Work Health & Safety management guidelines

NSW Department of Planning, Industry and Environment | dpie.nsw.gov.au

EDITION 6

For construction procurement

December 2019

Published by NSW Department of Planning, Industry and Environment

dpie.nsw.gov.au

Title: Work Health & Safety management guidelines

Subtitle: For construction procurement

Document number: DOC19/1307289

More information

Further information on these guidelines should be addressed to NSW Procurement Client Support Centre:

 Telephone: 1800 NSW BUY (1800 679 289)

 Email: [email protected]

Terms and definitions

Refer to Terms used in this guideline

download and otherwise freely deal with this publication for any purpose, providing you attribute the Department of Planning, Industry

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You may freely link to the publication on a departmental website.

Disclaimer: The information contained in this publication is based on knowledge and understanding at the time of writing (December

2019) and may not be accurate, current or complete. The State of New South Wales (including the NSW Department of Planning,

Industry and Environment), the author and the publisher take no responsibility, and will accept no liability, for the accuracy, currency,

reliability or correctness of any information included in the document (including material provided by third parties). Readers should make

their own enquiries and rely on their own advice when making decisions related to material contained in this publication.

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Contents

1 Scope ........................................................................................................................................ 2

2 Purpose .................................................................................................................................... 2

3 Application ............................................................................................................................... 2

3.1 Contracts valued up to $1 million ....................................................................................... 2

3.2 Contracts valued over $1 million ........................................................................................ 2

5 Specifying requirements ......................................................................................................... 3

6 WHS Management System ...................................................................................................... 3

6.1 Compliance ......................................................................................................................... 3

6.2 Evidence of acceptability .................................................................................................... 4

7 WHS Management Plan ........................................................................................................... 4

7.1 Compliance ......................................................................................................................... 4

7.2 Evaluation criteria ............................................................................................................... 7

7.3 Contractor performance ...................................................................................................... 7

8 Documents and records .......................................................................................................... 9

Appendix A: Terms and definitions ........................................................................................ 10

Appendix B: Preparing a WHS Management Plan ..................................................................... 11

Appendix C: Auditing a WHS Management Plan ....................................................................... 17

Appendix D: Sample WHSMP Audit Report ............................................................................... 23

Checklist 1 - Senior management commitment .......................................................................... 25

Checklist 2 - Communication and consultation .......................................................................... 26

Checklist 3 - Managing subcontractors and consultants ............................................................ 27

Checklist 4 – Design .................................................................................................................... 28

Checklist 5 - Risk management ................................................................................................... 29

Checklist 6 – Training .................................................................................................................. 30

Checklist 7 - Inspection, testing and servicing ........................................................................... 31

Checklist 8 - Incident management ............................................................................................ 33

Checklist 9 - Purchasing, handling, storage, packaging and delivery ........................................ 35

Checklist 10 - Client reporting and project performance measurement ...................................... 37

Checklist 11 - Internal review ..................................................................................................... 39

Checklist 12 - Documentation and records ................................................................................. 40

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1 Scope

These guidelines are aligned to AS/NZS ISO 45001:2018 – Occupational health and safety

management systems—Requirements with guidance for use).

They are specific to construction

procurement and apply to all project and contract activities on NSW Government construction

projects, including those involving private sector investment and financing.

Project and contract activities may include:

 detailing project requirements

 project management

 option and concept development

 design and construct

 asset maintenance and operation

 decommissioning and/or demolition.

The guidelines should be read and applied in conjunction with NSW Government’s Procurement

Policy Framework. https://buy.nsw.gov.au/policy-library/policies/procurement-policy-framework

and, if applicable:

 Quality management guidelines

 Environmental management guidelines.

2 Purpose

Contractors should use these guidelines when planning and implementing their WHS Management

System (WHSMS), and when preparing WHS Management Plans (WHSMPs). The purpose is to:

 specify the minimum WHS standards for all government construction projects

 provide a consistent approach to plan and implement safety management systems

 improve workplace safety for all construction industry workers

 increase productivity and efficiency by reducing accidents and lost time injuries

 demonstrate compliance with applicable Work Health & Safety (WHS) laws.

