The truth is that some contracting companies do not measure up to the new Mining Health and Safety Act, Regulations and Australian Standards.
After conducting countless audits and reviews of safety systems with contract companies as a health and safety manager, and now as an OH&S consultant, I have seen just about every imaginable variation of safety systems. Some companies have excellent systems that are well documented and the paper work matches the day-to-day reality of work. Generally, the following issues are critical in the development of a comprehensive and efficient system.
1. The highest priority should be the health and safety of employees. Contract companies have to set high standards of health and safety for their employees and ensure that each employee returns to their home and family in the same condition they arrived at the start of shift.
2. Safety Management Plans. Contract companies need to develop comprehensive Safety Management Plans and then ensure they comply with their own plans when audited. Audits of these plans should be both internal and external.
3. Independence. It is imperative that contract companies set their own standards of safety. When a contract company comes to a new project they generally have to comply with the Safety Management Plans of their host. The companies that do best are not dependent on the host company’s plans and standards, because they have their own plans in place and usually their standards are superior.
4. Induction and Health and Safety Training Programs. Successful contract companies ensure that they obtain and hold all employee records.
5. Medical and Health Records. The appropriate records should be kept and a system put in place that allows the company to ensure regular medical and health assessments are completed.
6. Safe Operating Procedures. Specific safe operating procedures (SOP), relating to the scope of work on the project have to be developed and most importantly made available to the entire workforce. Procedures should be independently developed and relate to an assessment of risk. Many times safe operating procedures have been developed but the personnel that are completing the task don’t know of the SOP or have access to it.
7. Safety Promotion Programs. Successful contracting companies operate their own safety promotions and are not reliant on the host company. Safety programs are driven by the needs of their people and the operation, not the agenda of the host company.
8. Tool Box Talks. Effective contract companies plan and conduct these talks and ensure all personnel get the toolbox talk information. Questions are documented and feedback given to the person who raised the issue. Records are kept of topics, issues or queries that were raised and the personnel who were present at that time. Personnel not present on the day have to be given the same information when they return to work.
9. Incident, Hazard, Incident Investigation and Reporting Procedures. A common need for contracting companies is the development of a more professional system for collecting and recording information in relation to hazards, incidents and investigations. Investigations need to be conducted with more independent rigor and professionalism.
10. Safety Statistical Analysis. Contracting companies need to ensure they keep accurate and current weekly and monthly statistics of each project and their company effort overall. Further, these statistics have to be readily available to the appropriate personnel.
11. Safety Inspections. Effective companies go beyond the relatively easy routine of conducting verbal safety inspections, and prepare the written work to record each inspection.
12. Statutory Safety Requirements. A considerable amount of work and effort has to be invested to remain compliant with current requirements. Short cuts and missing components are not acceptable.
13. Personal Protective Equipment. Too many contracting companies are content to let host companies do the work of finding improved PPE. Effective contracting companies exercise their own initiative and look to improve PPE for their own people.
14. Management Position Description and Safety Responsibilities. Some companies may have this in place but do not make it available. In most cases employees don’t know their company’s management positions and the management personnel don’t know their safety responsibilities.
15. Job Safety Analysis. Ensure that all personnel have been trained and fully understand this process and complete them to the required standard before any new activity is commenced.
16. Workers Compensation and Rehabilitation Program. Some companies don’t have a program in place and rely on the host company to control worker’s compensation and rehabilitation. Contract companies have an obligation to their employees to ensure that they have Rehabilitation Policy in place and it is followed.
17. Induction. A site induction conducted by the contract company should include:
- Induction to the contractor’s safety representative
- The host company’s contractors register
- The specific work environment
- Safe work practices
- Explanation of their safety program
- Employee individual responsibilities
- Introduction to the elected site safety representatives and nominated first aid attendants
- Function of their toolbox meetings and that it is mandatory attendance
- The function of their routine safety meetings
- Personal protective equipment policy
- Incident/accident and hazard reporting systems
- Procedure for hazard materials
- Procedure for work permits
- Procedure for tagging
- Licensed personnel