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withWorkplace

Healthand Safety

An Introduction to Workplace Health and

Safety Policies, Procedures and Evaluation

Getting Started

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Victorian WorkCover Authority

Revised June 2001First published February 1997

ISBN 0 7311 0478 1

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Getting Startedwith

WorkplaceHealth

and SafetyAn Introduction to Workplace Health and Safety

Policies, Procedures and Evaluation

Getting Started with Workplace Health and Safety 1

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The Getting Started with Workplace Health and Safety Series 3

Managing Health and Safety in your Business 4

The Legal Framework 5

Health and Safety Policies and Procedures 7

Preparing a General Health and Safety Policy 9

Specific Policies and Procedures 11

Evaluating Health and Safety Performance 20

Sources of Further Information 27

WorkSafe Victoria Offices 28

2 An Introduction to Workplace Health and Safety Policies, Procedures and Evaluation

Contents

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The four booklets in this Getting Started seriesprovide an introduction to:

E workplace consultation

E hazard management, workplace inspection andselecting a health and safety consultant

E workplace health and safety roles andresponsibilities, training, information and records;and

E workplace health and safety policies, proceduresand evaluation.

These booklets are written for employerrepresentatives, health and safety representatives,health and safety committee members and otheremployees. They explore the key features ofeffective health and safety managementarrangements, and are designed to show thatgetting started on improved health and safety in theworkplace is not difficult.

Successfully managing health and safety in theworkplace relies on commitment, consultation andco-operation. Everyone in the workplace needs tounderstand the need for health and safety, whattheir role is in making the workplace safer, and howthey can fulfil their responsibilities and duties underthe Occupational Health and Safety Act 1985.

The Act provides a framework for consultationbetween employers and employees on health andsafety. Effective consultation can make a realdifference to workplace health and safetymanagement. Change for the better is not difficultto achieve when employers and employees worktogether and co-operate to find solutions toproblems.

Setting up a hazard management program — toidentify workplace hazards, to assess the risks thosehazards pose to the health and safety of people inthe workplace, and to introduce measures tocontrol those risks — is the basis for a planned,systematic approach to making sure workplaces arebetter places to be. Consultation about health andsafety, and developing policies and procedureswhich are backed up by information and regulartraining will have a real effect on reducing andpreventing injuries at work.

These four booklets can help establish a health andsafety management program. Other publications,including a Guide to the Occupational Health andSafety Act 1985, and practical guidance on gettingstarted on health and safety is available fromWorkSafe Victoria offices listed at the end of thisbooklet.

Getting Started with Workplace Health and Safety 3

The Getting Started with WorkplaceHealth and Safety Series

Successfully managing health and safety in the workplace relies on commitment,consultation and co-operation. Everyone in the workplace needs to understand the need forhealth and safety, what their role is in making the workplace safer, and how they can fulfiltheir responsibilities and duties.

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To run a successful business you need to managethe quality of your product or service, and theproductivity of your business. You also need tomanage the health and safety of the people whowork for you. The way you do these things isdetermined by your management system.

Your management system may be an informalsystem of registers, diaries, instructions, workbooksand your memory. Or it may be a formal,completely documented system following theAustralian–New Zealand Standard AS/NZS 4801 —Occupational Health and Safety Management Systems:Specification with Guidance for Use. Further guidelineson establishing a safety management system can begained from the Australian Standards for QualityManagement and Quality Systems (ISO 9000 Series).The more complete and orderly your system is, theeasier it is for you and your employees to follow. Itwill also lead to better results for your business.

Health and safety is part of your business, just likeproduction and quality. Health and safety affectsproduction, quality, and your financial results. So itshould be managed in the same way as otheraspects of your business. To manage health andsafety effectively you need to:

E set your health and safety objectives, and planhow you will achieve them;

E decide who is responsible for getting thingsdone;

E give those responsible the skills and resourcesto do the job; and

E regularly check that you are meeting yourobjectives.

During this process it is important to write downwhat you are doing, to involve the people in yourworkplace in the process, and to keep checking tosee it is all working. Documenting your system,consulting with employees and evaluating andmodifying your system means your system will bemore effective.

The long term success of workplace health andsafety plans depends on the commitment ofeveryone in the workplace.You have a good chanceof getting this commitment if management consultswith employees. Section 31(2)(c) of theOccupational Health and Safety Act 1985 statesemployers are required to consult with health andsafety representatives about work activities andpractices whenever practicable. Employees havevaluable on-the-job experience and they will becarrying out the plan. They can help successfullywork health and safety into the day-to-day runningof the business.

4 An Introduction to Workplace Health and Safety Policies, Procedures and Evaluation

Health and safety is part of your business, just like production and quality. Health andsafety affects production, quality, and your financial results. So it should be managed inthe same way as other aspects of your business.

Managing Health and Safetyin Your Business

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The Occupational Health and Safety Act 1985 andassociated regulations set out a legal framework forworkplace health and safety. Specific sections of theAct apply to the development of policies andprocedures, and employers’ general duty of careunder the Occupational Health and Safety Act is to:“… provide and maintain so far as is practicable foremployees a working environment that is safe andwithout risks to health” (Section 21).

“Practicable” involves doing what can be done inthe light of:

a) the severity of the hazard or risk in question;

b) the state of knowledge about that hazard or riskand any methods of removing or mitigating thathazard or risk;

c) the availability and suitability of ways to removeor mitigate that hazard or risk; and

d) the cost of removing or mitigating that hazardor risk.

Section 21(2) sets out a number of ways to meetthis general duty.These include:

E providing and maintaining safe plant and systemsof work;

E arranging safe systems of work when workingwith plant and substances;

E providing a safe work environment;

E providing adequate welfare facilities; and

E providing adequate information on hazards, aswell as instruction, training and supervision toemployees, to enable them to work safely andwithout risks to health.

Section 21(3) states that employers have thesame responsibility to independent contractors andtheir employees who are working at the workplaceon matters under the employer’s control.

Section 21(4) provides that employers are alsorequired to, as far as practicable:

E monitor the health of their employees;

E keep information and records relating to thehealth and safety of their employees;

E employ or engage suitably qualified persons toprovide advice on the health and safety of theiremployees;

E nominate a person with an appropriate level ofseniority to be the employer’s representativewhen health and safety issues arise or whenhealth and safety representatives carry out theirfunctions under the Act;

E monitor conditions at any workplace undertheir control and management; and

E provide health and safety information to theiremployees, in appropriate languages, includingthe names of persons to whom an employeemay make an inquiry or complaint in relation tohealth and safety.

