Development of WHS Management Plans

COP | Code of Practice | D&C | Design and Construction | MSDS | Material Safety Data Sheet | NUL | National Uniform Legislation | NTG | Northern Territory Government | PC | Principal Contractor | PCBU | Person Conducting a Business or Undertaking | PPE | Personal Protective Equipment | SWMS | Safe Work Method Statements | WHS | Work Health and Safety |
Practice and code

PCBU | A Person Conducts a Business or Undertaking whether:- Alone or with others- Is conducted for profit or gainIt includes partnership or an incorporated association.Note: Employer is captured under the definition of PCBU(Refer to Subdivision 2, Section 5 of the WHS Act 2011). | PC | A PCBU that commissions a construction project is, thePrincipal Contractor (PC) for the project.If the person engages another PCBU as PC for theconstruction project and authorises the person to havemanagement or control to the workplace and to dischargethe duties of a PC, the person so engaged is the PC forthe project.Note: Construction projects can only one PC at anyspecific time.(Refer to Reg 293 of the WHS (NUL) regulations). |

A Work Health and Safety (WHS) Legislation was developed as a result of acomprehensive national review into work health and safety laws across Australia, whichinvolved substantial public consultation. This initiative provided a framework to protectthe health, safety and welfare of all workers at work and of all other people who might beaffected by the work. The WHS Legislation (NUL) has beencommunicated acrossall Australia Jurisdictions, so that there is the same standard of health and safety protection, regardless of the work being undertaken or the location of that work.
To improved WHS management on construction projects so safety awareness will increase amongst all personnel involved in the project. Benefits of having a Safety Management System includes an enhanced project safety performance, reduce work-related injuries, systematic approach to identify hazards and control risks and increase sense of responsibility and commitment from employees.In essence, a WHS Management Plan should outline the PC WHS structure, roles, responsibilities and authorities, methods of consultation, induction and training, risk management process, subcontractor’s management, injury management and continuous monitoring and review.

Developing a WHS Plan

A WHS Management Plan should demonstrate the integration of WHS requirements with the project procedures, practices and safety management of the project.

DCI has prepared for PC use the, “WHS Management Plan Template document” for preparing a WHS Management Plan and evaluate the Plan against the “Evaluation Template to determine whether a WHS Management Plan meets the minimum standard of compliance requirements.
Both documents outline the relevant sections of the WHS Plan and the minimum requirements to assist in meeting the intent of the WHS Regulations and the Construction
Work Code of Practice (COP).

The size and complexity of a WHS Management Plan will be relative to the size and complexity of the project and particularly to the amount of high risk work being undertaken. According to clause 309 of the WHS Regulation 2011, the WHS Management Plan must include, as minimum the following information:

a) names, positions and health and safety responsibilities of all persons involved with the work whose roles involve specific health and safety responsibilities;
b) the arrangements in place, between any persons working at the site, for consultation, cooperation and coordination of activities in relation to compliance with their duties under the WHS Act and Regulation;
c) the arrangements in place for managing any health and safety incidents, including reporting and incident notification;
d) any site specific health and safety rules and the arrangements for ensuring that all persons are informed of those rules;
e) the arrangements to collect and assess, monitor and review safe work method statements. Additionally, DCI would expect WHS Management Plans prepared according to this guide would meet the minimum requirements established in the “Evaluation Template” before commencing work on the project, which include the following requirements:

1. Project Description
2. WH&S Responsibilities
3. Consultation, Induction and Training
4. Identify Hazards, Assess and Control Risks
5. Managing Subcontractors
6. Managing incidents
7. Monitor and Review of Plan
Description of WHS responsibilities must include the name, position and appropriate authority of personnel to ensure that WHS requirements are met during the course of the project and to define who will implement and maintain workplace health and safety practices in line with the WHS Legislation obligations. Refer to Reg 309 (2) (a) of WHS
(NUL) regulations. The responsibilities should also define who can make decisions and take actions on WHS issues.

