Establishing WHS Practices

Workplace health and safety (WHS), also sometimes referred to as occupational health and safety (OHS), is an important aspect of any job role. As a practice manager, you will have a responsibility to understand and comply with all WHS processes and strategies that are specific to your workplace, as well as learning and applying legislative requirements and any industry standards that apply to your position. Of course, as you progress in your career and take on leadership and management positions, your responsibilities in regard to WHS will increase. You may be required to establish, maintain, and evaluate your organisation’s WHS practices in order to ensure that your organisation is conforming to its legislative requirements and that you are maintaining a safe environment for both workers and clients. This Study Guide will explore the key considerations involved in managing work health and safety and will help you to identify ways in which you can uphold WHS procedures and practices within a workplace.

All workplaces hold potential risks to people’s physical and emotional health and safety. Despite that, most accidents and injuries that occur in the workplace are avoidable when there are appropriate work health and safety practices in place. WHS practices serve to keep you, your colleagues, clients, and visitors to your workplace safe from accidents, injuries, and illnesses. The key goal of WHS practices is to provide a work environment that promotes the overall health and wellbeing of everyone in the work environment.

To help you understand the broader picture of WHS practice, consider the following definition:

Safe Work Australia is the statutory agency that is responsible for developing and coordinating national policies and strategies related to work health and safety issues. In the past, each state and territory in Australia had their own legislation, guides, standards, and acts covering WHS practices. A primary function of Safe Work Australia is to develop model WHS laws and strategies to improve consistency in compliance and enforcement of WHS laws across Australia.

At the time of this publication, all states and territories excluding Victoria and Western Australia had implemented the model WHS Act and Regulations. While there is now more consistency across Australia, each state government is still responsible for regulating the WHS laws within their state. The table on the following page lists the names and websites of the state/territory government departments that regulate workplace health and safety laws within Australia. These websites are provided to allow you to explore the WHS legislation that is relevant to your state/territory.

Next watch this video providing information from Safe Work NSW.

WHS Acts and Regulations set out requirements about how work should be undertaken and what policies and procedures must be in place in order to keep the workplace safe. They also provide information about the general duties of everyone in the workplace for fulfilling WHS requirements. Depending on an individual’s role and the industry they work in, the WHS requirements that they need to comply with will vary. Therefore, it is important to ensure everyone is familiar with their WHS responsibilities.

The key duties and responsibilities of the major WHS parties are outlined in the table below.

The person conducting a business or undertaking (PCBU) has the primary duty of care to, so far as reasonably practicable, ensure the health and safety of their workers. PCBUs can be either an individual or an organisation, (i.e., in the allied health sector PCBUs are generally the allied health organisation itself).

The responsibilities and accountabilities of the PCBU are supported by the PCBU’s officers (i.e., officers of the organisation) who must exercise ‘due diligence’ to ensure that the PCBU complies with their duty and that their organisation fulfils its WHS requirements. Not all leaders in a workplace are necessarily officers. An ‘officer’ refers to a person who “makes, or participates in making, decisions that affect the whole, or a substantial part, of” how the organisation operates (Workplace health and safety act 2011 (NSW) s. 252). Officers are generally those in senior management positions. These individuals have a legislative responsibility to exercise due diligence and be proactive in addressing WHS issues in the organisation in a timely manner. The following extract outlines the responsibilities involved in ‘due diligence’.

As you can see, work health and safety requires commitment and leadership from an organisation’s senior management; however, middle managers and workers of the organisation also have WHS responsibilities. Middle managers are responsible for complying with and facilitating WHS policies and procedures within the workplace. They may even be part of Health and Safety Committees. Similarly, workers are responsible for taking reasonable care and complying with WHS policies and procedures and may even become Health and Safety Representatives or members of Health and Safety Committees.

Safe work practices are the responsibility of everyone in the organisation – it is important that WHS practices are embraced by all and that everyone is aware of their responsibilities and accountabilities in ensuring health and safety in the workplace.

Most organisations have specific policies and procedures in place that underpin the management of work health and safety to ensure adherence to the relevant WHS laws. A WHS policy outlines the organisation’s commitment to the principles of WHS in compliance with relevant WHS Acts and Regulations, while WHS procedures outline the actions required to put the policy into practice (WorkSafe Victoria, 2006). To help workers understand their duties in promoting WHS, organisational management must develop clear WHS policies and processes that include easily understood and practical steps that workers can follow to fulfil their WHS responsibilities.

