When it comes to controlling risks in the workplace, it’s pretty easy to find a solution to most issues. What is harder, is ensuring that it is a practical and workable solution. The two key questions you need to be able to answer are:

1. Is this control practicable? ie, is the effort and scope of the solution in line with the potential for injury or illness?
2. Is this the best control that I can come up with? Is there another control that will provide a better level of safety protection?

The first question can only be answered on a very specific, case-by-case basis. No-one but you knows the risks inherent in your operations, how likely they are to occur, and what harm is likely to befall people encountering these risks.

The second question is quite simple in comparison – we must always utilise the Hierarchy of Controls.

Why use the Hierarchy of Controls?

The Hierarchy of Controls consists of five (or six – more on that later) separate types of control measure, in order of effectiveness.

When identifying a safety concern in your workplace, if your go-to response is “let’s develop a procedure and hand out some PPE”, then you’re doing it wrong, plain and simple. You are focussing on the final two controls, rather than the more effective methods at the top of the Hierarchy.

In fact, the WHS Regulations are very clear on the matter (See Regulation 36 at the AUSTLII website) – you must first attempt to Eliminate the risk. Only if this is not practicable, should we then consider Substitution, isolation* and Engineering controls. Finally, if the risk is still present, we can consider Administration and PPE controls.

(*Isolation is the “missing” sixth control type referred to earlier. It is often combined with other Engineering controls, and may or may not appear as a separate control type in the Hierarchy).

Understanding the Hierarchy

If we are to effectively consider the Hierarchy of Controls in our Risk Management processes, then we must understand what each level of the Hierarchy is all about.

Elimination

If an item of equipment is not utilised, it cannot cause harm. If a certain chemical is not present on site, then it cannot be spilled. Elimination is the simplest control measure to understand, as well as the most effective. We cannot be harmed by a situation that cannot exist.

Substitution

Substitution requires “swapping” one situation for another. It may be swapping one chemical for another, changing package sizes to address manual handling concerns, or replacing old, worn or damaged equipment with new items.

Of course, the entire point is to ensure that the new item has a lower inherent risk than the item that is being replaced. If this is not the case, then you are clearly wasting your time.

Engineering

Engineering controls (including Isolation) require a physical change to be made to the item or situation. Common examples include installing guarding on machinery, relocating noisy pumps away from work areas, and providing lifting equipment for manual handling

Administration

Administrative controls include Information, Instruction, Training and Supervision. Development of a Standard Operating Procedure is an example of an Administrative control. Administrative controls are essential (imagine trying to run a business without any form of staff training!), but they need careful management – more on that later.

 Personal Protective Equipment

PPE is unique, in that it makes no attempt to address a hazard directly. Instead, it seeks to protect the individual once the hazardous situation has already occurred. Wearing glasses is not going to prevent sparks being created during a grinding job, but it should prevent you suffering an eye injury. Similarly, the use of gloves will not prevent a chemical spill, but hopefully you will not suffer any nasty chemical burns.

But Why is it so important?

With an understanding of what each of these types of controls are, hopefully you can see why utilising the Hierarchy of Controls is so critical. If not, let’s make it clear:

The more your controls rely on human behaviours, the more prone to failure they are

Elimination is almost infallible – you can’t be hurt by a situation that doesn’t exist.

Substitution and Engineering are making a physical change to the situation or process. A well-designed control will prevent accidental exposure, but the truly determined individual may still find a way to circumvent guarding or climb a fence.

Administration and PPE controls are very useful and important, but are incredibly difficult to rely upon. Their success relies to a significant degree on human behaviours – things that require a conscious effort.

• I may have been away for that training session. Maybe I chose to ignore my training. Perhaps I honestly don’t remember the method I was instructed in.
• The documented procedure may be out of date. It could be that the procedure was written by someone who didn’t know the process itself. Maybe I think I know better, and choose to go about it my own way.
• My PPE is on the other side of the factory, and the job won’t take long. It’s really hot today, and my safety glasses are just going to fog up with sweat. The gloves I’ve been provided are stiff and uncomfortable, I’ll get the job done quicker if I don’t use them.

