The Work Health and Safety Act 2011 requires that the principal contractor for a construction project prepare a written work health and safety (WHS) management plan for the workplace before work on the project commences.
In essence, a WHS management plan should outline the principal contractor's WHS policies, training, risk management process, subcontractors management, injury management and continuous monitoring and review.
The principal contractor must ensure that everyone working on the project is made aware of the WHS management plan's content and their right to inspect the plan, before they commence work on the project.
The principal contractor must also review the WHS management plan to ensure it is kept up to date and that all relevant people are informed of any amendments.
Where the cost of the construction work is $250,000 or more, a principal contractor for a construction project must prepare a written work health and safety management plan for the workplace. The work health and safety management plan must be prepared before work on the construction project starts. The measures for eliminating risks or minimising workplace hazards as far as is reasonably practicable should be included in the work health and safety management plan.
Preparation of the plan should include at least:
- an assessment of climatic/environmental conditions including lighting levels;
- access to and from the workplace;
- specific instructions for workers;
- formwork drawings certified by the formwork/falsework engineer;
- plant and tackle required for lifting materials;
- residual current devices (safety switches) protecting the user of portable electric power tools;
- emergency and rescue procedures in the event of an accident, injury or other emergency (including the means of rescuing persons from safety harnesses following arrested falls); and,
- personal protective equipment on site such as safety harnesses, lanyards, safety helmets and eye protection.
Developing a plan
A work health and safety (WHS) management plan should demonstrate the integration of WHS requirements with the project procedures, practices and safety management of the project.
Access Canberra has prepared a sample template for principal contractors to use in preparing a WHS management plan.
The size and complexity of a WHS management plan will be relative to the size and complexity of the project and particularly to the amount of high risk work being undertaken.
The WHS management plan must include as a minimum:
- the names, positions and health and safety responsibilities of all persons involved with the work whose roles involve specific health and safety responsibilities;
- the arrangements in place, between any persons working at the site, for consultation, cooperation and coordination of activities in relation to compliance with their duties under the Work Health and Safety Act 2011 and Work Health and Safety Regulation 2011;
- the arrangements in place for managing any health and safety incidents, including reporting and incident notification;
- any site specific health and safety rules and the arrangements for ensuring that all persons are informed of those rules; and
- the arrangements to collect and assess, monitor and review safe work method statements.
Structuring a WHS management plan around headings will help ensure the mandatory aspects of a WHS management plan are documented. Importantly, it will also assist builders and/or construction companies in ensuring that other important requirements have been considered and addressed in respect of the project concerned. These heading include:
- Project description;
- Consultation, induction and training;
- Identify hazards, assess and control risks;
- Managing subcontractors;
- Managing incidents; and,
- Monitor and review of plan.
In this section of the plan a description of the key aspects of the project based on the main stages and potential hazards and risks should be incorporated.
This part of the plan should be specific to the project, highlighting main details such as project name, purpose, duration, stages and safety considerations on each phase of the project. This also includes the definition of the site location and layout plan and the interfaces to be considered during the course of the project. Project signage must include details such as the principal contractor name and contact numbers (including after hours) and show the location of the site office for the project.
The plan should also include provision for temporary accommodation, storage, pedestrian and vehicular routes.
Additionally, safety in design considerations should be outlined in this section including any relevant work health and safety hazards and risks reported by the designer.
This section should define the work health and safety (WHS) responsibilities of all project personnel from the tender process to completion of contract. In particular, this section should define who can make decisions and take actions on WHS issues, and in what circumstances.
The description of WHS responsibilities must include the name, position and appropriate authority of all such personnel.
Positions that should have their WHS responsibilities defined may include:
- corporate management such as the managing director and project director;
- superintendent or representative of the principal on site;
- project managers and site managers;
- WHS management representative;
- WHS committee members;
- workers; and,
- contractors and subcontractors,
Subcontractor information should include names, positions, contact details, WHS roles and responsibilities in connection with the project.
