OHS Professional Magazine March 2022 by Australian Institute of Health & Safety

PROFESSIONAL A U S T R A L I A N I N S T I T U T E O F H E A LT H & S A F E T Y P U B L I C AT I O N

MARCH 2022

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How to make OHS management systems really work

The atom of safety: how ANSTO achieved ISO45001 certification

Inside Isaac Regional Council’s safety transformation

How high reliability organisational theory can improve mining safety

contents MARCH 2022

How to make OHS management systems really work Aside from passing audits or other external compliance requirements, effective and efficient OHS management systems should assist with, and cause minimal disruption to, organisational operations

Features

OHS Professional Published by the Australian Institute of Health & Safety (AIHS) Ltd. ACN 151 339 329 The AIHS publishes OHS Professional magazine, which is published quarterly and distributed to members of the AIHS. The AIHS is Australia’s professional body for health & safety professionals. With more than 70 years’ experience and a membership base of 4000, the AIHS aims to develop, maintain, and promote a body of knowledge that defines professional practice in OHS.

Freecall: 1800 808 380 Phone: (03) 8336 1995 Postal address PO Box 2078 Gladstone Park VIC 3043 Street address Unit 2/217-219 Mickleham Rd Tullamarine VIC 3043 Membership enquiries email: membership@aihs.org.au Editorial Craig Donaldson email: ohsmagazine@aihs.org.au Design/Production Anthony Vandenberg email: ant@featherbricktruck.com.au Proofreader Heather Wilde Printing/Distribution SpotPress

Safety tech: inside the digital transformation of OHS: Digital adoption is the biggest barrier that stands in the way of businesses embedding OHS technology in their business, writes Nathan Hight

10 How can HRO improve safety in mining? Can the mining industry apply high reliability organisational (HRO) theory to reduce the rate of serious accidents and fatalities and improve safety performance?

Advertising enquiries Advertising Manager, Robbie O’Rourke Ph: (03) 9974 3315 Fax: (03) 9012 4215 E: robbie2@mediavisionaust.com.au For the OHS Professional magazine media kit, visit www.aihs.org.au. Disclaimer: The opinions expressed within are those of the authors and do not necessarily reflect AIHS opinion or policy. No part of this magazine may be reproduced in whole or in part without the permission of the publisher. Advertising material and inserts should not be seen as AIHS endorsement of products or services

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Lifting safety standards in WA’s petroleum operations industry: Frank Walsh won the Inspector of the Year Award for a proactive, collaborative, and innovative approach to improving safety in Western Australia’s petroleum operations industry

The atom of safety: how ANSTO achieved ISO45001 certification: The Australian Nuclear Science and Technology Organisation (ANSTO) was one of the first organisations in Australia to successfully achieve ISO45001 certification in 2018

Regulars Inside Isaac Regional Council’s safety transformation: The council has taken a holistic and forwardthinking approach to lifting safety standards and outcomes and this has significantly transformed safety across the organisation

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From the editor

CEO’s message

News

Book review

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MARCH 2022 | OHS PROFESSIONAL

EDITORIAL NOTE

Under the bonnet of OHS management systems There is often tension between ‘work as imagined’ and ‘work as done’ in the way OHS management systems are commonly designed, writes Craig Donaldson

Craig Donaldson, editor, OHS Professional

echnology has transformed the operations of organisations in many ways. As organisations implement digital transformation initiatives to reap a number of benefits, including costefficiencies, reduced administration, and improved compliance, OHS is one function that has also benefited from technology in many important ways. Aside from passing audits or other external compliance requirements, effective and efficient OHS management systems should assist with and cause minimal disruption to organisational operations, according to the industry experts interviewed for the latest instalment in our OHS Body of Knowledge series. This latest feature article examines OHS technology and related areas in a number of chapters, including 12.1 (systems), 12.2 (OHS management systems), 12.3.1 (rules and procedures) and 12.3.2 (document usability). Drew Rae, a senior lecturer in the Safety Science Innovation Lab at Griffith University

(and co-author of chapter 12.3.1) asserts there is a polite fiction that management systems exist for the purpose of improving health and safety. “The bulk of OHS management systems consist of models, frameworks and methods – variations on ‘work as imagined’. If these organising elements are written to appease external stakeholders or to satisfy the need to be audited, that pulls them further and further away from ‘work as done’,” he says. For the full story turn to page 18. Also in this issue, we look at how Queensland’s Isaac Regional Council has been through a significant cultural and safety transformation in recent years. Poor performance during a local government workcare audit identified a significant resourcing shortage and capability within the safety team in 2011, and the council has been on a journey of continuous improvement since. Jeff Stewart-Harris, CEO of Isaac Regional Council, says the safety team has been a catalyst within the council for helping with “cultural leadership work” critical to successful safety improvements. StewartHarris essentially says this work comprises five key elements: (1) leaders showing the way; (2) leaders setting and modelling the tone; (3) leaders creating environments for people to achieve; (4) leaders empowering their teams to achieve; and (5) monitoring what’s going on and either celebrating success or making corrections. For more information turn to page 14. We also continue with our profiles of winners from the Australian Workplace Health & Safety Awards 2021. Now in their second year, the awards recognise achievements in WHS across 11 award categories. In this edition we feature a story on Frank Walsh, who won the Inspector of the Year Award for

a proactive, collaborative, and innovative approach to improving safety in Western Australia’s petroleum operations industry. Walsh, who is a senior inspector with Western Australia’s Department of Mines, Industry Regulation and Safety (DMIRS), has systematically improved operational efficiencies by integrating digital innovations and reducing workforce exposure times to high-risk work activities. Go to page 26 for the full story.

“The bulk of OHS management systems consist of models, frameworks and methods – variations on ‘work as imagined’” Lastly, we look at how the Australian Nuclear Science and Technology Organisation (ANSTO) achieved ISO45001 certification successfully in our compliance feature (page 30). ANSTO, which is home to Australia’s most significant nuclear science and technology infrastructure, was one of the first organisations in Australia to achieve this certification in 2018. Shelley Levy, leader of high-reliability systems for ANSTO, says the main challenge was to continue operational business-as-usual safety support for operations and squeeze in a continuous improvement project. “This is where having a project leader and a project management plan kept us on track, with timeline goals to achieve along the way,” she says. n

The OHS Professional editorial board 2022

CHANELLE MCENALLAY National safety, property & environment manager, Ramsay Health Care

DAVID BORYS Independent OHS educator & researcher

KAREN WOLFE General manager of high reliability, ANSTO

OHS PROFESSIONA L | MARCH 2022

KYM BANCROFT Head of Health, Safety and Environment (AsPac), Serco Asia Pacific

LIAM O'CONNOR HSET group manager, SRG Global

LOUISE HOWARD Executive director of safety, Transport for NSW

MICHAEL TOOMA Managing partner, Clyde & Co Australia

PATRICK HUDSON Professor, Delft University of Technology

STEVE BELL Partner, Herbert Smith Freehills

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CEO'S MESSAGE 05

05 5

The profession’s ongoing journey to relevance, status, and success There has been a marked and positive change in the OHS profession in recent years, but there is still so much more to be done, writes Dave Clarke

Dave Clarke, CEO of the Australian Institute of Health & Safety

hile preparing this last editorial as CEO of the Institute, I’ve been reflecting on the journey that the health and safety profession has taken over the past seven-and-a-half years, and what lies ahead in its future. In articles in late 2014 through 2015, my observations were of an ‘adolescent’ profession, divided, frustrated, uncertain of its place, and lacking in clarity of direction. Social media was a sea of uncivil, pointscoring, sniping commentary between members of the profession – whether it was education versus experience, Safety Differently or Zero Harm vs the rest, debate about Hollnagel, Swiss cheese, or the acolytes of charismatic ‘leaders’ new ideas, declaring their own approach to be the only approach. The tenor was one of competitiveness, and most of all, righteousness. These are the symptoms of a profession which does not have clarity around roles and purpose, and has failed to connect its practice focus to the evidence base. The response of the Institute at the time was to create the Capability Agenda which describes five key components that are considered normal in a mature profession: (a) a strong, universally accepted knowledge base; (b) education assurance; (c) role clarity through defining the knowledge and skill requirements for health and safety roles; (d) capability assurance; and (e) a framework for structured lifelong learning and ongoing skills development. The Institute got to work on corresponding projects in each area: (a) investing heavily in new chapters and

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reviewing existing chapters of the OHS Body of Knowledge (BoK); (b) expanding and consolidating our work in education through the Australian OHS Education Accreditation Board (AOHSEAB), and a review of VET WHS training; (c) enabling and co-authoring the INSHPO OHS Profession Capability Global Framework for Practice; (d) introducing a national certification program; and (e) building a CPD framework for training and professional development. As we’ve been working through these priorities, we also changed our name (for the second time in the 75-year history of the Institute) to reflect the importance of health in our work. More recently the profession and the Institute has been weathering the challenges of COVID-19, and the AIHS is emerging from that by building a stable on online learning options for health and safety professionals. Today, in my eyes, AIHS and the profession have together taken great strides in the past seven years. We have greater clarity in all of the areas outlined above; social media is still lively but a more positive, interactive, information-sharing and learning environment, and over time we’ve seen some good policy developments. However, we now stand at a new crossroads of the next big set of challenges, and one of those is tackling our standing as a profession.

“We have too many people whose performance is poor; the average performers are sometimes not good enough, and the best performers are too few” Many members have told us over the years through surveys and direct engagement, that what they really want most from the AIHS is to help them be more influential, respected, and better positioned in their company. They want more status. However, the pathway to greater status for the profession is not about which

political doors the AIHS opens, or how much you see our logos or spokespeople in the press. Today, one of our greatest weaknesses as a profession – and the greatest deterrent to more power and influence – is the standard of the work the profession does. The best health and safety people are powerful in their company, valued, and have wide influence in their organisation. But this isn’t always the case. We have too many people whose performance is poor; the average performers are sometimes not good enough, and the best performers are too few. Why? One reason is that collectively we still lack a pervading culture of achieving excellence as our norm. We are not setting high enough standards of ourselves. Which comes first, the AIHS building that culture, or the profession generating it? Both. The AIHS and the profession are one and the same, and we share the common responsibility to lift our game to higher levels. If we do this one thing well, I believe the standing of the profession would be transformed. Toward this goal, the AIHS is building the structures and processes that make the journey to excellence more accessible. Previously those pathways have not been clear enough, and we must make improvements. Over the next year, we will be introducing a number of new reforms around training, professional development, and certification that are designed to be more relevant to people who want to achieve growth in their roles and in their careers. I urge everyone to explore the benefits of engaging in the certification program which provides a framework for your career development and lifelong learning. Seventy-five years on from our inception, the work of the AIHS continues. It’s been a great privilege to be a part of the journey, in which I’ve seen things change markedly and positively – but there is still so much more to be done. We are imperfect but we are impatient to be the best we can be. I would like to acknowledge and thank the people who worked tirelessly to build what was there before, the committed community I have worked with on my own journey, and the current hardworking AIHS health and safety leadership community poised to lead the profession to its next stage of maturity and growth. n

MARCH 2022 | OHS PROFESSIONAL

AIHS NEWS

Urgent changes needed to protect health of virtual workforce

Understanding the human factorsrisk migration link

C-suite executives face mental health challenges throughout COVID

The World Health Organization (WHO) and the International Labour Organization (ILO) recently called for measures to be put in place to protect workers’ health while teleworking. A new technical brief on healthy and safe teleworking, published by the two UN agencies, outlines the health benefits and risks of teleworking, and the changes needed to accommodate the shift towards different forms of remote work arrangements brought on by the COVID-19 pandemic and the digital transformation of work. Without proper planning, organisation, and health and safety support, the impact of teleworking on physical and mental health and social wellbeing of workers can be significant. It can lead to isolation, burnout, depression, domestic violence, musculoskeletal and other injuries, eye strain, an increase in smoking and alcohol consumption, prolonged sitting and screen time, and unhealthy weight gain.

