OHS Blog

Planning: Safety in Design – When and What to Consider?

The 2nd ‘Safety in Design’ Conference was held recently in Melbourne during May 2016. As the name suggests, the topics discussed on the day centered on the importance of considering and planning for safety in areas such as:

  • process and functional safety (e.g. when designing plant and/or guarding);
  • construction of new and/or refurbishment of buildings;
  • purchase of new plant; and
  • designing guarding for current plant (i.e. retro-fitting) – which has been raised by a number of our clients in recent times.

The presenters focused on the challenges of safety in design and the importance of balancing the risks and costs of today, whilst anticipating the needs of tomorrow through a “whole of life” design review. Whole of life considerations that are often forgotten about, include:

  • repair and maintenance;
  • cleaning;
  • training and licence requirements;
  • monitoring requirements (e.g. noise and/or dust); or
  • decommissioning, etc.

A key message from the conference was that safety needs to be considered at the concept stage, when decisions are made about the ‘intended purpose’ and/or ‘required deliverable’, as opposed to safety being considered only after the design commences. The following example was shared which gave this thinking some perspective:

If safety in design was considered after a decision was made to have a rail-road crossing, the safety considerations will be specific to the design, and in line with the “agreed deliverable”. The safety aspects of the design would make the rail-road crossing as safe as possible – it would include booms, lights, signals, etc. However, wouldn’t it be better if safety in design was considered at the concept stage? If the “goal” was to prevent cars and trains impacting, safer solutions such as a bridge and/or underpass may have been an option for consideration.

 

 

Being consulted with in the concept phased resonates daily in the workplaces we support. We recently had a client contact us to gather advice about what they needed to ensure was in place prior to purchasing a forklift, due to their walkie stacker: (1) not being able to access the top level of racking, and (2) not being able to reach-forward. After reviewing the “efficiency” that could be generated across a small floor area where load shifting occurred for less than 2 hours per day, against the hazards that would need to be controlled if a forklift was introduced (e.g. mobile plant moving at faster speeds, licencing requirements, fuel onsite – resulting in the management of hazardous chemicals, etc.), the client started to investigate walkie stacker options that provided the result / goal they were after. 

 

Safety in design (and procurement) should be considered when the “goals” of the design are being considered, not once the “finalised deliverable” has been prescribed.

 

Consideration of safety in the concept phase will support elimination, or provide the best opportunity to significantly reduce risk of whole of life design issues with an item of plant or a building. From our view point as health and safety consultants, past experience continues to demonstrate that trying to manage and reduce hazards post implementation can:

  • be financially expensive. Retro-fitting requires a new plan(s), sourcing materials and trades for smaller/one-off jobs.
  • be resource demanding. Someone at your workplace (or many), will be required to focus their time on a project that could have been resolved earlier. Their time will be utilised due to their involvement in supporting risk assessments, construction, managing contractors, etc. – everything can’t be “outsourced”. In addition, time will be spent training your workers in the new practices and/or processes.
  • impact safety culture. Your workers may feel that their voices are not considered as “known” hazards continue to reappear; as opposed to be managed better, or eliminated. 

We understands that there is incredible pressure on business owners to look for cost saving measures when purchasing new plant, leasing new premises, or refurbishing current premises in order to remain profitable. Therefore, managing risk by considering safety in the concept phase of the design, when project “goals” are being agreed on makes absolute sense.

 

www.actionohs.com.au | info@actionohs.com.au | 1300 101 OHS | 1300 101 647

Training: Improving the Impact of your Training – Blocked vs Random Practice

Training is critical for all organisations to ensure that workers have the appropriate knowledge and skill to competently complete the inherent requirements of their role safely.

What training looks like varies considerably and will often depend on the training requirement. We often ask the question to our clients “what consideration did you make when developing the training program in your workplace?” Often, their response is limited. This article takes a look at “blocked” practice versus “random” practice.

In a sporting context, everyone has been exposed to blocked and random practice. Think about going to the golf driving range, shooting a basketball or netball. When training to execute the skill, do you think it would be better to act out Scenario A 10 times, before moving onto Scenario B for 10 attempts, and then onto Scenario C for 10 attempts (this approach is referred to as blocked practice); or, would it be better to act out Scenario A once, Scenario B once and Scenario C once and repeat this 10 times (this is referred to as random practice)?

