The OHS Act clearly states that an employer must provide a safe and healthy work environment by identifying any hazards and where possible eliminate or mitigate the hazard. Where this is not possible, safe work systems must be developed and finally, PPE must be provided where it is not possible to make the work process safe. The General Safety Regulations sub-section 2 makes a similar statement and clearly states the employer must "make an assessment of the hazards and risks" and apply a similar process of elimination and engineering and then provide PPE as a last resort.
The Construction Regulations, (CR) in sub-section 9 deals with the requirements of the construction work risk assessment, which needs to be done by the contractor. The client is also tasked with doing a baseline risk assessment for an intended construction work project. The health and safety specification for the project must be based on this risk assessment. Furthermore, the designer is also required to advise the client, in writing, of any known dangers or hazards relating to the construction work to be performed.
I think it is fair to say that every decision made in the interest of health and safety is based on risk and thus risk assessments are a fundamental part of the process of providing a healthy and safe work environment.
The first requirement is to have the risk assessment performed by a competent person. Let us pause here for a moment and unpack the word competent.
The CR defines competency as having knowledge, training, and experience. The Regulation further states that where a qualification specific to the work exists, that qualification is required.
To my knowledge, there cannot be many people who can do a risk assessment for every possible task on a construction site or, for that matter, do a method statement or safe work procedure for the numerous tasks on a construction site. Thus, I think it is rare that a single person can meet all the criteria of being competent to do a risk assessment. This might seem a bit harsh, but the reality is completing a two-day risk assessor's course does not qualify one to do a comprehensive construction risk assessment.
So, I hear you ask, what is the solution?
Having had the privilege of attending numerous international health and safety conferences, where risk management specialists have presented on this very subject, it is very clear that risk assessments need to be done by cross-functional teams with a multi-disciplinary approach. (Elriza Esterhuizen, Identifying and Analysing Safety Risk, Juta 2016).
A risk assessment should be done by teams of people who are experts in the type of work process that is being analysed. For instance, the installation of a lift. This requires specialised skills and equipment and who better than the persons involved in the design and installation to provide input into the risk assessment. This team would be best placed to write the method statement for the works to be completed so that the risks can be identified and analysed for every step in the process. The subsequent safe work procedures for the task would, or should, be sufficient to execute the work safely, knowing that the experts have provided the correct information based on their "knowledge and experience". The "competent" risk assessor would play the role of leading the process, recording the results, and collating these results in the form of a written risk assessment.
There are numerous steps that need to be followed once the risk assessment has been completed, such as:
- A monitoring and review plan must be in place.
- The PC must inform all contractors of the anticipated hazards as identified in the risk assessment.
- All employees must be informed and trained on the following:
- Hazards identified;
- The control measures that have been put in place (SOP's).
- Any visitors to the site must be informed of all the hazards prevalent on the site.
As stated before, all decisions made, and systems used to provide for a healthy and safe working environment are based on risk. Thus, the safety plan for any construction site must be based on the risk assessment for the site and must address how the risks created by the hazards identified are going to be managed.
In conclusion, spend the time and the effort to do proper task specific risk assessments to ensure that employees can work safely and ensure that everyone understands the processes and procedures that need to be followed to work safely on site.