Most organisations will have a range of WHS-related policies and procedures. For example, most organisations will have policies and procedures relating to:

• Hazard identification, risk assessment, and control (e.g., a requirement to complete Hazard Logs when a hazard is identified in the workplace, monthly vehicle maintenance checklists, etc.)
• Hazard, incident, and injury reporting (e.g., a requirement to complete an Incident Report following a workplace injury)
• Consultation and participation (e.g., a requirement for monthly meetings for all workers in which WHS issues are discussed, designated persons for raising WHS issues, etc.)
• Quality system documentation (e.g., ensuring that authorised and standard documentation that meets legal requirements is used across the organisation, ensuring that incident reports, checklists, log books are completed, etc.)
• Use of personal protective equipment (PPE) (e.g., a requirement to specific protective gear, such as gloves, personal alarms, etc.)

These policies and procedures are specifically developed to ensure compliance with WHS legislation in relation to various aspects of managing work health and safety. You will learn much more about these various requirements throughout this Study Guide; however, for more practical information on how workplaces can comply with WHS laws, you can refer to the Model Code of Practice and other guidance materials available on the Safe Work Australia website.

If you are a manager or coordinator of an allied health organisation, you are likely to be involved in developing and promoting health and safety practices in your organisation. In addition to specific WHS policies and procedures, you may also need to develop and promote other policies and procedures that provide guidelines to workers in managing particular hazards or completing their work safely. Let’s take a quick look at some of these policies and procedures.

Human Resources Policies and Procedures

There are a number of human resources policies and procedures that serve to outline responsibilities and processes to ensure health, safety, and wellbeing of workers within workplace. These policies and procedures may include:

• Emergency management
• Fire prevention and control
• First aid
• Working environment risks
• Workplace violence (e.g., workplace bullying, aggressive clients, etc.)
• Shift work and remote or isolated workers
• Drugs and alcohol within workplace
• Smoking in the workplace
• Manual handling
• Safe vehicle operation
• Fatigue management
• Mental health

Human resources policies and procedures are designed to provide workers and management with best practice requirements for fulfilling their WHS obligations within the workplace. Some of these also help to fulfil obligations to comply with legal requirements such as the Fair Work Act and Anti-discrimination legislation. These are important policies and procedures and it is important to highlight them during workplace inductions and to ensure that they are easily accessible to workers. Additionally, it is important to understand that all policies and procedures will need to be reviewed regularly and updated (this is typically the responsibility of organisational management – you will learn more about review processes throughout this Study Guide).

Emergency Procedures

All workplaces must have clearly established emergency procedures that outline the steps that workers and others must take in response to an emergency. Typical examples of emergencies may include “fire, explosion, medical emergency, rescues, incidents with hazardous chemicals, bomb threats, armed confrontations and natural disasters” (Safe Work Australia, 2012a, p. 2). The content of emergency procedures usually includes:

The primary purpose of emergency procedures is to promote a consistent and measured approach that workers can follow to ensure everyone’s safety is the top priority when dealing with the event. Therefore, it is important to ensure that emergency procedures are suitable to the nature of the workplace and that workers are trained to follow the procedures. A summary of the procedures (e.g., evacuation plan, fire procedures) should also be displayed in the workplace and readily accessible by workers and visitors (e.g., clients, contractors, volunteers).

Code of Conduct

In most organisations, workers will also need to comply with a code of conduct, which is a document that outlines specific requirements that workers must comply with while carrying out their duties as part of their role. While Codes of Conduct do vary from organisation to organisation, they generally include a series of statements such as:

• I will immediately report abuse, neglects, accident, incident, injury or event.
• I will document all details of any accident/incident via an appropriate form.
• I will not be under the influence of drugs or alcohol at any time while conducting my duties.
• I will always act with due diligence in regard to WHS and ensure the safety and wellbeing of all those around me.
• I will execute my activities in accordance with appropriate standards and relevant legislation.
• I will only provide work-based activities for which I am capable and qualified and are safe to provide.
• I will report any concerns regarding WHS to the designated person.
• I will operate a motor vehicle safely and in accordance with all laws and legal obligations.
• I will maintain my best efforts to provide a working environment where services can be delivered safely.