Section 22 requires employers to ensure that thehealth and safety of members of the public is notadversely affected by their business activities.

Getting Started with Workplace Health and Safety 5

The Occupational Health and Safety Act sets out employers’ general duty of care, with specific sections on the development of policies and procedures.

The Legal Framework

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The Occupational Health and Safety Act 1985 alsosets out an approach to developing policies andprocedures where a health and safety committee isestablished (Section 37(4)(b)). One of thefunctions of a committee is to: “… formulate,review and disseminate (in such languages as areappropriate) to the employees the standards, rulesand procedures relating to health and safety whichare to be carried out or complied with at theworkplace.”

In other words, the Occupational Health and SafetyAct anticipates policies and procedures will bedeveloped for your workplace. It also anticipatesyour health and safety committee will be involvedin developing and implementing them.

What health and safety managementarrangements do you have in placenow?

To find out how your current health and safetyperformance measures up, some key questionsneed to be asked:

E Do you know if you are complying with thehealth and safety laws affecting your business?

E Do you have copies of the legislation,regulations, codes of practice and AustralianStandards which apply to your workplace?

E Are there arrangements in place forconsultation between management andemployees or their nominated representatives?

E Are there any elected health and safetyrepresentatives? Are they trained?

E Is there a health and safety committee? Is itfunctioning?

E Do you have a general health and safety policy?Is it in writing?

E Do you have policies to deal with particularspecific health and safety issues in yourworkplace?

E Is there a systematic written procedure foridentifying hazards and assessing risks in yourworkplace?

E Has a workplace health and safety inspectionprogram been introduced? Is it working?

E Are health and safety aspects always consideredwhen operating procedures and workinstructions are developed?

E Is health and safety always considered whenplanning, designing or purchasing new equipmentor processes?

E Do you have written operating procedures forall normal operations?

E Do new and transferred employees receiveinstruction in your health and safety policies andprocedures?

E Is there a procedure and timetable for reviewingworkplace procedures?

E Do you have procedures for emergencies andfirst aid?

E Do you know how well you perform in healthand safety?

E How do you know if you are meeting your ownstandards for health and safety?

E Is health and safety performance taken intoaccount when assessing the performance ofsupervisors and managers?

E What do your employees think of your safetystandards?

E Are all injuries, ill-health and incidents recorded,investigated, reported (if required) and analysedfor trends? Is this information made available tomanagers and employees?

6 An Introduction to Workplace Health and Safety Policies, Procedures and Evaluation

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Why should you have health andsafety policies and procedures?

Health and safety policies and procedures are partof a framework for effective health and safetymanagement. A general health and safety policystates management’s intention to provide a safe andhealthy workplace, and states the health and safetygoals of a workplace. It should also demonstrate theemployer’s acknowledgment of their legal dutiesand their intention to voluntarily comply with thoseduties.

Specific policies and procedures address particularissues or hazards.They are administrative measuresto control workplace hazards and should be usedtogether with other hazard control measures toeliminate or reduce the risk of workplace illness orinjury.

An objective of the Occupational Health and SafetyAct 1985 is the elimination, at the source, of risks tothe health, safety and welfare of persons at work.Regulations supporting the Occupational Health andSafety Act require the elimination of risks as thefirst step in risk control. For example:

E Elimination — eliminating toxic substances,hazardous plant or processes which are notnecessary to a system of work.

If risks cannot be eliminated, occupational healthand safety legislation requires that they be reducedso far as is practicable by using one or more of thefollowing methods:

E Substitution — substituting a toxic substance,hazardous plant or process with one known tobe less harmful to health. Substitution is not onlya preferred control method, it may also be the

least expensive. For example, substituting a lesshazardous material to control a vapour hazardmakes more sense than installing an expensiveventilation system.

E Isolation — enclosing or isolating a hazard suchas a toxic substance, plant or process fromemployees, to eliminate or reduce the risk ofinjury or illness. Using a fume cupboard orsound enclosure booths are examples of movinga hazardous process away from the main workarea (and other employees) to a site whereemissions can be controlled.

E Engineering controls — changing processes,equipment or tools, for example:

e machine guards and machine operationcontrols;

e ventilation to remove chemical fumes anddusts, and using wetting down techniques tominimise dust levels;

e changing layout of work levels to minimisebending and twisting during manual handling.

If a risk to workplace health and safety remainsafter the above methods have been used,administrative controls should be applied or, ifthese are still not adequate, personal protectiveclothing and equipment worn.These methods ofrisk control are not preferred because the sourceof the risk is not eliminated or reduced.

E Administrative controls — changing workprocedures to reduce exposure to existinghazards. For example:

e reducing exposure to hazards by jobrotation;

Getting Started with Workplace Health and Safety 7

Specific policies and procedures address particular issues or hazards.They are administrative measures to control workplace hazards and should be usedtogether with other hazard control measures to eliminate or reduce the risk of workplaceillness or injury.

Health and Safety Policies andProcedures

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e limiting the number of employees exposed tothe hazard by limiting access to hazardousareas.

E Personal protective clothing and equipment— devices and clothing which provide individualemployees with some protection from hazards.An effective personal protective clothing andequipment system requires considerable effortby the employer to ensure that:

e proper protective devices are selected;

e employees are individually fitted;

e proper instruction on the need for, and useof, personal protective clothing andequipment is provided;

e standards are enforced; and

e an effective system of cleaning andmaintenance is devised.

Administrative controls and protective clothing andequipment may provide interim solutions in aplanned program to eliminate or reduce aparticular risk, or they may be used in addition toother control methods.

Specific health and safety policies and proceduresshould provide clear direction or instruction bywhich workplace hazards will be identified, and therisks assessed and controlled by the measuresdescribed here.A formal policy or procedure canensure hazards are dealt with in a structured andagreed manner, rather than in response to a crisis.

More information about hazard identification, riskassessment and risk control is in the Introduction toHazard Management booklet in the Getting Startedwith Workplace Health and Safety series.

Who’s responsible for developingpolicies and procedures?

Developing policies and procedures is amanagement responsibility. Consultation withemployees however, is very important. Section31(2)(c) requires employers to consult with healthand safety representatives on work practiceswhenever practicable. Consultation helps to createpolicies that can be understood, will work, and willbe followed.

