The Plant Safety Management Model identifies three key elements of a plant safety management system. This article focuses on the Safe Plant element of the Plant Safety Management Model.
Safe Plant
Ensuring safe plant is provided to a work team or project for use is a fundamental element of a plant safety management system. There are four focus areas to ensure safe plant.
Focus area 1: Detailed plant hazard assessment
Why is this necessary?
This ensures provision of safe plant to operators/work groups. It is specifically required by:
- Workplace Health and Safety Legislation
- Workers compensation self-insurance
- AS4801 & Federal Safety Commissioner Accreditation
Detail:
Harmonised/Model Workplace Health & Safety Act:
- Section 19 Primary duty of care, Section 21 Duty to ensure safe plant
Harmonised/Model Workplace Health & Safety Regulation:
- Follow the hazard identification (reg 34), elimination (reg 35), risk assessment and control process (regs 35--37)
- Periodically review risk assessment focusing on adequacy of controls (reg 38)
- Used for designed purpose, no unauthorised alterations, meet certain design criteria, specific controls mandated for certain plant types (regs 205-226)
What is it?
A documented, detailed inspection and review of the plant item, against:
- Legislative requirements
- Australian & international Standards
- Leading industry practice
Identifies controls in place and how to maintain these effectively, based on risk.
Document used for:
- Proof the machine has been assessed
- Machine induction
- Operator education
Detail:
Traditional plant hazard assessments are undertaken using the following processes:
- Identify hazards (eg crush, pinch, exposure to dust/fumes/chemicals, pressurised materials, puncture, heat and cold etc.)
- Assess risks - most commonly using the "likelihood/consequence" matrix
i. How likely is an incident involving the hazard?
ii. What is the potential consequence of such an incident? - What control options are there - follow the hierarchy of controls:
i. Eliminate
ii. Engineering
iii. Substitute
iv. Administrative
v. Isolate
vi. PPE
Consideration of control options should recognise both mandatory and leading practice control options.
How to do it
A regimented process which recognises the subjectivity of the traditional process and the difficulty in achieving thoroughness and consistency in outcomes.
Detail:
Use Plant Assessor or an equivalent plant hazard assessment process (traditional process outlined above) - key issues to manage:
- Type, make and model specific is preferable
- Aim for a consistent, thorough and useable process
- A structured process will deliver better consistency and thoroughness
When to do it
- Upon receipt from supplier (suppliers are obliged to provide this information)
- Periodic re-inspection based upon complexity of plant (Plant Hazard Assessment Plan)
Detail:
Requiring Plant Hazard Assessments from plant suppliers have a positive obligation to follow the hazard identification risk assessment and control process, and provide the results of this to their customers. Tender documents and supply terms and conditions should include a clause requiring suppliers to provide this information. Plant Assessor was developed to assist:
- Reduce the variability in information received by customers
- Customers receive hazard assessments electronically into their Plant Assessor membership
- The customer commissions the plant item simply and quickly using Plant Assessor - without reinventing the wheel
Assessment of existing plant fleet - developing your plant hazard assessment plan
The legislative obligation to periodically reassess plant items gives rise to the need to develop a plant hazard assessment plan– not unlike a plant maintenance schedule.
In developing a plant hazard assessment plan, two key questions need to be considered:
-
Which plant items should I assess, and in what order?
-
How often do I need to reassess plant items?
The answers to these questions may be different for different users, and depend on the actual and perceived risk of the plant items. Determining the risk of plant items is partially subjective and requires consideration of a number of factors.
