Introducing a Harmonised OHS Management System
Guest article by George Robotham (contact details below)
“A health & safety problem can be described by statistics but cannot be understood by statistics. It can only be understood by knowing and feeling the pain, anguish, and depression and shattered hopes of the victim and of wives, husbands, parents, children, grandparents and friends, and the hope, struggle and triumph of recovery and rehabilitation in a world often unsympathetic, ignorant, unfriendly and unsupportive, only those with close experience of life altering personal damage have this understanding”
The introduction of the harmonised safety legislation has become a shambles with many states not introducing it on the previously agreed date. It looks like some states will reach the implementation date without the Regulations and Codes of Practice being published
First of all the harmonised legislation must be put in perspective. It is well recognised that while compliance with legislation is important it is only part of having a robust Safety Management System. Discussion on a major OHS discussion forum indicated you would be lucky to prevent 20% of your accidents if all you did was comply with legislation.
Where do we want to be? –This is an opportunity we will only get once and it will be a lot of grief so we may as well aim high, there may be casualties but no point being half hearted. What have we always wanted to do but never had a good reason to make wholesale change like now . This is an excuse to do some big things. Look at what others are doing
The full impact of the harmonised changes will not become apparent until the Regulations and Codes of Practice are set in stone. As unexciting as it is I would suggest the first step is to put in the discipline to read the Act, Regulations and Codes of Practice, establish the impact on your organisation and summarise this.
1. Review and understand legislation and determine what relates to us, speak with Workcover or equivalent, unions, workers and get their perspective
2. Where are we now – gather all the existing docs, audits, accident stats, what works, what is crap. Do the existing docs meet the new requirements ?
3. Impact analysis – what are the changes that are going to impact most (The various government web sites may contain useful information)
4. Action plan upgrade all company docs based on impact analysis
You cannot assume what the states end up going with will be exactly the same as Worksafe publishes. There will be a need to run education sessions for workers, supervisors and managers. Initial indications are that the increased penalties, changes to due diligence requirements, changes to contractor provisions and enhanced consultation requirements must be communicated. Having seen drafts of the codes of practice it is obvious there is significant change. Safe working procedures will have to be adjusted to accommodate the Codes of Practice.
Some things to think about-
- Have a lot of face to face communications and use e-mail and the internal newsletter
- Brief in particular the board, senior management and those likely to be officers
- Have a harmonisation section on the web site with F.A.Q.’s
- Write to customers outlining your commitment to harmonisation
- Write to suppliers and subcontractors outlining your expectations
- Take legal advice as necessary
- Develop a due diligence checklist
It may be decided to form a project team to oversee the management of the OHS processes, The existing safety committee may or may not be appropriate for the project team. A detailed project plan will be required.
Get down amongst the workers & get the real story according to those who are at the sharp end and make critical operational decisions every day
Open communication channels with managers, team leaders & workers
Build a robust Safety Management System built on the lessons in the paper What Makes a Safety Management System Fly (Published in an international safety best-practice publication)
Meet with business unit managers and their staff as the manager selects. Identify the business units OHS needs.
Carry out a force field analysis with the senior management team and a representative number of the business units, this will give some input to strategic and operational OHS management plans.
Get a feel for safety management system by reviewing recent safety management system audits. If an audit has not been carried out recently carry one out. . Need to establish what is in place, what is working and what is not working. Sometimes it is appropriate to recognise the efforts of the past, thank the people involved but be very upfront that there is the need for considerable change.
Examine past accident experience and consider if there are any immediate quick fixes that can be made. Identifying one or 2 accident types to address and addressing them can quickly give credibility to the safety effort, the chances are manual handling will be one of the accident types.
Use taxonomies of industry Class 1 (Permanently alters the future of the individual, fatal & non-fatal) personal damage to guide your actions rather than enterprise accident experience.
Meet with the government regulator, unions and other stakeholders to get their perspective on implementing required OHS change in the organisation.
One of the best pieces of OHS work I have seen was when one organisation implemented 18 internal standards of OHS excellence.
Standards were Visitor safety, contractor safety, compliance with statute law, use of personal protective equipment, management commitment, hazard identification/risk assessment, safe working procedures, loss prevention &control, employee involvement, emergency procedures, accident investigation, education/communication, inspections, health & fitness, injury management, etc and compliance with these standards must be audited.
One company I was associated with introduced the above standards and it put a massive increase in the focus on safety. What excellence in implementation of the standards would look like was defined and people were trained in this. A detailed set of audit questions, based on the fore-going was developed as was a detailed set of auditing guidelines and roles of auditors defined. Sites to be audited were briefed on the auditing guidelines and auditors were trained on the audit questions and auditing guidelines. A series of annual Executive Safety Audits was introduced at the various sites with an audit team led by a senior manager to give the process significant management horsepower. The largest audit team I was involved in had 10 auditors and audited the site for 4 days. A quality assurance approach where NCR (Non-compliance reports) were issued was used and formal processes were introduced to follow-up on audit recommendations.
I would recommend you consider a similar approach.
Examine the adequacy of current OHS learning and if necessary carryout an OHS learning needs analysis with the view of developing a Corporate OHS Learning Plan. Put a particular focus on reviewing induction learning. A high level learning program for supervisors and managers may be considered necessary.
In association with management and the safety project team develop a strategic OHS management plan. Once this is developed work with the business units on developing operational OHS management plans. Processes must be defined in writing so that they can be used if the process owner is run over by a truck.
Ensure managers / supervisors / informal leaders understand and practice OHS Leadership. Run a series of short workshops on OHS Leadership. Pilot the workshop with the safety team before going live to others.
Introduce the concept of “Safety Champions” and see how it is received. Need a corporate safety champion and one at each major business unit, the more management horsepower these people have the better.
Assess whether there is an adequate return on investment to have The Brief Group conduct a Mock Court for the management team. An alternative is to work with the organisations legal team on a similar approach.
Put the various OHS Management Plans into action and monitor their effectiveness through regular internal audits. Consider the advantages of external accreditation to A.N.Z.S. 4801.
- Senior management must not underestimate the power of their demonstrated commitment, example and expectation of high performance in safety, they have to become forceful advocates for safety.
- Beware of displacement activities, a displacement activity is something we do, something we put a lot of energy into, but when we examine it closely there is no valid reason to do it. OHS has many displacement activities.
- Ensure safety communications are focussed, succinct and targeted at the workplace level of the receiver. Use face to face communications wherever possible. Do not be surprised if your e-mails are misunderstood.
- All training should be short, sharp, interactive and based on need.
- Promotion of off the job and family safety will reap benefits at work.
- In our increasingly litigious society it is sad but true that every aspect of the safety management system must be thoroughly documented in case you end up in court. Saying you have done something can mean very little if you do not have documented proof. A supervisors diary can be admissible in court if details are thoroughly recorded.