Evaluating and Maintaining WHS

Monitoring and reviewing WHS management systems is a vital step to ensure that current practices are working effectively and to identify opportunities for improvement. Usually, WHS management systems are reviewed internally at scheduled timeframes or on an as-needed basis (e.g., following an incident or change in legislations). Processes that can be used to monitor WHS performance may include:

• Conducting workplace inspections – Are work safe practices being complied with? Are control measures still effective?
• Auditing policies and procedures for legislative compliance – Has there been any changes to WHS legislation?
• Checking training needs – Is any specific training required?
• Reviewing data from incident and hazard reports – Have all hazards been appropriately addressed?  What lessons can we learn from the incidents or injuries?
• Incident investigation – What is the root or contributing cause of the incident?
• Consulting workers – Are there any concerns about the current practices? Have the changes implemented been effective or created other hazards?

The results of these monitoring and reviewing processes enables you to identify any gaps in the WHS management systems which should be taken into account when developing WHS action plan to improve the WHS practices of your organisation. If necessary, remedial actions should be undertaken in a timely manner to address the gaps or issues identified.

Most organisations also conduct an annual WHS management system audit to verify the effectiveness of overall WHS management systems in their organisation. This can be conducted internally by the senior management in consultation with key WHS parties including workers, visitors, and contractors; or externally by a professional WHS auditor. A WHS management system review usually involves:

• Evaluating how well the organisation is performing against its targets and objectives (e.g., zero injury in workplace)
• Reviewing WHS processes and policies to ensure legislative compliance
• Reviewing the WHS reports to identify opportunities to improve the organisation’s WHS performance
• Considering any changes in organisational structure, activities or other aspects that will impact on WHS practices

Considering the outcomes of WHS audits (e.g., Have issues identified been resolved? Are the changes made effective? Is any specific training required?)

Outcomes of the annual WHS management system review must be documented and communicated to all workers. Recommendations for improvement can be used to guide your organisation in setting the WHS objectives and the focus of the action plan for the coming year.

Another way to evaluate and improve the WHS management systems in your organisation is by comparing your practices against similar organisations who have attained best practice – a process known as benchmarking. You may consider benchmarking the entire WHS management system in your organisation or focus on certain processes, methodologies, approaches, and practices. The goal of a benchmarking exercise is to identify areas for improvement so that strategies can be developed to address these gaps. The benchmarking process can be summed up in the seven steps listed below:

1. Establish benchmarking project
2. Select teams and train them
3. Identify processes to benchmark
4. Analyse your own processes
5. Select benchmarking partners
6. Build relationships and conduct visits
7. Analyse performance gaps and develop improvement strategies

^{(Archer, Borthwick, Travers & Ruschena, 2012)}

Many organisations use a benchmarking process to identify best practices in managing risks and reducing workplace injuries. For example, Disability Safe conducted WHS benchmarking to compare the incident statistics (e.g., lost time injury and its causes) of disability service organisations across Australia. They aimed to provide each disability service organisation with feedback on their WHS performance within the industry and to identify areas that require attention to reduce workers compensation premiums (Disability Safe, 2016). Although benchmarking processes can take up considerable time, money, and energy, it is a powerful tool to promote WHS accountabilities in your organisation and a systematic approach to continuously improve the WHS management systems in your organisation.

Ultimately, continuous improvement is the key to maintaining health and safety standards in a workplace. The outcomes of the review processes will help you identify gaps in the WHS management systems and opportunities for improving the WHS practices in your organisation. It is important that you communicate the outcomes of review processes with the workers in your organisation and develop a plan for improving the WHS management systems of your organisation in collaboration with relevant workers.

Determining WHS priorities

Following a review/audit, a WHS planning meeting is usually carried out with key WHS parties (e.g., WHS representatives and committees) to analyse the outcomes and discuss ways to continuously improve the WHS management systems. For instance, the audit may indicate that a particular policy or procedure needs to be updated for compliance. The data of incident, injury and near misses may also point out some hazards that needs to be better managed or training needs that have not met. Consultation with workers is often the initial step to understanding the underlying cause and identifying strategies to address the issues.

The initial step to improving WHS management systems is to determine specific WHS goals/objectives to establish clear direction of strategies to address the identified WHS needs. For example, if an increased number of injuries due to hazardous manual tasks has been found, the WHS goal should relate to taking action to minimise risks of hazardous manual tasks and reduce injuries. It is a good practice to set goals that are specific, measurable, attainable, realistic, and timely (SMART) to ensure the goals are tangible and realistic.

Once WHS goals are determined, management and workers will need to collectively decide which WHS issues or goals should be prioritised and which can be included in longer-term planning. Attempting to resolve too many WHS issues at once may result in higher risks and waste of resources which will, in turn, decrease the effectiveness of the strategies. Therefore, it is important to set WHS priorities to ensure resources are allocated appropriately and efficiently. Factors that need to be considered when setting WHS priorities include:

• The particular needs of your organisation
• The major hazards in your organisation
• Compliance with the legislation
• Resource and budget requirements
• Training needs

^{(SafeWork South Australia, 2014)}

It is important to ensure your organisation is complying with all WHS legislative requirements. If any non-compliance with WHS legislation is identified, it is obvious that the organisation must carry out actions promptly to meet the requirements. If the WHS goal relates to the management of hazards, the hazard with the highest risk level (using a risk matrix to rate its impact and likelihood) should be deemed a priority and addressed promptly. Essentially, any WHS goal that is high risk should be prioritised.