Plant Assessor approaches this task as follows:
Step 1: Risk ranking of plant
- List all plant fleet (type/make/model/identifier/workgroup)
- Sort list by plant type (e.g. excavators, backhoes, cranes, fixed plant)
- Consider the risk of each type of plant, including:
- Complexity of plant item
- Used for and in what environment(s)
- Incident history
- Rank plant types by risk (1 = high risk, 2 = medium risk, 3 = low risk, 4 = negligible risk)
- Consider workgroup experience and incident history and adjust type or individual machine risk rating
Step 2: Determining initial assessment timing and reassessment periods
Deciding what needs to be assessed immediately and what can wait will be a function of the makeup of the fleet and the owner’s perception of the risk of plant items. Based on experience with hundreds of plant hazard assessment plans, Plant Assessor uses the following rules of thumb in making these decisions:
| Risk rating | Initial assessment (1) | Reassessment period | Machine specific or type assessments (2) |
| 1 High risk | Immediate/year 1 | Annually | Individual |
| 2 Medium risk | Year 2 | Bi-annually | Individual |
| 3 Low risk | Year 3 & 4 | Every 3-5 years | Type or individual |
| 4 Negligible | Upon purchase | After incident only | Type or individual |
-
All plant should be assessed before commissioning. These timeframes relate to existing fleet that has not already been assessed.
-
High and medium risk plant should be individually assessed, as machines vary in design, specification and wear and tear. Type assessments are acceptable for low risk plant types. Care should be taken to make sure that all plant items in a type meet the same design.
Focus area 2: Daily inspection and fault rectification process
Why is this necessary?
Legislative obligation to provide safe machinery. Immediate identification of major and minor faults is critical.
Detail:
Machinery is maintained more thoroughly, operators see that the system works and take more pride in their equipment and safety generally.
What is it?
Daily pre-operational check, including basic mechanical checks and check that safety devices are in place and operational.
Detail:
Critical aspects:
1. Escalation of faults found to supervisor and maintenance personnel
2. Faults identified are reviewed prior to operation and decision to stand down considered when faults are critical
3. Repair of faults prioritised based upon risk and impact upon operations and efficiency
How to do it
Paper or electronic system requiring operator to check and sign off on specific aspects of plant.
Detail:
Daily pre-operational checks should contain basic mechanical and fluid checks, and confirmation that key safety devices are in place and functional. A generally accepted "school of hard knocks" principal is that daily checks should contain as few
line items as possible whilst covering key areas.
As a workplace becomes more safety conscious, checks can be expanded with a lower risk of them being ignored as too hard.
When to do it
Daily.
Detail:
Records of this process should be stored for a period of not
less than 12 months to illustrate diligence on maintaining safe plant. Records of plant involved in incidents should be kept for longer.
Focus area 3: Proactive and robust maintenance regime
Why is it necessary?
Proactive maintenance is important because:
- It is a legislative safety requirement
- It delivers improved safety & efficiency
- It helps maximise uptime & minimise breakdowns
Detail:
Harmonised/Model Workplace Health & Safety.
Regulation:Reg 213 - Maintenance and inspection of plant
- The person with management or control of plant at a workplace must ensure that the maintenance, inspection and, if necessary, testing of the plant is carried out by a competent person.
- The maintenance, inspection and testing must be carried out:
i. In accordance with the manufacturer's
recommendations, if any; or
ii. If there are no manufacturer's recommendations, in accordance with the recommendations of a competent person; or
iii. In relation to inspection, if it is not reasonably practicable to comply with paragraph (a) or (b), annually.
What is it?
Scheduled maintenance program, based on OEM specifications.
Detail:
A regimented process, actively managed to ensure OEM recommendations are understood, programmed and executed. The maintenance regime incorporates active collection of daily inspection reports containing faults, and repair of those faults.
How to do it
Reference to OEM maintenance schedules and recommendations is crucial. A systemised process is required as fleet grows.
Detail:
Basic maintenance systems for smaller fleets may be paper based (eg maintenance cards) or via spreadsheets. As fleets grow, specialised maintenance systems and fleet management
systems with maintenance modules allow simpler and more effective maintenance and fleet management. Fleet management systems can be used to schedule all of the aspects of ensuring SAFE PLANT, such as scheduling work orders to each item of plant requiring hazard assessments and SOP development.
When to do it
An essential ongoing process.