Specific aspects for which WHS responsibilities and authority definitions may include:
- consultation arrangements;
- dissemination of WHS information;
- managing WHS design issues;
- hazard identification, risk assessment and control measures;
- preparing, implementing, monitoring and reviewing safe work method statements;
- managing subcontractors and their compliance with WHS requirements;
- planning and conducting WHS Induction and other training;
- inspections, tests and compliance with site safety rules;
- incident reporting and investigations;
- WHS injury management and return to work;
- developing and implementing emergency procedures;
- WHS internal audits;
- review of WHS management systems implementation;
Consultation, induction and training
The principal contractor is required to consult, cooperate and coordinate with workers and others on matters related to work health and safety (WHS) that directly or indirectly affect the health and safety of people.
In this section methods of internal consultation, effective dissemination of information and decision-making process should be established. Interfaces between contractors should describe how forms of consultation will be coordinated and recorded.
The process should be applied by all staff and implemented across all activities with clients, contractors, subcontractors and others who may be impacted by the project operations.
The consultation should include a process to inform adjacent and surrounding occupancies of the WHS impact and changes due to the project activities. Additionally, in this section the principal contractor should describe the system to be implemented for effective communication with any personnel working in remote or isolated areas.
Arrangements for consultation can include pre-start briefings, toolbox talks and WHS meetings. Records should be kept showing topics discussed, dates of meetings and names of persons attending.
The plan should define how consultation and communication requirements are met, for example, through the establishment of a health and safety committee or health and safety representative or health and safety representative or other arrangements for consultation agreed by management and workers.
Where committees and health and safety representatives are in place for consultation this must be done according to mandated process.
Dissemination of information
This section should describe a system for communicating site specific work health and safety (WHS) rules to all staff as well as arrangements for dissemination of WHS information to all workers, including subcontractors, and other persons who may be relevant. Safety rules should be concise, simple, short, enforceable, and stated in a positive manner.
Consultation is required before taking any decision that may affect the health and safety of personnel while at work. When health and safety hazards and associated risks are identified, control measures should be put in place and should be communicated to all relevant personnel. Any changes to such controls should also be the subject of consultation before they are finalised.
Induction and training
Induction and training is a key element to ensure personnel are informed about work health and safety (WHS) risk management. The WHS plan must describe how personnel will be inducted on the health and safety requirements. In this section a specific site induction procedure should indicate the process to induct staff, visitors and subcontractors. It should also indicate how records will be maintained, usually three years after project completion.
The principal contractor must ensure that general construction induction (white card) training is completed by all workers, contractors and subcontractors prior to them commencing work on site.
A training plan is a tool to identify the training needs of personnel for each stage of the project. Training to be considered should include, as applicable, induction to the WHS systems of the company, site induction, emergency procedures, tasks training, general construction induction training, consultation training, as well as ongoing training needs. It should also include the training requirements for persons in supervisory positions, personnel conducting safety meetings, inspections, injury and accident investigation, job planning, analysis and leadership skills.
Induction and training will usually be required:
- when personnel commence work;
- when introducing site safety rules;
- when implementing relevant safe work method statements;
- when new WHS hazards or risks arise as a result of new tasks, systems, plant and equipment, substances introduced, new workplace or changes in the layout of existing workspace;
- after an incident occurs leading to injury investigations;
- when changes in the regulatory requirements are identified; and,
- for long duration activities where refresher training may be required.
Identify hazards, assess and control risks
This part of the work health and safety (WHS) management plan should describe the process to identify foreseeable WHS hazards, assess the risks and define the control measures to be implemented during the course of the project.
Although not a mandatory requirement as part of the WHS management plan, this is a mandatory requirement for principal contractor.
A procedure will need to be developed and implemented so that the hazards are controlled in the most effective and efficient manner. The principal contractor has an obligation to eliminate the hazards. If this is not reasonably practicable the principal contractor must control the risk by implementing measures to lessen the risk of harm to the lowest practicable level.