A code of conduct sets out an organisation’s expectations for workers to conduct their work in a safe, legal, and ethical manner. It is also important to note that a signed employee Code of Conduct can be considered a legal document and therefore failure to comply can result in legal prosecution.

Overall, it is important to ensure that information about the workplace’s WHS policies and procedures, as well as the specific WHS-related responsibilities of an individual’s role, is provided to all workers within the organisation. These documents are usually set out in the organisation’s policies and procedures manual or intranet that workers can easily access. While it is the worker’s responsibility to ensure that they understand and comply with these policies, it is important for organisations to foster an appropriate environment and encourage workers to seek clarification or raise WHS issues with their supervisor. Additionally, workers should be encouraged to refer to relevant policies and procedures when dealing with any WHS issues.

The presence of clear WHS and WHS-related policies and procedures helps to ensure that all workers comply with WHS requirements or identify the presence of hazards and breaches of policies. Let’s take a look at a case study that demonstrates how an allied health worker identifies a WHS-related issue, consults their policies and procedures, and takes appropriate steps based upon these policies and procedures.

In this scenario, the practice manager identified a WHS issue, checked her organisation’s policies and procedures to find out how to report the matter, and then followed those procedures. While in this example the worker readily identified the presence of an issue herself, in practice, the organisation should ensure that there are procedures in place to help workers identify the presence of any potential WHS hazards in the workplace so as to manage work health and safety risk. Indeed, effective hazard identification processes is a core component of the appropriate management of risks to health and safety in the workplace. Of course, it is not the only component – let’s explore the core aspects of managing work health and safety risk.

As previously discussed, PCBUs have the primary duty for managing work health and safety risks in the workplace. However, managers, coordinators, and supervisors may also be legally obliged to exercise due diligence to establish and maintain the WHS management systems of an organisation in compliance with the relevant WHS Acts and Regulations. Additionally, workers are required to understand, comply with, and contribute to the WHS practices of their organisation. This requires all workers to contribute to the management of WHS risks.

According to Safe Work Australia (2018), the process of managing work health and safety risks can be summarised in the following four steps:

1. Hazard identification – find out what could cause harm
2. Risk assessment – understand the nature of the harm that could be caused by the hazard, how serious the harm could be and the likelihood of it happening
3. Risk controls – implement the most effective control measure that is reasonably practicable in the circumstances, and
4. Review control measures – to ensure they are working as planned

Let’s explore each of these steps in detail.

A hazard refers to a source or situation with the potential for harm in terms of human injury or ill-health, damage to property, the environment, or a combination of these. A risk refers to the probability and consequences of injury, illness, or damage resulting from exposure to a hazard. For example, doing shift work in the evening can be viewed as a hazard because it increases the risk of personal danger due to fatigue. It is important for all workers to be able to identify potential hazards within their organisation.

Hazard identification is a process that involves identifying the hazard, or the potential for harm or damage, and what contributes to it. When developing a procedural guide for identifying hazards, it is useful to consider adopting the following processes:

• Inspecting the workplace (e.g., observing how work is performed, how equipment is used, what safety practices are used, the state of workplace housekeeping, etc.)
• Consulting with workers (e.g., asking about any problems or incidents that have not been reported)
• Reviewing workplace data (e.g., analysing information about reported workplace incidents, results of inspections, complaints, worker sick leave patterns, etc.)
• Reviewing external data (e.g., external regulators, safety consultants and manufacturers/suppliers are a vital source of information for hazards associated with specific industries, pieces of equipment or the use of specific substances)

Most of the time, hazard identification processes are conducted as part of routine workplace procedures (e.g., scheduled monitoring by the workplace health and safety officer). However, hazard identification processes should also be undertaken in specific conditions, such as:

• Before new forms of work and organisation of work are implemented (e.g., introduction of a new service)
• Before changes are made to a workplace, including changes to equipment, work processes, or work arrangements (e.g., before changing a specific process)
• As a part of planning major tasks or activities, such as equipment shutdowns (e.g., planning a group workshop)
• Following an incident report (e.g., following a physical outburst by an angry client that results in a staff member being injured)
• When new knowledge regarding the workplace becomes available (e.g., when a railing at the entrance to the building becomes loose)

Every organisation should have its own procedures in place to help workers identify hazards relevant to their work role. It can be useful to provide workers with a list of examples of common hazards found in the workplace to help increase the workers’ awareness and subsequent ability to identify hazards. The following table, adapted from Safe Work Australia Code of Practice (2011), lists some examples of common hazards that workers may encounter in a workplace. While some of these hazards may not be present in an allied health organisation, it is good practice to still be aware of them.