Detail:
A maintenance schedule for each machine should be set up after purchase and prior to commissioning, and incorporate plant hazard assessment and SOP development.
Focus area 4: Standard safe operating procedure for plant item
Why is this necessary?
Development, provision and training in machine Safe Operating Procedures is important because:
- It is a legislative safety requirement
- It delivers improved safety & efficiency
Detail:
Harmonised/Model Workplace Health & Safety Act:
- Section 19 (3) Without limiting subsections (1) and (2), a person conducting a business or undertaking must ensure, so far as is reasonably practicable:
1. the safe use, handling and storage of plant, structures and substances
2. the provision of any information, training, instruction or supervision that is necessary to protect all persons
from risks to their health and safety arising from
work carried out as part of the conduct of the
business or undertaking
Harmonised/Model Workplace Health & Safety Regulation:
- Regulation 39 - Provision of information, training and instruction
Plant Safe Operating Procedures are an important machine specific component of the key information and training used to ensure a safe operator and a safe environment. In essence the key management tools used here include:
- Plant SOPs
- Task risk assessments and safe work methods statements
- Site hazard assessments and site safety rules
- WHS Management Plan for projects >$200000
What is it?
Simple, readable guidance regarding dos and don'ts when using plant, preferably limited to 1 page.
Detail:
Plant SOPs should include, as a minimum:
- PPE details
- Operation
- Refuelling, maintenance, isolation basics etc.
It is important to recognise that this is NOT A TASK SOP, and therefore does not need to contain comprehensive task related instructions. It is a summary of key issues for a competent operator to remember, and abide by when using the plant.
Plant SOPS are a component of, and referred to in, task risk assessments and safe work methods statements for tasks that use plant items.
How to do it
Develop a template and follow consistent process in completing for plant items.
Detail:
Use Plant Assessor or develop these SOPs upon receipt and commissioning of plant with reference to OEM information. Review with operators periodically and after any incidents.
When to do it
Periodically.
Detail:
Upon receipt and commissioning of plant. Review when reassessing plant items. All operators to review and acknowledge periodically (preferably at the time of reviewing plant hazard assessment).
For more information, download the Safe Plant Guide.
Disclaimer: This information is intended to provide general information on the subject matter. This is not intended as legal or expert advice for your specific situation. You should seek professional advice before acting or relying on the content of this information.
Safe Operator
It is fair to say that almost every safety incident involving plant and equipment is caused or contributed to by a lack of operator knowledge or a failure to implement that knowledge. Ensuring a “safe operator” can be divided up into 3 key focus areas of activity; operator training and competency assessment, general safety and system knowledge and site and task specific procedures and knowledge.
Focus area 1: operator training and competency assessment
Specifics
- Initial Certification of Competency to operate machine and/or
- High risk work licence(s)
- Certified operator competencies and High Risk Work Licences should be verified periodically
- Both RTO assessors and in house assessors need to have their competency to assess operators verified periodically
How to obtain and manage
- Training and certification of competency to
Nationally Recognised Units of competency by RTO - Training and licencing by RTO approved to train and issue HRW Licences required
- Periodic verification against the competency, by an RTO or in house assessor - needs to be recorded and auditable
- RTO employee competency records should be transparent to RTO clients
Initial training and certification of competency (including high risk work)
- Liaise with RTO (see section on choosing an RTO) or experienced advisor to determine appropriate matching of available units of competency and your operator training requirements
- Once relevant units of competency are identified, engage RTO(s) to commence the process of training and certifying operator competency. This should involve recognition of prior learning for experienced operators
- High Risk Work Licences are issued by State regulators following receipt of confirmation of competency issued by an RTO authorised to do so by the relevant regulator (eg WorkSafe Victoria)
Government Incentives for VET: There continue to be considerable Federal and State Government incentives to support employers wishing to up skill and certify their staff as trained and competent.
This funding is available for existing and new employees, and can include subsidies, payroll tax, workers compensation exemptions etc. RTOs can provide advice on these.
