Learner Guide. WHS, OH&S Workbook

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1 Learner Guide WHS, OH&S Workbook 2014

2 Contents Introduction 3 Outline 4 Topic 1 5 Harmonisation (Legislation) 5 A Safe Workplace 6 Enforcement 7 National Legislative Structure and Overview 8 Federal (Commonwealth) Work Health and Safety Legislation 8 Statutory Body SafeWork Australia 8 States and Territories 8 Topic 1: Exercise 9 Topic 2 10 WHS, OH&S Legislation 10 WHS, OH&S 11 Duty of Care 12 Duties of Care under WHS/OH&S Acts 12 PCBU/Employer 12 Reasonably Practical 12 Officers 13 Workers/employees 13 Topic 2: Exercise 14 Topic 3 15 Establishing and maintaining a WHS/OH&S system 15 Structure of a Work Health and Safety Management System 16 WHS/OHS Policy 16 WHS/OH&S Programs/Procedures 16 Induction 16 Topic 3: Exercise 17 Topic 4 18 Consultation, representation and participation arrangements 18 Health and Safety Representatives 20 Health and safety committees functions: 20 Topic 4: Exercise 21 Issue resolution 22 Topic 4: Exercise 22 Records and Records Management Tracking the issues 23 1

3 Information Dissemination 23 Topic 4: Exercise 24 Summary 25 Topic 5 26 Controlling Risk 27 Risk control measures 28 Risk Control Deficiencies 28 Topic 5: Exercise 29 Summary 29 Glossary 31 ACRONYMS 32 WHS / OH&S 32 PCBU Person Conducting a Business or Undertaking 32 Officer 32 Worker 32 Other Acronyms 33 Final Assessment 34 BSBOH&S407A 35 Monitor a Safe Workplace 35 2

4 Introduction 3

5 Outline This Occupational Health and Safety (OH&S) Workbook is provided to cover the skills and knowledge required to assist you in completing your workplace project for the OH&S unit in the Certificate IV in Frontline Management. This workbook provides you with information and formative activities to complete before undertaking the workplace project, and focuses on the skills and knowledge required to monitor a safe workplace. The topics covered in this guide include: Providing Information to the team with respect to relevant provisions of OH&S legislation and codes of practice; Implementing and monitoring participative arrangements for the management of OH&S; Identifying and reporting inadequacies in existing risk control measures in accordance with the hierarchy of controls; Monitoring outcomes of reported inadequacies where appropriate to ensure a prompt organisational response; and Using aggregate information and data from the work area records to identify hazards and monitor risk control procedures in work area. The workbook activities assume participants: Have successfully completed the QBE Insurance: Welcome to QBE OH&S Online Training Module; Are fully aware of the process involved in the QBE Insurance "iq" online Employee Support system with respect to OH&S; and Have knowledge of the QBE Insurance Occupational Health and Safety Policy. Participants may wish to review these before commencing the workbook. To help you, at the back of this workbook there is a glossary and some acronyms although are not exhaustive given a working knowledge of the OH&S/ WHS system will be discovered by completing this workplace project. 4

6 Topic 1 Harmonisation (Legislation) 5

7 An Australian Government statutory agency, Safe Work Australia has been responsible for developing model nationally consistent legislation. SafeWork Australia s primary responsibility has been involved with improving work health and safety and workers compensation arrangements across Australia. It represents a genuine partnership between governments, unions and industry, working towards the goal of reducing death, injury and disease in the workplace. Each jurisdiction has and is going through the process of enacting its own legislation which mirrors the model laws. In addition, Codes of Practice (guidelines) that support the legislation have been and are being developed. In summary: Each state and territory had their own OHS, Workers Compensation (WC) and return to work (RTW) legislation; Under harmonisation this has NOT changed, however in NSW, QLD, ACT, NT, SA and TAS the OHS Act has become WHS Act. eg Work Health and Safety Act; VIC and WA are yet to adopt the model legislation refer to SafeWork Australia website for updates; and Each state and territory still has their own legislation, but after national harmonisation is complete (hopefully) they will all be consistent. A Safe Workplace The new work health and safety laws may change the way health and safety is managed in the workplace, but THE BASICS of keeping a workplace safe WILL REMAIN THE SAME. The basics are: Management commitment to health and safety; Utilising a risk management approach to decision making; Consultation between a Person Conducting a Business or Undertaking (PCBU s)/employers and all workers; Training and supervision of all workers; Reporting hazards and incidents; and Managing workers compensation (WC) and return to work (RTW). The key changes under the new work health and safety laws include: The duties of care are not defined by the nature of employment relationship. This means that the term employer that was applied in occupational health and safety laws (and currently still is in VIC and WA) is replaced with the term person conducting a business or undertaking (PCBU) and employee is replaced with a broadly defined term of worker ; The term worker includes employees, volunteers, contractors, sub-contractors, apprentices, work experience students and outworkers; The term workplace in most jurisdictions will be broadened to include any place where a worker goes or is likely to go while at work; There are positive duties for officers to exercise due diligence to ensure the person conducting a business (PCBU) or undertaking complies with its duty of care. This is a new way of expressing officers responsibilities under current law. Previously some Occupational Health and Safety Acts attributed liability to officers where a corporation is in breach of a duty. 6

