the site where the construction work is to be carried out Confirm designer is capable of meeting safe design obligations Not applicable Consult with the designer about safety. Require the designer to provide safe design information. Contract valued at $ 1m or more or lower if determined by the government agency Include safe design report and asbestos register (if refurbishment / demolition) Confirm contractor has Acceptable WHS Management System and has demonstrated satisfactory WHS management Review Project WHS Management Plan Audit the contractor s implementation of their Project WHS Management Plan. Review Contractor s WHS Management Monthly Reports. Investigate any reported Notifiable WHS Incident. Report WHS performance using Contractor Performance Reporting system. Contract below $1m Include safe design report and asbestos register (if refurbishment / demolition) Confirm contractor has demonstrated satisfactory WHS management Review WHS Management Plan Review the contractor s implementation of their WHS Management Plan. Review Contractor s WHS Management Monthly Reports. Investigate any reported Notifiable WHS Incident. Report WHS performance using Contractor Performance Reporting system. 6 Work Health and Safety Management Systems and Auditing Guidelines May 2014

11 3. What is a WHS Management System? This section defines the minimum WHS Management System standard required, at both the corporate and project levels. A WHS Management System contains a corporate system, project WHS Management Plan and safe work method statements. Corporate WHS Management System The Plan will address and provide all twelve (12) key elements described in these Guidelines for the project. See Section 6. WHS Management Plan A Corporate WHS Management System will demonstrate a contractor s WHS structure, policies and resources and identify who is accountable for this. It will also demonstrate the integration of WHS requirements with the general management procedures, practices and performance standards of the contractor. It should give clear guidelines for the contractor s consultation and risk management processes, define who has responsibility for WHS, and outline how these policies, practices, standards and procedures will be communicated. The WHS Management System will also demonstrate the methods used to make sure that the contractor and its service providers in the supply chain (with their agents and workers) understand their WHS responsibilities. As a minimum it will address and provide all twelve (12) key elements described in these Guidelines for the contractor See Section 6. Project WHS Management Plan For contracts under $1m the NSW Government Agency may determine that in place of a Project WHS Management Plan covering the twelve (12) elements, a Work Health and Safety Management Plan is required The WHS Management Plan must address the seven (7) element describes in these Guidelines. See Section 7 Both the Project WHS Management Plan and WHS Management Plan will identify and address project-specific WHS hazards for example, peculiarities of access and egress, areas requiring protection of people from site hazards, unusual work practices, and the like. A Project WHS Management Plan is a document setting out the specific WHS resources, consultation and risk management processes, responsibilities, procedures and practices, for a particular project. The Plan describes how the contractor intends to implement its Corporate WHS Management System for the whole of the project, and Safe Work Method Statements. Safe Work Method Statements A Safe Work Method Statement is a document that will identify the controls that will be put in place to control and minimise the health and safety hazards and risks associated with high risk construction work. See section 7. Work Health and Safety Management Systems 7 and Auditing Guidelines - May 2014

12 4. Documenting a Corporate WHS Management System Documenting the system WHS system documentation will describe WHS policies and procedures covering all the activities of the organisation, including how the documents will be managed, and who will be responsible for keeping and updating them. The WHS Management System documents will generally consist of the following components. WHS policy The WHS policy sets out the contractor s commitment to work health and safety. The most senior person within the organisation, such as the Chief Executive Officer or Managing Director, should endorse the policy. The WHS policy should include a commitment to: Risk management processes Compliance with relevant WHS legislation, regulations and codes Establishing measurable objectives and targets for continuous improvement WHS training Consultation, communication and cooperation Disseminating WHS and related information Implementing the WHS policy. WHS manual The manual broadly describes how the organisation will comply with each system element, and will refer to the other system documents for descriptions of the processes required. WHS procedures Each system element involves a number of activities, and the way these activities are to be performed will be specified in system procedures. At least one procedure is usually required and written for each system element. Procedures may be written in a text format, or presented as flowcharts or diagrams. They should spell out for each activity: Proposed risk management processes and how they will be recorded The purpose of the activity What should be done, and by whom When, where and how it is done What materials, plant, equipment and documents are to be used. Work procedures and instructions Technical procedures or work procedures address work-related activities. Examples are plant maintenance procedures, and site safety inspection procedures. These documents are particularly important for training and informing, as they describe the steps to be taken in performing tasks. Written instructions allow WHS requirements for particular tasks (applicable to most projects) to be built into day-to-day operational procedures. Work procedures and instructions should be provided for all tasks with WHS risks to help achieve best practice in WHS management and performance. They must be available and used at the work site in order to help control the work processes and associated risks. Forms and records Various forms are used to help keep a record of health and safety performance. The checklist in Appendix A also provides guidance in preparing a documented System. 8 Work Health and Safety Management Systems and Auditing Guidelines May 2014

13 5. Auditing Project WHS Management Plans General principles There must be a clear understanding between the audit team and the contractor about the scope and terms of the audit. The audit team should have a right of access at all reasonable times to the service providers WHS records, and be entitled to get from the contractor any information and explanations the audit team needs for the audit. If any dangerous or life-threatening situation is observed by the audit team in the course of an audit, the issue must be raised immediately with the contractor s local supervisor to enable corrective action to take place as a matter of urgency. A consistent approach These Guidelines have been developed to facilitate a consistent approach to audits of Project WHS Management Plans by government agencies. They may also be used by contractors with their reviews and audits. Audits should be carried out at least twice in the life of a project or as otherwise determined by a government agency to suit the level of risk in the course of a project. At least one audit should be carried out within three months of the start of site work. The audit results will be included by agencies, with other matters, in the Contractor Performance Reports. The objective of an audit The objective of an audit is to verify formally that the documented procedures in a Project WHS Management Plan are being followed. The audit process should focus on checking whether the contractor s workers are implementing the Project WHS Management Plan. Work Health and Safety Management Systems 9 and Auditing Guidelines - May 2014