Periodic verification
He's got a ticket; doesn't that mean he is competent? No!
Common sense dictates that unless a competency is used on a regular basis, it is likely to fade. In addition to this, changes in machine design and capability can adversely impact upon an operator's ability to operate a machine competently. The need to periodically verify operator competency is well recognised in some industry segments, however generally is not done well or consistently.
Verification of plant operator competency - what does it look like and how do I do it?
What am I trying to verify?
- Familiarisation with components and controls (location, name and how to use)
- The ability to complete pre-start checks (what and how to perform), start up, operate, park, shut down and secure
- The ability to load, unload and load restraint if relevant
- If VOC is being done in conjunction with specific site work:
- Specific safety considerations of task(s) in scope
- Tasks requiring unique operator competency
How do I conduct VOC?
VOC is a combination of knowledge testing and observation of operation. It is recommended to start with an initial discussion with and questioning of the operator regarding the machine, its controls, site and task requirements (if relevant). Conclude this discussion by observing the operator undertake pre-start checks.
Operation of the plant: This involves observation of the operator undertaking a defined set of actions/tasks, which align to the type of work the operator will be required to undertake.
For example, if an excavator operator is doing work on batters, digging trenches, slinging and lifting pipes, and backfilling - VOC should test these competencies as a minimum.
Who can conduct VOC?
Your RTO should be in a position to verify operator competency, or alternatively you may wish to bring this function in house. If going in house, it is important to ensure internal assessors have the competency to conduct the assessment, including:
- Competency to operate the equipment concerned including certificated competency and recent verification
- Competency to undertake the range of tasks being assessed
- Qualifications in training and assessment, such as a Certificate IV Training and Education
How Often Should I conduct VOC?
This is a question without a black and white answer. The period between verification will depend upon a number of logical variables including how much time the operator spends on the type of machine, their productivity and incident history. On major projects, this will also depend upon the requirements of the principal contractor, who may require evidence of VOC (or to conduct their own assessment) prior to commencement of work.
Details
Arguably the most important and onerous of the focus areas, this requires active management on an ongoing basis. The principle behind this focus area is the need for operators to be trained and certified as competent to a transparent standard. This helps to reduce the risks associated with varying operator skill by aiming to ensure a minimum standard of competency.
The national Vocational Education & Training (VET) system provides a framework to allow nationally recognised certification of training and competency assessment tailored to the needs of a broad range of industry segments including civil construction.
The following diagram illustrates the structure of the VET system as it relates to competencies of plant operators in civil construction.
The Resources and Industry Training Package RII09 includes some 767 Dedicated Units of Competency and 180 Imported Units of Competency (Total 947). Details of RII09 and its components can be found here. High Risk Work licences are included in relevant training packages. Registered Training Organisations (RTOs) are authorised to train and certify competence against certain units of competency and qualifications under the various training packages. In light of the VET structure, we can now consider operator training and competency assessment set out in the following table.
Focus area 2: general safety and system knowledge
Specifics
- Construction induction (White Card)
- Company induction and initial training:
- Ongoing WHS Consultation process
How to obtain and manage
- By RTO approved to train and issue White Card
- Initial company induction for employee
- Consultation tools
Initial employee company induction and White Card
- WHS Organisational Structure, WHS Consultation overview and mechanisms:
Hazard identification, risk assessment, incident reporting and injury management process - Emergency procedures
- Site work WHS Management overview
Construction induction 'White Card" training
All workers involved in any form of construction work are required to undergo this training, resulting in issue of a "White Card". This is aimed at ensuring a minimum level of general construction industry safety knowledge.
Ongoing WHS consultation process, including maintenance of policy/procedure knowledge
Ongoing consultation is essential to the maintenance of safety knowledge and employee engagement. Harmonised WHS laws require PCBUs to consult a range of issues including:
- Identifying work hazards and assessing risks
- Ways to eliminate or minimise risks
- Procedures for resolving health or safety issues, monitoring the health of workers or workplace conditions, information and training or consultation with workers, and
- Guidance from Safe Work Australia on consultation.