The answer is dependent on whether you were assessing the performance in the training, or the performance at a later date.

Blocked practice should produce better performance than random practice during the initial rehearsal/training.

 

Blocked practice is an effective way for the participant to “understand” the components of the individual skill. Once this skill is understood, it is random practice that facilitates the participant’s ability to retain the skill. 

 

Why? During random practice, the participant is required to fully focus on the skill and replay the entire motor pattern. Blocked practice sees the participant make small adjustments to the motor pattern, in line with how they executed the skill on the last occasion. In a “real” life situation, do you have the ability to make minor adjustments based on your last performance?

When designing effective training, consider the knowledge of the participants:

  • If the task is new for the worker(s), you may want to schedule training activities to transition from a blocked to a random approach when developing the training materials.
  • If it is re-training and the workers are familiar with the skill, you may want to schedule all training activities in line with random practice.

In addition, you will need to consider what do the attendees’ work tasks looks like? If their work requires constant variation in the task; random practice is likely to be more effective. Golf is a great example here, you often hear about players frustrated as to why their “form” at the driving range does not translate onto the golf course. The reason for this is, on the golf course they only get one shot/chance to execute the skill (and that shot counts). Whilst at the driving range, they implicitly make minor adjustments (to their motor pattern) between attempts, using the knowledge of their last attempt. This means that the consequence of errors is not as visible. It also means that the “form” they have described on the driving range, has been learnt from the adjustments they have made from their earlier shots during that practice session.

How can this be better managed? At the driving range, consider changing clubs or the scenario for each shot, train how you play. This is the same for training in the workplace – is there variation when your workers operate machines, or undertake certain activities?

To support learning, where appropriate, a key consideration for the person developing the training is to move away from a blocked approach to a randomised approach. Whilst challenging for your participants initially – it will improve their skills in the future.

Another aspect to consider is how your competency assessments are structured? If the operator can continue to attempt until they “pass”, does this demonstrate competency, or does this demonstrate that they have an ability to use the feedback provided from the knowledge of the last result? The importance of getting this right will depend on the impacts to your workplace of the “error”.

 

www.actionohs.com.au | info@actionohs.com.au | 1300 101 OHS | 1300 101 647

Technology: 10 Questions to Consider When Purchasing OHS Software

Businesses of all sizes struggle with managing their workplace safety responsibilities. When operations are busy, activities which have been initiated to ensure that the established risk controls are in place and working can often be forgotten. Let’s face it, there should be a reason why these activities have been scheduled, and if this reason is to protect the health and safety of workers, contractors or visitors, they should not be placed on the “to do later” list. Increased workloads, being “busy”, or “forgetting” is no justification.

 

At every workplace there should be a well understood reason for every health and safety task that is being undertaking. If the reason you are undertaking the task is not understood, maybe now is time to review those tasks, rather than just “forgetting” about them?

 

 

In addition to “tasks” being completed; the management of “the evidence” of tasks being completed is often unstructured. 

Software can assist. Software does assist. It is common place now for OHS Software programs to automatically email the identified workplace stakeholders, with reminders of when important tasks are scheduled for completion. OHS Software programs should then provide the workplace with a way to manage the OHS record(s) on completion. The simplicity of OHS Software means that it is something that many workplaces are now considering to introduce to support the visibility of their OHS Program and establish workplace efficiencies.

Whilst there are many software applications on the market, all OHS Software is not the same. The majority of the OHS Software programs that are on the market are “commercial off-the-shelf (COTS)”. This means that they have been made, ready for sale to the public. It means that they are not developed specifically to a workplace – that includes your workplace. They have been designed to be implemented easily into workplaces with minimal customisation. This means that the “80-20 rule” should be considered (i.e. at a minimum, the OHS Software program should be able to effectively deliver 80% of the outputs you require). However, with careful planning and by following the considerations below, you should be in a position to elevate that 80 closer to 100 – by identifying the OHS Software program that is “more-right” for your workplace’s needs.