All levels on the Hierarchy of Controls have their time and place, but you need to ensure you are at least considering each level whenever you are selecting a new control measure.

And don’t forget, the goal is to reduce risks “as far as reasonable practicable” – not “pick a control measure and move on”. Once you have identified a control, you must still consider the remaining levels in the Hierarchy to determine if there is anything further that can be (reasonably practicably) done to control the risk.

The Hierarchy of Controls is not a magic bullet, but it is an essential tool in effective Safety Management.

Chemicals in the Workplace

How many different types of chemicals do you use?

Are you giving chemicals the respect they deserve?

In our experience working with businesses, chemicals are one area that we must improve in.

You must ensure that chemicals users know the following:

• How to read a Safety Data Sheet (SDS) and understand all the information
• Storage requirements and segregation of other dangerous goods and obviously powders above liquids
• Emergency preparedness – your workplace emergency plans need to be developed and tested, taking into consideration your chemical risks
• First Aiders – they must know who to treat chemical injuries or exposure.
• Spill control – ensure you have the correct product and methods to deal with this issue
• Fire equipment – do we have the correct extinguishers and are they accessible
• Emergency shower and eyewash –  It may never be used but it must be fit for purpose and tested regularly.
• Prevent unauthorised access to your chemical storage area. They should be locked when not in use
• Hazardous chemical signage – Placards for dangerous goods to be clearly displayed at main entrance and storage areas; depending on the volume you store
• Manifest requirements, based on volume stored above the WHS Regulations requires additional processes.
• Package Group I,II, III – are you storing the correct amounts or do you require a Dangerous Goods Licence
• PPE – Must be fit for purpose, must be clean and washed after use, stored in an appropriate location and not in the chemical storage area
• If the SDS says face shield required, wear a face shield and not just safety glasses. there is a reason why a face shield is necessary

You also need to conduct chemical hazard identification (risk assessment) on every chemical you have on site. This will allow you to clearly identify your chemical gaps. Remember this is part of your Primary Duty of Care, provide safe substances.

Training of people to handle and use chemicals correctly. This includes Managers and Supervisors so they can assist in ensuring workers are using chemicals in a safe manner and in accordance with your procedures.

Training must include:

• SDS location and how to read.
• Storage areas locked when not in use.
• Emergency Preparedness- spill control – emergency evacuation
• First Aiders to ensure the first aid kits are stocked appropriately and they are trained correctly.
• Testing of emergency shower and eye wash
• How chemical cause injuries and illness. Poison Schedule 5,6 and 7.
• Health Surveillance – some may require workers to be monitored such as organophosphate requiring cholinesterase screening
• PPE training, correct supply, fit, use, cleaning, storage and replacement.

Even some non-hazardous products require PPE to be worn as they can cause irritation to workers.

Managing chemical risks in your business needs a systematic approach with risk assessment, consultation and communication, procedures and forms matched with training and supervision. We need to do more than just providing some basic PPE.

If a worker is injured when using a chemical, have a closer look to see what failed. Was it the worker’s fault or was it the lack of training, inappropriate storage, poor housekeeping, no supervision or inappropriate PPE supplied.

Chemicals are a necessary part of many businesses, so ensure you and your workers give chemicals the respect they deserve. They can be managed safely and cover your legal responsibilities.

For more information on the requirements of chemicals, give Andrew or Shane a call.

Drug & Alcohol Screening Program

How do you know you need a screening program!

This issue resinates with many businesses!

How big is this problem? Is it only a small group of workers?

Is it illicit drugs prescribed or over the counter mediation?

Is it being used in the workplace?  How do I address this without accusing them?

There are many more questions that we can ask, keep in mind the PCBU and Duty Holders must provide a safe workplace.

Be realistic about this, you will never stop people doing what they do; you just want to stop it coming to your workplace  and placing  you at risk.

