A compliance audit is not a guarantee of a risk free workplace. The risks addressed during an audit are determined by the workplace environment along with relevant injury data and industry input. The outcomes of compliance audits indicate if compliance is being achieved or if further actions may be required to meet legislative standards.
Risk specific audits address particular issues such as confined space entry, or working at heights and involve the inspection and testing of current workplace control methods. This type of audit has a narrow focus and looks at the effectiveness of policies and procedures in dealing with specific risks.
Under the Work Health and Safety Act 2011, there are specific requirements for persons who conduct a business or undertaking to audit:
An occupational health and safety management systems audit has a wider scope, and although addressing hazards and risk controls, it also looks at organisational structures, planning activities, responsibilities, implemented procedures, review cycles and measurement and evaluation issues.
A basic occupational health and safety management system has some of the following characteristics:
Many organisations undertake these audits on an annual basis as the amount of resources and time required to conduct a management systems audit can be substantial. These audits can be undertaken by appropriately trained internal staff or by an external third party.
This is an initial, no cost, ground based assessment of your site. We won't climb, but will take measurements and photos. You will get a report of our audit upon completion.
Managing the risk of working at heights is critical. A person conducting a business or undertaking (PCBU) must manage risks to health and safety associated with falls from one level to another that are reasonably likely to cause an injury (Part 4.4, section 78 of the Regulation).
Construction work duty holders must also comply with Part 6.3, division 4 of the Regulation, when determining how to manage risks associated with falls.
If a person can fall more than two metres, a safe work method statement (SWMS) must be prepared, detailing the hazards, controls, and methods of review and monitoring the hazard.
(a) PCBU must manage risks to health and safety associated with falls .. that are reasonably likely to cause an injury
If the SWMS states that the only control measures will be administrative controls or the provision of personal protective equipment, then it must describe all control measures that have been considered in determining the actual control measures to implement, and also address the general fall protection requirements.
The following scenarios highlight the importance of working at heights safety measures and the role of inspectors in enforcing compliance with them.
An inspector observes workers on a housing construction site carrying out re-roofing work at a height of less than three metres. To control the risk, the PCBU has implemented a travel restraint system and has ensured workers are trained to work at heights. The inspector has determined that this method has adequately controlled the risk of a fall. However, the safe work method statement (SWMS) for the work states that higher order controls, including temporary edge protection, will be used.
An inspector could issue an improvement notice to the PCBU under r300(1) of the Regulation for failing to comply with the SWMS. A prohibition notice could not be issued in this scenario as the workers are using a travel restraint system and therefore not exposed to an immediate or imminent serious risk.
An inspector observes workers on a housing construction site carrying out small works (installation of a whirly bird). The workers are at a height that is less than three metres. The SWMS states that administrative controls (training) will be used to manage the risk to workers and work is being carried out in accordance with the SWMS.
An inspector could issue a prohibition notice to stop the work at heights if the inspector has formed a reasonable belief that workers are exposed to an uncontrolled immediate or imminent serious risk.
If the SWMS did not address the requirements of r299(4) of the Regulation to describe all control measures considered in determining which control measures to implement where only administrative controls and personal protective equipment are to be used, the inspector could also issue an improvement notice under r299(1) of the Regulation.
An inspector observes workers on a domestic housing construction site carrying out re-roofing work at a height of less than three metres. Workers are using a work positioning system to control the risk of a fall (e.g. a secured lanyard and harness), which is in accordance with the SWMS for the work.
If the PCBU is able to provide the inspector with their determination (note: the WHS Act does not require this to be in writing) as to why the use of fall prevention was not reasonably practicable, then the inspector can not issue an enforcement notice. In this scenario there is no requirement for the determination to be documented.
If the PCBU is unable to provide any determination as to why the use of fall prevention was not reasonably practicable, then the inspector should discuss the relevant regulations, codes of practice and availability of other reasonably practicable options to control the risks associated with falls.
An inspector will only consider the use of an improvement notice if they form a reasonable belief that the PCBU is likely to continue or repeat a contravention of the Act.
An inspector observes workers on a housing construction site carrying out small works that have a short duration (replacing one roof sheet). The workers are using a travel restraint system that the inspector has determined is adequately controlling the risk of a fall and the PCBU has determined that, given the short duration of the task, it is not reasonably practicable to put in place fall prevention.
No enforcement action is required by the inspector.
In this scenario, the PCBU has made a determination (also not required to be in writing) about what control measures are reasonably practicable under the circumstances. Since the risk of a fall has been controlled, workers are not exposed to an immediate or imminent serious risk and a prohibition notice can not be issued.
Provided the PCBU can give the inspector their determination why fall prevention was not reasonably practicable (the PCBU has followed the process in s78 and s79 of the Regulation) then an improvement notice is not justified.
Last updated 18 November 2013 © The State of Queensland (Department of Justice and Attorney General)