3 Application

3.1 Contracts valued up to $1 million

All contractors bidding for government construction contracts must prepare and implement an

acceptable Work Health Safety Management Plan (WHSMP).

3.2 Contracts valued over $1 million

In addition to preparing and implementing an acceptable WHSMP, all Principal Contractors must

have a certified WHS Management System (WHSMS) aligned with AS/NZS ISO 45001 (or

AS4801)

AS/NZS ISO45001:2018 replaced AS/NZS 4801:2001. Contractors certified for AS4801 have until March

2021 to transition to ISO45001.

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Table 1: Application of contractor’s WHS requirements

Contract category At tender stage Before work begins During contract

Contract up to $1 million

(or lower if agency

determines there is

significant risk)

Provide evidence of

capability to

development and

implement a WHSMP

(e.g. a draft or previous

WHSMP)

Submit a WHSMP If required, update

WHSMP and submit to

government agency

Implement WHSMP

Submit monthly WHS

management reports

Report WHS incidents

Periodic audits of

WHSMP

Contracts valued over

$1 million

Provide evidence of:

 a certified WHSMS

 previous

satisfactory WHS

management

performance.

Submit a WHSMP If required, update

WHSMP and submit to

government agency

Implement WHSMP

Submit monthly WHS

management reports

Report WHS incidents

Periodic audits of WHS

System and Plan

The application of this guideline outlined in Table 1: Application of WHS Requirements may be

modified by an Agency subject to a detailed analysis of specific project and/or contract related

WHS risks. The risk assessment should be undertaken using processes that align with NSW

Treasury’s Internal Audit and Risk Management Policy for the NSW Public Sector (TPP15-03)

5 Specifying requirements

To ensure prospective contractors are aware of any project specific requirements, including the

extent of monitoring and auditing activities, agencies must specify all WHS management

requirements:

 as part of the request for tender and tender documentation

 in special clauses of the contract between the agency, the contractor and related suppliers.

These guidelines and the agency’s specified requirements do not in any way relieve contractors of

meeting their legal obligations under WHS legislation.

6 WHS Management System

6.1 Compliance

The WHSMS must comply with the requirements of AS/NZS ISO 45001 (or AS4801).

 Formal JAS-ANZ certification of a contractor’s WHSMS is required for construction related

contracts over $1 million

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 The WHSMS must contain procedures which will ensure compliance with NSW and Federal

Government WHS and other relevant legislation.

6.2 Evidence of acceptability

The contractor must provide evidence of current JAS-ANZ certification of its WHSMS. Contractors

that have been subject to any WHS prosecutions or penalties in the preceding three years will also

be required to demonstrate that any shortcomings in their system have been effectively remedied.

This may be done by an audit, management review or submitting corrective action and system

change information.

Accreditation under the Australian Government Building and Construction OHS Accreditation

Scheme (Office of the Federal Safety Commission) is deemed to comply with the requirements of

Section 6.1 of these guidelines.

6.2.1 Withdrawal of acceptance

During a contract, an agency may review and/or audit the contractor’s WHSMS to assess if it

remains compliant. Grounds to withdraw acceptance of the contractor’s WHSMS include:

 failure by a contractor or its service providers to implement a compliant WHSMS or

WHSMPs

 repeated safety breaches.

Before an agency withdraws acceptance of the WHSMS:

 the contractor will be given an opportunity to comment

 the agency must properly consider these comments.

If an agency decides to withdraw acceptance of the WHSMS, the contractor’s work under the

contract will be suspended until the non-compliance is rectified. The financial impact of this will be

settled according the terms of the contract.

An agency may (but is not obliged to) withdraw acceptance of a contractor’s WHSMS without

further review if it is withdrawn by another agency.

