How to Review the Safety Controls. When it comes to workplace health and safety, risk management involves identifying potential hazards, assessing the risks of those hazards and putting appropriate control measures in place to eliminate or reduce the risks. The work doesn’t stop there however. After control measures have been implemented, every workplace has an obligation to do their best to make sure they remain effective and to review them on an ongoing basis.
Especially as some of us are returning to work and adjusting to a post-COVID world, it’s important that any control measures that have been implemented pre- and post-pandemic are being reviewed and remain effective.
Review the Safety Controls
The control measures that you put in place should be reviewed regularly to make sure they work as planned. Don’t wait until something goes wrong.
There are certain situations where you must review your control measures under the WHS Regulations and, if necessary, revise them. A review is required:
- when the control measure is not effective in controlling the risk
- before a change in the workplace that is likely to give rise to a new or different health and safety risk that the control measure may not effectively control
- if a new hazard or risk is identified
- if the results of the consultation indicate that a review is necessary
- if a health and safety representative requests a
You may use the same methods as in the initial hazard identification step to check controls. Consult your workers and their health and safety representatives and consider the following questions:
- Are the control measures working effectively in both their design and operation?
- Have the control measures introduced new problems?
- Have all hazards been identified?
- Have new work methods, new equipment or chemicals made the job safer?
- Are safety procedures being followed?
- Has instruction and training provided to workers on how to work safely been successful?
- Are workers actively involved in identifying hazards and possible control measures? Are they openly raising health and safety concerns and reporting problems promptly?
- Is the frequency and severity of health and safety incidents reducing over time?
- If new legislation or new information becomes available, does it indicate current controls may no longer be the most effective?
If problems are found, go back through the risk management steps, review your information and make further decisions about risk control. Priority for review should be based on
the seriousness of the risk. Control measures for serious risks should be reviewed more frequently.
Quality assurance processes may be used if you design, manufacture or supply products used for work to check that the product effectively minimizes health and safety risks. Obtain feedback from users of the product to determine whether any improvements can be made to make it safer.
Reviewing Your Control Measures
There are two main components to consider when reviewing your control measures. First, when will you be reviewing them. Managing workplace health and safety is an ongoing process, so your organisation should be reviewing your control measures regularly. Instead of relying on the assumption reviews will happen on an ongoing basis naturally, a schedule should set for when the reviews will happen. How frequently these reviews are scheduled depends on the nature of your organisation. For example, if your company deals with numerous high risks, your control measures should be reviewed more frequently. By having a schedule, you will ensure that your control measures are examined even if they seem to be working fine.
In addition to a schedule, your organisation’s work health and safety plan should include triggers that indicate when a review is required. By having these outlined, it will ensure that measures are reviewed in advance of your schedule if necessary. According to Safe Work a review is required:
- When a control measure is not effective in controlling a risk
- When a change is being made at the workplace that an existing control measure may not be fit to manage
- If a new hazard or risk is identified
- If a consultation indicates a review is necessary
- If a HSR requests a review
The second component to consider is your approach in reviewing the control measures. Essentially you should follow the same steps you take to identify hazards at the beginning of your risk management process. This involves consulting with the workers who are most close to the risk being controlled and working together to address the following:
- Are control measures working effectively in design and operation?
- Are the frequency and severity of health and safety incidents reducing over time?
- Have the control measures created any new problems?
- Have any new equipment or materials been introduced that could affect the effectiveness of the control measure?
- Has any new legislation been introduced that could impact the effectiveness of current control measures?
- Are procedures being followed properly and is employee training up-to-date?
By asking these questions, if there are any issues that come to light with the effectiveness of the control measures, your Health and Safety Representatives and workers can consult to make decisions on what improvements need to be made.
Ensuring your control measures remain effective
Establishing a cadence for control measure checks is one way to ensure your control measures are working as planned. In addition, there are other steps you can take to make sure the effectiveness of your control measures is maintained and they can withstand any changes in operating conditions.
1. Assign accountability
All workers are responsible for being conscientiousness of workplace health and safety, but it’s important to establish to accountability among various levels of management. This ensures the responsibility is assigned to monitor control measures and follow through with processes to flag and fix issues quickly.
2. Open and effective communication
Risk controls stay most effective when processes are well communicated and proper signage is used (in more than one languages if necessary). Additionally, by encouraging open communication, workers will feel more obliged to speak up if problems are noticed.
Within any PCBU, there are many moving pieces and one person, whether it’s a supervisor or manager, can’t have eyes everywhere. As a result, there needs to be consultation with workers and HSRs to provide the most accurate insight into how a control measure is working.
4. Up to date training
Control measures often depend on workers having the appropriate knowledge and skill to manage their work safely. This competency should not be assumed, so regular training must be provided to ensure they are capable.
5. Keep updated on potential hazards
Manufacturers, suppliers and/or industry bodies may find new information about hazards, which could trigger a control measure review, or offer more effective controls for existing hazards that could better ensure the safety of your workplace. Therefore, it’s important to stay apprised of these updates, so that controls stay relevant and as effective as possible – and if changes are required, they happen before something goes wrong.
Controls are put in place to protect the health and safety of the people in your workplace; however, businesses, projects and technology move at a fast-pace, so those measures can quickly become outdated or less effective. By regularly reviewing your controls and establishing ways of maintaining them, any necessary updates should be made obvious and handled swiftly.
Keeping records of the risk management process demonstrates potential compliance with the WHS Act and Regulations. It also helps when undertaking subsequent risk assessments.
Keeping records of the risk management process has the following benefits. It:
- allows you to demonstrate how decisions about controlling risks were made
- assists in targeting training at key hazards
- provides a basis for preparing safe work procedures
- allows you to more easily review risks following any changes to legislation or business activities
- demonstrates to others (regulators, investors, shareholders, customers) that work health and safety risks are being
The detail and extent of recording will depend on the size of your workplace and the potential for major work health and safety issues. It is useful to keep information on:
- the identified hazards, assessed risks, and chosen control measures (including any hazard checklists, worksheets and assessment tools used in working through the risk management process)
- how and when the control measures were implemented, monitored and reviewed
- who you consulted with
- relevant training records
- any plans for
There are specific record-keeping requirements in the WHS Regulations for some hazards, such as hazardous chemicals. If such hazards have been identified at your workplace, you must keep the relevant records for the time specified.
You should ensure that everyone in your workplace is aware of record-keeping requirements, including which records are accessible and where they are kept.