Accident and hazardous event investigations often identify individual actions as causal factors (particularly when those actions are contrary to procedures), however, those same actions are often ones that may help in meeting productivity and economic goals without adverse safety consequences. A recent draft information paper from the National Offshore Petroleum Safety and Environmental Management Authority (NOPSEMA) examines how people can balance competing goals and make decisions that maintain safety. “By understanding how people adapt to local and temporal factors to balance competing goals, organisations can guide adaptations in a way that maintains rather than erodes safety margins,” said the paper, which noted variability is to be expected as individuals grapple with the goal conflicts confronting them daily.

Mental health challenges created by the COVID-19 pandemic have impacted workers differently depending on their seniority, generation, and location according to a research report. It found C-level executives have struggled the most with adapting to remote work realities and are suffering from mental health issues more often than their employees, but are also the most open to finding help in AI. The research report, which took in 12,347 people and was conducted by Oracle and HR research and Workplace Intelligence, found C-suite executives (53 per cent) have struggled with mental health issues in the workplace more than their employees (45 per cent). Furthermore, C-suite executives also had the hardest time adapting to virtual lifestyles with 85 per cent reporting significant remote work challenges including collaborating with teams virtually (39 per cent), managing increased stress and anxiety (35 per cent), and lacking workplace culture (34 per cent).

FIFO workers at significant risk of sleep loss and sleep disorders

How can leaders stick to their ethics and values in hard times?

Australians with chronic conditions less likely to work

Fly-in fly-out (FIFO) shift workers are losing out on valuable sleep due to the design of rosters, individual lifestyle behaviours, and the risk of potential prevalence of sleep disorders according to recent research. Edith Cowan University (ECU) conducted the biggest study of its kind in the global mining industry, monitoring the sleeping habits of 75 FIFO shift workers in Australia. Study participants wore a validated sleep and activity tracking device for three weeks over a “two and one” work rotation, which comprises seven day shifts, followed by seven night shifts, then one week off. Participants also answered questions about their sleep and lifestyle behaviours. The research found day shifts starting before 6am and requiring a wake-up time of 4am were reducing the opportunity to sleep and resulted in significant sleep loss prior to the shift.

Like other aspects of health and safety, ethics and values vary tremendously across leaders, settings, workplace culture, and individual incidents, according to Curtin University. Most (if not all) leaders would very much prefer to be both ethical and effective in their leadership, said Jacqueline Boaks, lecturer in the School of Management at Curtin Business School. “What leaders (and the rest of us) sometimes lack are the skills and abilities to confidently act towards ethics and values – how to communicate them to others and implement or act on them in a way that they can feel confident about and believe they will have a decent chance of success,” she said. Often leaders are also looking for the confidence to see that they may be supported in those ethical decisions,” said Boaks, who spoke at the Australian Institute of Health & Safety (WA Branch) Perth Safety Symposium.

Australians with chronic health conditions are less likely to be gainfully employed in the labour market, according to a report from the Australian Institute of Health and Welfare (AIHW). Chronic health conditions are the leading cause of poor health and mortality in Australia, but they also have a major impact on other parts of people’s lives. The report, Life and Work Experiences of Australians with Chronic Conditions, looks at how people with chronic conditions aged 15-64 were faring prior to 2020, providing baseline information for further research. It also takes an in-depth look at factors that were associated with poor health among mature working-age Australians (aged 45-64) living with chronic conditions. About 47 per cent of Australians are estimated to have at least one chronic health condition, such as arthritis, asthma, cancer, cardiovascular diseases, and mental and behavioural conditions, said AIHW spokesperson Katherine Faulks.

OHS PROFESSIONA L | MARCH 2022

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AIHS NEWS

Corporate Members

INVESTING IN HEALTH & SAFETY – GOLD MEMBERS

SHARING OUR VISION – DIAMOND MEMBERS APPENATE PTY LTD Art of Work Pty Ltd Avetta Boral Limited Enablon Australia Pty Ltd

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HealthSafe NZ Limited Safe365 Limited Safety Champion Software Pty Ltd Zenergy Safety Health & Wellbeing

Alium Works Australian Army Clade Solutions EY Federation University FZTEST Org Investigations Differently

Kitney OHS Relevant Drug Testing Solutions Safety Wise Solutions Teamcare Insurance Brokers Pty Ltd Transport for NSW Uniting

GETTING CONNECTED – SILVER MEMBERS

BEING PART OF THE NETWORK – BRONZE MEMBERS

Aurecon Australasia Pty Ltd Brisbane Catholic Education Clough Projects Australia Pty. Ltd Compita Consulting Pty Ltd Craig Mostyn Group Downer EDI Ltd Engentus PTY LTD FIFO Focus Herbert Smith Freehills HOK Talent Solutions Myosh Pilz Australia

5 Sticks Consulting ACTRUA Airbus Australia Pacific AusGroup Limited Australian Workplace Strategies Pty Ltd BWC Safety Pty Ltd FEFO Consulting Flick Anticimex Pty Ltd Green Light Environmental Services Pty Ltd Health & Safety Advisory Service P/L Integrated Trolley Management Pty Ltd Isaac Regional Council ITS Transport

Port of Newcastle Operations Pty Ltd Redland City Council Safesearch Pty Ltd Southpac International Group Sydney Metro The Safe Step Transurban Tru-Bilt Industries Ltd UnitingSA

Liberty Industrial Maroondah City Council Multiworks Australia National Training Masters Office for the Commissioner of Public Sector Employment One Maestro RMIT Vietnam SafeWork SA Services Australia University of Tasmania Valeo Construction

Strategic Partner Organisations Ai Group ASHPA Australian College of Road Safety (ACRS) Australian Institute of Management (AIM) Australian Institute of Mining and Metallurgy (AusIMM) Australian Transport Safety Bureau (ATSB) Commonwealth Scientific and Industrial Research Organisations (CSIRO) Environment Institute of Australia and New Zealand (EIANZ)

Farmsafe Australia Inc Health and Safety Association of New Zealand (HASANZ) Human Factors and Ergonomics Society of Australia (HFESA) International Network of Safety & Health Practitioner Organisations (INSHPO) National Road Safety Partnership Program (NRSPP) New Zealand Institute of Safety Management (NZISM)

Would you like to become a Corporate Member of the AIHS?

Primary Industries Health and Safety Partnership (PIHSP) Professions Australia SafeWork NSW SafeWork SA SANE Australia Standards Australia WorkSafe Victoria Workplace Health and Safety Queensland

Please contact AIHS on 03 8336 1995 to discuss the many options available.

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MARCH 2022 | OHS PROFESSIONAL

PARTNERSHIPS

Safety tech: inside the digital transformation of OHS Digital adoption is the biggest barrier that stands in the way of businesses embedding OHS technology in their business, writes Nathan Hight

here are numerous ‘safety tech’ platforms now on the market, some at very affordable prices for SME businesses. Yet from Safe365’s sales qualification process, only about 20 per cent of existing businesses report that they currently use any digital tools to support OHS. Those that do and have been well supported with change management and digital adoption strategies, are seeing the rewards in terms of reduced harm, increased compliance, greater workforce participation and engagement, and improved business performance. In many cases, these efficiencies, improved culture and safety maturity, and reduction of harm has also led to greater profitability.

Common gaps and challenges

The most common gaps for businesses looking to implement a digital OHS system is the absence of an implementation AND adoption plan that considers the needs of the c-suite, management and end users, user training (admin users and end users), key milestones to aim to break the adoption process into bite sized chunks, check-in points with key stakeholders (“how did we do?”) and ensuring it is all underpinned with a realistic timeline. The biggest issue generally is that most technology providers focus on the implementation of their software with the client, and not the adoption of the software – two different outcomes. The latter is the most critical piece of the puzzle… “how easy, intuitive, accessible and compelling is it for end users to use the technology solution…?” because the ultimate value of any technology system is generally underpinned by the quality of data being entered at ground zero. Data capture should be an easy, accurate and seamless process. If people dread “entering it into the system” it is unlikely quality data will be provided, and all the work that flows from that point will be impacted.

OHS PROFESSIONA L | MARCH 2022

Building the business case for safety tech

It is helpful to lay out the business’s objectives, strategic intent, and core brand values. It is important that whoever is assessing the business case for investment can clearly see how the proposed technology solution will improve achievement across these areas. It is also useful to lay out how OHS processes and practices are currently being delivered, with an analysis of the time involved and the identification of strengths and weaknesses from taking this approach. This might also identify some pain points and constraints with the current approach which become your core requirements. Then, identify your technology solution and present a ‘future state’ of how OHS processes and practices will be delivered using the proposed solution, identifying how it will achieve objectives such as improving safety, reducing costs, reducing compliance exposure, providing helpful data analytics for the business to refine productivity, employee engagement, and so on.

“The biggest issue generally is that most technology providers focus on the implementation of their software with the client, not the adoption of the software – two different outcomes” As a key tip, consider the lifecycle of any given data point when doing the business case. For example, a paper incident report or plant inspection checklist needs a worker to go to a central location, find the form, fill it out based on observations, then hand the report in. Another worker would normally spend

time collating all such forms, and identify anything adverse that needs follow up or attention. The report then gets filed somewhere. The point is, there are multiple people involved who are manually handling physical information, offering numerous opportunities for it to get damaged or lost, and running a serious risk of important tasks not being completed where this occurs – not to mention the time it takes to finish. With a digital solution, such as ‘checklists’ on Safe365, the worker can use their smartphone or tablet. The checklist is already available, and a number of data points are automated (identity, time/date, location, environmental conditions etc). The worker completes the workflow on the device and taps ‘submit’. They can get back to the job. Simultaneously, all applicable people receive a digital notification, are immediately able to see the record, and take action in a timely manner. Being digital there is less risk of information being lost or damaged, and the collation process for reporting is done with the click of a button. The cost and quality efficiency are profound. Multiply these processes by volume and you can start quantifying the value of using a technology solution for safety improvement, compliance improvement, productivity improvement, data-driven methodologies at work, and employee engagement. While larger enterprises in higher risk industries have been taking this approach for some time, these opportunities are now available for any sized business, in any industry, with innovative software as a service (SaaS) technology.