Developing procedures does not make employeesresponsible for hazards at work.The responsibilityfor ensuring the workplace is safe, and that workprocedures are followed remains a responsibility ofthe employer.This responsibility is set out in Part IIIof the Occupational Health and Safety Act 1985.

There may be times when you need to call onspecialist assistance from within or outside yourorganisation to help develop policies andprocedures.The Introduction to Hazard Managementbooklet also includes a section on selecting aconsultant.

8 An Introduction to Workplace Health and Safety Policies, Procedures and Evaluation

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Why do you need a general health andsafety policy?

A properly prepared health and safety policy clearlystates health and safety objectives and theorganisation’s commitment to improving health andsafety performance. It also acknowledges theemployer’s legal responsibilities.

Preparing a health and safety policy is an importantpractical step towards providing and maintaining awork environment that is safe and without risks tohealth.

How do you prepare a general healthand safety policy?

Successfully preparing a policy requiresconsultation. Elected health and safetyrepresentatives, nominated managementrepresentatives responsible for health and safetyand employees can all contribute to ensure aneffective health and safety policy.

Health and safety policies will vary from oneorganisation to another, and should reflect theparticular needs and operation of the organisationpreparing the policy.The policy should also reflectthe relevant requirements of the OccupationalHealth and Safety Act 1985.

The suggestions in this booklet can be used as astarting point when preparing or updating yourhealth and safety policy.

What should the policy include?

The policy statement should indicate, in clear andsimple terms, your company’s health and safetyobjectives. It should describe the arrangements toachieve those objectives, including the allocation offunctions and roles. It should be signed and datedby the chief executive or equivalent of yourorganisation.

Issues that should be covered include:

E senior management commitment to theprovision and maintenance of a workingenvironment which is safe and without risks tohealth;

E the integration of that commitment into allorganisational activities;

E a commitment to establishing the functions androles of all people in the organisation involvedin maintaining workplace health and safety;

E accountability of all levels of management forimplementing health and safety practices andprocedures;

E the importance of consultation and co-operation between management and employeesfor effective translation of objectives into action;

E training in, and communication of, health andsafety practices and procedures; and

E commitment to regular monitoring and reviewof the policy and its effectiveness.

Getting Started with Workplace Health and Safety 9

Preparing a General Healthand Safety Policy

Preparing a health and safety policy is an important practical step towards providing andmaintaining a work environment that is safe and without risks to health.

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What is an effective policy?

To be effective, a health and safety policy shoulddetail the organisational arrangements foridentifying and controlling health and safety issues.It should also lay the basis for employeeinvolvement, the setting of goals, action plans, andpolicy review.

Those preparing the policy should ensure that:

E there is a plan to implement the policythroughout the organisation;

E the contents of the policy show those involvedin its preparation understand the hazards andneeds of the workplace, and have worked outthe detailed arrangements needed to fulfil thepolicy;

E concern for health and safety is integrated intoevery level of the organisation;

E the policy functions in the same way asproduction or financial policy;

E roles and functions are clearly defined andassigned;

E methods of ensuring tasks are done areincluded;

E proper procedures and programs to support thepolicy are established, maintained and reviewed;

E there is adequate provision of financial andother resources to support the policy’sdirection; and

E there is recognition of the benefits ofconsultation between management, health andsafety representatives and employees.

Regardless of your organisation’s size, a writtenstatement of health and safety policy demonstratessenior management’s determination to ensure highstandards of health and safety.

A health and safety policy also provides a vitalmeans of support for managers, supervisors oremployees if they are faced with a conflict betweenproduction demands and the demands of safety.

Health and safety should not take second place.Preparing a policy, renewing and updating it in thelight of experience and workplace changes allowsthe organisation to promote and maintain themomentum of the health and safety program in theworkplace.

The policy should demonstrate concern for thehealth and safety of employees, and mostimportantly, management commitment totranslating that concern into effective action.

10 An Introduction to Workplace Health and Safety Policies, Procedures and Evaluation

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Specific workplace health and safety policies andprocedures are only one part of controlling risks tohealth and safety. As administrative controlmeasures, they are low on the risk controlhierarchy and should be used with other moreeffective measures such as elimination andsubstitution.

What is the difference betweenpolicies and procedures?

A policy is a statement about an issue in theworkplace and says what the business intends to doabout the issue.A policy describes:

E the desired standard;

E a specific objective to meet;

E a timeframe;

E arrangements for reviewing the policy;

E management’s commitment to fulfilling thepolicy;

E steps to be taken to implement the policy; and

E what is expected of all employees in relation tothe particular issue.

If the workplace is going to be successful infollowing that policy, all employees affected by theissue must know about and understand the policy.

A procedure sets out step-by-step instructions onhow to deal with an activity in the workplace.Activities which may have specific proceduresdeveloped include:

E working in confined spaces;

E resolving issues;

E evacuations;

E the overall work flow, from materials cominginto the workplace, to the final product goingout;

E workplace inspections; or

E administrative activity like purchasing.

Where there are workplace hazards, and risks tohealth and safety, the procedure sets out what todo at every stage of the activity.

Procedures need to work.They need to be testedthoroughly before they are implemented.Employees engaged in an activity must clearlyunderstand and be able to follow any relevantwritten procedure.

How do you establish specific healthand safety policies and procedures?

There are five steps to establishing specific healthand safety policies and procedures:

Step 1: Identify workplace hazards and issues.

Step 2: Collect information about the hazardousactivity or issue.

Step 3: Prepare the policy or procedure.

Step 4: Implement the policy or procedure.

Step 5: Review the policy or procedure and makechanges if required.

Getting Started with Workplace Health and Safety 11

Policies and procedures need to work.They need to be tested thoroughly before they areimplemented. Employees engaged in an activity must clearly understand the relevant healthand safety policy and be able to follow written procedures where appropriate.

Specific Policies and Procedures

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Step 1: Identify workplace hazardsand issues

The need for specific health and safety policies andprocedures can be determined through the processof hazard identification, risk assessment and riskcontrol. This process is described in detail in theIntroduction to Hazard Management booklet in theGetting Started with Workplace Health and Safetyseries.

Regardless of the type of work, many workplaceshave specific policies which support their generalhealth and safety policy and relate to all employees.Common policies include:

E non-smoking policy;

E policy on use of drugs and alcohol; and

E housekeeping policy.

