The management of OHS in the Commonwealth jurisdiction - Establishing an OHS management system
Introduction
This guide builds on the Safety, Rehabilitation and Compensation (SRC) Commission's OHS Risk Management Model. The model reflects the Commission's view that the most efficient and effective way to create and maintain a healthy and safe work environment is for Commonwealth agencies to integrate OHS risk management into their daily business operations.
The OHS Risk Management Model underpins the basic OHS infrastructure prescribed in the Occupational Health and Safety Act 1991 (the Act). It is suitable for application in both large and small organisations, in all work environments and for the prevention of any type of work related injury and/or disease.
The Model provides six general principles for the integration of OHS risk management into an organisation's daily business operations. These principles are:
- Senior management leadership and commitment;
- Active involvement of each individual in the workplace;
- Effective communication through consultation;
- Provision of appropriate information, education and training;
- Hazard identification, risk assessment and risk control at workplace level; and
- Development and implementation of OHS management information systems.
Most organisations have systems to manage a range of business issues, such as finance, human resources, and information. While financial, human resource and information management are important issues for any organisation, so too is the effective management of occupational health and safety (OHS).
In order to promote OHS in your organisation, it is essential that a formalised OHS system be established and, as much as possible, integrated into your daily business operations. These formalised systems are often referred to as OHS Management Systems.
An OHS Management System is "that part of the overall management system which includes organisational structure, planning activities, responsibilities, practices, procedures, processes and resources for developing, implementing, achieving, reviewing and maintaining the OHS policy, and so managing the OHS risks associated with the business of the organisation."
While setting up an OHS Management System may at first seem daunting, it should not be a difficult process. This booklet leads the reader through the development of a basic OHS Management System.
Purpose of the Guide
This Guide has been developed to help you meet your responsibilities, as an employer, under the Act. The purpose of this Guide is to enable you to establish or maintain effective OHS Management Systems in your workplace, and to provide practical advice on how to integrate OHS Management Systems into every aspect of your organisation's core business.
It should be noted that this Guide is not intended to be a substitute for the legislation.
What is contained in this Guide
This Guide contains information on:
- the Act and associated regulations; and
- managing a safe and healthy workplace.
Why have an OHS management system?
What are the benefits?
An investment in an effective OHSMS should lead to a reduction in workplace illness and injury, minimising the costs associated with workplace accidents and reducing the likelihood of prosecution for breaches of OHS laws. This illustrates the key focus of an OHSMS as being the reduction of workplace injury and disease, and their associated costs.
The second part of the statement mentions OHS law. Commonwealth employers have certain legislative obligations under the Act. These employers have a general duty to protect the health and safety of their employees at work.
Subsection 16(2) of the Act states that the employer must take all reasonably practicable steps to:
- provide and maintain a working environment (including plant and systems of work) that is safe for employees and without risk to their health;
- ensure that workplaces under their control are safe for employees and without risk to their health;
- ensure the health and safety at work of employees in connection with the use, handling, storage or transport of plant or of substances;
- develop, in consultation with any involved unions, a policy relating to health and safety that will:
- enable effective cooperation between the employer and the employees in promoting and developing measures to ensure the employees' health, safety and welfare at work; and
- provide adequate mechanisms for reviewing the effectiveness of the measures; and - provide to the employees, in appropriate languages, the information, instruction, training and supervision necessary to enable them to perform their work in a manner that is safe and without risk to their health.
An effective OHS Management System will assist the employer to achieve the obligations shown above.
The five principles of an OHS management system
OHS management is comprised of five principles that, if followed, will enable the integration of OHS into an organisation's management systems. These five general principles are:
1. Commitment
2. Planning
3. Implementation
4. Measurement and evaluation
5. Review and Improvement
These principles are dealt with in detail below.
1. Commitment
The primary principle of the Safety, Rehabilitation and Compensation Commission's OHS Risk Management Model is "Senior management leadership and commitment." It is critical to obtain the leadership and commitment of senior management in order to successfully implement an OHS Management System.