Keys to successful implementation The most important lesson I’ve learned from our clients is to focus on the adoption strategy of the technology, rather than the implementation of the technology. Implementation is relatively

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“We will see the emergence of far greater use of artificial intelligence to support OHS to a point that we will all have a highly informed, razor-sharp risk assessor in our pocket sitting on an app that will identify OHS risks and control strategies that will be mind-blowing” assessor in our pocket sitting on an app that will identify OHS risks and control strategies – that will be mind-blowing. Image recognition by Amazon Web Services (AWS) is already developing these tools: a user can hold their phone camera up to a worksite, and the system is able to identify hazards, alert the user, and suggest control strategies. What an awesome tool to support knowledge upskilling of our workers.

What can OHS professionals do?

Nathan Hight, co-founder and director of Safe365, says there is a trend away from the original ‘enterprise health and safety management systems’ towards SaaS type systems

easy, with each provider having their unique approach. The process mainly involves setting up the customer’s account, providing some preliminary training, and making sure they are ready to go. Digital adoption is a deeper, longer process that sets milestones about what you hope to achieve with the solution (“what good looks like”), and the actions you will take throughout the first 12-24 months to generate the desired objective. Think about the key users throughout this process rather than simply turning it on without developing the internal champions and super users. Instead, roll it out in waves. Each wave of users can then support the next layer in the business, and so on over time. Thus your people will know what’s going on, as well as how to get help when needed. This creates

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informal discussions between staff about your technology solution, and they will naturally help each other out – sharing tips and solutions. The result is a much stronger adoption outcome over time.

Future OHS technology trends

The biggest trend is the emerging shift away from the original ‘enterprise health and safety management systems’ towards SaaS type systems, due to the developments in cloud computing, much lower price points, much greater selfservice implementation and adoption considerations, and much shorter contracts to commit to. I also think we will see the emergence of far greater use of artificial intelligence to support OHS to a point that we will all have a highly informed, razor sharp risk

Safety tech is here. OHS problems are common enough globally that the market has attracted some great innovation in the form of digital solutions like Safe365. However, that being said, great OHS is fundamentally a people sport. If I were an OHS advisor or consultant, I would be enquiring about signing up with a safety tech provider partner program – knowing that with the right solution, it would provide a great service to more clients, grow my business, and remain relevant and up to date. It’s a case of getting the safety tech to work for me not against me. The emergence of such tech should not give rise to a debate about which is better – people or technology, but showcase the reality that a great OHS professional working with amazing digital tools is a powerful combination – one that will set you apart from the rest. n Nathan Hight is co-founder and director of Safe365, a SaaS application that can assess, improve, and monitor an organisations’ health, safety, and wellbeing capability, culture, performance, and engagement. Safe365 is a diamond member of the AIHS.

MARCH 2022 | OHS PROFESSIONAL

PERFORMANCE

How can HRO improve safety in mining? Can the mining industry apply high reliability organisational (HRO) theory to reduce the rate of serious accidents and fatalities and improve safety performance? Peter Wilkinson writes

OHS PROFESSIONA L | MARCH 2022

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n July 2019 the Queensland Minister for Natural Resources, Mines and Energy announced a review into mining safety. This was prompted by a fatality in July 2019, along with five fatalities in the 2018/19 financial year. The Brady Review report was released in December 2019. One of its recommendations stood out as being unusual for this type of review. This was that the mining industry in Queensland should adopt the principles of High Reliability Organisational (HRO) theory to reduce the rate of serious accidents and fatalities. This recommendation raised some challenging questions. Can HRO theory be applied in practice? What is the relationship between high reliability and safety? What would this mean for companies, the workforce and safety professionals? The Queensland Resources Council (QRC), supported by the Queensland Commissioner for Resources Safety & Health, commissioned the Noetic Group to answer these and other questions raised by the Brady Review. This involved field visits to ten sites, including large underground mines (coal and metalliferous), open cut operations, and quarries. Our role was not to advocate for or against HRO theory, but to inform and find a possible path for the industry to implement this recommendation. The full report can be found at www. qrc.org.au/policies/resources via the link beneath the video screen shot.

What are HROs?

characteristics. Instead they are best viewed as a set of linked ideas that taken together characterise an HRO, or an organisation aspiring to become an HRO.

driven by the extreme nature of the consequences of not performing reliably and safely, and associated pressures of not delivering their mission in this way.

Interest in HROs

Culture, safety culture and organisational practices

HRO ideas have received their fair share of attention from academics, regulators, and companies over the years in Australia and overseas. The interest in HRO ideas continues as they are applied in new domains, including emergency medicine, general health care, and software development. In Australia, more than one upstream oil and gas company has tried to apply the concepts, though information on the effectiveness of their program is not known. It was probably only a matter of time before HRO theory was suggested for mining.

Implementing HRO theory

Most companies we visited asked us how HRO concepts could be implemented. Unfortunately, there is little published guidance on how to transform an organisation into an HRO. This also begs the question about those organisations that are said to be HROs: did they deliberately choose to become highly reliable and safe? The empirical research that describes how they achieve their reliably safe performance came after they had evolved into this “HRO state”. They do not appear to have had the benefit of the published research to guide them. So how have these organisations become so safe and reliable? We can postulate that these practices were

“Isn’t becoming an HRO all about culture?” was a typical question encountered on our visits to mine sites. This was understandable, given that the frequently quoted five principles of HROs are written in terms of how an organisation aspiring to be a HRO should act. For example, “deference to expertise” sounds like a cultural attribute. However, the concept of culture, and especially “safety culture” is complex. During the course of the review, we needed to find a way to address this important topic, which was both practical and defensible. Our approach was informed by the Australian Institute of Health and Safety’s OHS Body of Knowledge chapters on culture. Chapters 10.2 and 10.2.2 in particular contain useful summaries of the difficulties associated with the concept of safety culture. These chapters also offer the following opinion: “… safety culture remains a confusing and ambiguous concept in both the literature and in industry, where there is little evidence of a relationship between safety culture and safety performance…. Informed by a literature review, interviews with key stakeholders and focus group discussions, it concludes that workplace safety may be better served by shifting from a focus on changing

HROs are organisations that consistently deliver on their mission whilst avoiding serious incidents, despite operating in environments characterised by high levels of inherent risk and/or operational complexity. The US Navy’s nuclearpowered aircraft carriers and submarines are usually quoted as exemplars of HROs. Others typically mentioned include air traffic control and air transport in general (at least in relation to scheduled passenger flying in developed countries).

HRO concepts The high reliability of these organisations is said to be due to (amongst other things) the effective application of the following principles: • Preoccupation with failure • Reluctance to simplify interpretations • Sensitivity to operations • Commitment to resilience • Deference to expertise In practice, these are not discrete

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Figure 1: Graph of number of articles published mentioning “HRO”, “High Reliability Organisations” or “High Reliability Organizations” each year between 2009 and 2020. Graph was made using published papers located on the ‘Web of Science’ database.

MARCH 2022 | OHS PROFESSIONAL

PERFORMANCE

Table 1: An example of one practical interpretation of an HRO principle

‘safety culture’ to changing organisational and management practices that have an immediate and direct impact on risk control in the workplace”. Noetic adopted this more practical approach to organisational culture, which focuses on organisational practices that can be observed and assessed. This view is supported by respected writers on both organisational culture and HRO concepts. We acknowledge and understand that this is an incomplete definition of organisational culture. However, it is one that could enable the identification of specific practices with a plausible link to the type of organisational culture suggested by HRO principles.

Organisational and management practices

As mentioned earlier, there seems little merit in simply repeating the five widely quoted attributes of HROs. They are too general. They need interpretation to make them more specific to those who are expected to help the organisation operate in accordance with the high-level principles. In accordance with our distinct interpretation of organisational culture, we identified specific practices, their

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links to the five HRO principles, and what actions would be needed for them to have a potentially positive impact on organisational culture. Once this was done, it became much easier for all parties involved to better understand the practical implications of HRO principles, as well as how their company or mine compared. An example of the approach is given in the table above. Other examples included: • Improving the quality of critical control monitoring to emphasise the importance of improving the workplace conditions, rather than counting the number of so-called critical control verifications • Widening the reporting of accidents, incidents, and hazards based on the recommendations of Andrew Hopkins in his Practical Guide to Becoming a “High Reliability Organisation” (see selected reading list at the end of this article) • Developing guidance for the most senior leaders on good practice in managing low probability, high consequence events (including “Principal Hazards”). More detail on these and other improvements is given in the QRC Report, which is available on its website.

Can HRO theory be adopted in regulation?

During our work, we were asked if the implementation of HRO theory could be legislated. As described earlier in this article, HRO theory can be viewed as being about an organisation’s culture. Safety regulators have taken a keen interest in culture, especially since the disasters of the mid-1980s, notably at the Chernobyl Nuclear Plant (1986) and the Piper Alpha oil platform (1988). Regulators have typically produced guidance, but not legislation. Examples include the UK Health and Safety Executive’s (HSE) guidance for the nuclear industry, “Organising for Safety” (1993), and more recent guidance to regulators on human and organisational factors. However, regulators have not usually attempted to directly regulate culture for good reason. As the UK HSE points out: “Clearly, safety culture itself is not enforceable, and interventions are generally reserved for receptive companies, or as part of an overall incident investigation. However, there can be enforcement to address outcomes of a poor culture. For example, if a company is unsuccessfully relying on procedural controls to avoid major accidents, there

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could be enforcement of management arrangements to either ensure compliance or provide alternative safeguards through the hierarchy of control”.

HRO theory – more than safety?

Noetic felt that there was an unstated assumption on the part of many people we met during our work for the QRC. This was that HRO theory was about safety. It is – in part – but not solely. This line of thinking was probably inevitable given it was a safety review that prompted the recommendations about adopting HRO theory. However, we also explored the question of reliability and its links to safety. Individuals that had improved safety performance in their area of work did so by taking a holistic approach to how work is efficiently designed, planned, and executed. The case study reported on above explicitly drew upon well-known quality principles and tools. We heard about it by accident during a site visit. It was not part of the briefing that had been prepared – nor did the company refer to it as an HRO type practice. However, in our opinion, it appeared to be so for the reasons evident in the case study. This is an important point for several reasons. This example, and the others mentioned in the QRC Report, suggest that there are more practical applications of HRO theory than have been recognised. Just because something is not labelled as an HRO practice does not mean it is not one. The converse is probably true too.