If there are other particular health and safety issuesor hazards in your workplace, you may need todevelop a policy which deals with them. Forexample, if there is a lot of manual handlingrequired in the workplace, then a specific writtenpolicy makes the employer’s intentions clear. It alsodefines roles in preventing and dealing with manualhandling injuries.

To work out what policies and procedures youmight need, the most useful information is availablewithin your workplace:

E consult with health and safety representatives.They are trained in health and safety legislation,principles and practice, and their input topolicies and procedures will be based on theirknowledge of health and safety and theworkplace;

E talk with employees.They know about the workprocesses because they work with them daily;

E look at accident and incident statistics. Theyoften indicate serious existing or potentialhazards; and

E check the minutes of the health and safetycommittee.They will provide a record of issuesneeding attention.

What procedures do you need?

You may not be able to develop a procedure forevery activity in the workplace — at least not in theshort term. Start with those which have the mostsignificant impact on health and safety.These mightbe specific activities such as handling hazardoussubstances, or they may be general processes suchas purchasing equipment. In some cases you willhave to start from scratch. In other cases you canbuild on a health and safety standard which must befollowed for a particular procedure.

There are many aspects of your work environmentwhere written procedures will help preventworkplace illness and injuries and control hazards attheir source. Some examples where writtenprocedures may be required are:

E specific workplace hazards

e identification and assessment of the risks

e risk control

e reporting hazards;

E issue resolution;

E consultation on proposed change;

E workplace inspections;

E investigating incidents and issues, with correctiveactions;

E reactive and response activities such as:

e first aid and medical emergencies

e reporting illness, injury

e reporting incidents and dangerousoccurrences;

12 An Introduction to Workplace Health and Safety Policies, Procedures and Evaluation

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E administrative activities such as record keepingand purchasing;

E legal responsibilities in relation to:

e contractors

e visitors

e injury records

e health monitoring

e complying with new regulations which applyto the workplace.

You will need to look at all the activities in yourworkplace to assess the needs and the priorities forpolicies and procedures. Taking stock of theactivities in your workplace will be part of youroverall management and you can use thisinformation in other aspects such as working outtraining needs and allocating roles or functions.

You will also need to be aware of changes in theworkplace and how these could affect your needfor policies or procedures. Changes to the plant,substances or the equipment you use, the layout ofyour workplace, or to regulations and codes ofpractice could create a need for new or revisedprocedures and policies.

To determine priorities, it will help to ask:

E Is the activity or hazard causing frequent orsevere incidents or ill health?

E Is the hazard or activity new to the workplace?

E How important is the issue to employees?

Step 2: Collect information about theactivity

You need accurate and up-to-date information toensure each policy or procedure contains the mosteffective preventive strategy. Some information youneed will be technical. Other information will bepractical and help with implementation.

What sort of information do you need?

The type of information you need is determined bythe activity concerned and whether you aredeveloping a policy or a procedure. In general, youneed information which will tell you or allow youto work out:

E the causes of the hazard and factors creating therisk;

E relevant legal standards or requirements;

E possible control measures; and

E workplace factors which will affectimplementation of the policy or procedure.

Where do you find the information?

There are many different sources of information.Much of the information is available in yourworkplace, but some will only be availableexternally. Possible sources include:

E health and safety representatives

E employees

E regulations, standards, codes of practice

E WorkSafe Victoria field officers and educationofficers

E investigation reports

E consultants’ reports

E your records, knowledge and experience

E product and equipment specifications

E WorkSafe Victoria’s website (www.workcover.vic.gov.au) and other government websites

E industry organisations

E publications and journals on health and safety.

Health and safety representatives and employeeswill probably be your most important informationsource. Without their contribution managementwill not be able to ensure the policy or procedureis realistic.

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Occupational health and safety legislation andregulations set out the minimum requirements youneed to meet. Codes of practice provideinformation on how to go about reaching thelegislative standards.

Inspection or consultants’ reports about conditionsin the workplace will also provide usefulinformation about hazards and existing controlmeasures. They can help make sure policies andprocedures reflect the circumstances actuallyexisting at the workplace. Finding out about thework environment also means health and safetypolicies and procedures can be prepared which areconsistent with other aims of the workplace.Youneed to be aware of all the possible problems oralternatives while an activity is being carried out sothey are all covered in the procedure.

Health and safety records will help identify thedegree of risk posed by a hazard and theeffectiveness of existing control measures. If you donot already have a good system for managing healthand safety records, the Introduction to Health andSafety Responsibilities, Roles and Functions in theGetting Started with Workplace Health and Safetyseries can provide useful guidance on establishing arecording system.

Product and equipment specifications providetechnical data on hazards and suitable controlmeasures, and Material Safety Data Sheets (MSDS)are a good source of detailed information aboutchemical risks and their control.

WorkSafe Victoria field officers will assist all partiesinvolved in workplace health and safety withrelevant information, specialist advice and educationactivities, such as:

E providing practical, accessible and customisedguidance material on hazard identification, riskassessment and risk control, and

E promoting the establishment of health and safetycommittees, and effective workplacecommunication, consultation and issueresolution procedures.

Other organisations in your industry may havealready developed control measures for hazards.You can learn from their experience.They might tellyou which control measures they use, how themeasures were implemented, if they worked andhow they have been changed if required.You couldalso check your industry association, or the SHARESolutions Manual for this type of information.

Step 3: Prepare the policy orprocedure

It is very important to consult with employeeswhile preparing policies and procedures. Employeeswill be involved with implementing any newarrangements, and because of their day-to-day“hands on” role, they are likely to know whetherthe proposed arrangements will work. If the peoplewho are affected by the procedures or policies areinvolved in their development, it is also likely thattheir commitment to making those policies andprocedures work will follow.

A draft policy or procedure could be prepared bymanagement, a working group, the health and safetycommittee, health and safety representatives, healthand safety officers or an experienced supervisor forcomment.The health and safety committee shouldreview the document before it is tested.

14 An Introduction to Workplace Health and Safety Policies, Procedures and Evaluation

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How do you write hazard policies?

A policy provides a broad statement of intentregarding a health and safety hazard or issue in theworkplace. A policy should be a statement ofcommitment, goals or standards, and responsibilities,and it should also set out how it will beimplemented.A policy should include the followingsections:

E a statement of the purpose of the policy;

E a statement of the legal duty of management;

E an expression of the organisation’s commitmentto controlling the hazard or issue at its source;

E an outline of how the hazard or issue will becontrolled, including resources to be providedand a timeframe for action;

E the roles and accountabilities of relevantstakeholders, particularly managers andsupervisors; and

E a description of how the policy will beimplemented.

