Sometimes the simplest things can result in major improvements to health and safety in the workplace. Adopting a “back to basics” approach has, in our experience, produced significant improvements, and in this Top Tip Tuesday we set out some key learnings in the form of practical do’s and don’ts.
Do:
- Conduct proper risk assessments in the appropriate format suitable for the workplace including baseline, issue-based and continuous risk assessments. The importance of conducting continuous risk assessments, in whatever form is suitable for the workplace, cannot be underestimated. Continuous risk assessments, such as Stop, Look, Assess, Manage (SLAM), if done properly by the entire team involved, identifies the activities, the risks associated with the activities (working environment, tools, equipment, machinery and people), and the controls to be implemented to avoid the risk from eventuating – a continuous risk assessment is often the final barrier between the health and safety system/activity and an incident or accident;
- Ensure that appropriate measures have been implemented to address the identified hazards and the assessed risks, including codes of practice, standards, procedures, and instructions. Managerial or engineering instructions play a vital role in “closing the gap” between what formal documents such as codes of practice, standards and procedures provide, and what actually goes on in the workplace, pending a review of the formal documentation and amendment of these formal documents;
- Ensure that a comprehensive health and safety training programme is in place consisting of induction/refresher induction, job-specific training, formal training, and continuous communication of key aspects associated with health and safety through workplace health and safety meetings, posting up at notice boards, etc.;
- Ensure that competent persons are appointed as supervisors/managers i.e. persons who know and understand the health and safety systems in place and the hazards to which team members may be exposed when carrying out activities;
- Implement a system of overinspection which is aimed at “closing the loop”, consisting of planned task observations, workplace observations, inspection by health and safety officers and health and safety representatives, supervisors, etc. The primary purpose of overinspection is to identify any shortcomings, and to ensure that these shortcomings are addressed, by incorporating the information in the risk assessments, subsequent amendment to the codes of practice, standards, procedures and instructions, subsequent amendment to the health and safety training material, and the training provided to employees, and implementation by supervisors which results in “closing of the loop”;
- Implement a system of contractor/service provider management which ensures that the principles set out above are integrated into the way in which persons in the workplace, including service providers, comply with the health and safety systems in place;
- Adopt a multi-disciplinary approach to health and safety management in the workplace i.e. make sure that all relevant persons are involved in the risk assessment process so that the various perspectives can be taken into account, and appropriate measures implemented to address the identified hazards and risks;
- Apply the principle “two heads, five minutes” i.e. where at least two persons consider the activities to ensure that they can be carried out safely, and wait five minutes, before the task is executed to ensure that all the relevant aspects have been considered;
- Investigate every high-potential incident, near-miss incident or accident thoroughly to identify the root cause. It is only by identifying the root cause that a similar incident or accident can be avoided by implementing appropriate remedial measures;
- Keep proper records. Often, key records such as pre-use checklists are illegible. It is important to ensure that key documents such as the pre-use checklist clearly identifies all the persons who participated in the pre-use inspection, what they found, and what measures were going to be implemented to address any shortcomings identified. The same principles apply in relation to continuous risk assessments such as a SLAM.
Don’t:
- Adopt a “us and them” approach between different functionalities in the workplace such as production versus engineering, engineering versus services, employees versus contractor employees/service providers, etc. – this leads to misalignment and potential incidents or accidents;
- Adopt a “tick box” approach to key documents such as continuous risk assessments, pre-use inspections of workplaces, equipment and machinery – adopting a “tick box” approach typically means that the key risks are not identified, which, in turn, means that the appropriate measures are not implemented to avoid those risks from eventuating;
- Assume that all employees know and understand the applicable codes of practice, standards, procedures and instructions simply because they have been carrying out the tasks for a long time and have been working in the workplace over any years;
- Ignore input from stakeholders such as trade unions;
- Assume that only the employer is responsible for health and safety – health and safety in the workplace can only be achieved through a collaborative process amongst all stakeholders including employees, service providers, trade unions, and the relevant regulators such as the Department of Employment and Labour and the Department of Mineral Resources and Energy.
By implementing these simple do’s and don’ts, there is potential for significant health and safety improvement in the workplace, and goes a long way towards complying with the various responsibilities set out in the Occupational Health and Safety Act, No. 85 of 1995 and the Mine Health and Safety Act, no. 29 of 1996.
Disclaimer: This article is provided for informational purposes only and is not intended to serve as legal advice. Readers should consult one of our legal professionals for advice tailored to their specific circumstances.