Implications for companies and safety professionals

The case study illustrates the importance of taking a wide view of innately hazardous work activities, rather a view focused solely on safety. As W. Edwards Deming (the acclaimed pioneer of quality management) pointed out in the 1990s, it is important to manage the system as a whole and not the parts individually. This is of course, well understood by most safety professionals. Indeed, an article in the September 2021 edition of this magazine referred to this important point, recommending that safety professionals need to look at the broader system within which “safety” is but one dimension. It is at least plausible that a more concerted approach to looking beyond the immediate safety issues and taking a more systematic approach to planning and resourcing will have broader benefits for safe and reliable operations, rather than looking at HRO purely as something to do with safety. Additional case studies illustrating this point are given in the QRC report.

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Conclusion

We set out to explain how HRO ideas could be implemented in mining. The consequences of disaster in those organisations regarded as HROs are not fundamentally dissimilar to some mineral processing and mining operations (especially those working underground). As a result, it was not surprising we found some practices similar to those that characterise HROs. They often needed improvement, but the foundations were present. For example, although most people we met understood the absence of a strong link between lost time injury data and catastrophic events, there was still an overfocus on these lagging indicators in comparison to leading measures and practices relevant to catastrophic incidents – such as underground fires and explosion. We also found practices that seemed to us to have the hallmarks of HRO practices, but which were not recognised as such. The bench height case study is but one example. The recommendation to adopt HRO principles was an unusual one from a safety review. However, it has stimulated wider thinking that, if turned into action, will have served a useful purpose. n Peter Wilkinson is the general manager – risk for the Noetic Group (part of the FTS Group) based in Canberra. Peter specialises in the management of low probability/high consequence risks. He has previously worked with ICMM on critical control management and has jointly authored with Andrew Hopkins a paper on safety cases in the mining industry.

Case study: Improving safety in productioncritical processes At an open cut operation, a HPI occurred when some material hung up on a dig face fell and partially covered a bulldozer working in parallel with the face. The operator suffered a minor cut to the hand, but the potential consequences could have been more serious. More importantly, the frequency of material being hung on the dig face was leading to frequent near misses, and had potentially become a ‘normalised’ hazard. Investigating the incident had identified several recommendations to improve geotechnical design and planning, operational procedures, and training. A significant change was a decision to reduce the maximum shovel face height from 16 metres to 13 metres as some shovels were repeatedly causing this issue to occur. As with any face height/bench height reduction, this change was initially viewed as a reduction in productivity, albeit a necessary one to address safety issues. The effect on safety was immediate, as the number of incidents at the shovel dropped from monthly to one every four months. However, over time it became clear that the changes had also led to a productivity gain as more consistent material movement results were obtained. Although maximum monthly figures were reduced, there was more consistency over time – with fewer incidents interrupting operation. This led to more overall material moved in the long term.

Selected reading list Brady, S. (2019). Review of all fatal accidents in Queensland mines and quarries from 2000 to 2019. Report for the Department of Natural Resources, Mines and Energy. Available at: https://documents.parliament.qld.gov.au/ tableOffice/TabledPapers/2020/5620T197.pdf. Borys, D (2019) Chapter 10.2: Organisational Culture: A search for Meaning. Australian Institute of Health and Safety OHS Body of Knowledge. Available at: 10.2.1 Organisational Culture – a search for meaning (ohsbok.org.au). Borys, D ( 2020) Chapter 10.2.2: Organisational Culture- Reviewed and Repositioned. Australian Institute of Health and Safety OHS Body of Knowledge. Available at: 10.2.2 Organisational Culture – Reviewed and repositioned (ohsbok. org.au). Christianson, M, Sutcliffe, K, Miller, M & Iwashyna, T (2011) Becoming a high reliability organization. Critical care (London, England), 15(6) p314. Hopkins, A (2009) Learning from High Reliability Organisations, CCH Australia, Australia. Hopkins, A (2021) A practical guide to becoming

a “High Reliability Organisation”, Australian Institute of Health & Safety, available at: https:// www.aihs.org.au/sites/default/files/A%20 Practical%20Guide%20to%20becoming%20 a%20High%20Reliability%20Organisation%20 -%20Andrew%20Hopkins.pdf. ICMM Critical Control Management: Implementation Guide (2015), available at: https://www.icmm.com/en-gb/guidance/ health-safety/ccmimplementation-guide. Johnston, S (2021) Applying High Reliability Organisational Principles in the resources industry (available at: https://www.ausimm.com/ bulletin/bulletin-articles/applying-high-reliability-organisational-principles-in-the-resourcesindustry/). Pantex (2008) High Reliability Operations: A Practical Guide to Avoid the System Accident. Roberts, K (2003) HRO Has Prominent History, Anesthesia Patient Safety Foundation Newsletter, 18:1. Weick, K & Sutcliffe, K (2015) Managing the Unexpected (2nd ed.), John Wiley & Sons, USA p46.

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Inside Isaac Regional Council’s safety transformation Isaac Regional Council has taken a holistic and forward-thinking approach to lifting safety standards and outcomes, and this has significantly transformed safety across the organisation

he Isaac Region is a local government area located in Central Queensland. It covers an area of 58,708 square kilometres and has a population of about 21,000 people – in addition to approximately 12,770 resource sector workers who regularly fly in/fly out or drive in/drive out of the region and stay in temporary accommodation. The region is also a significant source of revenue for the state’s economy, contributing about $12.212 billion to Queensland’s gross regional product. The region’s local government, Isaac Regional Council, has been through a significant cultural and safety transformation in recent years. Poor performance during a local government workcare audit (a requirement of selfinsurance under Queensland workers’ compensation legislation), in 2011 identified a significant resourcing shortage and capability within the safety team. The audit score was 40 per cent – well below the 70 per cent benchmark, The first step forward was in 2015 when Isaac appointed its first safety manager. This was a major breakthrough for the council with a dedicated safety leader introduced into the management team. And while 2016 saw some improvement in the audit performance (which reached 60 per cent), it was still below the benchmark. “This was the beginning of the safety improvement journey,” says Isaac Regional Council manager of safety and resilience Alexis Coutts, who took on the safety manager role in early 2018. “It was around this time we embarked upon certification within the water and waste directorate against safety ISO 45001, quality ISO 9001, and environmental standards ISO 14001.” Coutts says the safety team worked extensively with water and waste management to introduce this change and supported workshops with the executive team. It was the catalyst for a review of safety procedures and the decision

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Alexis Coutts, manager safety and resilience with Jeff Stewart-Harris, CEO of Isaac Regional Council

to move to a corporate management framework to ensure a consistent application of safety management across the council. “The commitment from the executive leadership team and the council body during this time drove a focused approach to safety,” says Coutts. “We regularly met with the leadership team and elected members to introduce new initiatives and provide oversight of our safety performance and improvement initiatives.” In 2019 the water and waste directorate achieved certification to three standards, and around this time, the safety management system was externally audited against the national audit tool for self-insurance and achieved 74 per cent compliance, which Coutts says was above benchmark. 2021 saw the council’s performance reach 86 per cent, with acknowledgment by the auditor that the

organisation was now “among the topperforming councils”.

Key components of the WHS strategy

A look back at the 2011 audit findings revealed that when issues had been identified, management at the time had failed to implement recommended actions, according to Coutts. “This was the foundation of developing the plan and strategy to improve our system. The approach to improve frontline operations was boosting opportunities for engaging with frontline workers and shifting from a compliance model to one of partnering.” A new electronic reporting system was also implemented, and this was made accessible to all workers to report incidents, hazards, and improvement opportunities. In addition, Coutts says timely reporting and critical tracking of improvement and rectification actions

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were vital to improving the system results. A “no-blame culture” was also instituted, and this change in attitude to investigations was event and processdriven – where the organisation focuses on all contributing factors rather than workers’ actions in isolation, says Coutts. A shift to one corporate management system was also significant, with the internal management system for water and waste built off the corporate system. Safety is a key component in this system, as it was modelled on the standards framework for Quality ISO 9001, environment 14001, and Safety 45001. “We don’t have a safety system sitting over to the left; our system is corporate and provides a framework for all council business,” says Coutts. Promotion of, and commitment to, rectifying hazards was another essential step, and all hazards raised via the council’s electronic reporting system are tracked through to completion. This program (hazard hunter) recognised

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“The approach to improve frontline operations was to boost opportunities for engaging with frontline works and shifting from a compliance model to one of partnering” individuals and workgroups for identifying and delivering solutions, and Coutts says this has improved safety outcomes and addressed previous criticisms of management by demonstrating its commitment to resolve matters raised. Marketing safety effectively also helped, according to Coutts, who said this involved establishing safety as a brand to make it easily identifiable with consistent messaging. “One of the ways we did this was through using our council’s name as an acronym for a risk management process,” she says. “Think ISAAC; it has been an effective tool to get people thinking about risk, not just safety risk, with the methodology aligned to the ISO

3100:2018 Risk Management Standard: I – Identify the task; S – Scope for hazards; A – Assess the risk; A – Address the hazards; and C – Caution at all times.” The council also introduced a program (called ‘hazard hunter’) that would produce positive and tangible results for frontline workers. This was developed in place of a reward program for safety performance related to injury rates. “We held recognition BBQs for winners each month, attended by senior management and facilitated by the safety team. As the council has remote workplaces, visits offer opportunities to chat with workers in a casual setting and recognise achievements and build strong relationships,” says Coutts.

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LEADERSHIP

Executive leadership and support The final initiative was developing an improvement plan that incorporated objectives and strategies from the policy. “This provided real-time oversight of safety to executive leadership and council, ensuring that our system was on track with its requirements, as well as identifying and following through on safety initiatives,” says Coutts. Jeff Stewart-Harris, CEO of Isaac Regional Council, says safety and wellbeing is one of the seven corporate values that the council lives by, and this flows down into processes and a set of expectations around behaviours of shared accountability for safety – both as individuals and collectively. “From the top-down and the bottom-up”, he says. “Around the executive table every fortnight, we get into detail around reviewing incidents and maintaining the strategic landscape of safety.” The executive team (also called the strategic

safety committee) also meets with the representatives from operational committees throughout the council to ensure they stay across potential safety issues. “So it’s truly a collaborative effort right across the workforce,” says StewartHarris. “The saying ‘what gets measured gets managed’ is true, and we’ve got management reporting, and elements that talk to our wellbeing, safety and resilience strategy,” says Stewart-Harris. At a more granular level, all leaders have several safety-related KPIs they are expected to perform and report against every month. “So, there’s a constant reminder to people about safety and safety awareness,” he says. “No amount of safety systems is going to keep people safe; it’s what happens between people’s ears that makes the difference. And that’s very much the ethos that we try to drive across

the organisation: personal accountability and corporate accountability working together.”