How do you write procedures?

A procedure is very specific, with step-by-stepdirections for an activity, including the steps to takeif a problem occurs.

Health and safety procedures can often beintegrated into procedures covering other aspectsof the workplace. For example, a purchasingprocedure should include an assessment of thehealth and safety implications of equipment. Thismeans health and safety issues are dealt with beforepurchase, saving time and money.

Sometimes a specific health and safety procedure,such as a first aid procedure, needs to beestablished.The procedure should be:

E clear and understandable by all employees whoare affected; and

E thoroughly tested before use.

The point of any procedure is to make an activityrepeatable, reliable, traceable, safe and without risksto health.

A procedure could include the following sections:

E a statement of the purpose of the procedure;

E the standards required, from a policy, or code ofpractice for example;

E the specific steps to be followed which willensure achievement of standards and controlmeasures;

E roles and accountabilities; and

E a clear statement of any actions to be takenwhen the procedure is not followed.

Procedures can be written in a range of formatssuch as work instructions, flow charts or guidelines.

Step 4: Implement the policy orprocedure

Policies can be used to provide information aboutparticular health and safety goals. They are astatement to all employees and therefore need tobe communicated to all employees.

Procedures are used in a variety of ways.They areused for instruction, supervision and hazard controlactivities, including investigations. Becauseprocedures must be understood before they can beimplemented, an important part of implementationis working out the best way to communicate theinformation to employees. Implementing aprocedure may also require resources and changesto existing administrative procedures.

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How do you inform employees?

Everyone should be aware of the policies andprocedures which have been developed for theworkplace. Employees directly involved will needdetailed knowledge of all relevant policies andprocedures.You could do this by:

E explaining policies and procedures duringinduction training;

E including information on policies andprocedures in refresher training; and

E filming and presenting information in a video.

Section 21(4)(e) of the Occupational Health andSafety Act 1985 requires employers to provideworkplace health and safety information inappropriate languages.

You could also:

E test persons covered by the policy or procedurebefore allowing them to undertake work (e.g.contractors);

E make up posters or laminated pocket cards forall employees;

E use illustrated flow charts for complicated orlong procedures; or

E prepare a health and safety manual for use by allemployees.

What support systems do you need?

Implementing a policy or procedure may requirenew equipment, revised maintenance procedures ordifferent reporting systems. For example, a policyto reduce incidents involving forklift trucks mayrequire a change to the workplace layout. Ifpedestrians and vehicles have to be separated, youmay need to paint lines, set up barriers and banforklifts and pedestrians in certain work areas atthe same time.The implementation process shouldinclude these changes.

What training will be required?

Changing the way people perform their jobsrequires training or instruction.Training may needto occur before the policy or procedure isintroduced.Training may be part of the policy orprocedure or it may need to occur on a regularbasis to ensure the policy or procedure continuesto be followed. Your policy or procedure shouldspecify what training will be undertaken as part oftheir implementation.The Introduction to Health andSafety Responsibilities, Roles and Functions booklet inthe Getting Started with Workplace Health and Safetyseries can help you identify and meet the trainingneeds in your workplace.

How do you test the policy or procedure?

In some cases, you might want to introduce a policyslowly, or introduce it in stages beforeimplementing it throughout your workplace.To dothis, choose “pilot” work areas in which to test thepolicy.These areas could be chosen on the basis of:

E the work area being representative of otherareas of the workplace;

E the severity of relevant hazards in the area; and

E the willingness of employees and management inthe area to participate in a test.

You should certainly test procedures beforeimplementation and work through the procedurewith experienced employees before it isimplemented.

Step 5: Review and make changes ifrequired

Policies and procedures need to be reviewedregularly.You need to make sure they are achievingtheir purpose, they are still relevant to yourworkplace, and they are providing value for money.You will want to know how well they achieve yourgoals for hazard identification or risk control.Youalso need to know whether the policies andprocedures are supporting your preventivestrategies. Make a plan or a timetable for reviewingevery procedure in your workplace.

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Review and evaluation are essential in thedevelopment of policies and procedures. As thecircumstances at your workplace change andgreater knowledge about hazards is gained, youshould work through the hazard identification, riskassessment and risk control procedure. Yourpolicies and procedures take account of thesechanges.

If you do not regularly review and evaluate yourpolicies and procedures, inadequacies will only berevealed when an issue is raised by the employees,or when there is an incident in the workplace. It isimportant to review and evaluate to find outwhether:

E the policy has achieved its purpose;

E the procedure works;

E the policy is being followed;

E the procedure is always followed;

E new hazard control measures are available orrequired; or

E new policies are needed to cope with changesto regulations, processes or the workplace.

You evaluate a policy or procedure in the same wayyou evaluate any other activity or part of yourmanagement system.

The key steps to follow are to:

E start with what you aimed to achieve when youprepared the policy or procedure;

E decide what things would show you whether thepolicy or procedure is achieving the aims or not;

E collect information on these performanceindicators;

E analyse the information and work out changesto the policy or procedure; and

E rework your policy or procedure, following thesteps in this booklet.

Where does reviewing a policy or procedurestart?

Start with the aims you had when you developedthe policy or procedure. In Step 1 you identified theneeds for specific health and safety policies andprocedures in your workplace. You will need toreview your needs regularly, and whenever there isa change to your workplace. Changes such as a newprocess, substance, regulation, or moving orexpanding your premises should be analysed to seeif they introduce new hazards. Your policies andprocedures should be modified to reflect thesechanges and new policies or procedures may berequired.

The objectives in your policy should be clearlystated.You will be checking to see if these aims arebeing reached. For example, if you have developed apolicy to stop smoking in the workplace, you willbe checking to see how well this aim has beenachieved.

Procedures are usually more straightforward.Youwill be checking to see if:

E the procedure is always followed withoutdifficulty;

E the procedure is the most effective one for theactivity or hazard; and

E the procedure results in the activity beingcarried out safely and without risks to health.

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What things will indicate policy or procedureeffectiveness?

Policies and procedures can be tested quite easily ifthey have been written clearly and specifically.

Because policies aim to improve health and safetyin a workplace, you need to look at measures ofhealth and safety to see if the policy is working.Thiscould include incident and dangerous occurrencestatistics. For example, if you have a manual handlingpolicy, you would look at incident, injury and near-miss records in your workplace.This would includechecking specific information such as body locationof the injury or illness, work area, and time of theincident.