Common consultation arrangements, company and site safety committees, elected WHS representatives for work groups and regular toolbox meetings. One of the most critical subsets of this key area is maintaining currency and knowledge of company policies and procedures.
Site and task safety (including development and implementation of SWMS) are also linked to this area.
Details
This focus area is principally aimed at ensuring operators have been through relevant inductions, and have a good working understanding of the safe systems of work employed by their organisation to manage safety risks, no matter where they are working.
Focus area 3: site and task specific procedures and knowledge
Specifics
- Site safety rules
- SWMS for high risk work
How to obtain and manage
- Site induction
- SWMS consultation, development, education and acknowledgement process
Site induction and site safety rules
Site rules and requirements based upon the contents of the site WHS Management Plan, including:
- Key personnel and responsibilities
- Consultation, cooperation and coordination arrangements
- Provision of facilities and housekeeping
- Specific site safety rules - developed in light of Steps 1 and 2 (site and project review)
- Housekeeping, traffic management, PPE
- Incident reporting & management
- First aid and emergency response
- Alcohol and drugs
- Plant and Equipment - site rules
- High risk work - management principles
Managing high risk work
Safe Work Methods Statements developed to manage risks of high risk work on site. Refer to Plant Assessor's Safe Environment article relating to development of SWMS, and how to maximise the effectiveness of SWMS. There must be a process for ensuring operators review, understand and sign off on the SWMS related to all tasks they are undertaking on a site.
How do I manage the process of ensuring a safe operator?
Whilst each focus area is relatively simple in itself, managing all of them together, particularly for a large workgroup can become a big job. Like any big job, it needs to be planned, scheduled and followed up. Project management skills are therefore important.
The planning should start with the development of a competency matrix for employees and regular contractors. This matrix should include a list of roles and/or staff on one axis, and a list of competencies/training/knowledge required on the other axis. Once the matrix is complete, training requirements then need to be determined for each competency, along with decisions regarding periodic retraining and verification of competency.
Capturing the resulting work in a calendar helps to remind when any form of training or competency assessment is due. As operations become larger, more resources need to be devoted to managing the process of ensuring all personnel maintain their knowledge and competency in the three key focus areas. Many larger organisations utilise learning and information management systems to assist in managing these obligations.
Download the Safe Operator Guide to find out more information about Safe Operators.
Disclaimer: This information is intended to provide general information on the subject matter. This is not intended as legal or expert advice for your specific situation. You should seek professional advice before acting or relying on the content of this information.
Safe Environment
The Safe Environment component of the Plant Safety Management Model refers to ensuring the site and task hazards are identified, assessed and controlled. There are four focus areas including:
- Site review
- Project task review
- Prepare the WHS Management Plant
- Implementing high impact elements of WHS Management Plan
Focus area 1: Site review, hazard identification, risk assessment and control
The review of site attributes is the logical first step in ensuring safe environment for the project. This should be undertaken using a traditional hazard identification, risk assessment and control process, which generates information which is then used in planning the management of task hazards.
Consider site attributes including:
- Access and egress to site - vehicle and pedestrian traffic, parking, employee pedestrian access etc.
- Geographic conditions - slope, rivers/creeks etc.
- Geological conditions - unstable ground conditions, undermining, sinkholes etc.
- Weather conditions - extreme heat, cold, wind, rain, snow or ice and seasonal factors etc.
- Neighbouring operations that may create hazards on site such as fumes, toxic substances, noise, explosion, cave in deluge etc.
- Size of site relative to project footprint - crowding, deliveries, storage
- Location of site - travel fatigue issues, work in combat zone or politically unstable country or province, possible terrorism etc.