Changing perceptions and stakeholder management

There has been a marked shift in perceptions of the safety team and how it contributes to organisational outcomes within the council, Coutts explains. “I think the view of safety has altered significantly whereby safety is valued and recognised as facilitators; the days of policing and strictly compliance view have passed,” she says. “The safety team has been able to effectively pivot to become facilitators as part of our improvement strategy. Safety is not the owner of the risk and cannot be a specialist in everything. However, we can facilitate stakeholders to deliver solutions.”

Improved hazard reporting

Reduction in duration of injury rates through better injury management

Isaac Regional Council’s hazard hunter program was recognised by its certification auditor as one of the better programs they’ve seen, with a reduction in some latent hazards in the workplace.

RI – restricted work injuries (suitable duties plans)

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LEADERSHIP

This has been recognised by management, and the safety team is often engaged to provide safety advice and support on matters at both operational and executive leadership levels. “Building relationships and rebranding were key elements of success. The safety team communication strategy was consistent and showed vulnerability, and in this way, we demonstrated our genuine intent to support workers,” says Coutts. Stakeholder management is consistent across the council’s workforce, and some important ways the safety team engages include HSW committees, executive leadership meetings; operational leadership meetings; the audit and risk committee; and council and team meetings.

Challenges and lessons learned

Organisational change of any sort is not without its challenges, and Coutts says there were some issues getting everyone in the council on board with a change in direction. “Council has many facets requiring stakeholder engagement and approvals. This was challenging, and I certainly didn’t get it right in the beginning, sometimes having to circle back numerous times,” says Coutts. During the past four years, however, she says the safety team has learned how to engage the right stakeholders at the right time before moving on to the next steps. “My view is that this would be very difficult for those safety professionals

with local government who are not given a seat at the leadership table to be able to influence.” At a local government level, Coutts says safety professionals must be able to engage with the executive leadership team as the organisation’s officers. “Through our improvement journey, we created a strategic safety committee which consisted of the executive leadership team and the safety committee members, which facilitated dedicated conversations and oversight of the operational committees and the improvement plan,” says Coutts. A joint consultative committee (union delegates and representatives, executive leadership, safety and resilience reps, and HR) – along with the council’s operational committee – are also involved in the oversight of policy and procedures directly impacting staff. Stewart-Harris says it’s important to make things as simple as possible for people in any culture renovation initiative. “One of the rules I try and bring to the organisation is, ‘let’s make it easy to do things right.’ Doing the right things comes back to the leadership, but it’s more of a question for management and their teams,” he says. Things are kept simple within the council through visual communication, with clever use of graphics, icons, colour, and other graphic design elements. “Alexis and her team have been able to make the safety system very legible,” he

Setting and monitoring of safety business objectives

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says. “Not everyone is strong with literacy, so it’s important to think about how safety is communicated and make that clear.”

How WHS adds business value

There has been a significant and measurable shift in both perceived and tangible value that WHS adds within the council, according to Coutts. For example, the council now has a streamlined and centralised management system for documents, limiting double handing and reducing the number of policies and procedures within its systems. There is also an expectation of guidance, and Coutts says developing an effective corporate management system has driven cultural change within the organisation, with set procedures for dealing with emerging situations. “This was demonstrated during our COVID response, and we had an established emergency management committee which stood up to respond to the emerging workplace issues,” she says. Key performance indicators (KPIs) have also been put in place for managers, and these are aligned to the policy’s objectives and the legislative requirements. Importantly, these KPIs are leading indicators, and support documentation of the routine operational activities of leaders. Coutts says KPIs include conducting team meetings, participation in procedural audits; wellness and safety chats; active participation in incident investigations and leading safety/value shares at meetings; and attending safety committee meetings to represent their area of responsibility. Stewart-Harris explains that the safety team has been a catalyst within the council for helping with “cultural leadership work” critical to successful safety improvements. “Safety in the past took the ‘big stick approach’, and it was all about the compliance mindset. That has changed, and Alexis and the safety team have played a key role in changing this and helping leadership and management come together under a cultural leadership approach to safety. Stewart-Harris essentially drives this as CEO, and he says this comprises five key elements: (1) leaders showing the way; (2) leaders setting and modelling the tone; (3) leaders creating environments for people to achieve; (4) leaders empowering their teams to achieve; and (5) monitoring what’s going on and either celebrating success or making corrections. These steps are a virtuous cycle within the council, Stewart-Harris says: “This work is never finished.” n

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How to make OHS management systems really work: an OHS Body of Knowledge review Aside from passing audits or other external compliance requirements, effective and efficient OHS management systems should assist with and cause minimal disruption to organisational operations, writes Craig Donaldson

echnology has transformed the operations of organisations in many ways. As organisations implement digital transformation initiatives to reap a number of benefits, including cost-efficiencies, reduced administration, and improved compliance, OHS is one function that has also benefited from technology in many important ways. The OHS Body of Knowledge – a comprehensive resource for OHS professionals which was first published in 2012 – examines OHS technology and related areas in a number of chapters, including 12.1 (systems, authored by David Borys, Steve Cowley, Susanne Tepe, Andrew Morrell and Wendy Macdonald) (to be replaced with a new chapter on systems and systems thinking, authored by Paul Salmon), 12.2 (OHS management systems, authored by Nektarios Karanikas and Pam Pryor), 12.3.1 (rules and procedures, authored, by David Provan and Drew Rae) and 12.3.2 (document usability, authored by Klaus Hofer).

Effective and efficient OHS management systems in practice

Rod Maule, GM safety and well-being for Australia Post explains that OHS management systems help ensure organisations have a holistic approach to their safety structures, processes, and procedures. They allow organisations

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to connect the dots between various activities in a systemic way, and like all tools, they need to be used at the right time and can be ineffective if applied to every problem. “As an analogy, if you think of the management system as a hammer, then you need to remember that not every OHS problem is a nail,” he says. “The core elements of any OHS management system should be that it connects the leadership activities to the context and hazards in the workplace and that you work on continuous improvement. In my view, they are key. The OHS Body of Knowledge gives you a good overview of the key elements in a system so you can work through where to focus your efforts.” Louise Howard, deputy executive director of health & safety for Sydney Metro, explains that OHS management systems need to be looked at more holistically, including systems (processes of work), documentation, data management, user accessibility and functionality. “If you are looking at an OHS management system as simply a set of documents, then do not expect this to be useful for your people and your organisation,” she says. “The core elements of an effective OHS management system are a simplified view of your regulatory obligations written in plain English, a concise and useful set of documents that are easily accessible and

integrated with processes of work and data management. Accessibility is by far the biggest challenge I see in this space; systems are cumbersome, hidden. Still in paper form, we really need to get into the 21st century and look at the usercentred design to make real use of our management systems.” Tim Fleming, safety director for Macquarie Group, says core OHS management system elements depend somewhat on each organisation’s structure, products, and services. However, as a general rule, these include a simple framework that addresses operational performance and standards, assuring legal and other compliance, and the most essential element: defining the organisation’s approach and commitment to safety and what sort of OHS performance it is looking to achieve. “This is nicely described in chapter 12.2 of the OHS Body of Knowledge, on OHS management systems” he says. “The OHS management system should seamlessly connect with other organisational systems. In its simplest form, an efficient system does not contain unnecessary bureaucracy and establishes a continual improvement loop like a simple plan-do-check-act method that involves those that are making safety decisions and involved in delivering the work.”

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OHS management systems, organisational systems and rules/ procedures

An integrated approach to systems to make sure they are connected with wider systems and work practices is essential, according to Maule. “Too often people and organisations have a system that is accredited and ticks all the boxes but is disconnected from the wider organisation or work that is done in real life,” he says. “In my experience, simplify your systems; try not to have everything proceduralised or documented to death. Remember the end-users – information needs to be accessible, simple, and helpful. Check that your procedures don’t contradict other parts of the organisation or system. The more complicated and complex the OHS management system, the more likely you will find contradictions between procedures. Keep it simple, keep it lean and remember you can never cover every eventuality – so don’t write procedures as if you can. A two-page guide is usually better than a 40-page document as no one reads the 40 pages, and even if they do, their ability to retain information is limited.” Fleming also says OHS management systems need to link directly with how the organisation works – specifically its core products and services. He gave the example of commercial systems, and with significant supply changes, a strong alignment with process safety, engineering, operations, and maintenance for industrial contexts, HR processes are important. In terms of specific processes and standards that underpin an OHS management system, he said many areas get a lot of attention: policy and objectives, leadership and culture, governance, assurance, risk management, process standards, resources and capability, communication/consultation, and incident management. “The majority of these obviously have strong links to other organisational systems,” says Fleming. Similarly, Howard says the key for an effective OHS management system in an organisation is to integrate the OHS component of work into existing systems and or ways of working. “If there is an existing quality management system or corporate framework, then integrate rather than have a standalone system. This can be said with anything health and safety; it must be integrated and not on its own island,” she says. She gave a couple of examples from

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her experience: one small, independently owned business that had part of their integrated management system ISO certified. “Quality, environmental, and safety were combined, easy to use and access, and relatively slim systems. They had dedicated support people, it was well understood across the 500-person business, and it was very rare to find people working outside the system,” she says. At Sydney Metro, the health and safety management system was integrated within the broader Metro Body of Knowledge and integrated management system. “This is a single system that our

people can access from all things project, risk, commercial and safety management, to mention a few items. Leadership was key here due to the growth we were experiencing and the need to have tried and true process in black and white to ensure we had consistency for our people as we were growing,” she says.

Where organisations fall down with systems As noted in chapter 12.2 of the OHS Body of Knowledge, Fleming says it can often be assumed that implementing an OHS management system on its own will ensure great OHS performance.

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However, to enable the best possible outcomes, an OHS management system requires a range of inputs, including an organisational commitment to the design, adaptation and change, and a consistent interaction with the content of other organisational systems and processes. “Authority to constructively challenge and come up with better ways is crucial in addressing gaps and inefficiencies,” he says. “Organisations that are less adaptive and compliance-only focussed in this OHS management system context generally lack the continual improvement and innovation needed to adapt their OHS management system to the point that it

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assists in achieving OHS performance excellence.” Howard adds that the size, relevance, and accessibility of OHS management systems are among the most significant issues for organisations she has seen. “Paper for the sake of paper, the workforce sees little relevance in the paper as it is, not how their work is done or how the paper adds additional work to their roles for no significant reason,” she says. “Lawyers or technical writers developing your system is not the answer; plain simple English is the key, as is understanding the workings of

“The more complicated and complex the OHS management system, the more likely you are to find contradictions between procedures”

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your organisation and what needs to be captured – rather than an ‘off the shelf’ approach. A lack of integration of your system into your key systems, data collection and reporting mechanisms is generally missed as the ‘OHS system’ is often looked at in a narrow-minded way of a document set, and nothing else.” Howard adds that lack of accessibility and not understanding users is the most fundamental pitfall, potentially exposing organisations, as the OHS management system is either not used, ignored, or applied in unintended ways. Maule also says organisations fall down when they start to think that the system is the solution to everything and forget it is just a tool to help navigate the safety challenges in the organisation. “You need to remember certification does not mean you have solved your problems – just that you have a recognised structure to help. Plenty of places with terrible cultures and poor leaderships can get accredited,” he says.

