Service providers are and remain responsible for meeting their obligations under WHS laws. Principal Contractor requirements Contract category At tender stage Before work begins During contract Contracts valued at $1m or more OR Where the government agency otherwise determines Provide evidence of a WHS Management System that meets the requirements of the NSW Government WHS Management Systems and Auditing Guidelines 5th Edition ( and previous satisfactory WHS management performance. Submit a Project WHS Management Plan. Implement Project WHS Management Plan Submit WHS Management Monthly Reports Report WHS incidents Contracts valued at below $1m Provide evidence of previous satisfactory WHS Management performance. Submit a WHS Management Plan Implement WHS Management Plan Submit WHS Management Monthly Reports Report WHS incidents Government agency requirements Contract category Preparing the tender During tender review Post award of contract - before work begins During contract Design consultancy Include safety relating to the site where the construction work is to be carried out Confirm designer is capable of meeting safe design obligations Not applicable Consult with the designer about safety. Require the designer to provide safe design information. Contract valued at $ 1m or more or lower if determined by the government agency Include safe design report and asbestos register (if refurbishment / demolition) Confirm contractor has Acceptable WHS Management System and has demonstrated Review Project WHS Management Plan Audit the contractor’s implementation of their Project WHS Management Plan.
Documenting a Corporate WHS Management System Documenting the system WHS system documentation will describe WHS policies and procedures covering all the activities of the organisation, including how the documents will be managed, and who will be responsible for keeping and updating them. The WHS Management System documents will generally consist of the following components. WHS policy The WHS policy sets out the contractor’s commitment to work health and safety. The most senior person within the organisation, such as the Chief Executive Officer or Managing Director, should endorse the policy. The WHS policy should include a commitment to: Risk management processes Compliance with relevant WHS legislation, regulations and codes Establishing measurable objectives and targets for continuous improvement WHS training Consultation, communication and cooperation Disseminating WHS and related information Implementing the WHS policy. WHS manual The manual broadly describes how the organisation will comply with each system element, and will refer to the other system documents for descriptions of the processes required. WHS procedures Each system element involves a number of activities, and the way these activities are to be performed will be specified in system procedures. At least one procedure is usually required and written for each system element. Procedures may be written in a text format, or presented as flowcharts or diagrams. They should out for each activity: Proposed risk management processes and how they will be recorded The purpose of the activity What should be done, and by whom When, where and how it is done What materials, plant, equipment and documents are to be used. Work procedures and instructions Technical procedures or work procedures address work-related activities. Examples are plant maintenance procedures, and site safety inspection procedures. These documents are particularly important for training and informing, as they describe the steps to be taken in performing tasks. Written instructions allow WHS requirements for particular tasks (applicable to most projects) to be built into day-to-day operational procedures. Work procedures and instructions should be provided for all tasks with WHS risks to help achieve best practice in WHS management and performance. They must be available and used at the work site in order to help control the work processes and associated risks. Forms and records Various are used to help keep a record of health and safety performance. The checklist in Appendix A also provides guidance in preparing a documented System.
Responsibilities of the parties Government agency Reviewing the plan The government agency will review the contractor’s Project WHS Management Plan to determine whether the 12 key elements detailed in the WHS Management Systems and Auditing Guidelines are clearly addressed. Scheduling audits The government agency will schedule, arrange and participate in Project WHS Management Plan audits with the contractor to be audited. Following up The government agency will follow up to confirm that the contractor has completed all the necessary corrective and preventive actions within the required timeframes. Audit teams The audit team will conduct the audits scheduled by the government agency with the contractor. The audit team must carry out a Project WHS Management Plan audit: With fairness and honesty With full regard to confidentiality and In a timely manner. When carrying out an audit, the audit team must have regard for the fact that contractors have a responsibility to protect the health, safety and welfare of their workers and others and service providers in the supply chain from any WHS risks arising out of the work. A member of the audit team must not participate in a Project WHS Management Plan audit if he or she: Is in debt to the contractor or its service provider Is a partner or other business associate of the contractor or its service providers Is a worker, agent or consultant of the contractor or its service provider Is a relative of one of the contractors or its service providers, or Has any other conflict of interest. (See for a checklist for auditing a Project WHS Management Plan) Qualifications The audit team must collectively have the following qualifications: Successful completion of a Management System auditing course covering: BSBAUD501A Initiate a quality audit BSBAUD502A Prepare a quality BSBAUD503A Lead a quality audit BSBAUD504A Report on a quality audit Demonstrated knowledge of WHS Acts, regulations, Codes and Standards as they apply to the construction industry. Demonstrated knowledge can be either formal WHS qualifications or the accepted equivalent; such criteria must be acceptable to senior management in the accrediting authority Knowledge of the contract, project work site, and site WHS requirements.