Procuring an OHS Software program should be considered a long-term relationship. To ensure that you get the right OHS Software program for your business, it is absolutely essential that you do your homework first. Listed below, in no particular order, are ten (10) questions you should consider, before purchasing a “web-based” OHS Software program:

  • Are you looking for an “OHS Software package” or “OHS Policy and Procedures”? OHS Software packages are effectively “frameworks”. This means that your workplace will be required to develop the OHS Policy and Procedures additional to the OHS Software licence. Some packages will provide a “Manual” that is in line with their OHS Software program (this is rare). If a Manual is provided, ask your supplier how much work will be required to align the Manual to meet your workplaces operational needs, and if any additional documentation may be required.
  • Are you looking at OHS Software or “Web-based” OHS Software? Besides being antiquated, OHS Software that is loaded onto individual computers (think the “old” Microsoft Office), does not have the “flexibility” of web-based OHS Software. The user is locked into being at their computer to access their OHS Management System. Web-based OHS Software will also allow users to access their OHS Management System anywhere, and on any device (where they have access to the internet). A bonus of web-based OHS Software is that the supplier should provide you with “free” automatic updates as the OHS Software develops – this cannot be said for Microsoft Office!
  • How easy is the OHS Software to use? This may sounds straight forward, but it is often overlooked as the procurement team gets caught up in the initial excitement of the “new” and “shinny” software program that is going to make “everyone’s” life easier. While some OHS Software packages may look great when demonstrated, it is important that you are considering/questioning:
    • if it provides the functionality you need?
    • does it address your business critical workplace’s needs?
    • if the user interface is clear and simple to navigate?
    • will your users, who may have varying levels of computer literacy, be able to easily use the OHS Software?
  • Are there limitations surrounding the number of workers (Users) who can access the OHS Software? The evidence tells us that health and safety is about the collective, not individuals, at a workplace. A number of OHS Software programs place limitations explicitly around the number of user licences a workplace has access to, or implicitly does this by “significant” increases in their pricing when multiple licences are requested. If there are limitations around the number of users who can access your OHS Software, ask the question…

…how will our workplace live the mantra that “safety is everyone’s responsibility”? 

  • Does the OHS Software have a lock-in period? If the OHS Software package effectively delivers all of the benefits that you signed-up to during the initial procurement, it makes sense that you would continue to use the software – right? As disclosed above, the majority of OHS Software is “Commercial off-the-shelf”, this means that the business you are looking to purchase the OHS Software from, often has not invested time in developing the software specifically for “your” workplace needs. This being the case, you should be very nervous of OHS Software suppliers that look to lock you into contract greater than 1 year. If the OHS Software: (i) behaves as promised; (ii) has effective help support; and, (ii) continues to improve in line with advances in technology, you will stay. For the majority of businesses, OHS Software does not need to be developed specifically for the organisation.
  • Can you access the OHS Software from Mobiles and Tablets? With so many organisations operating outside the traditional office setup; would workers being able to access your OHS Software from their mobile telephone and/or tablet be of benefit?
  • Does the OHS Software provide you with access to all Modules or just “some” Modules? All software can be a “tricky” to navigate. Whilst advertising a “starting” price, OHS Software providers will often charge additional fees that are “disproportional” to the initial outlay, for any extra modules that you identify in the future that could benefit your workplace as your safety program matures. Make sure you understand all potential future costs – even if you don’t think you will need them all right now. Running multiple systems due to cost, as we often see, is confusing and disorganised.
  • What does the OHS Software “Help” support look like? Before financially investing in an OHS Software system, you need to ensure that there is an easy way for questions and/or concerns that you have to be raised and managed. As a minimum, the OHS Software should provide you with access to:
    • a “Help” Support Manual.
    • the ability to raise issue either by email and/or telephone.
    • Note: It may also be in your best interest to understand if there is any cost associated with any help requests that you make.
  • What happens to “your” data if you decide that the OHS Software is no longer for you? Firstly, it is your data. Secondly, you have a legislative duty to maintain selected health and safety records. Therefore, it is absolutely critical that you have access to these. Can you export or download the data yourself? Or does the OHS Software provider charge you retrieval costs?
  • Does the OHS Software have compatibility with other IT Systems? All software should support efficiency. With workplaces typically having at least one IT Program established prior to implementing an OHS Software package, it is worth identifying how the OHS Software package can align with your current IT system(s)? For example, will you be required to manage employee information across multiple platforms (i.e. your payroll system and your OHS Software package)? Or will the two (2) packages be able to communicate with each other? If the OHS Software cannot directly communicate with other IT Programs you have installed, what other options have been provided to you to support efficiency? For example, is there the ability to import data?