“Lawyers or technical writers developing your system is not the answer; plain simple English is the key, as is understanding the workings of your organisation and what needs to be captured – rather than an ‘off the shelf’ approach” Boards and executive teams need to look much deeper than just passing an certification to see their challenges and where they need to focus. “You can be deceived into thinking we have been accredited to XYZ system for the past few years, and hence we are doing enough. That is not true, and it may, in fact, be giving you false comfort,” says Maule, who explains that continuous improvement is the key, as is understanding that “culture eats process every day of the week. The system is for helping you manage your risks; not an end in itself as outlined in the OHS Body of Knowledge chapter on OHS management systems in section 6.1 under emergent themes.”

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Advice for OHS professionals

An OHS management system should reflect how work is done and should be written for those who undertake the work, be easy to understand and apply, and not be left to a small few to implement, according to Fleming. “Chapter 12.3.1 (rules and procedures) of the OHS Body of Knowledge describes some really valuable concepts that OHS professionals should consider when drafting supporting procedures; a particular favourite of mine is to avoid the clutter and bureaucracy that OHS management systems and procedures can easily create,” he says. OHS professionals should be engaged in the business and understand the work and products, consult with those that undertake it and understand the organisation’s products and services risks, he adds. Time is well spent understanding how other organisational systems work and are structured, and how they can seamlessly interact with the OHS management system. In addition, consideration of various WHS legislation and OHS certification requirements is vital as they are an organisation’s OHS licence to operate and should be thought of as a minimum requirement only. “OHS professionals can spend large amounts of time writing OHS management systems and the associated processes, so it pays to take careful consideration as to whether a rule or procedure is really needed, or whether it is just something that is wanted because it has always been done that way before. It is easy to create a process, but removing it is a lot more challenging,” he says. “And don’t forget about how all this information gets to the right people across the organisation and the relevant supply chain at the right time. The OHS management system should be written for them.” Maule also says it is important to understand the context of why you have a system at your organisation, remember system limitations, and try to ensure the system is connected to the operational context and helpful to the end-users. “OHS professionals that simplify systems get more support from the organisation’s operators than those who complicate or overly prescribe the systems. Always remember systems are a means to an end, not an end in itself,” he says. Similarly, not designing, implementing or having an accessible OHS management system will fundamentally leave OHS professionals frustrated and playing a very reactive role in their organisation

instead of a proactive one – thus making the portfolio of OHS a lower priority in an organisation, according to Howard. “Strategically, OHS professionals need to find a way to holistically integrate the OHS management system into the fabric of their organisation, have a usercentred focus, and, in my experience, significantly cull or declutter what is currently part of the system,” she says. “Spend loads of time at the front end of the development of a new system or revamping one, really get into your organisation and find out what matters (don’t ask OHS professionals this, ask the business). Don’t bring in new digital systems; try to make use of existing ones and digitise the system so it is accessible to all and you can track interactions and engagement. The less time spent on systems (once it is working and is systematic), the better your organisation will be.” According to Howard, the focus needs to be on leadership and governance, engagement and collaboration, and evidence-based decision-making, putting an organisation in good stead for positive health and safety performance. “Don’t rely on your system to achieve this,” she says.

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The evolution of OHS management systems in perspective

As the new Chapter 12.2 of the OHS Body of Knowledge explains, OHS management systems became widespread in Australia through a regulatory push, and not because industry found them helpful, says Drew Rae, a senior lecturer in the Safety Science Innovation Lab at Griffith University. “I think we need to be honest about why organisations adopt management systems. There’s a polite fiction that management systems exist for the purpose of improving health and safety,” he says. “Regulators actively encouraged not just the adoption of management systems, but external certification, in some cases even offering incentives. The message was that certification provided a competitive and reputational advantage. This is still the case today.” OHS management systems are driven by external relationships and not by internal safety needs, according to Rae, who observes that even when a company doesn’t seek certification, the content and format of a management system is heavily driven by external auditing requirements. In this context, he says that OHS management systems are a form of

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OHS management systems and risk: striking a balance “When I ask professionals which element of an OHS management system is the most critical, most reply risk management,” says Nektarios Karanikas, associate professor in health, safety & environment at the Queensland University of Technology. “It is true, risk management lies at the centre of any OHS initiative as our collective mission is to minimise workers’ exposure to hazards. This is also what regulators expect. The problem is that we often forget the most important and effective elements of systems: their intended users, whether those are frontline workers, supervisors or managers.” If an OHS management system is co-created with them and exists for them, Karanikas says it is destined to be effective, as outlined in the OHS Body of Knowledge chapter 12.2. “I believe our overfocus on processes like risk management suggests we lack an adequate understanding of systems, as highlighted in the OHS Body of Knowledge chapter 12.1,” says Karanikas. “We invest too much time and energy in the ‘how’ of processes. We tend to standardise everything through numerous rules and procedures, including OHS management systems,

as noted in the OHS Body of Knowledge chapter 12.3.1.” However, Karanikas notes such organisational documents are as good as the capacities and capabilities of their users, including the balance between demands and available resources, the physical and socio-technical environment, and individual skills and knowledge. Karanikas also notes that several books on OHS management systems mainly cover processes, and the way these systems are presented in literature often resemble a long and rich checklist. However, this creates the misperception that an organisation must implement all the checklist items to claim it has an OHS management system. “I strongly argue this is incorrect,” says Karanikas. “A good OHS management system does not depend on how lengthy and detailed it is. It is about whether it matches the internal and external organisational contexts and meets worker needs. The four recommendations and eight guiding principles included in the OHS Body of Knowledge chapter 12.2 would be a good starting point for OHS professionals to develop an effective OHS management system.”

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COVER STORY

demonstrated safety work. An effective and efficient OHS management system is one that achieves its core function of passing audits or other external compliance requirements with minimal disruption to organisational operations. “That may seem like a cynical answer, but I don’t think we can improve our use of OHS management systems if we persist in polite fictions. Chapter 12.2, section 4 of the OHS Body of Knowledge lays this out explicitly. The bulk of OHS management systems consist of models, frameworks, and methods – variations on ‘work as imagined’. If these organising elements are written to appease external stakeholders or to satisfy the need to be audited, that pulls them further and further away from ‘work as done’,” he says.

“We could burn every piece of policy and procedure tomorrow, and the work would still happen. The work would still be safe, or the work would still be unsafe” Rae adds that chapter 12.2 (section 5) of the OHS Body of Knowledge rightly points out that evaluating whether management systems actually improve safety is very hard to do: “it’s beyond the reach of most formal or academic approaches to evaluating safety interventions,” he says. “Unfortunately, this means that we often default to measuring the performance of the systems through auditing and certification. This is entirely circular. We design a system to meet the standard, we decide that it’s a good system because it gets certified against the standard, and we have no way of knowing if meeting the standard was a good idea in the first place.” In such situations, Rae says there are only two options for an organisation or safety professional. “And neither option is great,” he says. “Firstly, you can try to redeem the OHS management system by making it as relevant to the real work of the organisation as possible. Chapter 12.2 (section 7) of the OHS Body of Knowledge offers some useful advice on how to do

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this, but it’s important to remember that any attempt to make a management system more relevant will involve fighting directly against the requirements of audits and certifications. If the goal is to make frontline work safer, ask yourself what external certification directly offers for the workers. Probably, the answer is nothing. Ditch the certification, ditch the audits, and focus on a system that meets the needs of the workers,” says Rae. A second option is to embrace the reality that management systems are a politically necessary form of demonstrated safety. “Write a system optimised to meet certification and prequalification requirements, with minimal impact on workers. Write the procedures and methods in a way that compliance can be achieved by administrative work conducted by administrative staff,” he says. “Ultimately, we can only get better at OHS management systems by properly embracing the ‘systems thinking’ that we talk so much about in safety but hardly ever actually follow. As chapter 12.1 explains, we can’t understand a system by focussing on each component separately. And as chapter 12.2 explains, the OHS management system is not just the tangible document that we often call our management system.” Written policies and procedures are just one component in the organisational system that needs improvement, and if we keep our attention on improving the overall system, Rae says, we might get less hung up on how to deal with the management system. “It’s just a component, and a non-core component at that. We could burn every piece of policy and procedure tomorrow, and the work would still happen. The work would still be safe, or the work would still be unsafe. That should tell us something about the relative importance of OHS management systems compared to other aspects of safety,” he said.

Behavioural science, psychology and improving documentation usability

Chapter 12.2 of the OHS Body of Knowledge defines a management system as “a set of interrelated or interacting elements of an organisation to establish policies and objectives and processes to achieve those objectives”. According to Klaus Hofer, CEO of CAT-i and author of chapter 12.3.2 on document usability in the OHS Body of Knowledge, it follows that the core elements of any management system are the people who build it,

maintain, and use it. “A system is the product of the people and context it was built and exists in. For a management system to be effective and efficient, it must be designed around the principles of human behaviour and cognition,” he says. The tools people use are also a core element of a management system, and one of the tools in an OHS management system are enabling documents. Effective and efficient documents take skill to build; Hofer explains they must be engineered for usability and those who use them. “Usability in documentation is hardly taken into account when developing a new enabling document. Documents are generally written by people out of touch with the people in the field who will be using them. Documents are written to close an audit finding or meet a compliance obligation. However, as others have observed, the existence of a document doesn’t make an organisation compliant (as explained in chapter 12.3.1 of the OHS Body of Knowledge),” he says. Many documents are long, complex,

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overwhelming and hard to navigate – meaning that when people are looking in a document for an answer, they can’t find it. “As we know, reading behaviour for people who need something is vastly different than for people who are curious or reading for fun. Many management system documents are not designed to aid search behaviour. The content is long and unwieldy when people need short sharp answers to their questions to find what they need and get on with their workday. “Documents that capture essential elements of OHS are written in a style not suitable for user consumption. Users are driven to find answers to critical safety questions; they are forced to blindly tap through a minefield of verbiage, and hope for safety. Most organisations do not consider human behaviour or psychology (needs, motivations, and drivers) when designing management systems,” he says. Collaboration with people who work in the field is essential when it comes to content, adds Hofer, who explains management needs to harvest and utilise the collective intelligence – and

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the key to unlocking this magic can be found in behavioural science and applied psychology. Hofer explains that if behavioural science and psychology are applied to management systems, the documents within the system become tools. These enabling documents are tools designed to solve or address a specific problem, risk, or process, and documents are engineered with the end-user in mind and around natural human behaviours. “Measurable language is used to clearly define the purpose of the document. The document is structured to aid search behaviour, which involves the application of Gestalt design principles,” he says. “The resulting document is specific, meets its purpose, and addresses the problem it is intended to solve while also being structured for efficient use. People can find what they need when they need it. When it comes to making safety-critical decisions, finding the information you need to make an informed decision in a short period while under pressure can make a huge difference.” n

References

12.1 Systems – David Borys, Steve Cowley, Susanne Tepe, Andrew Morrell and Wendy Macdonald (soon to be replaced with a new chapter on systems and systems thinking, authored by Paul Salmon) 12.2 OHS management systems – Nektarios Karanikas and Pam Pryor 12.3.1 Rules and procedures –David Provan and Drew Rae 12.3.2 Document usability – Klaus Hofer The AIHS is running a series of webinars in 2022 discussing the OHS Body of Knowledge. For more information, visit the AIHS events website.