Task and responsibilities for auditing This table provides an overview of the tasks and responsibilities of the government agency, Principal Contractor audited and audit team members in relation to auditing Project WHS Management Plans. A Project WHS Management Plan Review and Project WHS Management Plan Audit Checklist are included as Appendix A. . Task Responsibility `Description Review & Planning Review the Project WHS Management Plan to establish whether it satisfies the requirements for the 12 key elements Government agency The Project WHS Management Plan is submitted by the contractor and must be reviewed by the government agency to verify that it addresses all 12 key elements of the WHS Management Systems and Auditing Guidelines. Plan the audit schedule Government agency and contractor Prepare the schedule and consider the order in which the key elements will be audited. For example, the first audit may assess compliance with requirements pertaining to the key elements of Management Responsibility, Risk Management and Incident Management and Corrective Action. The first audit should occur soon after the commencement of site work – generally within the first three months. Engage the team Government agency Engage leader to manage audit, and form audit team Notify the contractor of the audit Government agency Discuss audit schedule with contractor and agree on date for the audit. Task Responsibility `Description & the audit Prepare for the audit. Government agency and audit leader Audit leader and audit team Develop program for and assign responsibilities to audit team members. Discuss scope and objectives of audit. Develop itinerary for audit. on communication to be used throughout the audit process. Review contractor’s Project WHS Management Plan.
Why communication and consultation are important Workforce participation in planning and managing WHS improvements is an effective means of tapping into the knowledge of workers and service providers about their activities and the ways in which WHS management and performance can be improved. Contractors must consult with other contractors and with their own workers to enable them to contribute to decisions that may impact on health and safety at work. When is WHS consultation required? Consultation is required before taking any decision that may affect the health, safety or welfare of workers they are at work, with their workers and affected service providers. This includes: When establishing the site-specific communication and consultation arrangements and when reviewing these arrangements When work-related health and safety hazards are identified, risks are assessed, and the assessment of those risks is reviewed When decisions are made about measures to be taken to eliminate or control those risks When introducing or altering procedures for monitoring those risks (including health surveillance procedures) When decisions are made about the adequacy of provisions for the welfare of workers and others When changes that may affect health, safety or welfare are proposed for the place where people work, to the systems or methods of work, or to the plant/equipment or substances used at work When conducting investigation into incidents, dangerous occurrences or near misses.