- Other attributes that may represent a hazard during or after construction works
Focus area 2: Project task review
This focus area is about getting an overview about the project and reviewing the nature of the work to be undertaken. It is important to take a risk management approach when undertaking this review and to map out the areas of work which are likely to involve high risk work. These include:
- Falls and falling objects
- Traffic management
- Essential services
- Hazardous and manual tasks
- Hazardous chemicals
- Asbestos
- Confined spaces
- Access and security
- Electricity
- Mobile and other plant
- Noise
- Steel construction
* Safe Work Australia Draft Construction Code of Practice 2012
Focus area 3: Prepare the WHS management plan
The WHS Management Plan documents the approach to managing safety on a project. Below are examples of high impact elements and other elements. All elements of the plan are important, however high impact elements require much more active management to develop and deliver. If high impact elements are not approached diligently, safety on the project will almost certainly be sub-standard in the areas that deliver the most critical systems and safeguards.
High impact elements of a WHS management plan:
- Managing high risk work
- Contractor management
- Induction and training requirements
Other elements of a WHS management plan:
- Key personnel and responsibilities
- Consultation, cooperation and coordination arrangements
- Provision of facilities and housekeeping
- Site specific safety rule. These should include but not be limited to:
- Housekeeping
- Traffic management
- Incident reporting and management
- First aid and emergency response
- Alcohol and drugs
- Plant and equipment - site rules
- PPE
- High risk work - management principles
Focus area 4a: Managing high risk work
This Focus Area revolves around the management of Safe Work Methods Statements (SWMS) which are mandatory for high risk construction work (Model WHS Regulation 299).
It is appropriate to consider some critical ‘must dos’ when managing and preparing SWMS to deliver considerable safety benefits on any project:
- Have a plan or map of project areas requiring SWMS and their interrelationships (refer focus area 2).
- Minimise the number of SWMS required. Combine multiple high risk tasks into one SWMS where practical. Do not complete for non-high risk or non-unique tasks.
- Use a consistent format and language, avoiding jargon where possible.
- SWMS should be facilitated and recorded by experienced personnel, in consultation with people who are or shall be undertaking the task concerned.
- Rigorously apply the hierarchy of controls, to avoid over reliance on administrative controls to manage every hazard identified.
- Ensure the induction process explains the site SWMS regime.
- Test knowledge of and compliance with SWMS in the workplace.
Focus area 4b: Contractor management
Contractor management is arguably the most difficult element of any construction project to manage due to the large number of external parties often involved. Contractor Pre-Qualification Pre-qualification involves contractors submitting information on their safe systems of work to a principal contractor, and being subject to an audit. Pre-qualification is suitable for principals and contractors who work on multiple projects together. It can be a time consuming and costly exercise, however saves a great deal of time when tendering for and undertaking multiple projects. Anyone employing contractors/subcontractors on site must ensure the contractors they employ have a safe system of work covering the activities they are undertaking.
For contractors using plant, this safe system of work needs to recognise the specific site and project requirements, and illustrate management of safe plant, safe operator and safe environment.
Focus area 4c: Induction and training requirements
Training and competency assessment are critical to the extent that a project safety management system relies upon competency, know how, and administrative controls to manage safety risks.
As a minimum, the following information should be accessible for every person working on a site:
All personnel
- General construction induction
- Site induction and knowledge of site safety rules
- Trade qualifications and general task competency
Personnel conducting high risk work:
- Knowledge of relevant SWMS
- High risk work licence where required
- Operator competency for plant
It is important for employers to maintain auditable records of the training and competencies required for each of their employees working on or around a project. When employing contractors, contracts should require:
-
Positive confirmation from the relevant contractor that their staff possess the relevant licences and competencies to undertake the relevant work.
-
The contractor has auditable records proving that these licences and competencies are current.
In addition to this, it is preferable to also systematically audit contractors’ records on a random basis, with a focus on personnel conducting high risk tasks.
Download the Safe Environment Guide for more information.
Disclaimer: This information is intended to provide general information on the subject matter. This is not intended as legal or expert advice for your specific situation. You should seek professional advice before acting or relying on the content of this information.