MARCH 2022 | OHS PROFESSIONAL

AUSTRALIAN WORKPLACE HEALTH & SAFET Y AWARDS

Lifting safety standards in WA’s petroleum operations industry Frank Walsh won the Inspector of the Year Award in the Australian Workplace Health & Safety Awards for a proactive, collaborative, and innovative approach to improving safety in Western Australia’s petroleum operations industry.

rank Walsh is a senior inspector with Western Australia’s Department of Mines, Industry Regulation and Safety (DMIRS). He has more than 14 years of experience in the petroleum and geothermal industries, including engineering, construction, production, and decommissioning. During this time, Walsh has systematically improved operational efficiencies by integrating digital innovations and reducing workforce exposure times to high-risk work activities. He has also contributed to the delivery of one of the most technically challenging geothermal wells ever drilled in Australia – pushing the limits of technologies at the time and completing the well to high safety and operational standards. Walsh believes that innovations in the workplace bring sustainable development in good health, reduced accidents, controlled environments, and improved workplace safety knowledge. This approach has resulted in improved workforce agility, reduced operation costs, and boosted performance and productivity. In his current role, he is responsible for the administration of Western Australian petroleum and geothermal safety legislation in the petroleum safety group. This is a division within the DMIRS which administers these regulations under a safety case regime. “I am responsible for reviewing the acceptability of each assigned operator’s safety documentation submissions and making recommendations to the Minister for acceptance,” he says.

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Reviewing safety cases

In his time at DMIRS, he has reviewed many safety cases involving onshore and offshore petroleum operations, encompassing decommissioning, well testing, well care and maintenance activities, seismic surveys, drilling, pipeline operations, integrity management and carbon dioxide sequestration. In one case, he was reviewing a diving safety management system submission, and it was apparent from the operator’s risk assessment that there was a lack of knowledge and experience in petroleum diving operations. “I presented the findings, communicated reasons to reject the case, and made recommendations on how safety compliance should be or can be met. My approach improved the branch’s understanding of risk, clarified requirements for resubmission, and shared good practice of risk management that would satisfy compliance,” he recalls.

“Despite disagreement with the alleged breach on the part of the operator, I was able to collaborate with them, to navigate through the complex multiple jurisdictions” In another case during an interagency meeting, Walsh identified a petroleum operation not adequately accounted for in its safety case. After

consulting with colleagues and collating supporting evidence, Walsh advised the branch of the non-compliance before informing the operator of the alleged breach. “Despite disagreement with the alleged breach on the part of the operator, I was able to collaborate with them to navigate through the complex multiple jurisdictions. After consulting with various stakeholders and acquiring insights on the complex nature of the regulations, I contributed to a joint effort with the inspection team to devise solutions that would enable the operator to meet safety compliance.”

Audits, inspections and incident investigations

Walsh regularly liaises with assigned operators to continually identify improvements and enhancements to safety culture and verify legislative compliance, enabling them to safely operate and meet project outcomes. Walsh says he achieves this by undertaking audits and inspections, and by conducting and reviewing incident investigations. “Regulatory tools, such as these, help identify, review and assess the critical risks associated with an activity,” he explains. “Subsequently, I prepare and report on whether the activities and their risks are adequately accounted for in the accepted safety case; or whether additional controls are required to meet compliance. Although compliance is measured against the operators accepted safety case, these safety documents must comply with regulations. I must ensure that these regulatory requirements are conducted

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Western Australia’s Department of Mines, Industry Regulation and Safety senior inspector Frank Walsh says industry operators must demonstrate that residual risks are reduced to as-low-asreasonably-practicable

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AUSTRALIAN WORKPLACE HEALTH & SAFET Y AWARDS

fairy, transparently, and equitably across the various operators and their associated operations,” he says.

Piloting remote inspections

To fulfil the branch’s KPIs during the COVID-19 travel restrictions, Walsh was also a member of a team that first piloted remote inspections. “Using my experience, industry guidelines, and standards, I devised a remote inspection sampling method that improves efficiency in identifying complex requirements of safety cases. This approach systematically examines all available information, identifies tiers of safety requirements, and promotes high quality and evidence-based verification,” he says.

“The operator initially challenged the finding; however, they later agreed to amend their procedures to define supervisory role requirements clearly” Another responsibility for Walsh involves operators that dispute a noncompliance finding, and in such cases, he justifies his position – backed by datadriven or evidence-based assessment. For example, an operator’s safety case required that a second supervisor review each work permit. “However, during the remote inspection, the evidence gathered had shown that a second supervisor did not verify 35 per cent of work permits. The operator initially challenged the finding; however, they later agreed to amend their procedures to define supervisory role requirements clearly,” he says.

Drivers of performance in practice

Walsh explains that his interest as an inspector stems from a passion for utilising his technical and regulatory experience in the petroleum and geothermal industries. “Moreover, I like to serve in this capacity to collaborate towards the development of mutually beneficial policies for safe, secure, and sustainable energy development in Western Australia,” he says. He gives the example of one of his earlier assigned operators at DMIRS, in which he was responsible for guiding, advising, and supporting them in understanding the Western Australian

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regulatory safety case regime. “The scale of such a project includes operations in petroleum exploration, asset maintenance, seismic surveying and development drilling production operations – all in the remote regions of the Western Australia. I provided the operator with DMIRS guidance materials on preparing a safety case and other regulatory requirements such as the petroleum safety reporting and levies. After examining the operator’s submission, I would provide feedback to ensure that their safety case systems and processes comply with legislation.” Furthermore, the operator’s compliance with legislation was essential to attaining a social licence to operate and building trust with local communities and environmental commentators, according to Walsh, who says these communities and external stakeholders look to local government to ensure operators in politically sensitive environments are held accountable at all times. He explains that his approach to safety case management, inspections and investigations has helped build best practices within the branch, achieve corporate objectives, and expand networks. “I have also fostered relationships that enhance the branch’s reputation in safety practices, establishing trust for long-term cooperation between the industry and communities. Outside my usual duties as an inspector, I actively contribute my time as an elected safety and health representative and Chair of the lunch & learn committee at DMIRS and volunteers at the United Nations Association of Western Australia (UNAAWA). These additional roles help build strong networks within the department and in the sustainability domain, a critical aspect to building productive workplace relationships,” he says.

Growth and development opportunities

As an inspector, Walsh believes professional growth and improvement should align with the organisation’s strategic goals. “These goals help define my professional aspirations and are measured by setting specific, measurable, attainable, relevant and time-bound targets. For example, Western Australia recently passed legislation to adopt the model WHS laws amalgamating three WHS Acts – industry, mining and petroleum safety. I defined the professional objective to become familiar with the new WHS Acts and Regulations,

and I would achieve this by participating in internal workshops and industry forums,” says Walsh, who also identified the required workflow changes this has to the internal management of the safety case regime and levy classification process. “As an individual, I believe personal growth and improvement is based on our values system, experiences, aspirations, and striving for best-in-class. As an intern

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at a Japanese factory, my experiences instilled in me the values of cooperation and sustainability. My volunteering experiences exposed me to understanding different viewpoints and empathy. My drive for excellence motivates me to apply new ideas to discover new limits. I continually evaluate and monitor both sets of goals throughout each year,” says Walsh. “I also subscribe to several professional

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associations to maintain industry connections and knowledge of current and emerging trends. Professional associations provide insight into the future of work and helps identify critical skills and knowledge to acquire.” Walsh says professional development is especially critical for mature industries such as petroleum because industry players continually look for a competitive advantage. Nurturing social capital for

good is essential, and Walsh says having strong networks helps grow and improve bonds, build bridges, and linkages across professional and personal aspects of life. “Personal bonds with family and friends help me emotionally, and socially balance any professional challenges,” says Walsh, who adds that goodwill and purpose in a professional setting also helps him develop camaraderie and trust between colleagues.

MARCH 2022 | OHS PROFESSIONAL

COMPLIANCE

The atom of safety: how ANSTO achieved ISO45001 certification The Australian Nuclear Science and Technology Organisation (ANSTO) was one of the first organisations in Australia to achieve ISO45001 certification in 2018 successfully

NSTO’s vision is to be a global nuclear science, research, and engineering partner with a reputation for tackling complex problems and delivering outcomes to create a more sustainable world. ANSTO produces nuclear medicines both for Australia and the rest of the world, working collaboratively across areas such as human health, the environment, and the nuclear fuel cycle to find solutions to some of the biggest questions in science for the benefit of all Australians. To find these solutions, ANSTO is home to Australia’s most significant nuclear science and technology infrastructure, including one of the world’s most modern nuclear research reactors, OPAL; a suite of neutron beam instruments; the Australian Synchrotron and the Centre for Accelerator Science. Shelley Levy, leader of high-reliability systems for ANSTO, says this landmark infrastructure is supported by research laboratory facilities and fieldwork, engineering workshops, engineering and maintenance teams, the high-reliability team (with a focus on radiation safety and industrial safety), and enabling functions. “There are three key principles: ‘safe, secure, sustainable’ which underpin “everything we do and every decision we make,” says Levy. “ANSTO is committed to ensuring our staff work in safe and supportive environments.”

The case for obtaining ISO45001 certification

Before ISO45001 certification in 2018, ANSTO had a well-established safety management system that had organically grown to address the requirements of the Commonwealth Work Health & Safety Act and regulations, the ARPANS Act and regulations, and the complexity and diversity of the work conducted by ANSTO. However, Levy says the safety management system was not certified to a standard. In 2016, ANSTO took ownership of the Australian Synchrotron in Clayton,

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system was rebranded as the ‘ANSTO atom of safety’, which fits nicely with our core operations,” says Levy.