14 Responsibilities of the parties Government agency Reviewing the plan The government agency will review the contractor s Project WHS Management Plan to determine whether the 12 key elements detailed in the WHS Management Systems and Auditing Guidelines are clearly addressed. Scheduling audits The government agency will schedule, arrange and participate in Project WHS Management Plan audits with the contractor to be audited. Following up The government agency will follow up to confirm that the contractor has completed all the necessary corrective and preventive actions within the required timeframes. Audit teams The audit team will conduct the audits scheduled by the government agency with the contractor. Is a relative of one of the contractors or its service providers, or Has any other conflict of interest. (See Appendix A for a checklist for auditing a Project WHS Management Plan) Qualifications The audit team must collectively have the following qualifications: 1 Successful completion of a Management System auditing course covering: BSBAUD501A Initiate a quality audit BSBAUD502A Prepare a quality audit BSBAUD503A Lead a quality audit BSBAUD504A Report on a quality audit 2 Demonstrated knowledge of WHS Acts, regulations, Codes and Standards as they apply to the construction industry. Demonstrated knowledge can be either formal WHS qualifications or the accepted equivalent; such criteria must be acceptable to senior management in the accrediting authority 3 Knowledge of the contract, project work site, and site WHS requirements. The audit team must carry out a Project WHS Management Plan audit: With fairness and honesty With full regard to confidentiality and In a timely manner. When carrying out an audit, the audit team must have regard for the fact that contractors have a responsibility to protect the health, safety and welfare of their workers and others and service providers in the supply chain from any WHS risks arising out of the work. A member of the audit team must not participate in a Project WHS Management Plan audit if he or she: Is in debt to the contractor or its service provider Is a partner or other business associate of the contractor or its service providers Is a worker, agent or consultant of the contractor or its service provider 10 Work Health and Safety Management Systems and Auditing Guidelines May 2014

15 Task and responsibilities for auditing This table provides an overview of the tasks and responsibilities of the government agency, Principal Contractor audited and audit team members in relation to auditing Project WHS Management Plans. A Project WHS Management Plan Review and Project WHS Management Plan Audit Checklist are included as Appendix A.. Task Responsibility `Description Review & Planning 1. Review the Project WHS Management Plan to establish whether it satisfies the requirements for the 12 key elements 2. Plan the audit schedule Engage the audit team Notify the contractor of the audit Government agency The Project WHS Management Plan is submitted by the contractor and must be reviewed by the government agency to verify that it addresses all 12 key elements of the WHS Management Systems and Auditing Guidelines. Government agency and contractor Prepare the audit schedule and consider the order in which the key elements will be audited. For example, the first audit may assess compliance with requirements pertaining to the key elements of Management Responsibility, Risk Management and Incident Management and Corrective Action. The first audit should occur soon after the commencement of site work generally within the first three months. Government agency Engage audit leader to manage audit, and form audit team Government agency Discuss audit schedule with contractor and agree on date for the audit. Work Health and Safety Management Systems 11 and Auditing Guidelines - May 2014

16 Task Responsibility `Description Preparation & conducting the audit 3. Prepare for the audit. Government agency and audit leader 4. Conduct the audit Hold entry meeting Follow audit methodology Audit leader and audit team Audit leader, audit team, contractor s representative, government agency Audit leader and audit team Develop program for audit and assign responsibilities to audit team members. Discuss scope and objectives of audit. Develop itinerary for audit. Agree on communication to be used throughout the audit process. Review contractor s Project WHS Management Plan. Review any other relevant documentation, for example, previous audit reports, contractor s actions to address any Corrective Action Requests from previous audits. Meet with government agency and contractor to confirm scope and objectives of audit and approach to be taken. Audit leader allocates responsibilities to team members. Meet with government agency and contractor to enable the audit team to explain the audit process and the approach to be taken. Review and assess the implementation and effectiveness of the Project WHS Management Plan. Visit the specific areas of the contractor s operation covered by the audit scope, and review and evaluate conformance to the Plan (see Appendix A for an Audit Checklist). Document any non-conformances. Request the contractor s representative to confirm the nonconformance by signing a document recording the non-conformance. 12 Work Health and Safety Management Systems and Auditing Guidelines May 2014

17 Task Responsibility `Description Preparation & conducting the audit Hold final audit team meeting Hold exit meeting Audit leader and audit team Audit leader, audit team, government agency, contractor Meet to review audit findings. Identify and discuss areas where the contractor is performing well. Clarify and discuss issues and areas of concern. Discuss any non-conformances. Prepare an audit report containing non-conformances and completion dates for corrective actions. The audit report should be written and provided on the day of the audit and explained to the contractor at the exit meeting. If this is not possible, then the non-conformances must be documented so they can be provided to the contractor at the exit meeting. The audit report should then be submitted within one week of the audit to the government agency, who should then immediately forward it to the contractor. Meet with government agency and contractor to discuss the audit report, corrective actions, and timeframes for completion by the contractor. The non-conformances should be documented and provided to the contractor at the exit meeting. If the audit report is available, the government agency will provide the contractor with a copy. If not the audit report will be provided as soon as possible thereafter. The contractor will be given the chance to comment on the audit, and the comment will be properly considered. Follow up actions 5. Follow up on implementation of corrective and preventive actions Record Government agency and contractor Government agency and contractor Make sure the required corrective action and preventive actions are carried out within the agreed timeframes. Audit reports and comments by the contractor will be managed within each agency for its projects. The results of audits and contractor performance will be included, with other matters, in Contractor Performance Reports. Work Health and Safety Management Systems 13 and Auditing Guidelines - May 2014