Positions that should be defined their WHS responsibilities include:
- Corporate Management (Managing Director, Project Director)
- Superintendent or Representative of the Principal
- Project Managers, Site Managers
- WHS Management Representative
- WHS Committees, as required
- Employees
- Contractors and subcontractors
Subcontractor’s information should include names, positions, contact details, WHS roles and responsibilities in connection with the project.

Some specific aspects for which WHS responsibilities and authorities need to be defined:
- Consultation arrangements (Refer to Part 5 of WHS (NUL) Act 2011)
- Dissemination of WHS information
- Managing WHS design issues
- Hazard identification, risk assessment and control measures
- Preparing and implementing Safe Work Method Statements (SWMS)
- Managing subcontractors and their compliance with WHS requirements
- Planning and conduction WHS Induction and Training

- Inspections and tests and compliance with site safety rules
- Incident reporting and investigations
- WHS injury management and return to work
- Developing and implementing emergency procedures
- WHS Internal audits
- Review of WHS Management Systems implementation Consultation, Induction and Training
Under the WHS Legislation the Principal Contractor is required to consult, cooperate and coordinate with workers and others on matters related to workplace health and safety that directly or indirectly affect the health and safety of people.

In this section methods of internal consultation, effective dissemination of information and decision making process should be established. Interfaces between contractors should describe how forms of consultation will be coordinated and recorded.

The process should be applied by all staff and implemented across all activities with clients, contractors, subcontractors and others who may be impacted by the project operations. The consultation should include a process to inform adjacent and surrounding occupancies of the WHS impact and changes due to the project activities. Additionally in this section the Principal Contractor should describe the system to be implemented for effective communication with personnel working in remote or isolated areas, refer to Reg
48 of the WHS (NUL) regulations.

This section should also include a process where the Principal Contractor reports to the
Superintendent Representative compliance with the WHS contract requirements.

Internal Consultation
Arrangements for consultation can include pre-start briefings, toolbox talks and WHS meetings. Records should be kept showing topics discussed, date of meeting and names of persons attending.

The plan should define how consultation and communication requirements are met, for example, through the establishment of a WHS Committee or WHS Representative or other arrangements for consultation agreed by management and employees.

Where Committees and Health and Safety Representatives are in place for consultation this must be done according to mandated process, “Consultation, Representation and
Participation” WHS (NUL) Act 2011.

Dissemination of information
This section should describe a system for communicating site specific WHS rules to all staff as well as arrangements for dissemination of WHS information to all workers including subcontractors and stakeholders. Refer to Reg 309 (2) (d) of the WHS (NUL) regulations. Safety rules should be concise, simple, short, enforceable, and stated in a positive manner.

Decision making
Consultation is required before taking any decision that may affect the health and safety of personnel while at work. When health and safety hazards and associated risks are identified, control measures should be put in place and should be communicated to all relevant personnel. It is also required to communicate changes to the methods of work, proposed place of work, to the plant/equipment or substances used at work that will affect the health and safety of personnel.

Induction and Training
Induction and training is a key element to ensure personnel are informed about WHS risk management. The WHS Plan must describe how personnel will be inducted on the health and safety requirements. In this section a specific site induction procedure should indicate the process to induct staff, visitors and subcontractors. It is required to indicate how records will be maintained (usually 3 years after project completion).

The Principal Contractor must ensure that the general construction induction training must be completed by all workers, contractors and subcontractors prior start working on site – refer to Reg 317 of WHS (NUL) regulations.

A training plan is considered to be the tool to identify the training needs of personnel for each stage of the project. This tool facilitates ongoing communication with personnel about WHS requirements to ensure that personnel maintain their competences, as required by the project phases.

Training programs should include as applicable, induction to the WHS systems of the company, site induction, emergency procedures, tasks training, general construction induction training, consultation training as well as ongoing training needs.

This section of the plan should indicate how training will be provided to all persons in supervisory positions, personnel conducting safety meetings, inspections, injury and accident investigation, job planning/analysis and leadership skills.