8 The duty to consult, co-operate and co-ordinate activities with the involvement of workers/employees existed under the previous OH&S legislation and this has been retained, however has been broaden to include other duty holders this duty aims to address situations where more than one duty holder is responsible for the same work health and safety matter to ensure that duty holders work together to control risk. Enforcement Safe Work Australia has developed a National Compliance and Enforcement Policy to complement the harmonised work health and safety laws. The policy aims to ensure that state and territory work health and safety regulators take a nationally consistent approach to compliance and enforcement. A Regulator Inspector may visit the workplace as a result of a serious incident/injury/illness, complaint, poor incident experience or to conduct a random inspection. Their role is to: Investigate incidents or breaches of WHS/OH&S legislation; Respond to complaints; Provide advice and information to PCBU s/employers, workers/employees, Health and Safety Representatives/Health and Safety Committees; Carry out inspections and examinations of the workplace; Target specific hazards as part of safety campaigns; and Resolve workplace WHS/OH&S disputes. 7

9 National Legislative Structure and Overview Federal (Commonwealth) Work Health and Safety Legislation Covers federal government departments e.g. Australia Post, Customs No direct jurisdiction on states and territories e.g. QBE and other organisations operating nationally must comply with each individual state and territories legislation not the Commonwealth s. Statutory Body SafeWork Australia Researches issues and consults with Federal, State and Territory Governments, employer and employee groups Disseminates information on issues which could form the basis for codes of practice to be adopted by states and territories e.g. manual handling. Promotes health and safety nationally States and Territories Each state and territory has its own WHS/OHS legislation: NSW, QLD, NT, ACT, TAS, SA : Work Health and Safety Act, WHS Regulations WA: Occupational Safety and Health Act and OH&S Regulations VIC: Occupational Health and Safety Act and OH&S Regulations Each state and territory has its own authority that regulates WHS/OHS legislation: - ACT: WorkSafe ACT - NSW: WorkCover NSW - NT: NT WorkSafe - QLD: Workplace Health and Safety QLD - SA: SafeWork SA - TAS: WorkSafe TAS - VIC: WorkSafe VIC - WA: WorkSafe WA Individual state and territory websites and also The Commonwealth and Safe Work Australia are valuable information sources. The following website is a good reference. 8

10 TOPIC 1: EXERCISE ANSWER THE FOLLOWING QUESTIONS FOR YOUR WORKPLACE: 1. What is the full name of the state WHS/OH&S Act your worksite is operating under? 2. Who is the main authority responsible for administering and enforcing OH&S legislation in your state/territory? 3. What is the function of Safe Work Australia? 9

11 Topic 2 WHS and OH&S Legislation 10

12 WHS, OH&S Each State and Territory in Australia is responsible for enacting and enforcement of workplace health and safety laws in its jurisdiction. This legislation has two main components, creating a legislative framework supported by Codes of Practice (COP) and Australian Standards for the management of health and safety in the workplace. These are: Acts; o establishes general duties of care and other legal obligations Regulations o Regulations support the Act by providing more detailed requirements for specific hazards e.g. manual handling They can include references where appropriate and frequently include relevant standards as the basis of the Regulation Regulations are legally binding and enforceable. Codes of Practice o Codes of practice are designed to provide practical guidance e.g. risk management, consultation, manual handling. Should be followed unless another solution achieves the same or better result. May be used in support of preventative and enforcement functions e.g. prosecution Note: Acts and Regulations passed by parliament are also referred to as statute law (as distinct from common law, which is based on decisions of the court). Standards (some COP/Standards have been incorporated into the Regulations). E.g. Risk management Under WHS/OHS legislation, the Act and its Regulations are legally binding to both PCBU s/ employers and workers/employees. 11