18 6. WHS Management System elements Twelve (12) key elements 1. Senior Management commitment, p 16 Equivalent to AS4801;2001 Element 4.2 OHS Policy and Structure and responsibility 2. Communication and Consultation, p 17 AS Consultation, communication & reporting 3. Managing subcontractors and consultants p 19 WHS Regulations 2011 Chapter 6 Construction work 4 Design, p 21 WHS Regulations 2011 Chapter 6 Construction work 5 Risk Management, p 23 AS Planning and hazard identification, hazard/risk assessment & control of hazard/risks 6. Training, p 25 AS Training and competency 7 Inspection, testing and servicing, p 26 AS hazard identification, hazard/risk assessment & control of hazard/risks 8 Incident management and corrective action, p 28 AS Reporting, Incident investigation, corrective and preventive action 9. Purchasing, handling, storage, packaging and delivery, p30 AS hazard identification, hazard/risk assessment & control of hazard/risks 10 Client reporting and project performance measurement. p 32. AS Monitoring and measurement 11. Internal reviews. P 33 AS OHSMS Audit and 4.6 Management review 12. Documentation and records, p 34 AS Documentation, Document and data control, Records & record management 14 Work Health and Safety Management Systems and Auditing Guidelines May 2014

19 1 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. The system starts at the top The requirement is to develop a WHS 'Management System', not merely a site 'safety program. Responsibility for the system starts at the senior management level, with a corporate WHS policy that applies to all projects. Defining responsibilities The first step after establishing the WHS policy is to define responsibilities, authorities and who is accountable for all activities, personnel and positions which can have an effect on WHS, from the initial tender process through to completion of a contract and handover of the project. Senior management must provide appropriate levels of competent supervision and contract management, that are trained, know their responsibilities and have sufficient authority to make sure that WHS requirements are met. Identifying a Senior Management Representative A Senior Management Representative must be identified and made responsible for implementing and maintaining the WHS System/project plans and monitoring compliance. Specific issues for which responsibilities should be defined Senior management must clearly detail the responsibilities and authorities of personnel for each specific task. It is important to make clear who can make decisions on WHS issues, especially regarding the actions required with actual and potential non-compliances, nonconformance or other problems. (See box ) Some specific WHS matters for which responsibilities and authorities need to be defined in both job descriptions and documented procedures: Defining the contractor s WHS policies and objectives Identifying personnel responsible and qualified for WHS processes Identifying internal audit and review requirements Allowing for enough time and sufficient resources to implement the contractor s WHS management system Managing compliance with WHS legislation, regulations, codes and standards Managing compliance with the contractor's WHS management system Managing WHS design issues Acquiring and disseminating WHS and related information Establishing and implementing consultation arrangements with workers, workplace committees and others representatives on WHS matters Planning and conducting WHS training, including induction, task and refresher training Developing and implementing emergency procedures Assessing the contractor's service providers ability to comply and compliance with WHS requirements Compliance with safe working rules Identifying hazards, and assessing and controlling WHS risks Preparing and implementing Safe Work Method Statements Verifying (by inspections and tests) that work areas, work methods, materials, plant and equipment comply with WHS legislation, Regulations, Codes and Standards Stopping, rejecting or quarantining unsafe work methods, work areas, materials, plant and equipment Reporting incidents and illness/injury, and providing and collating incident, illness/injury information and statistics Investigating incidents and illness/injuries, and initiating corrective and preventive actions Developing and implementing injury management programs and co-ordinating the rehabilitation of injured personnel (This is not necessarily a complete list) Work Health and Safety Management Systems 15 and Auditing Guidelines - May 2014

20 2. WHS Communication and Consultation This element is about establishing the process for sharing relevant WHS information with workers and other contractors such 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. Why communication and consultation are important Workforce participation in planning and managing WHS improvements is an effective means of tapping into the knowledge of workers and service providers about their activities and the ways in which WHS management and performance can be improved. Contractors must consult with other contractors and with their own workers to enable them to contribute to decisions that may impact on health and safety at work. When is WHS consultation required? Consultation is required before taking any decision that may affect the health, safety or welfare of workers while they are at work, with their workers and affected service providers. This includes: When establishing the site-specific communication and consultation arrangements and when reviewing these arrangements When work-related health and safety hazards are identified, risks are assessed, and the assessment of those risks is reviewed When decisions are made about measures to be taken to eliminate or control those risks When introducing or altering procedures for monitoring those risks (including health surveillance procedures) When decisions are made about the adequacy of provisions for the welfare of workers and others When changes that may affect health, safety or welfare are proposed for the place where people work, to the systems or methods of work, or to the plant/equipment or substances used at work When conducting investigation into incidents, dangerous occurrences or near misses. How to consult To meet consultation and communication requirements contractors should: Facilitate the establishment of WHS Committee or HS Representative(s) (HSR) or other arrangements for WHS consultation agreed by management and workers Ensure that all workgroups will be represented by either the WHS Committee or Representative Elect the WHS Committee or HSR or WHS Representative, where required Ensure that each member of the WHS Committee or HSR or WHS Representative undertakes HSR/WHS consultation training Record, publicise and encourage workers representatives to participate in the workplace consultative processes on a regular basis Consult on the job on safety issues through regular communication between managers and workers Provide access to relevant WHS information through notice boards, toolbox meetings, circulars and safety alerts Liaise with their service providers to coordinate WHS consultation and communication on work sites 16 Work Health and Safety Management Systems and Auditing Guidelines May 2014

21 Communication and consultation are important to make sure workers and other contractors share information, are provided with information about, and have input into, decisions relating to: Hazards associated with their work and the work site. WHS risks they may be exposed to Measures to eliminate or minimise that exposure The work site arrangements for the management of WHS Work Health and Safety Act Part 5 Consultation, representation and participation Work Health and Safety Regulation 2011 Chapter 2 Representation and Participation Code of Practice - Work Health and Safety Consultation, Co-operation and Co-ordination The procedure for reporting hazards to management. Work Health and Safety Management Systems 17 and Auditing Guidelines - May 2014