Induction and Training will be required in the following circumstances:

- Personnel commencing work - Introducing site safety rules - Implementing relevant SWMS - When new WHS hazards or risks arise as a result of new tasks, systems, plant and equipment, substances introduced, new workplace or changes in the layout of existing workspace - After an incident occur leading to injury investigations - When changes in the regulatory requirements are identified - For long duration activities a refresher training is required
A procedure will need to be developed and implemented so that the hazards are control in the most effective and efficient manner. The PC has an obligation to eliminate the hazards; if this is not “reasonably practicable” the PC must control the risk by implementing measures to lessen the risk of harm to the lowest possible level.

The hierarchy of control is recommended to be considered until a control measure or a combination of measures can achieve the required reduction in exposure. Hierarchy of control measures are as follows: eliminate, substitute, isolate, engineering, administration and Personal Protective Equipment (PPE).

The plan must include a Risk Management Process which includes hazard identification, risk assessment and mitigation procedures to be applied for the project. A site specific project risk register should be developed identifying the above requirements and using the hierarchy of control to minimise the risks. All high risk construction work activities on the project must be listed in the risk register.

Safe Work Method Statements (SWMS)
Under the WHS Regulation clause 299, SWMS are required to be prepared for high risk construction work before work commences.

High risk construction work is defined by law as any of the following:

 involves a risk of a person falling more than 2 m; or  is carried out on a telecommunication tower; or  (c) involves demolition of an element of a structure that is load-bearing or otherwise related to the physical integrity of the structure; or  involves, or is likely to involve, the disturbance of asbestos; or  involves structural alterations or repairs that require temporary support to prevent collapse; or  is carried out in or near a confined space; or  is carried out in or near: o a shaft or trench with an excavated depth greater than 1.5 m; or o a tunnel; or  involves the use of explosives; or  is carried out on or near pressurised gas distribution mains or piping; or  is carried out on or near chemical, fuel or refrigerant lines; or  is carried out on or near energised electrical installations or services; or  is carried out in an area that may have a contaminated or flammable atmosphere; or  involves tilt-up or precast concrete; or  is carried out on, in or adjacent to a road, railway, shipping lane or other traffic corridor that is in use by traffic other than pedestrians; or  is carried out in an area at a workplace in which there is any movement of powered mobile plant; or  is carried out in an area in which there are artificial extremes of temperature; or  is carried out in or near water or other liquid that involves a risk of drowning; or  involves diving work.

Safety in Design
The new Legislation imposes additional duties on persons that design, manufacture, construct or commission plant, substances or structures to ensure so far as is reasonably practicable that they are designed or manufactured without risks to the health and safety of users. There are also requirements to provide adequate information at the time of supply, including information about design and construction details, the purpose for which the plant or structure was designed or manufactured, the results of any calculations or tests conducted and any requirements to ensure the plant or structure (or substance) is safe when used for the purpose it was designed or manufactured for.
The plan would require defining how Safety in design process will be applied to mitigate hazards/risks for each stage of the life cycle of the project at the design stage as far as possible. The process should identify hazards and analyse risks during the conceptual design phase to decommissioning phase.
Managing Incidents
This section should outline the procedures developed by the Principal Contractor for management of incidents, emergencies and first aid.

Incident Management
This procedure should describe details of the reporting, logging, investigating, and corrective actions in response to injuries, incidents and accidents at the worksite and client sites.

This section should describe the arrangements to stabilise and evacuate any injured person, isolating the incident scene, making the workplace safe after the incident, notification and investigation. Refer to Section 35 – 39, Part 3 of the WHS (NUL) Act
2011 and Reg 42, 43 of the WHS (NUL) Regulations.