13 Duty of Care Within workplaces there are various laws governing the relationship between PCBU/Employer and workers/employees. Many of these laws relating to OH&S/WHS, have been developed based on common law principles. Duty of care requires each person to take reasonable care to avoid foreseeable harm to others, it applies when there is some form of control between the parties e.g. PCBU/employer and worker/employee. Duties of Care under WHS/OH&S Acts PCBU s/employers and workers/employees must comply with relevant state and Territory laws in the jurisdiction within which they operate. In each jurisdiction (Commonwealth, State and Territory) there is a Work/Occupational Health and Safety Act that gives responsibilities to workplace parties. These are: PCBU/Employer Under WHS legislation this has a wide definition however, in relation to QBE, the PCBU/Employer is QBE. The Primary Health and Safety Duties of a PCBU/employer are to ensure as far as is reasonably practicable: The health, safety of workers & others (more than just employees); Provide and maintain work environment without risk to anyone s Health and Safety; Provide and maintain safe plant, structures & substances; Provide and maintain safe systems of work; Consult with workers and other PCBU s; Ensure safe use, handling & storage of plant, structures and substances; Provide adequate facilities; Provide information, instruction, training & supervision; Monitor health of workers and condition of workplace; Maintain accommodation if provided; and Notify certain incidents to the regulator (serious incidents, injury/illness e.g. collapse of an excavation, fatality, amputation etc} (note - VIC and WA have not as yet adopted the model legislation however, primary duties for an employer are similar): Reasonably Practical The test for what is reasonably practicable is an objective test what can be done what is reasonably able to be done. That is: What is the likelihood of a hazard or risk occurring (how often does it occur, how might people be exposed to the risk?); What is the degree of harm or possible consequences (what information is there on the possible consequences, how many could be injured? What could increase the severity?); 12

14 What the person concerned knows or ought to know about the hazard/risk and control measures (consider WHS/OH&S regulations, codes of practice, industry practices, technical standards); Availability and suitability of ways to eliminate or minimise the risk (is there any effective way of eliminating or minimising the risk?); and Costs associated with eliminating or minimising and whether they are out of proportion to the risk. Officers As defined in the Commonwealth Corporations Act, Officers include a secretary or director of a corporation: Someone who makes, or participates in making, decisions that affect the whole, or a substantial part of a corporation; or Someone who has the capacity to significantly affect a corporations financial standing; or Someone who is accustomed to having their instructions actioned by the board this does not include those who provide advice to the board as part of their role. In the case of QBE this would include board of directors, CEO and senior executive team. Officers must exercise due diligence to ensure the PCBU complies with their duties. They must take reasonable steps to: Acquire and keep up to date knowledge on health and safety matters; Gain an understanding of the hazards and risks of the business; Ensure the PCBU uses appropriate resources to eliminate or minimise risks; Ensure PCBU receives, considers and responds to info re incidents, hazards, risk; and Ensure PCBU implements processes for complying with their duties e.g. incident reporting, consulting, acting on prohibition and improvement notices (PIN), training. Workers/employees (Note - VIC and WA have not as yet adopted the model legislation however, for an employee are similar): Take reasonable care for his or her own health and safety; Take reasonable care his or her acts or omissions do not adversely affect the health and safety of other persons; Cooperate with all reasonable instructions from the PCBU as far as reasonably able; and Comply with all reasonable policies and procedures e.g. report incidents/hazards. Under the various state and territory WHS/OH&S Acts, Officers are responsible for ensuring the PCBU s/employers duties of care are implemented. Part of this would be ensuring the PCBU/Employer has a documented system in place and ensuring line managers are responsible and accountable for implementing and monitoring the safety system for continuous improvement. In the case of QBE line managers (including frontline managers) would be responsible for the WHS/OH&S procedures on iq e.g. Incident reporting and investigation, ergonomic risk assessments. 13

