How a Simple Process Drives Safety Compliance
Safety management systems have come a long way in the last 250 years. Just think back to workplace conditions during the Industrial Revolution – almost no pay, child labour, very long hours, and extremely dangerous work conditions with exposure to chemicals, accident-prone machinery, and no WHS requirements whatsoever.
But this has changed over the years. Legal reforms and acts were introduced – the Factory Act, the Employer’s Liability Act, and finally, the 1974 Health and Safety at Work Act. This legal document became the foundation for workplace health and safety processes in the UK and the rest of the world. And it led to the increasingly more complex safety processes we have today.
The core purpose of WHS is to keep people safe. Simple. With the increasing complexity of requirements and standards, Business owners, project managers and safety officers alike have to be careful of falling into the trap of using compliance to document requirements like the SWMS as their main measure of WHS compliance. This article looks at why adhering to document requirements is a poor standalone indicator of compliance. We also suggest how a simple safety process drives the success of your WHS compliance.
Documents are Symbols of a Process
Safety isn’t symbolic. It is real and should be treated in the real world, not on a document. Safety management systems do involve documents, but they symbolise a process. For example, a SWMS is a safety planning tool that identifies the risks of high risk construction work and the actions taken to manage those risks. It symbolises the process you are going to take when dealing with the risks and making sure your workplace and its workers are safe from those risks. When it’s under the (judges) hammer, the process symbolised (documented) matters most – not the symbol or the document itself.
Downloading a generic template for your SWMS, JSA, or any other safety document is like taking the symbol without taking the process it represents. And that defeats the whole point of your safety management system and its documents. To comply with WHS requirements, you should be focusing on the processes required to keep your workplace and its workers safe – not just on the documents themselves.
WHS audits look at whether you have followed an effective process that actively reduces the risks in your workplace. They care about if you have actually provided a safe work environment. Not simply whether you have ticked the box of completing a piece of paperwork.
In 2013, The Supreme Court Qld in a case against a QLD construction company for the death of two workers cited:
“work practices focused too much on the work performed onsite and did not pay adequate attention to the dangers presented by the conditions of the site itself”
In other words, not considering risks on the ground, in the real world can have significant impacts when taken to the extremes. Focussing too hard on the details of the tasks to be completed can lead to ignoring all the risks that are actively present
What you focus on matters. And if you want to pass your WHS audit and actually keep your workers safe, then it’s time to focus on the safety management process behind the symbols and documents.
But I still go through a process when filling in a template?
Safety management systems aren’t just about the symbols. They’re about the processes behind them. But you may be wondering – isn’t downloading a generic template still technically a process? Sure. But think about this. What process is more effective at satisfying the Work Health and Safety Act requirement to provide a safe work environment? Is it:
- Find a generic SWMS template on Google, Officeworks or other source
- Complete the boxes provided by the template as best as you can
- Gather up or seek out workers individually and gather signatures
- Store it onsite until the work is done
- Transferring the document to a folder in your office when you are done with the site
Or:
- Identify a the risks onsite, in person
- Build a new SWMS or modify the existing version to cover all task & site-specific risks that are present. Pushed to everyone to sign.
- Monitor how measures are being implemented while work is being completed with real time automated risk rating notifications
- Review by anyone relevant once the work has been completed
- Automatic document storage once complete for any future audits, follow-ups, or learning
From a legal standpoint, the second option is better,
The very purpose of developing a SWMS is to ensure that employers and workers have taken the time to identify the high-risk tasks to be done on site. And then, it is to develop measures to manage these risks and tasks in the context of the work being done. The very nature of a SWMS is that it is specific. It is created specifically in response to a specific site, specific tasks, and specific risks. A generic templated SWMS will not meet the intention behind WHS requirements. Instead, it will defeat the real power of the SWMS and even take away from your safety management.
As WorkSafe Victoria explains, “our concern is not what is written but what actually happens”. A generic SWMS is a symbol of safety that only provides guidance. To focus on the process and comply with WHS requirements, your SWMS and other safety documents need to be customised. It is the second process that is more likely to pass a WHS audit because it demonstrates an active approach to creating a safe work environment. And it is the first process that will get a much more severe punishment when a safety incident does happen, even though both processes are represented by the same type of document.
