Procedure: Work health and safety hazard management

Purpose

This procedure describes how the Australian National University (ANU) manages Work Health Safety hazards for the health, safety, rehabilitation and claims (WHS) management systems. WHS hazard management is a requirement of the Work Health and Safety Act 2011 (Cth) (WHS Act), Work Health and Safety Regulations 2011 (Cth) (WHS Regulations) and the Safety Rehabilitation and Compensation Act 1988 (Cth) (SRC). This document is linked to the University’s Work Health and Safety policy and is one of the WHS Management System procedures.

Definitions

Consequence is the outcome of an event affecting the objectives.

Duty of care is the requirement of the person conducting a business or undertaking (PCBU), so far as reasonably practicable, to ensure that the health and safety of any person at the PCBU is not put at risk. This includes the provision of: safe systems of work; safe amenities, facilities, structures and work environments; training; supervision and health monitoring [WHS Act, section 19].

Dynamic Hazards are hazards that are short and immediate and less than 6 months existence in a workplace.

Hazards are sources or situations or thing with a potential for harm a person. Hazards at work may include: noisy machinery, a moving forklift, chemicals, electricity, working at heights, a repetitive job, bullying and violence at the workplace. [Work Health and Safety (How to Manage Work Health and Safety Risks) Code of Practice 2015 Section 1.2].

Likelihood is the chance of something happening.

Local area is the relevant College/Research School/Service Division.

Risk in relation to any potential injury or harm, is the likelihood and consequence of injury or harm occurring [AS/NZS 4801:2001].

Static Hazards are hazards that are longer than 6 months existence in a workplace.

Workers is anyone who carries out work for the University and include staff, Visiting and Honorary Appointments (VaHA), volunteers, titleholders, affiliates, labour hiring workers, students gaining work experience and contractors of ANU. HDR students may be ANU workers depending on their role but they are covered under the scope of this chapter.

The Work Health and Safety Management System (WHSMS) Handbook provides practical guidance for University and its local areas on how to implement the University WHS Management System and defines the responsibilities and actions required by management and workers within the management system.

Procedure

Scope

1. This procedure applies to all activities conducted by or on behalf of the University with the potential to impact on work health and safety.
2. This procedure provides instruction for managing WHS hazards to meet the requirements of the WHS Act. The key steps in this procedure for complying with WHS hazard management are how to

• identify WHS hazards;
• report WHS hazards;
• assess WHS hazards;
• control WHS hazards;
• monitor WHS hazard controls; and
• review the effectiveness of WHS controls.

Process

3. All WHS hazards are recorded, reported and managed at the University to comply with the Duty of Care requirements in the WHS Act.
4. The WHS hazard identification and assessment process (WHS hazard and risk assessment) at the University occurs as a structured planned process or ad-hoc from channels such as observation, review of work processes or as a result of an incident/event.
5. Typical examples of when the WHS hazard and risk assessment occur at the University are when, for example:

• conducting existing activities, tasks, processes or operating existing plant/equipment that you know there are no risk assessments;
• starting new activities;
• any time there is a change to the work practice, procedures or work environment;
• purchasing new or used equipment or using new substances;
• planning to improve productivity or reduce costs;
• working in a new location that the hazards and risks are significantly different from the normal workplace;
• new information about workplace hazards becomes available such as changes at the workplace occur that may impact on the effectiveness of control measures;
• responding to workplace incidents (injuries or near misses) or responding to concerns raised by workers, health and safety representatives or others at the workplace; and
• designing and planning products, processes or places used for work.

Planning for a WHS hazard assessment process

6. Structured WHS hazard and risk assessments (HRA) are conducted by people with competency in conducting hazard and risk assessments.
7. When planning to conduct a WHS hazard assessment, the assessors have a cross section of skills and experience, where needed and where possible, including those who work in the area or on the activity and, if required, subject matter experts.
8. To improve the productivity of the group contributing to the WHS hazard and risk assessment process, the assessors consider and discuss the key contextual information when possible, such as:

• the scope of the assessment (e.g. boundaries of work practice or areas of work) and the work process;
• the stakeholders and workers who are affected by this assessment;
• any legal or other requirements in accordance with WHS Legal and Other Requirements Matrix;
• visit the area/ activity and observe how things are done;
• any previously identified matters from inspections, audits, historical injuries, incidents and relevant hazard reports;
• technical information such as manuals or supplier information; and
• relevant policies, processes, standards, registers and guidelines.