Incident investigation will help the Principal Contractor to identify control measures that will prevent recurrence of the same incident. Some definitions to be considered when Term | Definition | Accident | An undesirable event which results in harm to people, damage toproperty or loss time | Incident | An “incident” is any unplanned event resulting in, or having apotential for injury, ill-health or other loss. | Near Miss | Any unplanned incident that occurred at the workplace that didnot result in an injury but had the potential to do so. | Lost Time Injury(LTI) | A work injury resulting in time lost from work of equal to or greaterthan one workday or shift (8 hours) on which the injury occurs. | Medical TreatmentInjury (MTI) | A work injury that does not result in lost time but requirestreatment by a medical practitioner. | First Aid Injury(FAI) | A work injury for which only first aid treatment was administeredon site. | undertaking an incident investigation include:

be reported in a timely manner after they occur. Notification to the regulator (NT WorkSafe) must be in accordance with the statutory reporting requirements of Part 3 clauses 35 to 39 of the
WHS (NUL) Act 2011,

Emergency Procedures
An emergency plan must be prepared for a construction project to ensure to the extent possible the safety of all employees, visitors, contractors, and subcontractors at the time of emergency situations.
The plan should include:
- effective response to any emergency situation (that are reasonable foreseeable)
- evacuation procedures
- emergency services notification
- medical treatment and assistance
- communication of emergency instructions to all workers at the site

The plan should describe the arrangements for information and instruction requirements to relevant workers in relation to implementing the emergency procedures. All employees and contractors should be trained in the emergency plan. The Principal Contractor should define the inspections to be carried out for the means of access and egress to determine that they are clear, unobstructed and operable. A site specific emergency evacuation map must be developed showing the muster point.

First Aid Treatment
In this section the Principal Contractor must ensure that there is provision for and access to first aid equipment and other first aid facilities at the workplace. This section should include arrangements for training in first aid and how first aid equipment will be provided by contractors and subcontractors. Refer Reg clause 42 of the WHS (NUL) Regulations.
First aid information should include the frequency to restock the first aid kit(s) as well as emergency phone numbers for medical services and key company personnel.

Monitor and Review of Plan

This is a legislated requirement (refer to Reg 311 of the WHS (NUL) Regulations.

WHS internal audits and inspection programs are the tool to monitor high risk activities and construction works. The purpose of the audits is to determine whether an area is complying with the documented procedures and to recommend improvements or corrective actions.

This section should define a plan to monitor frequency, thoroughness and results of inspections and audits throughout the project.

Document Control
Additionally, this section requires a process to describe how project safety documentation is maintained. A procedure should be established for the control, approval, retention time, dissemination, storage and disposal of WHS documents and records.

Safety records include training records, qualification of individuals, inspection reports, plant and equipment records, work permits, safety equipment records, incident investigation reports, risk assessments, MSDS, minutes of safety meetings, audit reports, workers compensation records, etc.

Work Health and Safety (WH&S) Management Plan Evaluation Template

This template has been developed in accordance with Reg 309 of the Work Health & Safety
Regulations and Work Code of PracticeOP).WHS Management Plans prepared according to the Guide Document for Development of WHS Management Plans August 2012 would meet the minimum requirements established in this evaluation.
The complexity of any submitted WH&S Management Plan will be relative to the size and complexity of the project and particularly to the amount of high risk work being Assessment Criteria | Yes /No | Comments(Details of Agency evaluation) | Description |  Does the project WHS Plan refer to the correctproject and address? | | |  Are provisions to ensure a site layout plancovering temporary accommodation, storage,pedestrian and vehicular routes, plant locationand emergency provisions been devised? | | |  Does the project description include reports on allhazards and risks at or in the vicinity where theconstruction work is to be carried out that havebeen identified as part of a safety in designprocess? | | |  Does the WHS Plan address the requirement forthe Principal Contractor to: ensure that signage isinstalled showing the PC’s name, telephone,contact numbers (including after hours telephonenumber), show the location of the site office forthe project and be clearly visible from outside theworkspace? | | | undertaken. Consultation, Induction and Training |  Is there a process for staff and visitor induction ortraining, to allow access to site that communicatesall relevant safety information?Note: General construction induction training mustbe completed prior start on-site | | |  Has a schedule of Principal Contractor andSubcontractor meetings been developed (this mayinclude pre-shift briefs, toolboxes, WHSMeetings)? | | |  Are details of any WH&S meeting participantsdocumented – that is, will other contractors andsubcontractors be required to attend? | | |  Does the WHS plan include any site-specifichealth safety rules, and the arrangements tocommunicate these rules as well as other WHSrequirements to all workers, contractors andsubcontractors? (safety information to be providedto visitors and stakeholders, as required) | | |  Is there a process to inform adjoining andsurrounding occupancies of the WH&S impacts /changes due to the project? | | |  Does the WHS Plan describe the system foreffective communication with personnel working inremote or isolated areas (if applicable) | | |  Has a schedule and process for reporting to theSuperintendent Representative been developedby the Principal Contractor that satisfies the WHScontract requirements? | | |  Does the WHS Plan include arrangements forensuring that any relevant WHS training isprovided to the workers, as required? | | |