In the allied health sector, workers are not only exposed to hazards in their work environment, but they also need to be aware of hazards relating to direct client care. The type of hazards identified in each allied health organisation will also vary depending on the nature of services provided. To help you better understand how to develop procedures for hazard identification within the allied health sector, let’s look at a few hazards common to allied health workers.

Hazardous Manual Tasks

A major cause of injury in the allied health sector is attributed to hazardous manual tasks (SafeWork SA, 2014). In the WHS Regulations, a ‘hazardous manual task’ refers to:

Identifying potential hazardous manual tasks involves identifying tasks that have the potential to cause a musculoskeletal disorder (MSD). MSDs are defined by WHS regulations as conditions such as “sprains and strains of muscles, back injuries, joint and bone injuries or degeneration, nerve injuries or compression, muscular and vascular disorders (result from hand-arm vibration) or soft tissue hernias” (WorkCover NSW, 2015). Hazardous manual tasks in allied health organisations could include moving heavy furniture without the right equipment, pushing clients in wheelchairs, lifting clients, repetitive movements (e.g., typing on keyboards), driving for long periods, and prolonged sitting in inappropriate posture.

SafeWork SA (2014) suggests that you identify hazardous manual tasks by:

• Completing a workplace inspection with employees
• Reviewing injury records to identify injuries related to hazardous manual tasks in the past
• Asking employees about tasks that they find difficult to do.

To reduce risks from hazardous manual tasks, it may be necessary to alter the design of the workplace (e.g., install ramps and handrails) or work systems (e.g., job rotation) to limit workers’ exposure to these tasks. It is also important to ensure workers are trained to complete these tasks using appropriate tools (e.g., trolleys for lifting) and techniques (e.g., kneel rather than bend when lifting heavy objects). Practical guidelines on identifying and addressing hazardous manual tasks can be found in the Hazardous Manual Tasks Code of Practice that can be found online through the Safe Work website (Safe Work Australia, 2016).

Slips, Trips, and Falls

Slips, trips, and falls in a workplace can also result in multiple MSDs and significant injuries. Major slip, trip, and fall hazards may include uneven or damaged floor surfaces (e.g., a ripped piece of carpet), loose mats and rugs, wet or oily floors (e.g., spills or recently washed floors), poor lighting, uneven steps or paths, a box left in a walkway, or even a faulty chair. These potential hazards must be reported promptly and recorded according to workplace procedures.

Workers should be trained to monitor their work environment and keep paths clear of hazards such as equipment, rubbish, and electrical cords. When more permanent hazards are identified (i.e., damaged floor surfaces), they should be eliminated promptly, if possible (e.g., repair/replacement organised), and workers should be informed immediately to prevent incidents. Alternatively, preventative measures (e.g., using luminous reflective tape to mark stairs) should be implemented to reduce the risk of slip, trip, and fall.

Infection Control

Depending upon the exact nature of the work, allied health workers may also be exposed to high levels of ‘biological risk’ (e.g., viruses, pathogens, etc.). A worker who comes to work with a cold or flu can also be a hazard as they have the potential to not only affect others in the workplace, but may also be incapable of performing their duties. Therefore, it is important that allied health workers understand and implement infection control procedures pursuant to WHS legislation and organisational policies and procedures.

Infection control in the workplace aims to prevent pathogens being passed from one person to another (Victoria State Government, 2018). The general approach to ‘infection control’ is to plan for the worst and assume that everyone is potentially infectious. It is vitally important to establish proper procedures that relate to personal hygiene and that promote workplace cleanliness. The following extract outlines some infection control methods suggested by the Victoria State Government (2018).