Use of the hierarchy of control will assist in identifying a control measure, or a combination of measures which can achieve the required reduction in exposure.
The hierarchy of control measures are:
- Eliminate the hazard (remove it completely from your workplace) - if this is not practicable then...
- Substitute the hazard (with a safer alternative) - if this is not practicable then...
- Isolate the hazard (as much as possible away from workers) - if this is not practicable then...
- Use engineering controls (adapt tools or equipment to reduce the risk) - if this is not practicable then...
- Use administrative controls (change work practices and organisation) - if this is not practicable then...
- Use personal protective equipment - this should be the last option after you have considered all the other options for your workplace.
The plan should include a risk management process which includes hazard identification, risk assessment and mitigation procedures to be applied for the project. A site specific project risk register should be developed identifying the above requirements and using the hierarchy of control to minimise the risks. All high risk construction work activities on the project must be listed in the risk register.
Safe work method statements are required to be prepared for high risk construction work before any work commences.
This section of the work health and safety (WHS) management plan should identify the key subcontractors for the project and how their safety plan and their safe work method statements (SWMS) will be managed by the principal contractor.
The principal contractor is required to include the procedure for engaging subcontractors and for monitoring and reviewing of their performance.
There must be arrangements for the collection, assessment, monitoring and reviewing of all subcontractor risk assessments, SWMS and their safety performance.
The plan should include a database or register containing information of all the service providers. The register will facilitate the management of insurances, licenses, accreditation information and verification of documents. The principal contractor will need to define how subcontractors will be monitored in order to minimise risk and ensure compliance with WHS legislation, contract requirements and project safety procedures. This can be achieved through periodic evaluations and audits of subcontractors.
This procedure should describe details of the reporting, logging, investigating, and corrective actions in response to injuries, incidents and accidents at the worksite and client sites.
This section should describe the arrangements to stabilise and evacuate any injured person, isolate the incident scene and make the workplace safe after the incident. It should also outline the procedure to be followed to notify Access Canberra if the incident is a notifiable incident including the requirement to preserve the incident site in such instances. It should also outline the requirements for investigation of incidents.
Incident investigation will help the principal contractor to identify control measures that will prevent recurrence of the same incident.
Some definitions to be considered when undertaking an incident investigation include:
- Accident - An undesirable event which results in harm to people, damage to property or loss of time.
- Incident - Any unplanned event resulting in, or having a potential for injury, ill health or other loss.
- Near miss - Any unplanned incident that occurred at a workplace that did not result in an injury but had the potential to do so.
- Lost time injury - A work injury resulting in time lost from work of equal to or greater than one workday or shift (eight hours) on which the injury occurs.
- Medical treatment injury - A work injury that does not result in lost time but requires treatment by a medical practitioner.
- First aid injury - A work injury for which only first aid treatment was administered on site.
Monitor and review of plan
The principal contractor should outline how the work health and safety (WHS) management plan will be monitored and reviewed over the course of the project.
WHS internal audits and inspection programs are the tool to monitor high risk activities and construction works. The purpose of the audits is to determine whether an area is complying with the documented procedures and to recommend improvements or corrective actions.
This section should define a plan to monitor frequency, thoroughness and results of inspections and audits throughout the project.
Additionally, this section requires a process to describe how project safety documentation is maintained. A procedure should be established for the control, approval, retention time, dissemination, storage and disposal of WHS documents and records.
Safety records include (but are not limited to) training records, qualification of individuals, inspection reports, plant and equipment records, work permits, safety equipment records, incident investigation reports, risk assessments, minutes of safety meetings, audit reports and workers compensation records.
- The principal contractor must ensure a copy of the plan is kept until the project is completed.
- If a notifiable incident occurs, the plan must be kept for two years after the incident occurs.
- A copy of the plan must at all times be readily accessible to anyone carrying out work on the project.