Some issues are not so easily measured.You couldlook through the record of issues raised by healthand safety representatives, minutes of the healthand safety committee meetings, or other record ofissues raised and resolved (or not resolved) todetermine how well a policy is achieving its aims.

Where there is an end result that can be checked,it is usually obvious if a procedure is being followedor not. For example, a day supervisor has to followthe following procedure: “Inspect the work areawith the health and safety representative to identifyhazards every week using a given checklist.Take anyaction possible to control hazards immediately.Report to the area manager”.This procedure couldbe evaluated by looking at the checklists andreviewing action taken.

Sometimes you may need to watch an activity tosee if the procedure is being followed. It is oftenmore difficult to check whether it is being doneevery time.You may have to devise a test, or plan anevaluation measure when you are preparing theprocedure. For example, if a procedure contains astep which cannot be directly checked, like dippinga tank before opening a valve, then you could put ameasure into the procedure. Perhaps a requirementsuch as having to fill out a check slip which ishanded to a second operator could be included.

What information should be collected?

To evaluate a particular policy or procedure, youcollect information about how it is being followed,and any results that might indicate how successfulit is. Collecting this information may involve:

E a survey of employees who are affected by thepolicy or procedure;

E a review of health and safety committee minutesor issues book and issues raised by health andsafety representatives;

E reports from your health and safety informationsystem;

E a review of health and safety activities over theprevious year; or

E a walk through the workplace to see howactivities are carried out.

If the information you collect shows a policy orprocedure is not working, then you need to knowwhy. For example, if employees must follow aprocedure for the safe maintenance of machinery,and an inspection of the workplace some time laterfinds they do not follow the tag-out/lock-out steps,then it would seem the procedure is not working.You need to know why it is not being followed tocreate a workable procedure.

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What is the next step?

The next step is to analyse the information andwork out changes for the policy or procedure. Inmost cases you will be able to see, or theemployees will be able to tell you, if there issomething wrong with a policy or procedure. Insome cases, the problem might not be so obvious,or there may be several factors affecting the waythe policy or procedure is being followed.Wherethe information shows a policy is not working, youcan start by looking at each part of the policy:

E Is the purpose or objective clear?

E Is it relevant?

E Are the standards realistic?

E Is the time frame for achieving the objectivereasonable?

E Is the organisation committed to the objective?

E Is the suggested approach workable?

E Are the resources available?

E Are the responsibilities being fulfilled?

E Is the implementation going according to plan?

You can also look at the policy as a whole and thesteps taken to implement it.

If your information shows you a procedure is notworking, or is not being followed, you will have towork out why this is happening. Perhaps:

E there was not sufficient information, instructionor training for employees;

E there was an unforeseen event not covered inthe procedure;

E the work organisation did not support theprocedure being followed;

E many of the employees were not literate andthis was not taken into account when preparingwritten procedures;

E it was not practical; or

E the procedure did not match the workplacehealth and safety policy or the actual issue,problem or activity.

Once you have information about why theprocedure is not being followed, or is not working,you can suggest changes that could make it work.You should look at the procedures which areworking to get ideas for changes to the ones whichhave not worked. It is important to know why someprocedures do work, so you can include thesefeatures in new or changed procedures.

When you have found out why a policy orprocedure is not working, you can decide to:

E develop a new procedure;

E determine whether you need to change workpractices;

E revise the policy or procedure so that it meetsyour needs; or

E change your standards — perhaps there are newlegal requirements or new control measuresrequiring higher standards.

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Why should you evaluate health andsafety performance?

The aim of evaluation is to check how well you aregoing towards achieving your stated health andsafety objectives or goals.You use the informationyou get from your performance evaluation to makechanges to the way you manage health and safety.This enables you to get closer to achieving yourgoals.

Once you have set up prevention strategies such aspolicies and procedures, you need to make surethey continue to work to keep your workplace safeand without risks to health. Evaluation is animportant part of effectively maintaining health andsafety in your workplace.

Measurement of your health and safetyperformance is the basis for refining and improvingyour health and safety management system. Youneed to measure and analyse how well you aremeeting your legal requirements as well as yourown business objectives.Then you will be able tomake improvements and evaluate again.This part ofthe booklet shows you how to evaluate your healthand safety performance.

How do you evaluate health andsafety performance?

There are five steps to evaluating health and safetyperformance:

Step 1: Know what your health and safetyobjectives are.

Step 2: Develop performance measures which indicateachievement of your objectives.

Step 3: Collect information on your measures ofeffectiveness.

Step 4: Analyse the results and decide uponimprovements.

Step 5: Implement changes and start again.

Step 1: Know what your health andsafety objectives are

The first step of evaluation is having an objective orgoal. In health and safety management, your goalswill be to:

E meet the legal requirements or standardsapplying to your workplace; and

E ensure the workplace, as far as practicable, issafe and without risks to health.

You can evaluate a single part of your health andsafety management system (e.g. training) or theentire system.

How do you identify your objectives?

The employer’s primary objective is to meet legalobligations to provide and maintain so far aspracticable, a working environment that is safe andwithout risks to health for employees.This is statedin Section 21 of the Occupational Health and SafetyAct 1985.

20 An Introduction to Workplace Health and Safety Policies, Procedures and Evaluation

Evaluating Health and SafetyPerformance

Once you have set up prevention strategies such as policies and procedures, you need tomake sure they continue to work to keep your workplace safe and without risks to health.Evaluation is an important part of effectively maintaining health and safety in yourworkplace.

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To evaluate your health and safety performance,you will need to look at what you are doing toachieve your objectives, and how well you are doingit. For example, you might have an overall objectivewhich aims to “… foster a healthy, safe, satisfyingand non-discriminatory work environment”.Yourpolicy might state this will be achieved through:

E effective management with commitment andpersonal involvement at all levels of theorganisation;

E work planning and control, so hazardoussituations and conditions are avoided;

E facilities, equipment, education and training, toensure healthy and safe working conditions andmethods; and

E teamwork and effective two-way communicationas an integral part of every job.

To evaluate your system against these objectives,you firstly have to look at what programs orstrategies have been developed to meet theobjectives. For example, are you providing training?If you are, you need to evaluate how well thetraining is contributing to “healthy and safe workingconditions and methods”.

