How to Maintain and Review WHS Risk Controls
If all WHS risks in your workplace have been eliminated or you have used the hierarchy of control measures to minimise all WHS risks so far as reasonably practicable, then you are in a very good work health & safety position. Our article last week, How to Minimise WHS Risks in Your Workplace, covered how to do that.
However, that was last week, and over time, WHS risks controls need to be maintained and reviewed to ensure they are still effective. Two clauses in the WHS Regulation deal with this; clause 37 deals with the maintenance of control measures, and clause 38 deals with the review of control measures.
Maintaining effective risk controls and reviewing risk controls is very dependent on teamwork in your workplace - Managers, Supervisors, Team Leaders, HSRSs, Health & Safety Committee members, workers and others. And of course, the PCBU and its Officers. They all have an important part to play.
As you read further below about the actions that are recommended, you may find it useful to consider which people in your workplace should be responsible or involved in that action. And are they suitably trained to take effective action?
Maintenance of Control Measures
You can find very useful recommendations about how to maintain effective controls on page 23 of the Code of Practice, How to Manage Work Health & Safety Risks. In brief, these recommendations are:
Accountability - managers and supervisors should be provided with the authority and resources to implement control measures and ensure procedures are followed and maintained effectively.
Maintenance checks - check that control measures are suitable, are set up and used correctly, and regularly inspection and testing carried out, and repair or replacement of damaged or worn plant and equipment.
Up-to-date training and competency – Control measures, particularly lower level controls, depend on all workers and supervisors having the appropriate competencies to do the job safely. Training should be provided to maintain competencies and to ensure new workers are capable of working safely.
Up-to-date hazard information – Information about hazards, such as plant and substances, may be updated by manufacturers and suppliers and should be checked to make sure controls are still relevant. New technology may provide more effective solutions than were previously available. Changes to operating conditions or the way activities are carried out may also mean that control measures need to be updated.
Regular review and consultation – Control measures are more effective where there is regular review of work procedures and consultation with your workers and their representatives.”
Review of Control Measures
Page 24 of the Code of Practice How to Manage Work Health & Safety Risks, has useful guidance about how to do a review under the heading of How to Review Controls:
“Consult your workers and their health and safety representatives and consider the following questions:
Are the control measures working effectively in both their design and operation?
Have the control measures introduced new problems?
Have all hazards been identified?
Have new work methods, new equipment or chemicals made the job safer?
Are safety procedures being followed?
Has the instruction and training provided to workers on how to work safely been successful?
Are workers actively involved in identifying hazards and possible control measures?
Are they openly raising health and safety concerns and reporting problems promptly?
Is the frequency and severity of health and safety incidents reducing over time?
new legislation or new information becomes available, does it indicate current controls may no longer be the most effective?”
5th November 2019