Strategic and operational steps on the path to certification

Shelley Levy, leader of high-reliability systems for ANSTO

Melbourne. The Australian Synchrotron had an established AS4801 certified safety management system. To operate as part of ANSTO with a unified approach to safety management, the senior leadership team of ANSTO was committed to integrating the two safety management systems into one safety system for ANSTO in line with the structure of ISO45001. Levy says the integration process provided an ideal opportunity for ANSTO to: • Restructure the safety management system to integrate the operations of the Australian Synchrotron • Future-proof the safety management system for any future expansions to ANSTO’s operations • Align the structure of the safety management system to the requirements for ISO45001 certification • Ensure the safety management system was integrated with certified quality and environmental management systems that aligned with ISO standards • Streamline and consolidate the safety management system to improve its sustainability • Rebrand and improve the usability interface on the ANSTO intranet. “The ANSTO safety management

The WHS team were the drivers of the certification project across the organisation and three geographically dispersed campuses: Lucas Heights and Camperdown in New South Wales and Clayton in Victoria, says Levy. “We had the support and commitment of our senior leadership team. Two key roles were committed to achieving the certification: WHS compliance, and WHS systems. We took a project management approach, developing a project management plan, a change management plan, and a consultation plan. ANSTO is very proud of our consultative approach, so we also engaged our health & safety representatives and quality coordinators throughout the business to support the project.” There were several critical activities we conducted in the process: • Review the content of the standard • Map the existing safety management system against the clauses of the standard to identify any gaps • Capitalise on what’s already in place, including cross overs with the established and certified quality management system • Work with the safety team at the Australian Synchrotron to align the two safety management systems into one and to reflect multi-campus operations • Develop parts of the system to address the gaps (reverse engineering) • Regular briefing meetings with the executive team, health & safety representatives and project champions, and information sessions for the broader business at special seminars or team meetings to clarify what the changes would mean to on-the-ground operations • Provide training for crucial advocates in

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32 COMPLIANCE

the industry on ISO45001 • Develop a “safety management system implementation tool” (a checklist) that all parts of the business could work through to make sure that they had identified the relevant factors of the safety management system to their operations and that they had implemented the requirements • Engage an external consultant to conduct a more formal gap analysis audit just in case we had missed anything. “It’s important that this external consultant was not our certifying body so that any advice provided was impartial,” says Levy, who says it was important to address the findings of this audit. • Once the final audit plan was set with our certifying body, set up briefing sessions with each section of the business so they would know what to expect during the certification audits, and provide coaching on how best to represent their part of the organisation. • “When we were ready, our certifying body conducted our stage one audit. This audit was primarily with the safety team on the system itself to ensure that it addresses each of the clauses of the standard. We then progressed to stage two of the audit, where the certifying body dug deep into the implementation of the safety management system across all parts of the organisation,” says Levy.

Addressing challenges and issues

According to Levy, the main challenge was to continue operational business-as-usual safety support for operations and squeeze in a continuous improvement project. “This is where having a project leader and a project management plan kept us on track, with timeline goals to achieve along the way.” “Funnily enough, having a wellestablished safety management system was a bit of a challenge,” says Levy. “Having to identify gaps and then reverse engineer the system to accommodate identified improvements was a bit of a back-to-front way of approaching the design of a system. ANSTO had excellent operational information in the system, but some of the fundamental starting points had perhaps been established so long ago that we took them for granted and did not explicitly explain them anywhere.” For example, Levy says fundamentals such as describing the scope and the context of the system, identifying interested parties, planning for safety

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and what to measure and monitor from the system were the missing components that needed addressing. “It’s only now that I realise how properly defining these boundaries of the system helps us maintain it proactively and alerts us to potential changes and risks to the system,” says Levy.

Benefits of obtaining ISO45001 certification

“ANSTO is very proud of achieving ISO45001 certification. It is also looked upon favourably by our regulators including Comcare, ARPANSA, and the Therapeutic Goods Administration. Certification to an internationally recognised standard is also beneficial to ANSTO as a part of the international nuclear community,” says Levy. ANSTO has found efficiencies in the integration of its safety, quality and environmental systems; streamlined reporting functions; management review processes; integrated audits to reduce audit days; integrated risk management processes; systems for incident reporting and action tracking; and cross-pollination of ideas across the three systems that support each other. “The certification and surveillance audit constructively challenges us with a fresh set of eyes to constantly look for opportunities to improve. Any minor non-conformances or opportunities for improvement are valuable,” says Levy. “A certified safety management system provides assurance to our community, our collaborators, and contracting partners that entrust us to operate safely in our environment and to look after their workers, researchers, and students while they are with us. It lets ANSTO, as an Australian Government organisation, set a good example for our business partners and collaborators and lends credence to our expectations that our partners will work with us to provide a safe workplace for all workers and visitors.”

Safety management system next steps

Levy says the ANSTO high-reliability team is ambitious and can see ways to improve systems and support. “We are still on a mission to further consolidate and streamline the safety management system to make it easier to navigate, more sustainable, and easier to manage, including further opportunities to integrate with our quality and environmental management systems,” she says. “We will be improving information

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for our workers on proactive and day-today risk management of psychological hazards. We are also working on improving the guidance to our workers on the influences of human factors in good work design and safe, secure, and sustainable operations. We will continue our consultative and participatory approach for improvements to ensure the safety management system reflects ‘work-as-done’. We would also like to define safety key performance indicators better so that they cascade down through each part of the organisation and can be more easily reported up to get a picture of the organisation’s safety performance overall.”

ISO45001 certification and advice for others

“If the test of any decision is ‘would you do it again?’ I’d have to say yes,” says Levy. “If you are designing a new safety management system, I would recommend using the structure of the ISO45001 standard to set yourself up in a strong position. If you already have a safety management system, a gap analysis against the criteria of the standard can strengthen your system and the (dare I say it) systematic risk management processes that support your operations.” In terms of achieving certification from a certifying body, Levy says to be open to the audit and surveillance process and embrace the opportunity for a new perspective on opportunities to identify system and practice improvements. “The certifying body will be looking to help you get the best out of your system, and the ongoing surveillance supports a continuous improvement approach. Accompany the auditors as they interrogate different parts of the business,” says Levy. “It provides you as a safety professional with new insights into the operations of your organisation (and we often find that the most valuable learnings from audits are the things we quietly observe ourselves along the way). Always seek ISO certification from an ISO-certified accreditation body. Many thanks to current and previous members of the ANSTO senior leadership team and the ANSTO high-reliability team: Ralph Blake, Vanessa Sharp, Karen Wolfe, Maria Prior, and other supporting champions at ANSTO. Thanks also to our certifying body BSI Australia for their support and respectful, constructive challenges to our safety management system.” n

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BOOK REVIEW

Book review: Managing COVID-19 Risks in the Workplace: A Practical Guide

ublished in October 2021, this book represents a timely collaboration between WHS specialist Michael Tooma FAIHS, partner of global law firm Clyde & Co, recipient of AIHS’s Lifetime Achievement Award, and University of NSW professor of epidemiology, hospital infection and infectious diseases control, Mary-Louise McLaws. She is also a World Health Organization adviser. Their book aims to provide clear and readable guidance for businesses and others subject to Australia’s work health and safety laws to help minimise the risk of contracting COVID-19 from the SARS-CoV-2 virus.

“It is a book that OHS professionals can use to support their advice to boards and senior management” The authors assess that the COVID pandemic “will be an ever-present risk for several years to come,” so a challenge in writing such a book is the rapid change in context that occurs as new variants of the virus (such as Omicron) transmit and accelerate around the world and in Australia. This is addressed by

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Authors: Michael Tooma and Mary-Louise McLaws Publisher: LexisNexis, 2021 ISBN: 9780409354676) RRP: $100 (hardback or eBook) basing the nine chapters on the solid platform of the WHS laws (and earlier legislation current in Victoria) and on proven public health and infection control principles consistent with the ‘hierarchy of controls’. As most readers will know, employers and business owners of all types, supported by senior officers with ‘due diligence’ obligations, have a duty to do all that is ‘reasonably practicable’ to eliminate and minimise the risk to workers, customers, and the public arising from their operations. This includes preventing and controlling the spread of the disease and any foreseeable secondary consequences that may arise, such as from isolating at home where ergonomics, poor mental health, and domestic violence may become issues. As with all WHS, proper riskbased planning with genuine worker consultation, including in relation to amendments when circumstances change, is essential and legally required, with duties unable to be delegated and breaches potentially subject to severe penalty. Mature WHS regulators encourage systemic understanding and action, not blame, for victims. Worker duties are not ignored, and critical lessons from past outbreaks are documented. There is a good deal of practical health information and advice, tailored to potential virus exposure mechanisms. In the absence of elimination,

vaccination is an ‘isolation control’. Surface contamination is a potential infection route requiring regular cleaning of high-touch surfaces. When an infected person exhales, speaks, coughs, or sings, airborne droplets greater than five microns in diameter are heavy enough to drop out of the air within one and a half to two metres, reinforcing the importance of masks and social distancing. Smaller particles can remain in the air and be carried further or accumulate for a susceptible person to inhale. Appropriate ventilation and air-conditioning can make an enormous difference with both airborne types. The book has plenty of metrics on target rates and timing of fresh air exchange using airconditioning, and explains that opening doors and windows with a light breeze of just four km per hour “at 20°C and 50 per cent relative humidity disperses a plume of particles in just five seconds”. Reducing risk to an entire workforce, responding to an outbreak, and reporting to authorities are some other important topics covered. The principles established in the book foreshadow or allow ready adaption to new circumstances. For example the National Cabinet meetings, held on 13 and 20 January 2022, addressed an extensive range of ‘essential workers’ in guidance that stated: “Employers should apply [a] risk management

approach using the hierarchy of control framework to minimise and manage the risk of transmission of COVID-19. A system-based risk managed approach that applies appropriate mitigations… Employers are also responsible for … operationalising this guidance as part of their COVID management plan”. A longer-term protocol was stated to be under development. This 100-page book by Tooma and McLaws is not inexpensive but does achieve its aim of providing contextualised guidance for business, public sector, and NFP employers who need to apply WHS law and infection and disease controls in their workplaces to protect employees, contractors, customers, and the public. The risk-based systemic approach has now been endorsed at the highest levels of government, and can adapt to future changes in the pandemic and other risks to health and safety. It is a book that OHS professionals can use to support their advice to boards and senior management of larger organisations, and it can also be provided to duty holders of smaller entities as a readable source to help make sense of both the law and the changing health situations they continue to face. n

Reviewed by: Kym Bills FAIHS, Chair, SA branch of the Australian Institute of Health & Safety

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