Other more specific objectives relate to strategies,commitment, roles and functions, and theenvironment within the workplace. Some examplesare:

E Strategic goals

e health and safety strategies will be developedannually to improve health and safetyperformance; and

e health and safety systems and programs willcontinually be reviewed, upgraded andmonitored to improve standards andperformance.

E Commitment and responsibility goals

e personal commitment to health and safetywill be demonstrated at all levels;

e a high level of health and safety awarenesswill be fostered at all levels;

e all managers will have responsibility for thehealth and safety of employees under theirmanagement;

e all employees will take the care they are ablefor their own, and their work mates healthand safety; and

e specific, defined, responsibilities will beclearly understood by all employees.

E Work environment goals

e health and safety practices and procedures,and the work environment, will be regularlyreviewed and revised;

e formal consultation and communication withhealth and safety representatives andemployees in all health and safety matters willoccur through health and safety committees,team briefings and management involvementand commitment;

e all incidents and near misses will be reported,investigated and corrective action taken as apriority; and

e the purpose of an investigation will be todetermine the cause of the incident toprevent future occurrences.

Part of the evaluation against these goals will be toaudit whether the arrangements have been made asproposed. For example, are health and safetystrategies developed each year?

Evaluation will also include assessing how well thearrangements are working to achieve the objectives.In the example provided, you would look at eachindividual strategy and evaluate how well it isachieving the aim of improving health and safetyperformance.

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How do you meet legal requirements andstandards?

Many legal requirements will be straightforward.For example, all employers are required to reportserious incidents, and to keep records relating tothe health and safety of employees.

If you handle hazardous materials, you may berequired to keep a dangerous goods manifest, or tomonitor levels of employee exposure to chemicals.There are standards for the work environment andexposure levels for employees that must bemonitored and achieved.These include atmosphericcontaminants, noise, radiation and so on.The legalrequirements you must satisfy depend on the workprocesses, substances, plant and equipment in yourworkplace.

Other legal requirements are managementstrategies for providing a workplace that is safe andwithout risks to health. For example:

E providing adequate information on hazards, aswell as instruction, training and supervision toemployees, to enable them to work safely;

E providing adequate welfare facilities; and

E advising employees of the details of theresolution of an issue.

These requirements may be the basis for developingyour overall or specific objectives for themanagement of health and safety in your business.

These requirements are examined in more detail inthe Introduction to Health and Safety Responsibilities,Roles and Functions booklet in the Getting Startedwith Workplace Health and Safety series.

Step 2: Develop performancemeasures which indicate achievementof your objectives

Step 2 involves the development of measures whichwill indicate progress towards achieving your aimsand objectives. These measures may be stated inyour objectives, or built into the health and safetyprograms you establish in your workplace.Whatever indicators you choose to measure yourperformance, you should put them in place at thebeginning, when you establish the objective, plan orprogram. Look for long-term as well as short-termmeasures of your performance.

You will need measures to look at your overallmanagement of health and safety, and to look atindividual strategies and programs.

To evaluate your overall management system, orany specific aspect of it, you will need to use a rangeof measures. Short term measurements, long termindicators, quantitative measures, qualitativemeasures as well as measures of timeliness will berequired.

You need to choose measures that will tell youabout the program or activity you are evaluating.For example, if your objective is to reduce thenumber of lost time injuries, then you can use yourinjury and illness records to measure if this is beingachieved, and by how much (quantitative measures).

If your policy states that “a high level of health andsafety awareness will be fostered at all levels”, thenyou will have to work out what would show youthis is being achieved.You may have to look at healthand safety committee minutes, at a record of issuesraised, or you may talk to employees about theirawareness of health and safety (qualitativemeasures).

If you wish to evaluate your aim “to plan andcontrol work so hazardous situations andconditions are avoided”, then you need to look at,and follow, aspects affecting this strategy. Forexample:

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E your system for workplace inspections, correctiveactions, reporting and follow-up (hazardidentification, risk assessment and risk control);

E your system for developing and reviewing workprocedures and instructions;

E your investigation and follow up of accidents,incidents and near-misses;

E your injury and illness records; and

E your system for checking all new and changedplant, equipment, substances or processes in theworkplace.

What are some short-term measurements?

Some short term measures include:

E an assessment of whether your plans are beingimplemented;

E the proportion of health and safety grievanceswhich were resolved successfully at shop-floorlevel; and

E any reduction in the number of health and safetygrievances.

What are some long-term indicators?

The main aim of your health and safety managementsystem is to reduce work related injury and illness.Some of the changes that take place in yourworkplace to achieve this goal may not show up inthe short term.These may include:

E injury and illness rates;

E incidence of gradual onset injuries; and

E the hidden costs of injury and illness.

What are some other quantitative measures?

These are measures you can get from your healthand safety records.They could include:

E the number of incidents;

E the number of employees trained;

E the number of work procedures developed orreviewed; and

E the number of hazards identified and eliminated.

What about qualitative measures?

Qualitative measures give you more informationabout the numbers, and are helpful in analysing thesuccess and failure of particular strategies.Qualitative measures in the workplace couldinclude:

E the types of issues being raised by employeesand health and safety representatives;

E employees’ level of awareness of the health andsafety policy;

E how the health and safety performance is beingtaken into account in the performance assessmentof supervisors and managers; and

E evidence that management is leading byexample.

What are some measure of timeliness?

An important aspect of effectiveness is whether theactivity happened in a timely way. Measures of thiscould include:

E whether the training timetable is being followed;

E whether the timetable for implementing thestrategies is being observed;

E the response time for corrective action oninspections; or

E maintenance requests being handled promptly.

When should you plan your measures ofeffectiveness?

You need to plan the measures you will use whenyou set up programs or strategies. For example, youmay need to establish ways of collecting recordsabout injuries and illnesses. This could includesetting up a first aid register as well as a procedureto make sure Workplace Injury and IllnessRecording forms are completed.

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Step 3: Collect information on yourmeasures of effectiveness

Once you have decided what measures to use, youneed to decide how this information will becollected, how often it will be collected, and whowill collect it.These decisions will depend on theprogram or strategy being evaluated and the typesof measures you are collecting.

How do you collect the information?

You will probably use a checklist when you areauditing the system, or measuring if certainactivities have been completed against a fixed timeschedule. Some possible questions to ask are:

E Do the injury and illness recording proceduresmeet the requirements of the OccupationalHealth and Safety Act 1985?

E Are all incidents, illness and injury, and nearmisses:

e recorded

e investigated

e reported if required

e analysed for trends, and

e reported to employees?