It is generally senior management that drives the process of integrating OHS Management Systems into an organisation's core business. When actively pursuing improvements in OHS, senior management demonstrate a genuine concern for the welfare of employees,there is a higher likelihood of successful change in the organisation's OHS performance at all levels. This could include staff becoming involved as health and safety representatives or by nominating for health and safety committees. This in turn will lead to greater commitment to health and safety policies and greater awareness of the need to be sure that activities in the workplace reduce the risk of injuries and accidents.
In providing leadership and commitment, senior management must ensure that adequate human and financial resources are allocated to enable implementation and integration of OHS management into the wider management systems.
Senior management must be willing to participate in an initial review of the organisation's current OHS position, as well as being involved in subsequent reviews of OHS. This will provide a clear picture of the organisation's OHS performance over the last few years, including:
- hot-spots, or areas in the organisation that have a higher incidence of injuries;
- injury trends (for example, stress or manual handling);
- organisational hazards and methods of risk assessment / control;
- identification of gaps in current OHS Management Systems; and
- compliance with legislative requirements.
One of the most visible signs of an organisation's commitment to actively manage OHS is expressed in its Health and Safety Management Arrangements (HSMAs). An employer will be compliant with paragraph 16(2)(d) of the Act if it has current HSMAs in place. The HSMAs should express the whole organisation's OHS responsibilities, as well as its commitment to OHS improvement. Additionally, it should be tailored specifically to the organisation and thus be linked directly to corporate objectives and values.
HSMAs must be developed in consultation with employees and/or their employee representatives and the HSMA must include provision for consultation on OHS matters between the employer, employees and/or employee representatives.
An organisation's HSMAs is a committment and intent to manage its OHS responsibilities. In publishing the HSMAs the organisation is sending a clear message that it has a vision and commitment to OHS management that is to be applied throughout the whole organisation.
The HSMAs should contain broad strategies to ensure that such a commitment is met, such as:
- securing the health and safety of employees by providing and maintaining a healthy and safe work environment;
- providing financial and other resources to ensure that necessary OHS programs and activities are established and maintained;
- consulting and cooperating with employees and their employee representatives to achieve a healthy and safe workplace;
- complying with the legislation as a minimum standard and implementing in full, the requirements of the Act and Regulations;
- making all levels of management within the organisation accountable for OHS; and
- providing on-going training to staff, including managers and inducting new staff in basic OHS principles.
If the HSMAs are supported by good OHS management, including regular evaluation and review, and are driven by a strong commitment from senior management, the organisation will be moving towards best practice in the prevention of work-related accidents and illnesses.
2. Planning
The planning stage of an OHS Management System is where an organisation plans to align its OHS objectives and targets with its HSMAs.
One of the first things to do in the planning stage is to assess the results of an initial OHS review. Once assessed, senior management should plan realistic objectives and targets that fulfil the organisation's HSMAs. These targets and objectives should be measurable through the use of performance indicators (for a definition of these terms, see the Glossary).
For example, the organisation may set an objective "to eliminate manual handling injuries in a particular workplace." The target may be "nil injuries in the financial year" while the performance indicator may be "the percentage of manual handling injuries recorded in that financial year in the particular workplace." This concept is relatively simple and can easily be applied across a Group, Division or the organisation as a whole.
During the planning stage, it is important for the organisation's OHS Management System to be mapped out thoroughly. This mapping process should include:
- details of the objectives, targets and performance indicators;
- financial and human resources allocated to assist in achieving these objectives and targets;
- strategies for inclusion of the OHS Management System into mainstream corporate/business plans;
- communication strategies for informing staff of the implementation of, or improvements to, the organisation's OHS Management System;
- particulars of risk management or OHS audit systems currently in place, or to be implemented, in core business activities;
- activities necessary to bring the organisation to full compliance with all relevant legislation; and
- procedures which allow for the regular review of the OHS Management System.