22 3. 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 All contractors must show their commitment to the implementation and monitoring of their WHS Management System, including how they intend to select and monitor their service providers and workers compliance. Contractors should demonstrate: A clear chain of responsibility Adequate supervision How they consult with their workers and service providers The formal arrangements for interfacing with their service providers The formal arrangements for interfacing and communicating with labour hire companies How they and their service providers comply with WHS requirements. Communication and consultation is vital when working with service providers. WHS issues to discuss and resolve with subcontractors may include: Site Safety Rules Safe Work Method Statements Changes to work site conditions Introduction of new processes, materials and substances onto the work site WHS training Hazard identification and risk assessments. Principal Contractors The WHS Regulation 2011 provides that a Principal Contractor must be appointed or identified for all construction work: Costing over $250,000, or Of high risk (as defined in WHS Regulation), or Involving demolition or asbestos work for which a licence is required under the WHS Regulation Contractors appointed as the principal contractor by an agency must show how their Corporate WHS Management System procedures address the additional responsibilities of a Principal Contractor, as well as, their normal responsibilities as a contractor, workplace controller and employer. A Principal Contractor also has responsibility for the following: WHS Induction training Principal Contractors must make sure that all persons carrying out the work on site are provided with WHS induction training prior to commencing such work. The Principal Contractor must keep records of such training. See key element 6. Certificates of competency Principal Contractors must make sure that the relevant certificates of competency, licences or permits required to carry out particular work on site are sighted prior to commencement of that work. See key element 5 and key element 6 Consultation Principal Contractors must facilitate consultation between all service providers on site and their workers, as well as between the service providers. See key element 2. Hazardous chemicals register Principal Contractors must keep a register of all hazardous chemicals present at the work site, (including all those used by all service providers on site). See key element 9. Service provider compliance Principal Contractors must monitor on-site service provider compliance with legislation, the project WHS Management Plan and Safe Work Method Statements. Where non-compliance is identified, any affected work must cease until the safety issue is rectified WHS Management Plan Principal Contractor must make the WHS Management Plan readily accessible and ensure all people made aware of the contents prior to commencing work. The Principal Contractor must review, and as necessary revise the project WHS Management Plan. 18 Work Health and Safety Management Systems and Auditing Guidelines May 2014

23 Safe Work Method Statements The Principal Contractor must require Safe Work Method Statements to be prepared for high risk construction work. The Principal Contractor must obtain a copy of the Safe Work Method Statement before the high risk construction work commences. The contractor must ensure the SWMS is reviewed and also revised if circumstances change which require a review of the control measures. Subcontractors / consultants Working with service providers in the supply chain Working with service providers in the supply chain adds another dimension to the risk management process. WHS legislation obliges service providers in the supply chain to manage risks to the health safety and welfare of all persons working at the service provider s place of work. Risks to some service providers can be higher, and need special attention, because they: Are on a site for a short period of time Are working with various people on various sites Sometimes work in isolation from the main project activities. The benefits of working closely with service providers on work site WHS issues may include: Better management of on-site safety Improved identification of hazards and control of WHS risks Improved development and compliance with WHS Management Plans and Safe Work Method Statements Fewer project delays. requirements. Some aspects to look for in selecting service providers include: Past performance and demonstrated capability Quality of past work Safe work practices, including past use of WHS Management Plans and Safe Work Method Statements Ability to comply with WHS requirements Having an acceptable Corporate WHS Management System Compliance with workers compensation and other insurance arrangements Records of the various levels of WHS induction and other training Evidence of any WorkCover NSW certificates of competency, licences or permits relevant to the proposed work. Monitoring service providers in the supply chain Contractors must show how they monitor and review the performance of their service providers. This can be achieved through such things as: Performance reporting Monitoring compliance with Safe Work Method Statements, safety procedures and site safety rules Monitoring compliance with WHS, workplace injury management and workers compensation requirements Monitoring compliance with induction and other training requirements. Selecting service providers Selecting service providers on their ability to comply with WHS requirements is an important aspect of service provider management. To assist this, a panel could be maintained of qualified service providers that have been confirmed as capable of meeting base Work Health and Safety Management Systems 19 and Auditing Guidelines - May 2014

24 4 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. Consideration of WHS issues in the design phases of a construction project is essential to optimising WHS outcomes. Design decisions made at the early stages of a project influence construction processes and the health and safety of personnel on site during and after construction. Contractors' corporate WHS Management Systems and WHS Management Plans should cover and include procedures that address the following. Management of the design process The design process should include consideration of WHS requirements, hazard identification, and the evaluation and control of health and safety risks, in relation to: Use and maintenance, especially risks arising out of the nature of the design of a facility, including operational risk management The construction method, and, when removal and disposal will be required, the demolition method) The construction work site, such as existing services below ground and geo-technical issues Compliance with WHS legislation, regulations and Codes of Practice The design process should also include the development and provision of design related construction risk and operational risk management information about: The facility to be constructed that may affect health and safety Plant and equipment that may affect health and safety. Design procedures Contractors, their clients and designers should consult about the hazards identified during all stages of the design. This includes hazards identified with construction, use, maintenance and disposal, and determining and describing how they will to be managed. Design procedures should: Define the process for consultation with the Client and designer about: health and safety risks arising from the design during construction work are eliminated or minimised any information they have in relation to hazards and risks at or in the vicinity of the workplace where the construction work is to be carried out Describe how the safe design report, safe design WHS file or similar design information will be obtained from the Client or designer Require a review of the safe design information applying a hazard identification and WHS risk assessment approach Apply the hierarchy of hazard controls to design out or otherwise manage hazards Include the process for consultation with subcontractors, consultants and users about hazards and WHS risk management Describe the communication and consultation process for discussing with workers and service provides of WHS design issues and risk control measures Aim to achieve reasonable and safe constructability; safety with use; longevity of product; reduced, simplified and safe maintenance; and safe disposal Specify how the safe design information will be incorporated into the Project WHS Management Plan 20 Work Health and Safety Management Systems and Auditing Guidelines May 2014