If you are measuring performance against specifiedtargets, for example reducing numbers of injuries,you could use information from your health andsafety records.This could include reports on:

E the frequency of incidents and dangerousoccurrences;

E average lost time; and

E costs.

If you are evaluating the effectiveness of yourinformation and communication strategy, you couldcollect qualitative information from:

E discussion with health and safety representativesand employees;

E health and safety committee minutes;

E issues raised and resolved logbook; or

E interviews, questionnaires or observations.

In all cases, information should be obtained byspeaking directly to the people doing the task whichis being evaluated.

How often should you collect information?

How often you collect this information will varyaccording to the nature of the measures, and thesystem or strategy you are evaluating. For example,some indicators relating to training will need to beassessed at the end of every training course.Theoverall performance of your health and safetymanagement system may only need to be assessedannually.

Whatever your timetable, you need to continue tocollect information on the measurements regularly,so trends and changes can be identified.

Who should collect the information?

Information can be collected on the health andsafety performance of a work area or location. Itmay also be collected on a health and safety systemoperating throughout the workplace. In both casesthe role or function of collecting the informationshould be clearly allocated.

In specific locations, supervisors or managers cancollect information on the areas under theircontrol. Small workgroups or teams can collectinformation on their own area.The manager whoserole or function includes implementing a health andsafety system or plan in that area may also do theevaluation.They would do this in the same way theywould evaluate and report on sales or costs in theirarea.

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The health and safety committee and health andsafety representatives should be involved inevaluation.This may include a role in collecting andproviding information. In larger organisations youmay want or need external assistance to evaluateoverall policy or management systems.

Step 4: Analyse the results and decideupon improvements

Measurement is not an end in itself.You need toanalyse these records.You need to understand theinformation so it can be used to identifyimprovements to both your health and safetymanagement system as well as particular strategies.

The measurements you have collected will showwhether a strategy is achieving its objective, or ifperformance is up to the standard you set. If youhave not achieved your objective, then you need tolook at the information you have collected todetermine the reasons.This will help you to arrangeimprovements or changes to the objective orstrategy.

If performance is not up to your standard in aparticular area, you may choose to develop astrategy to improve it.

What should you do if a strategy is notworking?

If a strategy is not working, there is a number ofquestions to ask:

E Was the objective realistic and achievable?

E Is the objective relevant to current technologyand values?

E Was the strategy implemented as planned?

E Was there adequate training, information andunderstanding of the strategy?

E Were there resources available to implementthe strategy?

E Did work organisation allow the strategy towork?

E Was responsibility for implementing the strategyallocated?

E Are the responsibilities understood?

E Did the information you collect accuratelymeasure performance of the strategy?

Use the information you get from this analysis tofine tune your strategies, to reset your standardsand to identify areas of health and safety needingmore systematic management.

Step 5: Implement changes and startagain

Once you have identified improvements to yourhealth and safety system, you should make theresults known and implement corrective action.Follow-up corrective action must be taken promptlyto demonstrate management commitment to healthand safety.

New or improved strategies should be implementedand then the evaluation process will begin again,using any lessons, mistakes and achievements to helpthe process.

Effective evaluation is a continuous cycle of action,analysis and change.

Getting Started with Workplace Health and Safety 25

Implement

Monitor

Analyse

Change

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To sum up …

This booklet has shown that preparing policies andprocedures is not hard. It has also shown thatpolicies and procedures do not need to becomplicated documents. An effective policy orprocedure, based on controlling hazards at theirsource, will ensure effective health and safetymanagement and efficient allocation of resources.In short, effective policies and procedures can helpensure your management of health and safetycontributes to the overall success of yourenterprise.

Preparing written agreed policies and procedureshas valuable rewards. Rather than dealing withevery health and safety hazard on a crisis basis,everyone has clear guidance on what to do. Insteadof ad hoc, time-consuming responses, theworkplace will be able to concentrate on solvingthe issues before they become problems. Day-to-day management will improve and handling unusualoccurrences will be more efficient. If yourmanagement of health and safety improves, so doesyour organisation’s success.

Health and safety performance evaluation is asimple, cost effective process. It will show you if youare spending time and money to good effect. Itshould be a regular and continuous process withthe results always feeding back into your health andsafety plans.

The Victorian legislative framework andperformance-based regulations emphasise thesystematic management of health and safety as theprimary strategy for preventing injury and illness atwork. Quality management systems provide theopportunity to include health and safety in businessmanagement. This means there is a greateremphasis on workplaces being able to measuretheir own performance and use thosemeasurements to drive continuous improvement.

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Occupational Health and Safety Act 1985

Guide to the Occupational Health and Safety Act 1985Available from your local WorkSafe Victoria office.

Other books in this Getting Started with Workplace Health and Safety seriesAvailable from your local WorkSafe Victoria office.

SHARE Solutions ManualAvailable from the National Occupational Health and Safety Commission.

Victorian WorkCover Authority LibraryPhone 9628 8260.

WorkSafe Victoria field officersContact your local WorkSafe Victoria office.

Employer associations

Unions

OHS consultants

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Sources of Further Information

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28 An Introduction to Workplace Health and Safety Policies, Procedures and Evaluation

WorkSafe Victoria Offices

WorkSafe Victoria

WorkSafe Victoria offers a complete rangeof health and safety services:

A emergency response

A advice, information and education

A inspections

A licensing and certification

A publications.

For further assistance and information, contactany of the WorkSafe Victoria offices listed below.

Head office

Victorian WorkCover Authority24th Floor222 Exhibition StreetMelbourne Victoria 3000

GPO Box 4306Melbourne Victoria 3000

Phone 9641 1555Fax 9641 1222Toll-free 1800 136 089

Local offices

Ballarat 5337 1400

Bendigo 5443 8866

Dandenong 8792 9000

Geelong 5223 2300

Melbourne 9628 8115

Mildura 5021 4001

Mulgrave 9565 9444

Preston 9485 4555

Shepparton 5831 8260

Traralgon 5174 8900

Wangaratta 5721 8588

Warrnambool 5562 5600

Publications

Phone 9641 1333Fax 9641 1330

Website

www.workcover.vic.gov.au

Email

[email protected]

WorkCover Advisory Service

24th Floor222 Exhibition StreetMelbourne Victoria 3000

Phone 9641 1444Fax 9641 1353Toll-free 1800 136 089

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