15 TOPIC 2: EXERCISE ANSWER THE FOLLOWING QUESTIONS FOR YOUR WORKPLACE: 1. What is a duty of care? 2. Who has a duty of care in relation to WHS/OH&S? 3. Under WHS/OH&S who, has principle responsibilities for safety in the workplace? 4. What must Officers/ senior managers do in relation to WHS/OH&S? 5. Locate any codes of practice relevant to your workplace. 6. Locate and note any Australian Standards that are relevant to your worksite? 14

16 Topic 3 Establishing and maintaining a WHS/OH&S system 15

17 A WHS/OH&S management system should be integrated with operational, human resources, quality and environmental systems as part of an overall management system. A WHS management system can be defined as a planned, documented and verifiable method of managing WHS. It may be simple or complex and sparingly or highly documented depending on the size and nature of the organisation and its activities. It is recognised as a management system due to its allocation of responsibilities, accountabilities and resources from senior management through to all workers. WHS/OH&S management in the workplace is of paramount importance to any organisation in any industry - particularly in an office environment where the risks may not appear to be so obvious. Structure of a Work Health and Safety Management System WHS/OHS Policy A WHS/OH&S policy is a statement of intent by an organisation, outlining its commitment to complying with legislation and providing a safe workplace. It should also set out the organisations objectives and how these will be achieved and who will be responsible. The policy document forms the basis for the development of a WHS/OH&S management system. WHS/OH&S Procedures WHS/OH&S procedures are the specific activities that the organisation conducts to achieve the policy objectives and commitment. Procedures can be general in nature or may apply to specific hazards. These are the processes line managers would use on a daily basis to maintain a safe and healthy workplace and contribute to compliance and due diligence requirements. A range of WHS/OHS procedures would include: General procedures (which would apply to any organisation): Consultation; Risk management; Incident/hazard reporting; Induction/training; and Workplace inspections. Specific procedures (these may be different from organisation to organisation depending on their activities): - Emergency management response procedure - Managing first aid procedure - WHS risk management procedure - WHS data and records management procedure - Managing ergonomic and manual handling hazards procedure Induction Guidelines for employees covering general rules and behavioural standards, job related activities and specific hazards. These would mirror the organisations WHS/OH&S procedures. Examples of rules/standards: Consultative arrangements; Incident/hazard reporting; Emergencies; Behaviour no practical jokes etc; and Bullying / harassment. 16

18 TOPIC 3: EXERCISE ANSWER THE FOLLOWING QUESTIONS FOR YOUR WORKPLACE: 1. After accessing the QBE WHS/OH&S policy, outline and describe the following: Who are the stakeholders? What are the legal requirements? and Are there any issues you can identify with respect to your worksite that should be addressed to comply with the policy? 2. What are the critical WHS/OH&S procedures that should be in place in QBE workplaces 3. Who in the workplace are the principle group who would use these critical procedures? 4. What is the role of workers/employees in relation to QBE s WHS/OH&S policies and procedures? 17

19 Topic 4 Consultation, representation and participation arrangements 18

20 Under current work health and safety/occupational health and safety requirements (refer duties of care), everyone has responsibility. In particular PCBU s/employers and as part of these responsibilities (duties of care) they must consult with workers/employees (including other PCBU s). This topic discusses in more detail the variety of roles and responsibilities of those involved in the consultative process. Matters of workplace health and safety should be regularly discussed in a workplace, and this would involve the sharing of relevant information. In line with this workers/employees must be given reasonable opportunity: To express their views and raise WHS/OH&S issues in relation to the matter; To contribute to the decision making process; Views of workers must be taken into account; and Workers are consulted and advised of outcomes in a timely fashion. Under WHS/OHS legislation it is mandatory for the PCBU/employer to consult with workers/employees when: Identifying hazards and assessing risks arising from the work; Making decisions on ways to eliminate or minimise risks; Making decisions about the adequacy of facilities; Proposing changes that may affect health and safety; and Making decisions about procedures for: o Consultation; o Resolving issues; o Monitoring health of workers (where applicable); Monitoring the conditions at any workplace under the management or control of the PCBU; and Providing information and training for workers. The WHS/OH&S legislation makes it mandatory for the PCBU/Employer to consult with workers/employees through consultation, representation and participative arrangements. This would involve PCBU/employers and workers/employees working in cooperation for the development of a supportive organisational culture to provide a healthy and safe workplace. The consultative arrangements within the WHS/OH&S system require the identification of all the stakeholders and their roles, as defined by the legislation in each State and Territory across Australia. The major stakeholders are: PCBU/employer Officers/Management; Workers/employees; Health and safety representatives; Health and safety committees; QBE Workplace health and safety team (manager/coordinator); and Workplace health and safety inspectors (regulator). Everyone has a role to play in WHS/OH&S, including allowing PCBU/employers and workers/employees to consult in relation to workplace issues that may impact workers/employees health and safety. 19