How to Prioritize the Process
The simplest way to boost the effectiveness of your safety process is to use a digital safety platform like SafeWorkPro. While you can do your safety management physically or digitally, doing it digitally is what will make the difference. Why?
Safety management software simplifies your safety management. Turning a complex process into a simple, easy to understand workflow that allows for an easier way to assess, mitigate, monitor and review workplace risks of all nature. It makes sure that your safety management system is customised, comprehensive, and lets you focus on the process. Leave the document creation, distribution and storage to the software. With safety management software, you can seamlessly customise, prioritise, and ensure your safety management system and its processes exceed WHS regulations.
SafeWorkPro is the Australian safety management software that can make sure your workplace prioritises the process over the symbols.
- Customise your SWMS, JSA, or other safety documents specifically to your worksite using our flexible document builder
- Make sure your specific workplace risks are managed and your workers are safe
- Ensure your company truly complies with WHS requirements
Do all of this seamlessly and in one place with the SafeWorkPro platform. Click the button below to find out more.
More From The SafeWorkPro Blog
Working in Confined Spaces Risk Assessment
Whether you work in an office or under the sun, sometimes everyone feels like they’re working in a tiny, unescapable box. When it comes to high risk construction work however, there is a specific meaning for working in confined spaces. This affects the many different factors a confined spaces risk assessment must take into account when conducting hazard management.
Regulation 5 of Australia’s Work Health and Safety Regulation defines a confined space based on to the hazards associated with it. Under this definition and under the codes of practice outlined by Safe Work Australia, a confined space means an enclosed or partially enclosed space that:
o is not designed or intended primarily to be occupied by a person; and
o is, or is designed or intended to be, at normal atmospheric pressure while any person is in the space; and
o is or is likely to be a risk to health and safety from:
- an atmosphere that does not have a safe oxygen level, or contains contaminants, including airborne gases, vapours and dusts, that may cause injury
- fire or explosion, or harmful contaminants
- engulfment.
- examples may include vats, tanks, pits, pipes, ducts, flues, chimneys, silos, containers, pressure vessels, underground sewers, wet or dry wells, shafts, trenches, tunnels
Many of the generic risks involved with working in confined spaces include:
o loss of consciousness, impairment, injury or death due to the immediate effects of:
- airborne contaminants
- fire or explosion from the ignition of flammable contaminants
- difficulty rescuing and treating an injured or unconscious person
o asphyxiation resulting from oxygen deficiency or immersion in a free-flowing material such as grain, sand, fertiliser, water or other liquids.
An effective and compliant confined space risk assessment example will take notice of these generic but identifiable hazards:
- Restricted entry or exit
- Presence of harmful airborne contaminants
- Unsafe oxygen levels caused when oxygen in the atmosphere is:
- Fire and explosion
- Unstable substances that risk engulfment
- Uncontrolled introduction of substances
- Contact with biological agents
- Exposure to mechanical hazards
- Contact with electrical hazards
- Skin contact with hazardous substances (this will require a hazardous substances risk assessment)
- Noise
- Manual tasks
- Radiation
- Environmental hazards
For more details on these hazards and the related risk control measures, read the SafeWorkPro Blog.
Control Measures for Confined Space Safe Work Procedure
In previous articles on the SafeWorkPro Blog, we’ve looked at the risks and hazards of working in confined spaces. But what good is a risk if there no control measures?
Below is an extensive list taken the codes of practiceby Safe Work Australia, that outline the various control measures available to construction workers and PCBU’s involved in high risk construction work. Before conducting work in a confined space, it is strongly recommended that all duty holders consult this list, and more importantly, the relevant codes of practice. The control measures outlined by Safe Work Australia include:
Entry permit: A PCBU must not allow or direct a worker to enter a confined space to carry out work unless the person has issued a confined space entry permit for the work. A space entry permit must be completed (in writing) by a competent person and specify:
- specify the confined space to which the permit relates record the names of persons permitted to enter the confined space and the period of time that the work will be carried out
- set out risk control measures based on the risk assessment, and contain space for an acknowledgement that work in the confined space has been completed and all persons have left the space.