Vehicle and Driver Safety

In the allied health sector, workers are often required to travel or transport clients in company vehicles. Given the significant vehicle usage within the organisation, it is important to ensure that the vehicles are mechanically sound and fit to drive. To identify hazards relevant to vehicle use, you should take into consideration:

Safe driving procedures can be developed to ensure that workers allow sufficient time for travelling between locations and take regular breaks when travelling for long distances. If necessary, safe driving training can be delivered to provide workers with tips for safe driving, strategies for dealing with road rage, and worker safety information (e.g., keeping doors locked, always lock vehicle and remove keys when existing vehicle, etc.) (SafeWork SA, 2014). Regular vehicle checks should also be conducted to ensure that vehicles are in a safe operating condition. These checks are often carried out by the worker completing a vehicle inspection checklist. An example checklist is included below.

Work-Related Stress and Fatigue

Stress in the workplace is a significant issue and one that is costly to the Australian workforce. The consequences of stress include lost productivity, absenteeism, increased work accidents, and trained staff leaving the workplace. Workers in the allied health sector, such as practice managers, are particularly susceptible to burnout and need to be vigilant about managing stress and fatigue.

According to Safe Work Australia (2013), the following factors can be considered psychosocial hazards in the workplace:

Not all stress is bad; however, ongoing, unmanaged stress at work can lead to burnout and vicarious traumatisation. This is particularly relevant for allied health workers who are highly involved in providing direct client care (Safe Work Australia, 2013). Consultation with workers is vital to identifying psychosocial hazards in an organisation. Management may also identify trends in an organisation by reviewing incident reports, sick leave, and annual leave records, and records of absenteeism and staff turnover.

Although stress cannot be fully eliminated in the workplace, it can be prevented or monitored to reduce its impact on workers’ psychological health. At the organisational level, having clear and orderly work procedures and training can help workers to manage work-related stress. At the personal level, it is also important to ensure that workers are equipped with personal self-care strategies and supported to debrief after a challenging incident. Regular supervision and support are also important to help workers recognise signs of stress and fatigue. When necessary, external support can also be accessed via suitable workplace support services.

Workplace Violence

Workplace violence (including sexual harassment, bullying, and challenging client behaviours), is considered to be one of the major contributors to work-related stress in Australian workplaces. In the allied health sector, workers often come across situations where they feel their personal safety is threatened (e.g., working alone with challenging client, working after dark, or working in isolated or remote areas). Allied health workers may also experience challenging, aggressive, or violent behaviours from interacting with clients (e.g., involuntary client) or other workers (e.g., workplace bullying). These incidents can have a cumulative effect and result in psychological harm over time.

Allied health organisations should develop WHS policies and procedures to address potential workplace violence (e.g., Prevention of workplace violence policy; Challenging behaviour procedures, etc.). Workers need to be provided with information, instruction, training, and supervision so that they are able to prevent or manage the occurrence of violence in the workplace (e.g., withdraw immediately if workers feel unsafe and report the situation, how to report workplace bullying, etc.). Some organisations will use duress alarms or implement specific systems to flag potential risks or challenging clients to relevant workers. It is also important to ensure that workers can access support systems such as debriefing and Employee Assistance Programs after incidents. As it can be difficult to anticipate the occurrence of workplace violence, training workers in interpersonal skills is also beneficial to de-escalate challenging situations and reduce impact of workplace violence (SafeWork SA, 2014).

Strategies to prevent and manage workplace violence are available in the following guidance materials:

• Guide for Preventing and Responding to Workplace Bullying (Safe Work Australia, 2016)
• Violence in the Workplace Guide (SafeWork NSW, 2022)
• Work-related Violence: Preventing and Responding to Work-related Violence (SafeWork SA, 2021)

A Note on Workplace Support Services

Although not mandated by WHS law directly, many organisations do offer workers opportunities to use various workplace support services. These services are available as additional support to workers such as those who have experienced an undue amount of stress or workplace violence. Their focus is in preventing or reducing long term impacts of incidents on workers. Typically, workplace support services may include:

• Employee assistance programs (counselling, critical incident support, disaster response, wellbeing checks, caching, peer support, team assessment, etc.)
• Medical services (flu vaccinations, health screenings, exercise and relation, nutrition and healthy eating, etc.)
• Training (managing mental health, bullying and harassment, building resilience, navigating change, mentoring, conflict resolution, building effective teams, etc.)

Workplace support services are usually offered by independent third-party services, which helps to ensure confidentiality and neutrality for workers. By offering this option to workers, organisations are able to demonstrate that effective strategies have been put in place to deal with incidents, crisis, or events that can cause trauma to its workers.