21 Health and Safety Representatives Powers of Health and Safety Representatives: Inspect the workplace; Accompany an investigator during an investigation; Represent workgroup members in health and safety consultation with the PCBU; and Investigate health and safety complaints. Additional powers once trained: Direct unsafe work to cease and issue provisional improvement notices; Must use powers carefully and only in relation to health and safety issues; Ensure actions do not intentionally harm the PCBU; and Represent workgroup members professionally and in a timely manner. Health and safety committees functions: Facilitate cooperation between the PCBU and workers in instigating, developing and carrying out measures designed to ensure Health and Safety; To assist in developing standards, rules and procedures relative to Health and Safety; Such other functions as prescribed or agreed with PCBU; Can have a committee for a specific project; Health and safety representative s focus hazards for their workgroup; and Health and safety Committee s focus more systems and procedures. 20

22 TOPIC 4: EXERCISE What WHS/OHS roles are played by the people in your QBE worksite who hold the following positions under the ACT? You may need to refer QBE iq or the relevant WHS/OH&S website for your state or territory. 1. PCBU/Management: 2. Workers / employees: 3. Workplace health and safety representatives/committee: 4. WHS/OH&S manager: 5. Workplace health and safety inspectors: 21

23 Issue resolution Any workplace health and safety issue that is raised by workers/employees in the workplace must be addressed by managers in a timely and effective manner. It is important for an organisation to develop an agreed procedure for dealing with health and safety issues, suggested procedure is: Step 1: Raise the concern with the immediate manager. Step 2: If the issue is not resolved within a reasonable time frame (commensurate with the Risk) the employee may involve their health and safety representative. Step 3: The health and safety representative should endeavour to resolve the matter in the workplace with the immediate manager or next level of management. Step 4: If unresolved, the health and safety representative should refer to the health and safety committee for resolution (high risk issue would be referred to committee chairperson and senior management). Step 5 In extreme cases where an issue cannot be resolved then the health and safety representatives or health and safety committee chairperson may refer the issue to or approach the State or Commonwealth WHS/occupational health and safety authority (regulator). TOPIC 4: EXERCISE Consider a situation in which a worker complains to their manager (who has been working with the organisation for a long time) they are having issues with their back. Their doctor has suggested they require a new chair. Based on the doctor s advice, the worker/employee is adamant they need a new chair. The existing chair meets Australian Standards. The issue remains unresolved after a week. How would you resolve this issue using current QBE Insurance procedures? What information does the frontline manager need to obtain as part of their investigation/ risk assessment? 22

24 Records and Records Management Tracking the issues It is a legal obligation to maintain health and safety records in a workplace, with accountability and responsibility being the key factors in WHS/occupational health and safety management. Examples of WHS/OH&S records that must be kept include (but not limited to): Induction and training; Incident reports with investigations and corrective action; Injury registers; Risk assessments; Workplace inspections; Issues and resolution/outcomes; and Minutes of meetings {committee meetings/tool box talks etc). Organisations must establish a process that monitors and communicates any workplace changes including responsibilities and accountability. Keeping records assists in maintaining an effective WHS/occupational health and safety management system. Senior management plays a pivotal role in all organisations by accepting a range of accountability and responsibility functions. This includes importantly commitment, consultation and issue resolution, risk management, incident reporting and induction and training. Information Dissemination Organisations should have procedures that ensure WHS/OH&S information is communicated to all employees as part of best practice within the organisation. Information about the outcomes of participation and consultation in any organisation has to be provided in a manner that is accessible to workers/employees. A number of communication mechanisms are available to any organisation, depending on its size. These may include combinations or only one of the following: Noticeboards can be located in most work units; Newsletters distributed on a regular basis; Intranets available at any time; Meetings teams meet to discuss common issues; Electronic Mail available to employees who have computer access; and Videos available as training aids. 23

