The Most Important OHS Due Diligence Tool

The Most Important OHS Due Diligence Tool  
 
By: Bruce Whitehead from The Brief Group

If you were to pick one aspect of, or thing in your safety management system as the most important, what would it be? It would have to be important from an injury prevention and a compliance perspective wouldn't it?

I think I know what it is, and my answer would not change irrespective of your business type. Interestingly, not one OHS Act or Regulation in Australia mandates that you have one.

The answer is a Risk Management Register, otherwise known as a corrective action register, risk register or hazard register.

Let me tell you why it is the most important OHS Due Diligence tool in your business:

Managing workplace safety is all about identifying hazards, assessing risk, eliminating or controlling that risk, and making sure any controls implemented are effective. The Register documents all of these processes.

Hazards should be addressed by reference to gravity of risk. The Register prioritises your hazards from most serious, to least serious.

If an employee is injured as a consequence of a known hazard, as opposed to a merely foreseeable one, your chances of being prosecuted are much higher. The Register assigns accountability and timeframes to provide senior management some comfort that a program of corrective action is in place.

Controls devised must be capable of being referenced back to the Hierarchy of Controls coupled with an assessment made at the time of arriving at the decision, that the risk has been mitigated As Low As Reasonably Practicable (ALARP). The Register makes provision for these two expectations to be signed off.

Senior management has a duty to monitor the efficacy of the company’s hazard identification processes. The Register should make provision detailing which system process resulted in each hazard being identified, thereby allowing more informed assessments to be made on process performance. Being “proactive” for senior managers involves maintaining an active interest in key system processes.

Senior management has a duty to monitor the efficacy of the company’s corrective action processes. The Register enables simple positive performance indicators to be developed, such as a preferred close-out rate based on number of hazards identified versus number of hazards closed out within agreed timeframes. A Register is also very easy to audit.

Good businesses demonstrate an active interest in their key system processes and recognised good compliance. The Register identifies which person was responsible for identifying the hazard.

To ensure consistency, employees assessing risk should apply one standard risk matrix. The Register stipulates the company endorsed matrix.

Once controls have been implemented, there must be a period of review to verify the efficacy of those controls in mitigating the risk. The Register entry cannot be signed off until the system prescribed period of review has passed.

Companies should aim for consistently high standards of risk control between sites and departments and minimise unnecessary reinvention. A Register can be centrally maintained, whilst signed off entries should be filed by hazard type for future reference.

Senior management should be deploying OHS resources to those parts of the business subject to the greatest amount of risk. The Register can quickly orientate decision makers to high-risk areas so more strategic, informed investments can be made. Outstanding Register issues can be quickly escalated by the Document Owner to persons of authority for resolution.

Safety meeting agendas typically lack substance and punch. The Register can be tabled at these meetings creating greater workplace visibility and accountability.

If I was a director or person concerned in the management of any of my clients’ businesses, this Register is the one document, above all others that I would want to see.

Bruce Whitehead is a director of OHS compliance specialist firm The Brief Group. Browse their smallbusiness[HQ] directory listing here.

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