Once hazards have been identified, it is important to assess their risk level by conducting a risk assessment. Assessing risk involves considering how severe the risk is, the actions that need to be taken, and how urgent the risk is. Risk assessment involves gathering facts about the nature of the hazard, the way it can lead to injury, accident, or death, and the impact it will have.

A vital part of a risk assessment procedure is to assess the severity of the risk. Most organisations use a risk matrix to help identify hazards that are likely to cause risk to workers. An example of a risk matrix is shown below. While there may be slight variations in the structure of the risk matrix between organisations, it will generally seek to assess the potential impact of the hazard (the seriousness of the consequences) and the likelihood of it happening.

^{(Adapted from SafeWork SA, 2014)}

Management often prioritise risks according to their potential for harm. By rating the impact of the hazard and the likelihood of it happening, they are able to categorise the hazard by its risk rating and determine its priority. Depending upon the complexity of the risk matrix used (i.e., degree of detail in the measurements), it is not uncommon to end up with hazards that have the same risk rating when assessing the hazard and allocating a risk rating. If this occurs, it is important to re-assess and compare those with the same risk rating against each other in order to identify which hazard you feel is more serious. Hazards that cause the greatest risk should be listed first and they should be the priority.

When developing procedures for risk assessment, it is important to provide a template for documenting the findings. Factors that increase or decrease the impact should also be identified and recorded. A tool that is often used as part of the risk assessment process is a Hazard Log. An example of what a Hazard Log can look like is included below. The specific documents used in different organisations will vary, however, all will identify hazards and the possible risks associated with each hazard. Completing this form also involves the assessment of the effectiveness of any existing strategies to manage the risk.

Alternatively, organisations may use a Risk Register (such as the one shown on the following page), to record the information required for a risk assessment. This register also allows for the documentation of action plans that will be implemented to eliminate or reduce these risks.

^{(Safe Work Australia, 2018 p. 38)}

While completing regular risk assessments is best practice in all situations, it is important to note that a risk assessment is mandatory under the WHS Regulations for high-risk activities (e.g., entry into confined spaces, diving work, and live electrical work).

Within the allied health sector, it is common to combine the Risk Matrix and the Hazard log to establish documentation that centres on controlling the risk associated with specific activities around the workplace. Consider the following case study to see how the risk matrix can be used in conjunction with completing a hazard log sheet.

Case Study

Jane has recently been employed as a practice manager at a doctor’s office, Rathdown Pines. Rathdown Pines has recently undertaken a number of renovations to the drop-in centre. Jane has been assigned the responsibility of conducting a risk assessment. During her review, she identified a number of hazards, including:

• The latch to the door on the rear staff entrance is broken and doesn’t lock correctly. Clients have been known to smoke outside the rear entrance despite requests from management to not do so.
• The light in the carpark is broken and a worker complained of feeling unsafe when walking to their car after work. However, the light has been broken for two months without incident.
• A worker identified that a pile of timber left over from the renovations was a potential tripping hazard. While the wood has been neatly stacked together in a pile, it still presented as a tripping hazard due to the amount of foot traffic in the area.

Jane recorded each of these hazards on the hazard log sheet (see below). Jane also used the Risk Matrix to determine the seriousness of the risk for each hazard:

• The security door was rated as extreme risk due to its major impacts (theft, vandalism, staff safety, client confidentiality) that are very likely to occur given the amount of people that tend to gather close to the door
• The broken light in the carpark presented a major impact with regards to personal safety and tripping hazard. However, it rated a likely possibility of happening. It was assigned a high risk rating.
• The used timber pile presented a moderate impact (tripping hazard) but deemed unlikely to occur due to the size of the pile and it being neatly stacked. It was given a low risk rating.

Hazard/s	Risk (what could go wrong)	Existing Risk Controls	Current Risk rating (use the Risk matrix)	Are any additional controls required?	Residual Risk (Use the Risk matrix)
The security door to the rear staff entrance will not lock properly (latch doesn’t catch	Theft, vandalism, staff safety, breach of client confidentiality	None	Extreme
Broken light in the carpark	Tripping hazard, personal safety	None	High
Used timber pile near drop-in centre renovations	Tripping hazard	Removed all nails from the wood pile and neatly stack in a pile	Medium

Controlling risks is the most important step in the risk management process. Controlling risks involves eliminating the risk if it is possible and if not, minimising the risk as much as possible by implementing procedures to control the risk. When deciding how to control risks, PCBUs/officers are required to consult with workers and their representatives. If more than one risk needs to be controlled, the risk that is most likely to cause the most harm should be prioritised and controlled first (Safe Work Australia, 2018).