 Has induction and training requirements beenconsidered for the following circumstances:- Personnel commencing work- Introducing site safety rules- Implementing SWMS- New hazards or risks arise as result of newtasks, systems, plant and equipment,substances introduced, new workplace orchanges in the layout of the workplace- After an incident occur- When changes to regulatory requirements- For long duration activities | | |

Managing incidents |  Have arrangements for managing safety incidentsbeen developed? | | |  Has an emergency management procedure that isapplicable for the site conditions been developed?Note: This must include first aid equipment andfacilities and training of personnel to administerfirst aid at the workplace. | | |  Does the emergency management plan include:- effective responses to emergency situations;- evacuation procedures;- emergency services notification;- medical treatment procedures;- communication of emergency instructions to allworkers at the site;Is the emergency management plan site specific(not generic) | | |

 Has induction and training requirements beenconsidered for the following circumstances:- Personnel commencing work- Introducing site safety rules- Implementing SWMS- New hazards or risks arise as result of newtasks, systems, plant and equipment,substances introduced, new workplace orchanges in the layout of the workplace- After an incident occur- When changes to regulatory requirements- For long duration activities | | |

 Are there arrangements to ensure testing andrevising of the emergency managementprocedures?(refer Reg 43 (b) of the WHS (NUL) regulations) | | |  Are there arrangements to ensure training of allworkers including visitors on the emergencymanagement plan?(refer Reg 43 (c) of the WHS (NUL) regulations) | | |  Have emergency contact details been provided? | | |  Does the plan ensure timely reporting of notifiableincidents will occur in accordance with thestatutory reporting requirements to theSuperintendent or the Representative?- Reporting to the Superintendent or otherappointed representative of the Principal.- Principal Contractor’s internal reporting andincident investigation- Reporting to NT WorkSafe | | | . Monitor and review of Plan |  Does the Principal Contractor have a system inplace for the review of their WHS ManagementPlan to ensure it remains up-to-date and projectpersonnel are aware of any revision?(refer Reg 311 of the WHS (NUL) regulations) | | |  Has WHS internal audits and inspection programsbeen established that is incorporated at all levelswith appropriate staff, auditors, and other experts? | | |  Is there a plan to monitor frequency,thoroughness and results of inspections andaudits throughout the project? | | |  Does the Principal Contractor describe theprocess to be used to ensure documentation iscontrol, approved and maintained relating to theproject? (noting statutory requirements for thestorage and disposal of documents) | | |

Reference http://www.worksafe.nt.gov.au/home.aspx Safe Work Australia http://www.safeworkaustralia.gov.au/sites/SWA/Pages/default.aspx Northern Territory Legislation http://notes.nt.gov.au/dcm/legislat/legislat.nsf/d989974724db65b 1482561cf0017cbd2?OpenView
Office of the Federal Safety Commissioner
http://www.fsc.gov.au