25 Designers Designers are required to give adequate information to each person who is provided with the design in order to give effect to it concerning: The purpose for which the structure was designed The results of any calculations, testing, analysis or examination Any conditions necessary to ensure that the risks associated with the structure are minimised when used for a purpose for which it was designed, or, during construction, maintenance and demolition. One way of communicating this information is for the designer to establish a safe deign WHS file for transfer to the client and contractor. A safe design report needs to be prepared for designs of structures that have unusual or atypical features which present hazards and risks during the construction phase that are unique to the particular design. The safety report should include information about: Any hazardous materials or structural features and the designer s assessment of the risk of injury or illness to construction Codes of Practice Construction Work, Demolition Work, and, Safe Design of Structures, Work Health Safety Act 2011 Part 2 Health and safety duties, and, Work Health Work and Health Safety and Management Safety Regulation Systems 2011, 21 and Auditing Part 6.2. Guidelines Duties - of May Designer 2014 of Structure and person who commissions construction work.

26 5 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, contractors 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 Before installing, erecting, commissioning or altering plant or equipment Before changes to work practices are introduced While work is being carried out when new or additional information becomes available, or hazards become apparent Responding to concerns raised by workers, health and safety representatives or others at the workplace New information about workplace risks becomes available Responding to workplace incidents Required by the WHS Regulations for specific hazards. Risk Management process Reviewing the adequacy of the risk assessment and the effectiveness of the control measures Work processes A work process may be a specific activity or a number of activities. It may include measures such as temporary work (for safe access and exit), emergency procedures, plant maintenance, and protective or preventive measures (to make work sites safe). All construction related work processes have some potential to be hazardous to those involved or on the work site. Poorly planned or poorly controlled processes are most likely to cause illness or injury. How to identify a hazardous process Identify illness/injury and incidents that have occurred in the past, and recognised high risk work (See box on Page 24) Consult with personnel and advisers to identify what they consider to be safety issues Inspect the work area for specific hazards Review all applicable information, such as Safety Data Sheets to identify the WHS hazards involved and precautions required Effective procedures should be developed and implemented at the place of work to identify hazards: Prior to works commencing on site Prior to using work site premises for the first time Source: Code of Practice: How to Manage Work health and Safety Risks. Minimum documentation for effective risk management Contractors must document: Methods for identifying WHS hazards, and assessing and controlling WHS risks Practices to minimise the risk of illness/injury and incidents occurring, and ensure compliance with the relevant WHS legislation, regulations, standards and codes Safe Work Method Statements General site safety procedures and rules 22 Work Health and Safety Management Systems and Auditing Guidelines May 2014

27 Emergency procedures Training requirements, including induction, toolbox talks, work activity and refresher training Using Safe Work Method Statements for identifying, assessing and controlling high risk construction work For effective WHS management, frameworks must be established by contractors for identifying high risk construction work and for devising measures to control the specific risks. Work instructions Work instructions or Safe Operational Procedures can provide such a framework, enabling the necessary planning to be undertaken and written instructions to be made available on how to perform each task in a safe manner. Workers need to be able to demonstrate they are competent to work in accordance with the work instruction. This means they need to be trained and assessed in accordance with the work instruction and then monitored on an ongoing basis. Details of training and assessment could be recorded in a training register. General site safety procedures General site safety procedures and rules must be in force on every work site. These include rules for protective clothing, safe access and egress, traffic and personnel movement, induction and other training and locating and identifying services, including electricity and gas. The procedures and rules must be documented and appropriately communicated to all people working on the site. The contractor must provide and maintain adequate amenities for the welfare and personal hygiene needs of people on the work site. High risk work requiring a licence Particular risk control measures (such as specialised facilities, proven work methods and specialised training) are required for high risk works. Contractors should consult with their service providers, and together identify and document any high risk work, licence requirements, competency and training needs and implement appropriate measures to control the associate risks. High risk construction work that Involves a risk of a person falling more than 2 metres Is carried out on a telecommunication tower Involves demolition of an element of a structure that is load-bearing or otherwise related to the physical integrity of the structure Involves, or is likely to involve, the disturbance of asbestos Involves structural alterations or repairs that require temporary support to prevent collapse, is carried out in or near a confined space Is carried out in or near: - a shaft or trench with an excavated depth greater than 1.5 metres - a tunnel Involves the use of explosives Is carried out on or near pressurised gas distribution mains or piping Is carried out on or near chemical, fuel or refrigerant lines Is carried out on or near energised electrical installations or services Is carried out in an area that may have a contaminated or flammable atmosphere Involves tilt-up or precast concrete Is carried out on, in or adjacent to a road, railway, shipping lane or other traffic corridor that is in use by traffic other than pedestrians Is carried out in an area at a workplace in which there is any movement of powered mobile plant Is carried out in an area in which there are artificial extremes of temperature Is carried out in or near water or other liquid that involves a risk of drowning involves diving work High risk work requiring a licence Forklifts Erection of scaffolding > 4 metres Rigging Dogging Cranes including tower cranes, mobile cranes, vehicle loading cranes, bridge and gantry cranes Hoists including personnel and materials hoists, elevated work platforms and concrete placing booms Pressure equipment such as boilers, turbines and steam engines Reach stackers. Work Health and Safety Management Systems 23 and Auditing Guidelines - May 2014