This is by no means an exhaustive list and it should not cover the full breadth of your review. If you would like further support, or have any questions, please do not hesitate to contact us. With regards to additional considerations, we will look to provide more information in future blogs. If you have any feedback on your experience with procuring OHS Software, we would love to hear from you.

 

www.actionohs.com.au | info@actionohs.com.au | 1300 101 OHS | 1300 101 647

Prosecutions: 2015 Summary for NSW & Victoria

Workplace prosecutions are something that health and safety practitioners should maintain oversight of to identify trends. This article provides an overview of the prosecutions listed by WorkSafe Victoria and Safe Work NSW for 2015 as of 15 March 2016.  

 

Prosecutions: Numbers and Related Legislation

2015 saw a total of 85 health and safety prosecutions in Victoria and 52 prosecutions 52 in NSW.

Prosecutions NSW and VIC 2015_Updated MAR16

Within Victoria:

  • 80 prosecutions were recorded against the Occupational Health and Safety Act 2004
  • 2 prosecutions were recorded against the Dangerous Goods Act 1985
  • 1 prosecution was recorded against the Occupational Health and Safety Regulations 2007
  • 1 prosecution involved both the Occupational Health and Safety Act 2004 and the Occupational Health and Safety Regulations 2007
  • 1 prosecution involved both the Occupational Health and Safety Act 2004 and the Dangerous Goods Act 1985.

Within NSW:

  • 21 prosecutions were recorded against the Occupational Health and Safety Act 2000
  • 30 prosecutions were recorded against the Work Health and Safety Act 2011
  • 1 prosecution was against the Explosives Act 2003.

Interestingly, whilst the Occupational Health and Safety Act 2000 in NSW was superseded as of 1 January 2012, approximately 40% of the prosecutions listed in NSW during 2015 were against the superseded Act.

 

Prosecutions: An Overview of Fines

The average fine in both states exceeded $50,000. In NSW the average fine was only slightly greater when comparing between the current and superseded legislation; however, the amounts for both: (i) median fine ($80,000 v  $47,250), and (ii) the greatest fine (412,500 v $300,00), were greater when prosecuted against the current legislation. This is in line with the guidance that was provided on enactment, that penalties would increase when the harmonised Work Health and Safety Legislation was introduced.

 

Prosecutions Fines NSW and VIC 2015_Updated_MAR16

 

Prosecutions Fines NSW Median Max

 

In NSW each prosecution resulted in a monetary fine. In Victoria 59 fines were issued (69% of the total prosecutions). In addition to the fines, WorkSafe Victoria issued seven (7) Enforceable Undertakings. In these cases, the enforceable undertaking is a legally binding agreement between WorkSafe Victoria and the employer. The employer is obliged to carry out the specific activities outlined in the undertaking. Such scenarios ensure that the workplace implement agreed corrective actions.

 

Prosecutions: What is the Cause and where are the Gaps?

With respect to the criteria/codes that lead to prosecution – the top 10 criteria, as defined by WorkSafe Victoria, are outlined below.

  1. Failure to provide a safe system of work – 34%
  2. Guarding – 20%
  3. Failure to provide a safe working environment – 18%
  4. Failure to notify WSV of a notifiable incident – 16%
  5. Failure to provide and maintain plant – 16%
  6. Failure to provide information, instruction, training or supervision – 13%
  7. Falls/work at height offences – 13%
  8. Crush injuries – 12%
  9. Failure to conduct a risk/hazard assessment – 8%
  10. Failure to preserve incident site – 8%.

 

Prosecutions Criteria NSW and VIC 2015_Updated_MAR16

Combined, failure to provide a safe system of work and safe working environment resulted in over half of the prosecutions. This outlines the requirement for workplaces to actively:

  • Assess their workplace risks. Workplaces should consider listing all foreseeable hazards in the workplace, and document the current controls that have been implemented to support the management of the hazard. At this time, the workplace should consider additional/ alternative control strategies. If the risk associated with the hazard can be further mitigated, this should be documented with a Safety Action Plan developed to support implementation.
  • Consider safety when procuring equipment. Often safety is an afterthought. Considering safety prior to purchasing will better ensure that controls do not require retro-fitting and/or additional equipment is not required to manage the “new” hazard presented – both having financial implications.
  • Considering safety when engaging contractors. Workplaces often engage contractors to support processes that they are not familiar with, which means new hazards may be introduced to the workplace. Prior to engaging contractors, along with price, seek information from those you are about to engage to ensure that they can maintain that safe working environment you have established.