25 TOPIC 4: EXERCISE How is WHS/OH&S information commonly communicated at your QBE worksite? CASE STUDY An inspector arrives at your workplace unannounced. She says she is responding to a complaint. Several workers have complained that they have to carry heavy boxes up and down the stairs. They have also complained that they have sore wrists, because they have to spend most of the day stacking small objects into boxes, or shelving that is about one and a half metres high. The inspector states that employers have an obligation to ensure health and safety in the workplace. She asks to see your risk assessments for manual tasks. You do not have any. The inspector issues an improvement notice. Locate the relevant section of the Act on the WHS/OHS web site for your state or territory to answer the following questions. 1. Is there a maximum or minimum weight workers can carry? 2. Can an inspector arrive unannounced? 3. Does an organisation have to conduct risk assessments? 4. Do you have to answer questions asked by your inspector? 24

26 Summary As the responsibility for WHS/occupational health and safety is shared across many different people who have different levels of authority/accountability, it is important that a business adopt a participative approach to establishing its policies and procedures, and in dealing with issues as they arise. The main stakeholders in such consultative arrangements are: Management; Workers/Employees Health and safety representatives; Health and safety committees; QBE Workplace health and safety team Workplace health and safety inspectors. Procedures should be in place for consultation and participation and resolving issues. Such procedures should include: Key stakeholders and their roles and responsibilities How consultation will be facilitated When consultation must be undertaken Raising issues immediately; How to raise issues and to who should they be reported Involvement of health and safety representative/committee; and The role of the relevant government authority if the issue is not resolved. All health and safety records including those relating to issues must be kept, as part of the accountability for WHS/occupational health and safety management. It is also important that appropriate communication methods are used, so that all workers/employees are kept up to date about WHS/occupational health and safety issues. 25

27 Topic 5 Controlling Risk 26

28 Controlling a risk means eliminating the hazard altogether, or minimising the chance that it will actually harm people. Part of this process may involve reviewing the current risk management procedures. An improvement in these is likely to result. However, deciding and implementing a control measure is not the end of the risk control process. Control measures have to be evaluated in order to determine: Whether the risk has actually been controlled; and That no hazards have been created by the control measures. Assessing risks is a way of determining the likelihood or potential a hazard will cause injury or ill health to anyone at or near a workplace. The number of people exposed to the hazard and the duration and frequency of exposure will also influence the level of risk. After identifying a hazard assessment of its associated risks must be performed. Analysing a risk requires you to: Estimate consequences (i.e. how bad could the injury be): e.g. fatality, lost time injury (LTI), medical treatment injury (MTI) or first aid Estimate the likelihood of the consequence, taking into account any existing controls that are in place. Determine the level of each risk To determine the risk level/rating, the following risk assessment matrix can be used. This rating then forms the basis for action prioritisation. 27

29 The above table outlines the required action in response to an assessed risk rating. Risk control measures must also be maintained, for example, work procedures have to be monitored to ensure they are being followed, such as ensuring headsets are worn, or that work areas are kept neat and tidy. New risk assessments must be done whenever circumstances change. For example your office lay out changes or new equipment is installed. Risk control measures A six-tiered hierarchy of control exists to control workplace hazards. These control measures are adopted in legislation for controlling occupational health and safety risks. Elimination - processes, which are not necessary to a system of work. Substitution - substituting a toxic substance, or hazardous plant or process, with one known to be less harmful to health. Substitution is not only a preferred control method it may also be the least expensive. For example, substituting smaller boxes but still carrying them upstairs may be more appropriate than installing a lift, or using a less hazardous material to control a vapour hazard makes more sense than installing an expensive ventilation system. Isolation - enclosing or isolating a hazard, such as a toxic substance, plant or process, from employees, to eliminate or reduce the risk of injury or illness. Engineering controls - changing processes, equipment or tools. For example, installing larger computer monitors or ergonomic chairs, or providing devices and clothing that offer individual employees some protection from hazards. Administrative and training controls - changing work procedures to reduce exposure to existing hazards, for example: reducing exposure to hazards by job rotation, or limiting the number of employees exposed to the hazard by limiting access to hazardous areas. Personal Protective Equipment (PPE) controls- Ensure that all workers/employees are wearing correct protective equipment and clothing whilst near the hazard Risk Control Deficiencies As a result of applying the hierarchy of controls, a number of inadequacies may be identified in the WHS/OHS system. This will enable new measures to be implemented. For an organisation to be effective, a system of monitoring should be also in place, including: Self checking - at nominated points in the work process; and 28

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