28 6 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. Conditions on construction work sites are often hazardous and change frequently, and the safety of many can be put at risk by incorrectly performing a simple task. Due to the changing nature of construction sites and construction work, training needs should be regularly reviewed and reassessed. Requirements for training Training programs must cover WHS induction, task training, emergency procedures, WHS committee and WHS representative consultation training as well as ongoing training needs. operation, use of hazardous substances, manual handling and First Aid. WHS induction training An appropriate induction program builds understanding and responsible attitudes, as well as knowledge about site safety rules, and WHS issues, hazards, risks and procedures. Induction training must cover WHS matters associated with: General construction work Each specific work activity to be undertaken The specific work site. Site-specific training must explain the site safety rules, relevant Safe Work Method Statements, content of the WHS Management Plan, risk management procedures, emergency procedures, and consultative arrangements at the work site. Programs for general construction work and specific work activity based training must be checked regularly to make sure they are current.. Contractors must: Identify the project-specific WHS training needs of management, supervisors and other workers in accordance with the WHS Management Plans and the WHS risk identification and control measures identified for the project Require that all their workers and service providers undergo induction and necessary task and ongoing training to conform with WHS requirements Maintain records of WHS training provided and keep these records for at least three years after project or contract completion Refresher training To ensure the required knowledge and attitude are maintained, refresher training will be required on longer-duration projects or for particular high-risk activities, such as work underground or in confined spaces, plant 24 Work Health and Safety Management Systems and Auditing Guidelines May 2014

29 7 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 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. The work site activities, work methods, materials, plant and equipment will be subject to planned inspections and test programs to verify compliance and conformity. Inspection and testing will also occur at key stages of the project, including receipt of products, during high-risk activities and on completion of construction. Checklists and records are commonly used to measure compliance and conformity. Inspection and Testing Plans An Inspection and Testing Plan should be developed for each work process/product before that work begins, allowing for the WHS risks involved. It should take into account. The timing and nature of high-risk construction work and/or an activity requiring a high risk work licence The identified work site hazards, and the risks and controls associated with these hazards The likelihood of unforeseen hazards or risks emerging in between inspections Any instructions provided by the designers, manufacturers or suppliers of products Any regulatory requirements, such as registration of plant. An Inspection and Testing Plan will specify: Particulars of the inspection and test program, including hold/witness points, methods and acceptance criteria for WHS with processes and products Personnel to whom the responsibility for an inspection or test and acceptance has been assigned, and their qualifications The type and form of the records to be maintained Where records will be kept, allowing that these will be made available to any party who has a legislated or contractual right of access. Incoming products Inspection and tests usually start with incoming materials, manufactured products, plant and equipment. In some cases inspection and tests are carried out at the supplier s or other premises. The levels of direct inspection and testing required by a contractor will depend on the extent of the quality control exercised by their suppliers and subcontractors, and on the importance of the particular component or work activity. As a minimum, an incoming materials inspection on the work site should check for correct type and quantity, safe packaging, correct labelling, correct documentation, provision of WHS information, and that no transit damage has occurred. Plant and equipment Plant and equipment must be regularly inspected and maintained, in accordance with regulatory requirements and the instructions provided by manufacturers, designers or suppliers. In particular, lifting equipment and fall arrest equipment must be checked regularly. These inspections and tests must be carried out by suitably qualified personnel in accordance with approved procedures and requirements. Inspection and test status A method of identification is required to show that incoming products, construction work generally, plant, equipment, temporary work, protection systems and work environments have passed the required inspections and tests. Work Health and Safety Management Systems 25 and Auditing Guidelines - May 2014

30 A system of tags, colours, stickers, stamps, barriers, special storage areas or records should be used to indicate inspection and test status, to indicate special precautions are to be taken, and to designate unsafe areas/plant. Measuring equipment So that accurate measurements can be made during inspections and tests, measuring and testing equipment should be regularly maintained and calibrated in accordance with the manufacturer s instructions, and maintenance and calibration records kept. Servicing Where ongoing servicing is provided, such as maintenance of plant and equipment or followup repairs, then WHS requirements must be identified and addressed in any service Management Plan and procedures. Such servicing should generally be carried out in accordance with the manufacturer s instructions, paying particular attention to maintenance of safety devices and the use of appropriate lock-out, isolation, danger tags, and permit to work systems. Health surveillance and monitoring The need for, nature and frequency of health surveillance may be specified in legislation, in guidelines, Codes of Practice and/or determined by a risk assessment and monitoring of workers The contractor should identify work activities where personnel exposure monitoring / health surveillance is required and develop procedures for conducting this health surveillance monitoring. Work activities that may require health surveillance/monitoring include: Exposure to hazardous substances, such as asbestos, lead Noise, >85dB (A) over continuous periods Radiation Exposure to hot and cold work environments Records There are regulatory requirements for keeping records of some types of inspections, testing and servicing, for example: Electrical equipment inspection reports Plant inspection and testing records Plant maintenance records Maintenance and calibration records for measuring equipment. Health surveillance and monitoring records WHS Inspection and Test Plans Should define the requirements and criteria for performing health and safety inspections and tests on the project Should define the frequency, content, and competency requirements of personnel conducting the inspection and tests Should define and incorporate statutory inspection requirements in relation to plant and equipment eg lifting gear, temporary structures, mobile and tower cranes, scaffold, gas monitors, fire fighting equipment, first aid kits etc Should identify the records required to demonstrate the performance of the inspection and test Inspection checklists and measures should: Cover all the WHS risks known to be present on the work site Verify that risk controls are working effectively Provide scope for identifying and managing new or previously unforeseen WHS risks. Inspections and tests are particularly required with WHS for: Plant and equipment Incoming products Work site conditions Work methods and monitoring adherence to Safe Work Method Statements Work site access and exits Personal protective equipment Protective measures High risk construction work activity 26 Work Health and Safety Management Systems and Auditing Guidelines May 2014