Guarding and maintenance of plant equates for over one third of prosecutions. Guarding is a high level control that ensures there is separation between workers (and their limbs) and moving parts. Management and supervisors should be undertaking regular walk-throughs to ensure that guarding is not overridden. The guarding that management and supervisor walk past is the fatality and/ or amputation that they accept. Where guarding has been removed, management and supervisors should talk with the operators to understand the basis for this. Are operational KPIs realistic? Can processes be reviewed? Is the plant fit for the purpose that the workplace wants? Is additional equipment required?

Worth a mention is the 16% of workplaces that failed to notify WorkSafe Victoria of the notifiable incident that occurred in their workplace and the 8% of workplaces that failed to preserve the incident site. Both of these requirements are expressed clearly within the Occupational Health and Safety Act 2004. If your workplace is not familiar with what incidents require notification, or there is no training or reference in your procedures on how to manage a notifiable incident – it is something you should consider reviewing immediately.

Finally, apart from legal fees, fines and a negative prosecution result, the lengthy duration of legal proceedings can impact workplace resources (e.g. with conflicting focuses between the prosecution and workplace safety). The impact also flows through to other areas of the business resulting in a negative safety culture, low morale amongst workers as well as the negative impact on business development due to ‘loss of faith/brand damage’ that is perceived by the general public.  

 

www.actionohs.com.au | info@actionohs.com.au | 1300 101 OHS | 1300 101 647

 

Planning: What is your health and safety strategic plan?

Does your workplace have an OHS plan? If so, does your workplace have OHS objective and targets to support you to achieve the outputs of this plan? If you have established objectives and targets, are these periodically reviewed, evaluated and redefined (if necessary)? Or do they sit there in the background, getting reviewed ad-hoc…or worse still post incident?

 

“A target without a plan is just a wish…” 

 

When we take time to consider the statements above, it is evident that to achieve workplace safety goals requires careful and considered planning. Why then do many workplaces continue to leave their Health and Safety Program in “the hands of the Gods”?

To get started…

  • Ensure Senior Managers are aware of their legislated health and safety duties and due diligence obligations.
  • Establish stakeholders to define your workplaces health and safety objectives and targets. It is important that the objectives and targets that your workplace agrees on, are aligned to your Health and Safety Policy. When establishing targets make sure that they are:
    • S – Specific
    • M – Measurable
    • A – Achievable
    • R – Realistic
    • T – Time-framed 
      • Lead performance indicators: Measure the actions your business takes to improve performance.  They are in-process measures and can be predictive.
      • Lag performance indicators: Report on outcomes. This is an after-the-event measurement, essential for charting progress, but less effective when attempting to influence the future.
      • Note: Lead indicators often require an investment in time to implement. Generally, lead indicators require initiative and/or action prior to a result being seen by a lag indicator.
  • With consideration to your workplace’s Health and Safety Targets, establish a Safety Action Plan. Within the Safety Action Plan outline timeframes and attach responsibilities.
  • Communicate Health and Safety Targets to workplace.
  • Periodically review Health and Safety Targets and Safety Action Plan.

 

As outlined at the beginning of this newsletter, we have opened up our 2016: Safety Planning Survey to all of our friends. Complete the survey (which will remain open during April) and one of our consultants will contact you at a convenient time to discuss. Alternatively, do not hesitate to Contact Us. 

 
www.actionohs.com.au | info@actionohs.com.au | 1300 101 OHS | 1300 101 647

Training: Are you training for compliance or safety?

The majority of workplaces we speak with understand the need for training; however, many do not “understand” the purpose of training. Well-kept and documented training records demonstrate excellent compliance practices, not excellent training practices.

The purpose of training is not to demonstrate your records management skills; it is to ensure that your workers have been provided with the right skills to complete their job safely. Think about it for a moment; has your training been developed for you workers, or have they been developed to tick a compliance box?