According to the Work Health and Safety Regulations, PCBUs and other duty holders are required to work top down through the hierarchy of control when controlling risks (Safe Work Australia, 2018). The strategies described in the hierarchy of risk control are known as control measures. The control measures have been ranked from the most reliable and the highest level of protection to the least reliable and the lowest level of protection. The hierarchy of control consists of three levels:

Essentially, wherever possible you want to start off by applying Level 1 strategies and eliminating the risk. However, if that is not possible, then you should attempt a Level 2 strategy of substitution, isolation, or engineering controls. Finally, if none of those are possible, it would then be appropriate to apply a Level 3 strategy of administrative controls or the use of personal protective equipment to protect workers from the hazard.

In most cases, there is also information about suitable control measures for common hazards within codes of practice, WHS procedures, WHS Acts and regulations, and other guidance materials. While these are great sources of guidance, in many cases, organisational management may need to develop specific control measures by reviewing information from risk assessments and determining the most appropriate control.

There is often more than one possible control measure to control any risk, and sometimes it will be necessary to use a combination of methods. In this case, the control measure chosen for implementation should:

1. Provide the most reliable and highest level of protection – towards the top of to the hierarchy of control
2. Be readily available – can be purchased, made to suit or to be put in place
3. Be suitable for the circumstance in your workplace – it will work properly given the workplace conditions, work process and your workers

^{(Safe Work Australia, 2018)}

It is important that the risk controls and hazard-specific procedures are consistent with the hierarchy of control. For example, in the event that there was a spillage of liquid on the kitchen floor (e.g., a drink), WHS procedures should state that it should be cleaned up immediately – Level 1 Elimination. It would be inappropriate in this case to set up barriers to isolate the workers from the spillage or to prevent workers from accessing the kitchen. Inconsistency between the organisation’s hazard-specific procedural manual and the hierarchy of control can increase the risk associated with the hazard. Furthermore, there are some risk controls that have legislative requirements, such as using correct disposal methods for sharps and medical waste. It is important that these legal requirements are reflected in the organisation’s hazard-specific procedures manual and that these procedures are consistent with the hierarchy of control.

Let’s look at an example of hazard identification, risk assessment, and risk control in the allied health sector – this example highlights how management considers options for risk control before selected the most appropriate option.

A Note on The Principles of Good Design

Risk control measures are most effective, and usually cheaper and more practical to achieve, at the design or planning stage (Safe Work Australia, 2018). In other words, the best way of eliminating hazards or risks is by not introducing the hazard into the workplace in the first place.

For this reason, the Principles of Good Work Design were developed to promote the importance of eliminating or minimising hazards and risks from the early stage of designing work practices. These principles also offer support to the second principle underpinning the Australian Work Health and Safety Strategy 2012-2022, “Well-designed, healthy and safe work will allow workers in Australia to have more productive working lives” (Safe Work Australia, 2012c, p.3). There are ten principles of good work design:

^{(Safe Work Australia, 2012c)}

If you are a manager or supervisor of an allied health organisation, one of your obligations is to ensure the workplace is safe and complies with these principles. If you want to consider these principles in more details, the Principles of Good Work Design handbook can be accessed from the Safe Work Australia website.

A Note on Use of Personal Protective Equipment (PPE)

As part of risk control, allied health workers may be required to use specific Personal Protective Equipment (PPE) such as gloves and masks order to minimise the risk of harm in the workplace. For example, a practice manager or allied health worker should wear gloves when applying first aid. Alternatively, if a practice manager or allied health worker is working with potentially violent clients, their organisation may have them wear a personal alarm as a safety measure.

In order to minimise risk to workers, PPE should also be properly maintained, repaired, or replaced when needed. Organisations should develop an effective system for maintaining their PPE and ensuring that the equipment is clean, hygienic, and functioning (Safe Work Australia n.d.). Suitable storage is important for keeping PPE free from contamination, loss, or damage. Additionally, alarms should be tested regularly.