3. Implementation
The effectiveness of an OHS Management System will depend, to a large degree, on how successfully it has been implemented and integrated into the organisation's daily business operations.
As mentioned in the planning stage, it is important for appropriate levels of human and financial resources to be dedicated to the project. It may be necessary to take people off-line for the time it takes to bring the project to a successful completion. In addition, people allocated to the project must understand and support the objectives of the OHS Management System.
Communication and consultation strategies should be put in place so that all staff understand the necessity of implementing an effective OHS Management System. These strategies may include:
- information seminars introduced by the CEO and presented by appropriate members of the senior management team;
- preparation of brochures or booklets detailing the HSMAs;
- inclusion of information in any internal newsletters or information emails circulated to staff;
- placing information on bulletin boards or placing posters or signs in prominent areas of the building; and
- consultative forums that enable staff and unions to have input to the process _ this will help to promote staff ownership, which enables smoother implementation of OHS Management Systems to occur.
During this implementation phase, consideration should be given to how the OHS system is going to be integrated into mainstream business activities and policies. It may be necessary to extend current management systems to include specific mention/actions in relation to OHS. The organisation may:
- prefer to make OHS a leading agenda item at senior management meetings, or staff meetings as the case may be, depending on the organisation's structure or core business;
- make OHS awareness training compulsory for all new inductees, with half-day refresher courses for all staff on a yearly basis;
- provide specific competency-based training for employees involved in hazardous situations on a regular basis (for example, hazardous chemical usage);
- require health and safety committee members to undergo training so that they become familiar with the organisation's hazard identification, risk assessment and risk control procedures;
- engage an OHS Advisor or Workplace Health Officer who is responsible for monitoring the organisation's OHS performance;
- include OHS requirements in any contract for the purchase of goods and services and contracts of employment; and
- prepare a policy and provide appropriate resources for the implementation of an Emergency Control Organisation that contains first aid officers, fire wardens, and security personnel or systems.
This list is not exhaustive- there are many methods of integrating OHS into other management systems in your workplace. You may wish to refer to the Australian/New Zealand Standard AS/NZS 4801:1997, and AS/NZS 4804:1997 for further examples.
When integrating OHS into management systems, care should be taken to develop policies and procedures for the range of work classifications and workplaces in your organisation. For example, your work population may include clerical / management staff, maintenance staff, plant operators, or staff involved with hazardous substances. Make sure workers receive training appropriate to the work they are required to undertake and their responsibilities.
It is worth noting that there are additional resources to which you may have access, and can utilise, when integrating OHS into management systems. Think about internal staff first - you may have staff studying in the field of OHS who would like to be involved in the process. There may be scope for staff interested in project management, or staff at the middle management level, to be involved as well.
There is also a wide range of external help available, such as:
- Comcare's State OHS Managers;
- Comcare's Prevention Unit;
- publications produced by Comcare, such as Identifying Hazards, Managing Risks, which provides specific information on risk management in the Australian Public Service;
- other agencies which have gone through the same process;
- people within your local OHS network;
- consultants, suppliers or professional trainers;
- employer associations, such as your local Chamber of Commerce;
- employee associations; and
- universities or students who may assist you from a research perspective, which is mutually advantageous.
4. Measurement and evaluation
Once an OHS Management System is put in place within an organisation, it is necessary to measure and evaluate performance to enable the organisation to monitor the effectiveness of the system, and where necessary make adjustments to ensure a process of continuous improvement.
During the planning stage, procedures for measurement and evaluation of the system should be developed. These procedures should provide information on:
- persons responsible for the monitoring and evaluation process;
- systems developed for the measurement of OHS performance, for example, an OHS Management Information System, which records the number of incidents and accidents, lost-time injury frequency rates, number of hazard inspections and their results per year, etc (Comcare has also developed a Customer Information System which is available to key agency personnel at no cost - this may be particularly useful for agencies requiring regular reports, and is available via your Comcare National Customer Manager);
- testing methods specific to your agency (for example testing the Emergency Control Organisation via a fire drill, or personal monitoring for employees involved in hazardous operations); and
- audit tools to be used, such as OHS-specific audit tools, internally developed audit methods.