Whilst your business may have well-presented training materials, do these training materials focus on all learning styles? If your training is based on paper based instructions or reading off a computer screen, you may have missed the mark for some workers. Robust training should be developed to include all learning styles. One of the most common and widely-used categorisations of learning styles is Fleming’s VARK model. This model suggests there are three learning styles:

  • Auditory:The worker learns through listening. These workers depend on hearing and speaking as their main way of learning. Auditory learners must be able to hear what is being said in order to understand. These workers may have difficulty with instructions that are written.
  • Visual:The worker learns when ideas, concepts, data and other information is associated and presented with images and techniques.
  • Kinaesthetic (Tactile):Learning takes place by the workers doing the task or role playing the task, rather than listening to how the task is done or watching a demonstration.

Whilst most workers will learn across all styles, some may be strongly aligned to one style. To ensure that training is not only a compliance exercise, look to incorporate all three learning styles into the delivery of all of your training sessions.

 

www.actionohs.com.au | info@actionohs.com.au | 1300 101 OHS | 1300 101 647

Technology: Wait, there’s more “stuff” that you don’t have easy access to!

A Safety Officer’s workplace is often a nightmare of folders, disorganised paperwork, papers, folders and more folders; mixed with checklists, spreadsheets and templates. 

Action OHS Consulting is often engaged to undertake safety audits. The nervous Safety Officer that greets us is not an irregularity. Whilst there is no need to be nervous – I get it. Folders for incidents, folders for chemicals, folders full of meeting and training records, spreadsheets acting as risk registers, contractor registers and incident registers partly in Excel with the other part in either Word or Access, not to mention email chain after email chain. This form of management often means that in addition to the desktop audit, we are also engaged to visit multiple sites to “verify” safety performance.

This form of management, to the surprise of the client, regularly leads to gaps in the implementation of the Safety Management Plan that are only picked up when we are on-site. Whilst the client will continue to unsuccessfully search for the requested safety record, is this gap due to the safety record being misplaced, lost, or not completed – we will never know.

There has to be an easier way – and there is. With technology advancing, cloud and web-based solutions are becoming more relevant and accessible.

Cloud based software provides a more efficient and transparent way of working. Automated reminders and remote visibility of implementation, the days of the Safety Officer having to be on-site to “influence” safety is quickly disappearing. Influencing safety is about impacting behaviours and empowering site management to talk and manage safety ongoing. It is about understanding the ‘pain points’ associated with the implementation of your workplace’s health and safety system, with a view to continuously improve these. If a Safety Officer “needs” to be on-site for “safety to happen”; the issue is not safety; it is the knowledge and/or skills of your workplace managers.

The endless nightmare of paper files, or records stored on hard drives, shared over email – restricts the Safety Officer to do their job. It restricts the Safety Officer’s ability to access information to verify and monitor performance when they are not at the workplace.  It moves their role from being a safety leader or coach, to a safety compliance officer. It restricts their ability to influence which limits their ability to improve safety performance.

From our experience, it is obvious that most businesses are keen to take a step forward…some, however, are unsure how to.

Setting up a system that facilitates remote access to workplace specific information such as: incident records and registers; programmed tasks or events; chemical registers; and, maintenance or contractor registers, will allows the Safety Officer to monitor, gather knowledge, and then influence. If the system can also guide your workplace stakeholders of “what they need to do” by email or text message – surely this only makes implementation of your safety system more easy.

With technology progressing, change is imminent and now is an opportune time to consider if you want to lead or follow.

If you are looking to head down the technology pathway, before you start the conversation with providers, take some time to identify what “you want” from a cloud based software system. Consider your current stressors and pain points. Identify your “not negotiables” and “it would be nice if it could”. Be aware that you will be dealing with businesses that have a commercial interest in your decision, meaning that there is a lot of “slick” marketing out there designed to confuse and convince you that their option is the only fit for you. Start the conversation. Ask questions. Ask alot of questions, making sure you think about who you are dealing with. For example, are you dealing with a software company that is knowledgeable about software? Or, a safety focused company that is knowledgeable about software and safety?  

 

 www.actionohs.com.au | info@actionohs.com.au | 1300 101 OHS | 1300 101 647