31 Code of Practice Managing Noise and Preventing Hearing Loss. Code of Practice Managing the risk of hazardous chemicals in the workplace. Code of Practice Managing the work environment and facilities. Work Health and Safety Regulation 2011 Part 4.1 Noise Part 4.8 Diving Work Chapter 7 Hazardous Chemicals Chapter 8 Asbestos Work Health and Safety Management Systems 27 and Auditing Guidelines - May 2014

32 8 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 Managing WHS issues A WHS issue exists when materials, construction methods, plant or equipment, temporary work, protective systems, work practices, work site conditions or other work activities do not meet WHS requirements. WHS issues also include incidents and near misses. It is essential that WHS issues are documented and rectified, with monitoring of trends to identify root causes. Incident management Incident management involves taking action to: Notify WorkCover of notifiable incidents Promptly detect, identify and document any non-compliance Report illness/injury and incidents Eliminate unsafe work practices and unsafe areas Quarantine non-complying materials and other products Advise appropriate parts of the contractor, its service providers and relevant authorities Rectify irregularities, non-conformances and non-compliances Consult with personnel about proposed changes that may affect their health, safety or welfare at work. Corrective action WHS inspections, audits and reviews, incidents, illness/injury, and near misses provide definite pointers to unsafe work practices and processes. Incidents, near misses and illness/injury and their causes should be recorded, investigated and analysed. The results should be used to bring about improvements in policies, standards, procedures, processes and work practices, and progressively lift WHS performance. Procedures should be established and used for recording and implementing corrective actions. These procedures should include consultation with personnel and advisers so that their views on any proposed measures can be taken into account before implementation. Ongoing process Corrective action should not only arise when an inspection, audit or review is carried out or an illness/injury or incident occurs. Work site activities should be regularly assessed for WHS issues and potential risks to health and safety, and action taken to minimise risks by the Contractor, in consultation with affected workers and service providers, to avoid illness/injury and incidents. Contractors must establish procedures for recording the results of these assessments, and the corrective action taken. With the reviewing of past errors and issues, and anticipating possible future errors and issues, contractors and their service providers should continue to improve the level of WHS performance achieved. Workplace injury management Workplace injury management encompasses all measures for facilitating an early and safe return to work of workers who have been injured or become ill. An injury management and return to work program is a requirement of all employers under the Workplace Injury Management and Workers Compensation Act as amended. The return to work program should address: Treatment of injury and illness Rehabilitation and return to work Retraining Claims management Employment management practices Statistical techniques Statistical techniques should be applied to illness/injury, incident, injury, disease and compensation data, both at the work site level 28 Work Health and Safety Management Systems and Auditing Guidelines May 2014

33 and at the planning level with the Contractor. This is with a view to monitoring the trends so that corrective and preventive action can be taken where necessary to improve WHS performance, including injury management. Matters that could lead to WHS issues: Non-compliance with WHS risk management processes Non-compliance with WHS policy, procedures, instructions, standards or specifications Causes of an illness/injury or incident, (This is not a complete list but only a guide) Improving health and safety performa nce Investigate the causes of illness/injuries and incidents, record the results of the investigation Analyse workplace activities for potential hazards to health and safety. Purchasing and hiring Purchasing and hiring activities involve bringing materials, plant, equipment and services onto the construction work site. Substandard materials or poorly maintained leased plant or equipment may cause serious illness/injury. Contractors must define and implement systems to manage safely purchasing and hiring for the work site. For example: All plant, equipment, goods or substances Develop and take correc bought or hired must be assessed eliminate against the root cause required WHS standards (as exist injury for and incidents do n chemicals and other hazardous substances, for most building materials, such as cement and glass, and for plant and equipment) Before new plant, equipment, goods or substances are introduced into the workplace, WHS hazards must be identified and risks controlled, and consultation with Develop the personnel and take involved preventative must occur action: eliminate the hazards to reduce the The likelihood four principles of the of risk hazard of harm control to people. should also be applied to purchasing and hire decisions. See key element 5. Analyse the results of WHS reviews and audits for potential system and operational improvements Supply Communicate system and operational improvements to those working with the Contractors system. must make sure that the products supplied, such as plant, equipment, materials, goods and substances, are safe and without risks to health and safety when properly used. Adequate information must be provided to the people who are supplied with the product. This includes information about: The purpose of the product The testing and inspections required Work Health and Safety Management Systems 29 and Auditing Guidelines - May 2014

34 9 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. Installation, commissioning, operation, maintenance, cleaning, transport, storage and dismantling information Systems of work needed for the safe use of the product The knowledge, training or skill needed to undertake inspection and testing Emergency procedures Contractors that erect or install plant or equipment, or use materials, goods or substances, 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-supplied products Sometimes the client may provide products for use for a project by a service provider (such as materials and equipment to be incorporated into the constructed work, or software, data or services). When this occurs, the service provider needs to know the product is safe to use, and any special safety precautions that are necessary. The same procedures used for receiving products from other suppliers will apply. Product identification and traceability Contractors must keep sufficient records to enable products to be identified and traced if future health and safety issues arise. For example, identifying on drawings where clean fill was used and where it came from would allow tracing later if testing subsequently found the fill to be contaminated. Traceability of components allows safety analyses to be undertaken if subsequent testing reveals a substandard product. Disposal and decommissioning The safe disposal of used or left over goods and substances or the decommissioning of hired plant and equipment should be planned and the required disposal/decommissioning processes identified prior to purchasing or hiring. Materials handling and manual handling are major activities on construction work sites. Contractors should plan and implement procedures to make sure that plant, equipment and materials are handled, stored, packaged and delivered in accordance with legislative and other requirements and good WHS practice. Highest priority given to safety issues WHS risks associated with the use and movement of products need to be identified and managed. This may be achieved by action such as: Conducting hazard identification and risk assessments before products are moved Developing and implementing Safe Work Method Statements or work instructions Minimising the use of hazardous chemicals and dangerous goods Arranging appropriate storage, handling and licensing of dangerous goods and hazardous substances Checking that operators of plant and equipment have the appropriate licences Planning safe entry and exit points for materials storage sites and work sites Using mechanical devices to lift and move products instead of manual handling. Manual handling Particular attention needs to be given to identifying and assessing any manual handling risks prior to the commencement of related work. Hazardous chemicals and dangerous goods Procedures should allow for verification and ensuring that dangerous goods, and chemicals and other hazardous chemicals are labeled, stored, transported and used appropriately, and are accompanied by a Safety Data Sheet (SDS). A register must be kept of all hazardous chemicals brought onto a construction site. High risk work licences Many materials handling activities are hazardous and require licensed operators such as riggers, crane operators and other plant operators. 30 Work Health and Safety Management Systems and Auditing Guidelines May 2014