The audit of an OHS Management System will often identify a gap between the effectiveness of the current system and what would be considered a "best practice" system. For this reason, it is necessary to implement a system which will allow corrective action to be taken where required. Corrective action may be necessary to fix a gap in the system as a preventative measure following evaluation. It may also be employed as a reactive measure following an incident in the workplace. It is preferable that any corrective action taken is preventative, and therefore proactive in nature.
Preventative action may result from workplace inspections, discussion with operational staff, through testing of hazardous operations, or other measurement and evaluation exercises. Your organisation has the opportunity at this stage to implement changes in the OHS Management System that may prevent the future injury, illness or even death of a staff member. This is by far the best time to introduce change because "prevention is better than cure."
Much progress in occupational health and safety has come as a result of reactive measures following an incident. Generally, these incidents are investigated in order to find out what happened and what can be done to control any risk of future exposure to the hazard. During any investigation it is vital that corrective action be identified so that the incident does not recur, or if it does, then as a minimum the appropriate measures will have been put in place to minimise any risk to the health or safety of staff involved.
5. Review and improvement
It is important to regularly review an organisation's OHS Management System. With changes in work systems, legislation, technology, organisational structure, chemicals, machinery and plant (to name a few), it is vital that an employer keep abreast of changes within their work environment and ensure that the health and safety of staff is not compromised as a result of these changes.
It is easy to become complacent following the introduction of an OHS Management System. This is the reason ongoing review and improvement is so important - to ensure that OHS performance is continuously improved wherever possible.
Comcare conducts audits of agencies' OHS Management Systems through its Planned Investigation Program. This is primarily a regulatory activity, and while these audits are useful in identifying areas requiring improvement, it is also essential that an agency conduct regular reviews of its OHS management system of its own initiative. This ensures that continuous improvement in the field of OHS occurs.
Review of OHS management systems may be carried out at any stage following integration with your core business activities, and can take many forms. For example:
- a full annual audit of the effectiveness of the system;
- regular monthly reviews following analysis of objectives, targets and performance indicators;
- a review following hazard inspections;
- during audit of a particular group, division or branch (for example, an ANAO or internal audit);
- as a feedback mechanism from staff following training; and
- following an investigation into an incident or accident.
As mentioned earlier, regular reviews of the performance of your OHS management systems and appropriate corrective action will result in a process of continuous improvement. This process should identify:
- reasons why OHS performance may be below the organisation's targets and objectives (possibly through deficiencies in the OHS Management System);
- any instances of non-compliance with legislative requirements;
- opportunities to improve the organisation's OHS performance through adjustment of the OHS Management System;
- changes necessary as a result of the introduction of new technology, plant, equipment, chemicals or work practices; and
- the effectiveness of any changes made.
Other sources of information
While this Guide provides an overview of OHS matters, it should not be considered as the only source of information. Other sources include:
- the Occupational Health and Safety Act 1991
- the Occupational Health and Safety (Safety Arrangements) Regulations 1991
- the Occupational Health and Safety (Safety Standards) Regulations 1994
- approved codes of practice
- agency-specific documents which detail appropriate practices and procedures for the effective management of OHS at the workplace, for example:
- OHS policy and agreement
- OHS hazard policies and procedures (for example, prevention strategies aimed at reducing the incidence of Occupational Overuse Syndrome or Manual Handling Injuries) - publications produced by Comcare which may be relevant to your requirements, for example:
- Identifying Hazards in the workplace (OHS 10)
- Officewise: A guide to health and safety in the office - your organisation's OHS Manager and/or Advisor
- your organisation's HSMA policies and procedures
- email OHS.help@comcare.gov.au
- Comcare's Call Centre 1300 366 979