Whilst using appropriate PPE is important to maintaining good WHS practices, it is noteworthy that use of PPE is, as shown in the hierarchy of control, the least effective way to control risk – it is a Level 3 strategy. Safe Work Australia suggests only using PPE in the following circumstances:

• When there are no other practical control measures available (as a last resort)
• As an interim measure until a more effective way of controlling the risk can be used
• To supplement higher level control measures (as a back-up).

^{(Safe Work Australia, n.d.-b)}

It is important that control measures are put in place and reviewed frequently to ensure their smooth and effective operation. It is good practice to be proactive in your efforts and try to preempt potential WHS issues.

Under the WHS Regulations, there are certain situations where review of control measures must take place so that the procedures can be revised if necessary. These conditions should be stipulated in your organisation’s WHS procedures manual in regard to reviewing controls.

It is appropriate to repeat the steps taken during initial hazard identification to check controls. The procedures of reviewing controls should also stipulate consultation with workers or WHS representatives and consider the following questions:

The controls review procedures manual should also include steps for when problems are encountered. For example, when there is a problem you should revisit the risk management steps, review the information, and make an informed decision on risk control. When determining priority for review, precedence should be given to those with the most serious risk and should subsequently be reviewed with greater frequency.

A Note on Obtaining Expert WHS Advice

When managing WHS risks within an organisation, there may be circumstances when you need to engage a suitably qualified person for advice on specific area of WHS. Obtaining professional advice will help you make informed decisions in identifying and controlling the hazards in your organisation.

Situations when expert WHS advice is necessary may include:

The type of advice you need will depend on the circumstances. In some cases, you may find it adequate to build in-house WHS knowledge by accessing sources such as WorkSafe’s Advisory Service, inspectors, published guidance, compliance code, WHS Regulations, and industry or employer associations for advice on managing a particular hazard (WorkSafe Victoria, 2008). However, if further expertise is required, you may consider engaging an external consultant on either a one-off or as needs basis. You will need to consider the nature of your organisation and the hazards in your organisation to select the most appropriate WHS consultant. The following table outlines the main area of expertise of various WHS consultants (adapted from WorkSafe Victoria, 2008).

To ensure the WHS consultant is suitably qualified, you may want to access information from your relevant regulatory bodies or engage a WHS consultant through one of the following peak bodies suggested by WorkSafe Victoria:

• Australian Institute of Occupational Hygienists (www.aioh.org.au)
• Human Factors & Ergonomics Society of Australia Inc (www.ergonomics.org.au)
• Safety Institute of Australia (www.sia.org.au).

It is important to note that employing or engaging a suitably qualified person to provide WHS advice does not relinquish the PCBU’s legal responsibilities to ensure health and safety of their workers. The PCBU’s duties cannot be delegated.

To help workers understand their duties in promoting WHS, organisational management must ensure that clear WHS policies and procedures are developed. These policies and procedures must include easily understood and practical steps that workers can follow to fulfil their WHS responsibilities. Additionally, each worker’s responsibilities should be clearly listed in organisational WHS policies and procedures. Some organisations also use a WHS responsibility and accountability matrix to document the responsibilities and accountabilities of each role or person within the organisation. An example of WHS responsibility and accountability matrix is included below.

^{(University of Wollongong, 2016, p. 14)}

Other processes that are commonly used to help workers of all levels remain accountable to promoting WHS in the organisation include:

• Ensuring that workers are properly trained in their duties
• Creating checklists/sign-off sheets to ensure duties are completed as needed
• Regularly reviewing checklists/sign-off sheet to ensure duties are being completed
• Integrating WHS accountability as part of performance review processes

For example, a duty of care checklist can be developed to help managers or supervisors to monitor workers’ accountability on WHS matters. An example of this type of checklist that was developed by Courtenell (n.d.) is included below.

Ultimately, the PCBU and its representatives are responsible for ensuring that all WHS legislative requirements are reflected in the organisation’s policies and procedures and that they are being complied with. You will learn more about these requirements throughout the remainder of this Study Guide.

Workplace health and safety practices are not only a legal requirement but also essential for ensuring health and well-being of everyone in the workplace. In this section of the module you have learned about WHS legislation and the key processes of risk management – hazard identification, risk assessment, risk control, and review control. In the process of managing risks or hazards in your organisation, it is important that you always consult with the workers in your organisation to ensure that the procedures are effective and appropriate. The next section of the module will explore the processes involved in consultation in more detail.