Identifying WHS hazards

9. This is the most important step in the WHS hazard and risk assessment process. The assessors ensure all hazards associated with the activity/task/process/plant/equipment/location being assessed are identified in the hazard and risk assessment. Common hazards are listed in WHS Hazard and Risk Assessment Template to assist the hazard identification process. A variety of techniques and business improvement tools is used to aid this such as brainstorming the steps involved or key activities.

Recording WHS hazards

10. WHS hazards that are observed and under local control are addressed immediately. If immediate action is not taken or has happened more than once, record in Figtree.
11. WHS hazards that are not under local control are entered online via Figtree.
12. WHS hazards that are related to local activities/tasks/processes/plant/equipment or locations under local control have documented hazard and risk assessment, either static or dynamic, against them.
13. Every local area ensures all WHS hazards are captured on a WHS hazard register. The local area chooses to populate either one master WHS register or separate registers for different types of WHS hazards such as plant and equipment, remote area works etc.
14. The local areas provide WEG with all WHS hazard registers to consolidate into a master register for the entire University WHS hazard register.

Assessing inherent WHS hazard level

15. The assessors score the inherent WHS hazards using the WHS hazard “Likelihood”, “Consequences” and “WHS hazard rating matrix” Tables 1, 2 and 3 below:

Table 1 Likelihood

Table 2 Consequences

Table 3 WHS Risk Matrix table– Please find here.

Identifying current controls and legal requirements

16. The assessors identify applicable controls (both current and planned) and the legal requirements (if known) for each of the WHS hazards, aiming to eliminate or where not possible, reduce the risk of the hazard so far as reasonably practicable.
17. The controls identified are in accordance with Hierarchy of Controls listed in Table 4

Table 4 Hierarchy of controls

Assessing residual hazard level

18. The assessors score the residual hazard rating taking into consideration the controls listed from the above using Tables 2 and 3.
19. If the residual risk is high or extreme (i.e. score is 13 or above), the assessors (author) identify additional controls to reduce the residual risk to medium or low. This may involve seeking professional advice from Local WHS Officers, or Work Environment Group, or expert advice from Subject Matter Experts.

For residual risk high or extreme activities that cannot be reduced further after seeking professional or expert advice, seek approval (i.e., approval from Dean or COO, refer to Table 5) prior starting any work.

The completed WHS hazard and risk assessment is approved based on the highest level of residual risk of hazards as per Table 5. No work occurs until this approval is gained.

Table 5 Risk assessment Approval Authority table – Please find here.

20. Hazard and risk assessment template is accessed via WHSMS Handbook Chapter 3.1 Hazard Management Appendix B.

Prioritisation of Controls

21. One purpose of the hazard assessment process is to determine priorities in hazard management control. To effectively control hazards the Directors, Deans, Supervisors and/or Managers allocate and prioritise resources in accordance with the level of hazard rating.
22. If a WHS hazard is assessed to have a residual hazard rating of 13 or above, using Table 3 WHS hazard rating table, then these hazards take precedence for remedial action and are undertaken as reasonably practicable.

Consultation and communication of WHS hazards

23. WHS hazard and risk assessments are consulted with all workers affected by the assessment or their representatives so far as reasonably practicable.

25. WHS hazards and risk assessments are communicated to relevant workers and HDR students during their Tier 3 WHS induction or via any other channels, ensuring they understand the hazards and risks associated with their activities and:

• implement controls as identified; or
• review with their supervisor on the current risk assessment to generate their own risk assessments; or
• conduct a new risk assessment.

WHS Hazard Register and Static Risk Assessment Register

26. School Directors, Division Directors, College Deans and General Managers ensure there is a WHS Hazard Register covering all hazards, risks and controls as per hazard categories for areas under their control.
27. School Directors, Division Directors, College Deans and General Managers ensure all risk assessments for static activities are recorded on the area’s Static Risk Assessment Register. Risk assessments for dynamic activities do not need to appear on the Static Risk Assessment Register.

Change process in the WHS context

28. During the time of change, the area to focus on include the following as applicable:

• consultation;
• prevention;
• early intervention;
• rehabilitation and return to work; and
• management and leadership involvement.