For each WHS goal, you will have to identify actions required to achieve the goal, who will be responsible for the actions, and a realistic timeframe for completion and review of actions. These details should be documented in a WHS action plan.

A WHS action plan seeks to document the actions or steps necessary to remedy or manage identified risks and to improve work health and safety. A WHS action plan can vary in format, complexity, and length depending upon the size of the organisation and the magnitude of the issues. However, action plans generally consist of the following information:

• Goal/objective
• Actions/steps required
• Person responsible
• Timeframe for completion of actions
• Review date

The scope of a WHS action plan can be organisation-wide or focused on a particular WHS aspect in the organisation. A template for WHS action plan is included below.

While determining actions required to achieve the WHS goals, it is vital to take note of any legislative requirements that may apply to the targeted aspect and any codes of practice or industry practices that may provide information for best practice. If the WHS action involves implementing control measures to eliminate or minimise risks of hazards, the planned actions must be consistent with the hierarchy of control (that you learned about in Section 1 of this Study Guide) and you will have to select the most reliable, available, and suitable method for achieving the WHS goal. It is also important that specific, concrete steps are listed in the WHS action plan to ensure that the plan is clear and easily understood by all levels of workers in your organisation – this helps ensure that required actions are actually taken.

To ensure accountability, you must also state who is responsible for each of the actions. Under the WHS Act, different levels of workers have different accountabilities for WHS. Some WHS actions (e.g., developing new incident reporting procedures) may fall into the accountability of a particular level of worker who has the appropriate authority and resources. Other WHS actions may require the commitment of all levels of workers (e.g., reporting incidents timely using appropriate incident reporting procedures).

When determining the person responsible for a WHS action, it is good practice to first consider the resources and expertise within the organisation – this will incur lower costs in managing WHS compared to acquiring expert advice or paying for services outside of the organisation. Increasing workers’ engagement in managing WHS issues will also help to promote the WHS awareness among workers in your organisation.

When setting a timeframe for completion, it is important to factor in the priority of the WHS goal. Where possible, WHS actions for higher priority goals will need to be completed promptly considering the risks of goal not being met (e.g., a high priority hazard may cause major damage if actions are not taken promptly). At the same time, the timeframe set must be realistic and practical. You should always consult with the responsible workers to ensure they have sufficient time and resources to complete the required actions. If it is not possible to complete required actions within the required short period of time (e.g., training needs to be provided prior to carrying out actions), you may also consider implementing temporary measures to control the risk.

The action plan must also document a review timeframe to ensure that WHS actions have been carried out successfully and to assess whether the actions have been effective in achieving its purpose. This date is usually set for an appropriate time after the date of completion for the WHS actions.

The following case study demonstrates the process of developing a WHS action plan in an allied health organisation.

Once an action plan is developed, it is important to ensure those who have been delegated responsibilities have a clear understanding of their task/requirements. If necessary, information or training should be provided for them to carry out their tasks/requirements. In some cases, such as when a new WHS policy is introduced, written materials (e.g., memo, instructions, etc.) or formal meetings (e.g., tool box talk, training, workshop, etc.) may be required to inform relevant workers of their roles in implementing the WHS action plan.

Once the action plan has been put into action, it is important to monitor achievement against the plan. If you are the manager of a work group, you have a responsibility to ensure actions are being completed as per the agreed schedule. You may need to follow up with individual workers who have been assigned responsibilities as part of the action plan to monitor their progress and ensure they have enough resources to complete the assigned tasks.

By monitoring the action plan, you will also be able to evaluate the effectiveness of the actions implemented in achieving its goal/objective. This may include evaluating the short-term impact (e.g., reduced number of injuries) and the long-term (e.g., improved health and wellbeing of workers) impact of the implemented actions. If the actions implemented are not effective in achieving its goal/objective, the strategies will need to be revised in collaboration with your work group. Corrective actions or changes made to the plan should always be communicated to workers in a timely manner and clearly documented.

In addition, as the circumstances of your organisation change, its WHS priorities and resources available may also change. Therefore, action plans should be reassessed and updated on an on-going basis in consultation with the work group. Circumstances in which the action plan will require an update may include:

• In response to change in WHS legislation requirements
• In response to recent workplace injury or incident
• When new information about risks becomes available
• In response to expert WHS advice or opinion

As you review a WHS action plan, it is also important to identify any potential barriers in improving WHS in your organisation. Common barriers to improving WHS may include:

• Lack of human and financial resources
• Underdeveloped or overly complicated action plan
• Attempting to implement too many strategies at the same time
• Unrealistic timeframes
• Lack of relevant knowledge or experience
• Lack of commitment from management

Incorporating strategies to address these barriers in the action plan will help increase the effectiveness of the WHS actions implemented and demonstrate the organisation’s commitment to maintaining a safe and healthy workplace. Support and commitment from senior management is vital to the implementation of WHS action plans. It should also be recognised that persons responsible in implementing WHS actions may need additional support and should be allowed to complete the required tasks during work time.

Let’s revisit the previous case study to explore the process of monitoring and updating a WHS action plan.

Managing workplace health and safety is an ongoing process. Regular review and evaluation are essential to ensure that the WHS practices in your organisation are effective and appropriate. In this section of the module, you have learned about the processes involved in developing and reviewing a WHS action plan. Such processes are important aspects of providing a safe and healthy workplace.