There's a lot of advice about WHS policies and procedures out there, but what are the most important things to consider?
Below are 10 tips for a WHS policy review that will help ensure a safe work environment.
1. Lead from the top
Ensure the business has a solid safety policy and that leaders regularly promote it. By improving the company culture, many hazards and WHS risks can be reduced. Aim to convince employees that safety is a top priority and won't be compromised by other factors.
2. Identify hazards that are likely to result in injuries
Hazards are everywhere. Focus on a manageable list of hazards that are likely to result in injuries in the workplace. While improvements in culture may be effective in addressing some of these hazards (e.g. ladders), go through the hierarchy of controls set out in the Work Health and Safety Regulation 2011 to ensure the best control measures are employed.
3. Identify hazards that could cause major injuries
Focus on those hazards that could seriously injure a person. While these hazards may not be likely, the cost to the business will be substantial. These types of hazards may require physical changes to the business (such as guarding). Prioritise these hazards for attention and allocate an annual budget for their mitigation.
4. Conduct a legal audit
Depending upon where a business is in Australia, there will be a variety of WHS obligations. Initially, keep things simple. Identify all the legal WHS obligations that apply to the business and determine whether there is at least one policy, procedure or practice in place that is designed to satisfy that obligation. Where a WHS obligation is identified that is not addressed by the business, make it a priority for action.
5. Conduct a safety audit
Safety audits are often based on Australian Standards, but they can overlook legal obligations under various statutes. Therefore, it's advisable to perform legal audits first. The results can then be shared with the WHS auditor, who can address any legal gaps in their audit program. Conducting safety audits at least once a year helps ensure the business keeps improving.
6. Identify your officers and senior officers
Officers, as defined under the Work Health and Safety Act 2011 (WHS Act), have specific obligations under that Act, and senior officers, as defined, can be charged with industrial manslaughter under the same Act. Having clarity around which employees are officers or senior officers allows for a more precise allocation of safety responsibilities and key performance indicators.
7. Review employment and other contracts from a WHS perspective
Professionals often draft contracts focused on commercial litigation. This can result in commercial arrangements that will not be useful in the event of a WHS incident. Have your contracts reviewed by a specialist WHS lawyer.
8. Appoint a WHSO and consult workers
Work health and safety officers (WHSOs) are appointed by the business. They can be contractually bound to follow the directions of the business (so long as the contract does not conflict with the WHS Act). They are often a more workable solution for identifying where the business can achieve safety gains and prioritising those opportunities against available resources.
Consulting with workers is an obligation under the WHS Act, but more importantly, it creates an opportunity to build a culture of collaborative improvements in safety. Done well, consultation will identify abundant opportunities for improvement and will engage the workforce on a journey to a safer, more cost-effective work environment.
9. Develop incident response plans
While businesses should focus on achieving safety gains, it is always important to acknowledge what can happen when things go wrong. Engage experts to assist in developing incident response plans so that the business is protected against legal, public relations and financial risks. Once the plans are prepared, develop simple procedures so that all employees know what their responsibilities are and how they are expected to behave if an incident occurs.
10. Conduct drills
Hopefully, safety incidents will be rare. While this is the goal, the consequence is that workers may become unfamiliar with their obligations in the event of an incident. For example, if workers are authorised to press an emergency protection or alarm device (such as a button or lanyard), they should be instructed to activate the device to ensure they are confident in their ability to do so if needed.