Isolation: All potentially hazardous services should be isolated prior to any person entering the confined space. These services may include piping, vents, drains, conveyors, service pipes, machinery, plant, electrical equipment or fire protection equipment.
- Physically tag, lock, close or blank hazardous service
- Removal of valve, spool piece or expansion joint in piping that leads to confined space
- Remove energy source to any agitator, fans or other moving parts in a confined space (if energy source cannot be removed consider choking, wedging, chaining or removing any moving parts)
- Reduce any device with stored energy including hydraulic, pneumatic, electrical, chemical, mechanical, thermal or other types of energy, to a condition of zero energy
Atmosphere conditions: a safe atmosphere has a safe oxygen level, is free of airborne contaminants o has concentrations below their allowable exposure standard, has concentrations of flammable gas or vapour below 5% of its LEL. Control methods include:
- Purging: use an inert gas, such as nitrogen, to clear flammable gases or vapours out of the confined space. Following purging, the space should be ventilated with sufficiently fresh air and any removed contaminants should be expelled to a location that presents no further risk. Before conducting work in the confined space, atmospheric testing should be carried out
- Ventilation: may be necessary to establish and maintain a safe atmosphere and temperature for as long as work is conducted in the confined space
- Natural ventilation: only if the confined space has sufficient openings and the source of fresh is not contaminated by any exhaust or other pollutants
- Mechanical ventilation: use local exhaust ventilation (LEV) for localised contaminant generation (eg extraction of welding fumes). LEV should be monitored during operation and have controls clearly identified, tagged and protected
- Dilution ventilation: air must be introduced in way that ensures effective circulation through the confined space with openings, contamination level and area layout put into consideration
Respiratory protective equipment (RPE): if it is not reasonably practicable to ensure a safe oxygen level, remove the confined space of contaminants or when there is an unknown concentration of a hazardous substance is present, then respiratory protective equipment must be worn.
- AS/NZS 1715: Selection, use and maintenance of RPE
Safety monitoring: a standby person must be assigned to the vicinity before a worker enters a confined space to continuously monitor the wellbeing of those inside the space.
- The standby person should be aware and understand the risks inside the confined space and be able to recognise signs and symptoms of distress that workers in confined space may experience (reg 69)
- The standby person should remain outside the confined space and do not other work that impedes their monitoring duties
- A required rescue and safety equipment should be available to standby person
- The standby person should have the authority to order an evacuation and never enter the space to attempt a rescue
What is Job Safety Analysis?
Did you know that panthers and leopards are the same animal? No jokes. Only their fur coats are different, everything else is the same. Believe it or not, job safety analysis forms are similar (minus the claws, teeth, agility and general awesomeness).
Otherwise known as a risk assessment or a job task analysis, job safety analyses (JSA for short) aim to identify hazards and implement measures that will control or at least minimise the risk involved in construction work. Job safety analysis forms come in a variety of types but all share the common traits. The below job safety analysis template comes from the Victorian WorkCover Authority and gives you an idea of correct layout.
As you can see from the above job safety analysis worksheet, there are four parts to a good JSA template.
1: Classify the tasks: along with everyone involved in the high risk construction work, write down each of the steps that make up the job.
2: Hazard and risk identification: besides each step, write down what injuries or health threats are involved.
3: Document the control measures: next to each hazard assessment, specify what control measures will be used to eliminate or reduce the risk of injury or ill health.
4: Distribute responsibility: outline who is responsible for the implementation of each control measure.
One more point that you’ll need to remember. If an incident does occur in the workplace that results in injury or ill health, your job safety analysis could very well be used in court proceedings. This means every duty holder must sign off and review the job safety analysis worksheet should safety conditions change.
So it’s all pretty similar stuff. Panther or leopard? Risk assessment or job safety analysis? Same things, different names.