Subcontractors / consultants Working with service providers in the supply chain Working with service providers in the supply chain adds another dimension to the risk management process. WHS legislation obliges service providers in the supply chain to manage risks to the health safety and welfare of all persons working at the service provider’s place of work. to some service providers can be higher, and need special attention, because they: Are on a site for a short period of time Are working with various people on various sites Sometimes work in isolation from the main project activities. The benefits of working closely with service providers on work site WHS issues may include: Better management of on-site safety Improved identification of hazards and control of WHS risks Improved development and compliance with WHS Management Plans and Safe Work Method Statements project delays. Selecting service providers Selecting service providers on their ability to comply with WHS requirements is an important aspect of service provider management. To assist this, a panel could be maintained of qualified service providers that have been confirmed as capable of meeting base requirements. Some aspects to look for in selecting service providers include: Past performance and demonstrated capability Quality of past work Safe work practices, including past use of WHS Management Plans and Safe Work Method Statements Ability to comply with WHS requirements Having an acceptable Corporate WHS Management System Compliance with workers’ compensation and other insurance arrangements Records of the various levels of WHS induction and other training Evidence of any WorkCover NSW certificates of competency, licences or permits relevant to the proposed work. Monitoring service providers in the supply chain Contractors must show how they monitor and review the performance of their service providers. This can be achieved through such things as: Performance reporting Monitoring compliance with Safe Work Method Statements, safety procedures and site safety rules Monitoring compliance with WHS, workplace injury management and workers’ compensation requirements Monitoring compliance with induction and training requirements.
The elimination of at the design or planning stage is often easier and cheaper to achieve than making changes later when the risks become real hazards in the workplace. Consideration of WHS issues in the design phases of a construction project is essential to optimising WHS outcomes. Design decisions made at the early stages of a project influence construction processes and the health and safety of personnel on site during and after construction. Contractors' corporate WHS Management Systems and WHS Management Plans should cover and include procedures that address the following. Management of the design process The design process should include consideration of WHS requirements, hazard identification, and the evaluation and control of health and safety risks, in relation to: Use and maintenance, especially arising out of the nature of the design of a facility, including operational risk management The construction method, and, when removal and disposal will be required, the demolition method) The construction work site, such as existing services below ground and geo-technical issues Compliance with WHS legislation, regulations and Codes of Practice The design process should also include the development and provision of design related construction risk and operational risk management information about: The facility to be constructed that may affect health and safety Plant and equipment that may affect health and safety. Design procedures Contractors, their clients and designers should consult about the hazards identified during all stages of the design. This includes hazards identified with construction, use, maintenance and disposal, and determining and describing how they will to be managed. Design procedures should: Define the process for consultation with the Client and designer about: health and safety risks arising from the design during construction work are eliminated or minimised any information they have in relation to hazards and risks at or in the vicinity of the workplace where the construction work is to be carried out Describe how the safe design report, safe design WHS file or similar design information will be obtained from the Client or designer Require a review of the safe design information applying a hazard identification and WHS risk assessment approach Apply the hierarchy of hazard controls to design out or otherwise manage hazards Include the process for consultation with subcontractors, consultants and users about hazards and WHS risk management Describe the communication and consultation process for discussing with workers and service provides of WHS design issues and risk control measures Aim to achieve reasonable and safe constructability; safety with use; longevity of product; reduced, simplified and safe maintenance; and safe disposal Specify how the safe design information will be incorporated into the Project WHS Management Plan
Work instructions Work instructions or Safe Operational Procedures can provide such a framework, enabling the necessary planning to be undertaken and written instructions to be made available on how to perform each task in a safe manner. Workers need to be able to demonstrate they are competent to work in accordance with the work instruction. This means they need to be trained and assessed in accordance with the work instruction and then monitored on an ongoing basis. Details of training and assessment could be recorded in a training register. General site safety procedures General site safety procedures and rules must be in force on every work site. These include rules for protective clothing, safe access and egress, traffic and personnel movement, induction and other training and locating and identifying services, including electricity and gas. The procedures and rules must be documented and appropriately communicated to all people working on the site. The contractor must provide and maintain adequate amenities for the welfare and personal hygiene needs of people on the work site. High risk work requiring a licence Particular risk control measures (such as specialised facilities, proven work methods and specialised training) are required for high risk works. Contractors should consult with their service providers, and together identify and document any high risk work, licence requirements, competency and training needs and implement appropriate measures to control the associate risks.