29. When changes are proposed or identified for work practices that have an impact on the safety and wellbeing of workers, the existing WHS Hazard and Risk Assessment is reviewed and updated, or a new WHS hazard and risk assessment is conducted. Potential changes include:

• introducing new or different equipment;
• using new/alternate substances;
• planning to improve productivity or reduce costs;
• designing and planning products, processes or places used for work;
• updating drawings;
• moving into new, renovated or refurbished workplaces; or
• organisational changes.

30. Both physical and psychosocial risks are identified and managed and the outcome of the risk assessments are communicated and consulted in accordance with the requirement of this procedure.
31. Pre-occupancy inspections are conducted should relocation occur into a new/renovated/refurbished workplace.
32. During the time of change, consultation needs to occur with workers who are impacted by the change and their Health and Safety Representatives, if elected. Managers and supervisors are responsible for communicating and discussing the impact of the changes with workers individually depending on the nature of the change.
33. During organisational changes, the HR Director ensured formal arrangements are in place to ensure ongoing feedback and consultation with workers.
34. Early intervention, Rehabilitation and Return to Work assistance is provided during change in accordance with the University’s Rehabilitation and Claims management system.
35. Leadership and management involvement during organisation change is in accordance with policy: Staff Consultation and Organisational Change, procedure: Managing change and procedure: Organisational arrangements change.
36. This section of the procedure is further explained in and supplemented by WHSMS Handbook Chapter 3.18 Change Process in WHS Context.

Monitoring and review

37. Monitoring and review of WHS hazard and risk assessments occurs at the local area level and the University wide level as described below.

University wide monitoring and reviewing of WHS hazards

38. WEG monitors and presents a report to the Senior Management Group on the effectiveness of the WHS hazard process at the site wide level of the University. This involves:

• maintaining an overall register of all the WHS hazards at the University;
• reviewing for opportunities from a University perspective to reduce the overall risk/hazard profile at the University via High or Extreme risk activities reported via the Quarterly Due Diligence Report and Annual Risk Profile Reviews;
• quarterly reporting to the WHS University Committee on the implementation of the WHS management system using the traffic light status report;
• reviewing hazards and effectiveness of associated controls as a result of incident investigations or audits; and
• reporting to management on the unacceptable levels of risks/hazard at the University.

Local area monitoring and review of WHS hazards

39. Supervisors and managers are responsible for reviewing risk assessments in accordance with their residual risk level.

Table 6 Risk Assessment Review Timeframe

40. Directors, General Managers and Deans:

• Monitor the Static Risk Assessment quarterly for overdue reviews; and
• Monitor and review annually WHS Hazard Register and Static Risk Assessment Register during the Annual Risk Profile Review Process to ensure all residual risk high and extreme activities or hazard profiles are reduced to Medium are lower.

41. Directors and General Managers report to the University and the relevant local WHS Committee on the hazards and risks through the Quarterly Due Diligence Report and the Annual Risk Profile Review process.
42. Directors and General Managers report the implementation of the WHS management system via Handbook guidance via traffic light status report quarterly to local and University WHS committees.

Safe work procedures

43. The use of Safe Work Procedure (SWP) as a control is a risk assessment decision, except where described below. WHSMS Handbook Chapter 3.1 Appendix F provides a flow chart to assist local areas to make decision on whether to use Safe Work Procedure as a control.
44. SWP is used for providing work instructions and/or as assessment criteria for Tier 3 Work Safely Proficiency Training.
45. For all activities requiring Tier 3 Work Safely Proficiency Training, safe work procedures are created and maintained as per the WHS documentation procedure.
46. Safe work procedures are reviewed in the same time frame in accordance with the residual risk of the corresponding risk assessments.

Training and competency

47. WHS hazard and risk assessment team complete a risk management course provided by WEG.

Please note

The Hazard Management sections of this procedure are further explained in and supplemented by WHSMS Handbook Chapter 3.1 Hazard Management.

The Hazard Management of boating and diving activities are described and fully explained in WHSMS Handbook Chapter 3.21 Boating and Diving Safety Management.

The Change Process in the WHS Context section of this procedure is further explained in and supplemented by WHSMS Handbook Chapter 3.18 Change Process in WHS Context.

The Pre-occupancy inspection part of the Change Process in WHS Context section of this procedure is further explained in and supplemented by WHSMS Chapter 4.1 Workplace Inspections Section 4.1.3 Pre-Occupancy Inspections.

Sources

Refer to ANU WHS Legal and Other Requirements Matrix.