 5 Tips for Drug & Alcohol Screening

1. Develop a procedure outlining how the screening process works, especially your actions for an unconfirmed positive.

 2. Communicate and Consult with workers, don’t rush this process. You are wanting people to change their lifestyle, so you may get some backlash but stay firm in your approach.

 3. Urine or Saliva screening. Keep it simple urine shows history and not reflected on current fitness for work.  Saliva screening shown very recent usage.

4. Internal or external screening provider. Internal screening may be seen as unfair in workers minds.  External screening treats every one equally as they are only providing a service, they are in and out with less disruption to the workplace.Screening program needs to cover every shift as well as everybody no matter what their job title is.  Screen the majority to control the minority.

5. Unconfirmed result, do you remove them from work or allow them to return to work. You need to know this answer before this happens.

If you require more information on how to run a D&A screening program or need a professional to conduct this for you, contact Andrew 0418 809 411 or email andrew@regionalsafety.com.au

Beating the Heat

How did your workplace beat the heat? Across Australia workplaces had to adjust to working in extreme heat for several days.

Now is the time to review how well your business actually managed this hazard.

No doubt the welfare of your workers is a high priority, but were your actions suitable?

Heat stress affects individuals differently so it is critical that hydration levels are maintained and people managed at the first sign of heat distress.

12 Tips in Managing Heat Stress
1.Work rosters, start earlier and finish earlier or staggered over shorter start & finish times.
2. Provide additional air flow or cooling from portable water coolers or fans.
3.Review tasks to be performed and if that increases or exposes workers to hot environments, review the need to conduct that task.
4.Have additional workers covering each shift and allow for additional breaks in air conditioned or cool areas.
5.Provide additional cool drinking water, bottles or dispensers.
6.Outdoor work, enforce the wearing of a broad rim hat, sun smart long sleeve clothing, sunglasses and sunscreen.
7.Workers to take sufficient water with them when working outside.
8.Place a cool towel around your neck whist working if this does not create a safety hazards.
9.Erect a shade structure to work under.
10.Cease work and retreat to a cooler environment before the temperature becomes unbearable.
11.It is critical management, supervisors and workers keep discussing the heat situation and agree to action.
12.Keep workers out of the direct sunlight or environments where radiant heat increases the risk of heat stress to workers.

For further information on how to manage heat stress contact shane@regionalsafety.com.au

Managing  Contractors

Gone are the days of using a contractor and believing they take all  safety responsibly away from you.

While this was never the case, it was the way legislation was often interpreted.

WHS Legislation, believe it or not, has clearly outlined individual’s responsibilities. The PCBU – Person Conducting a Business or Undertaking, Officer, Duties Holders, Workers and Other  Persons all have a part to play in ensuring the workplace is safe.

Businesses engage contractors as they have the skills, experience and after a few quotes the cheapest price.

We may ask for some safety paper work and give it a quick read and say ’Okay’.

The contractor should also be asking the same from you. How you are going to keep the contractor safe and away from the hazards they may be exposed  to in your workplace?

Just because they sign the visitors book and wear a high visibility vest does not mean they are going to be safe from your specific workplace hazards.

If this is the approach to managing contractors in your workplace, your systems need reviewing.

Don’t forget the contractor is a PCBU and needs to have a documented  safety system reflecting their operations that is used in providing a safe workplace, for their workers and yours.

If you are not sure what is required of you or your contractor contact Shane to give you some tips.

5 Tips for Contractors

1. Ensure your selected contractor has the required safety documents and valid product, public and/or professional indemnity insurance.

2. Have an agreement with the contractor as part of your selection process. This will inform you on how exposed your business could be.
Your agreement should be specific to the works being performed.

3.Induct the contractor into your workplace – the higher the risk the more comprehensive the induction.

4.Inform other management & workers that contractors are on site, the tasks they are performing and the area they are working in.

5.Review the contractor site / task specific procedure, SWMS, risk assessments and site inspections with the contractor and their workers to  ensure, together you have addressed a  safe environment and the contractor is working safely whilst on your site.

For more information on how to Manage Contractors call Andrew on 0418 809 411 or andrew@regionalsafety.com.au