An important factor for the success of construction projects is accurate and detailed documents such as plans, specifications, Standards and Codes. These include documents dealing with WHS work practices. WHS Management System documents, including procedures, work instructions, checklists, forms and electronic data must be approved for adequacy before use, and be made available at all appropriate locations and to all applicable personnel. A contractor should have and implement procedures and processes to verify that at any point during a project: Documents and data are accurate, easy to understand and up-to-date Documents and data can be easily found when required, and the people who need them get them when they need them Documents and data are periodically reviewed and revised as required by competent personnel Changes are recorded and, unless otherwise required, superseded documents and data are removed from use WHS records It is important to keep records to monitor the effectiveness of WHS management and to verify that people follow the required procedures. Records also provide evidence of compliance with the corporate WHS Management System, with WHS Management Plans and with the various WHS requirements, standards, regulations and laws that apply. Identification, filing, retrieval and retention Procedures should be established and used to: Clearly identify the current version of the document that is applicable to the project Identify, collect, document, retain and protect WHS information and data Allocate responsibility for the retention of records Maintain a register to control the storage and disposal of records Audit compliance and show evidence that required actions have been taken on WHS records and record issues. (This is not necessarily a complete list, and other records and documentation may also be required)
1 Senior Management Commitment Question Does this element of the WHS Management System/Project WHS Management Plan (hereafter System/Plan) clearly describe: No. Page Number or Evidence of Implementation 1. Specific senior management responsibilities and commitment to continual improvement? 2. Specific responsibilities of management and personnel responsible, their qualifications and accountabilities to deal with WHS matters, including the names of staff in the Project WHS Management Plan? Responsibilities, including names and positions, for: a). Allocating adequate resources to deal with WHS matters? b) Ensuring that WHS policies, Management Systems and Plans are communicated to workers? c) Managing compliance with WHS legislation, regulations, standards and d) The injury management and rehabilitation of injured workers and others? e) Ensuring WHS workplace consultation is operating? Findings: 3
2 Communication and Consultation Question Does the System/Plan clearly describe how the contractor plans to: No. Page Number or Evidence of Implementation 1. Facilitate the establishment of WHS Committee or HSR or WHS Representative or other arrangements for WHS consultation agreed by management, workers and service providers. 2. Review site consultation arrangements with workers and service providers. 3. Ensure that all workgroups will be represented by either the WHS Committee or Representative or are involved in the site specific other agreed arrangements 4. the WHS Committee or HSR or WHS Representative, if applicable to the agreed site communication and consultation arrangements 5. Ensure that each member of the WHS Committee, HSR or WHS Representative undertakes WHS consultation training 6. Record, publicise and encourage workers representatives to participate in the work on a regular basis 7. Consult on the job through daily communication between site managers, workers and service providers 8. Provide access to relevant WHS information through notice boards, toolbox meetings, circulars and safety alerts 9. Liaise with their service providers to coordinate WHS consultation and communication on work sites. Findings:
6 Training Question Are procedures clearly described for the following activities: No. Page Number or Evidence of Implementation 1. Identifying the training needs of management, supervisors, workers, subcontractors and visitors? 2. Providing site WHS induction training, task training and refresher training? 3. Providing WHS Committee/WHS or HSR representative with consultative training? 4. Providing specific training necessary to conform with WHS requirements? 5. Providing training in emergency procedures? 6. Keeping appropriate records of WHS training? 7. Making sure all workers working on site have who will be on the project have completed general construction induction training? Findings
11. Internal Review Question Does the System/Plan clearly describe procedures for systematically reviewing (including auditing) WHS activities and Management Plans, including: No. Page Number or Evidence of Implementation 1. Carrying out reviews at regular intervals? 2. Identifying deficiencies in the WHS Management System and Plans? 3. Specifying the responsibilities and competency of those carrying out the review? 4. Documenting reviews? 5. Conducting regular audits of implementation and compliance with the WHS Management System and Plans? 6. Identifying the root cause of any and implementing corrective actions? 7. Implementing follow-up procedures to assess the effectiveness of any corrective action? 8. Communicating the results of reviews to Senior Management and the status of corrective actions. Findings