35 Procedures should be in place and used to check (before the work begins) that the operators of plant and equipment have the appropriate licence certificates and are competent to operate the equipment. Code of Practice Hazardous Manual Tasks Code of Practice - Managing the risk of hazardous chemicals in the workplace Code of Practice Labelling of workplace hazardous chemicals Code of Practice Preparation of Safety Data Sheets for hazardous chemicals Work Health and Safety Management Systems 31 and Auditing Guidelines - May 2014

36 10 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 Performanc e Measureme nt Performance measuremen t 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. The benefits associated with the introduction of a performance measurement system for WHS include: The ability to provide an indication of how an enterprise is performing in relation to WHS issues The ability to identify problem areas where adverse outcomes are occurring and subsequently to identify where preventive action should take place The ability to document effects of attempts to improve WHS. For example, a measurement system could provide feedback as to whether implemented safety interventions are operating adequately The ability to promote WHS reviews of existing work practices and work organisation The use of performance measures for benchmarking or comparative performance assessments Project Performance procedures should: Define the methodology for establishing, monitoring and reviewing WHS objectives and targets for corporate and project level Require objectives and targets to be incorporated into the Project WHS Management Plan Specify how requirements in regards to preparing regular WHS performance reports / records, e.g. monthly Define the process for collating WHS performance reports from all projects and benchmarking performance across the contractor operations Require the review of the Performance Reports by the contractor s senior management and provide feedback to the Project Team Reporting Culture Reporting culture is the willingness for the contractor to report incidents, near misses and errors to the Client. A reporting culture is one in which reporting is actively encouraged by all NSW Government Construction Agencies and contractors, with an emphasis on learning from these reports. These Guidelines enhance the reporting culture. Client Reporting The contractor should establish procedures for the timely reporting to the Client of: WHS Incidents, including, for notifiable incidents, investigation reports and corrective actions; Worksite incidents, including such things as near misses, contact with hidden services WorkCover site visits WorkCover Notices issued and corrective action taken Visits by Unions, Federal Safety Commission and similar organisations to the site Results of internal reviews, site inspections and implementation of inspection and testing plans Results of audits, including nonconformances and the implementation of corrective actions 32 Work Health and Safety Management Systems and Auditing Guidelines May 2014

37 11 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. Procedures must be established and implemented for the systematic review of the WHS Management System and project WHS Management Plans and their implementation, and the responses required to these reviews. Reviews must be capable of identifying deficiencies in the System and project WHS Management Plans and their implementation, and assessing the effectiveness of corrective actions. Reviews should be scheduled to suit the importance of, and risks with, the element or area being reviewed. Results of internal reviews must be brought to the attention of the contractor s personnel responsible for the area reviewed, who must take corrective action immediately Contractor Senior Management must be provided with reports on the outcomes of internal reviews and the status of outstanding corrective actions. The reviews should: Be carried out at regular intervals Examine each of the key System/Plan elements Be capable of identifying deficiencies in the System and project WHS management plans and their implementation Be carried out by persons with the skills, competency and knowledge of the System and plans Be fully documented, recorded, and reviewed by the contractor s senior management Be available for review by external auditors Result in corrective action being undertaken to rectify any deficiency in the System or plans Include follow-up actions to assess the effectiveness of any corrective action Work Health and Safety Management Systems 33 and Auditing Guidelines - May 2014

38 12 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. WHS Management System documents, including procedures, work instructions, checklists, forms and electronic data must be approved for adequacy before use, and be made available at all appropriate locations and to all applicable personnel. A contractor should have and implement procedures and processes to verify that at any point during a project: Documents and data are accurate, easy to understand and up-to-date Documents and data can be easily found when required, and the people who need them get them when they need them Documents and data are periodically reviewed and revised as required by competent personnel Changes are recorded and, unless otherwise required, superseded documents and data are removed from use WHS records It is important to keep records to monitor the effectiveness of WHS management and to verify that people follow the required procedures. Records also provide evidence of compliance with the corporate WHS Management System, with WHS Management Plans and with the various WHS requirements, standards, regulations and laws that apply. Allocate responsibility for the retention of records Required records and documentation include: Project WHS Management Plan or WHS Management Plan Safe Work Method Statements Safe work procedures Training records First aid treatment records Emergency procedures Hazard identification and risk assessments Incident and illness/injury reports Plant and equipment records Work permits Safety Data Sheets Hazardous chemicals records Inspection, testing and servicing records Details of qualifications held by individuals Internal review reports Minutes of workplace WHS meetings and Toolbox Talks Safety equipment records WHS design review records Audit reports Injury and workers compensation management records Maintain a register to control the storage and disposal of records Audit compliance and show evidence that required actions have been taken on WHS records and record issues. (This is not necessarily a complete list, and other records and documentation may also be required) Identification, filing, retrieval and retention Procedures should be established and used to: Clearly identify the current version of the document that is applicable to the project Identify, collect, document, retain and protect WHS information and data 34 Work Health and Safety Management Systems and Auditing Guidelines May 2014

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