7 WHS Management Plan

7.1 Compliance

A WHSMP sets out the specific WHS resources, consultation and risk management processes,

responsibilities, procedures and practices, for a particular project/contract. It describes how the

contractor intends to implement (where applicable) its WHSMS for the whole of the project

including Safe Work Method Statements (SWMS).

The WHSMP must demonstrate how the organisation will implement key elements of their

WHSMS. Refer to checklists in Appendix D – Sample WHSMP Audit Report. Additional checklists

may be developed by an agency to suit specific project/contract WHS requirements.

Some specific matters for which responsibilities and authorities need to be defined in documented

procedures:

 Defining the contractor’s WHS policies and objectives

 Identifying personnel responsible and qualified for WHS processes

 Identifying internal audit and review requirements

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 Allowing for enough time and resources to implement the contractor’s WHS management

system

 Managing compliance with WHS legislation, regulations, codes and standards

 Managing compliance with the contractor's WHS management system

 Managing WHS design issues

 Acquiring and disseminating WHS and related information

 Establishing and implementing consultation arrangements with workers, workplace

committees and others’ representatives on WHS matters

 Planning and conducting WHS training, including induction, task and refresher training

 Developing and implementing emergency procedures

 Assessing the contractor's service providers’ ability to comply and compliance with WHS

requirements

 Compliance with safe working rules

 Identifying hazards, and assessing and controlling WHS risks

 Preparing and implementing Safe Work Method Statements (SWMS), including for high risk

construction work as defined in the WHS Regulation (2017)

 Verifying (by inspections and tests) that work areas, work methods, materials, plant and

equipment comply with WHS legislation, Regulations, Codes and Standards

 Stopping, rejecting or quarantining unsafe work methods, work areas, materials, plant and

equipment

 Managing and reporting incidents, near misses and illness/injury, and providing and

collating incident, near misses and illness/injury information and statistics

 Investigating incidents, near misses and illness/injuries, and initiating corrective and

preventive actions

 Developing and implementing injury management programs and coordinating the

rehabilitation of injured personnel.

7.1.1 Principal contractor

The Work Health and Safety Regulation 2017 provides that a principal contractor must be

appointed or identified for all construction work:

 Cost is $250,000 or more, or

Contractors appointed as the principal contractor by an agency for construction related contracts

above $1 million must show how their WHSMS procedures address the additional responsibilities

of a principal contractor, as well as, their normal responsibilities as a contractor, workplace

controller and employer.

7.1.2 High risk work

Risk control measures (such as specialised facilities, proven work methods and specialised

training) are required for high risk works.

Contractors should consult with their service providers, and together identify and document any

high-risk work, licence requirements, competency and training needs and implement appropriate

measures to control the associate risks.

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The high-risk occupations requiring a licence include:

 Forklifts

 Erection of scaffolding > 4 meters

 Rigging

 Dogging

 Cranes including tower cranes, mobile cranes, vehicle loading cranes, bridge and gantry

cranes

 Hoists including personnel and materials hoists, elevated work platforms and concrete

placing booms

 Pressure equipment such as boilers, turbines and steam engines

 Reach stackers.

7.1.3 Incident management

Contractors must establish procedures to control the use of products and work practices which do

not meet WHS requirements and to address appropriately WHS issues through corrective action

and workplace injury management procedures.

Incident management involves:

 detecting, identifying and documenting any non-compliance

 eliminating unsafe work practices and unsafe areas

 quarantining non-complying materials and other products

 advising appropriate parts of the contractor, its service providers and relevant authorities

 rectifying irregularities, non-conformances and non-compliances

 managing and reporting illness/injury and incidents

 consulting with personnel about proposed changes that may affect their health, safety or

welfare at work.

The WHSMP must clearly state:

SafeWork NSW must be notified before any potentially-dangerous work-related

activities are undertaken.

You must call 13 10 50 immediately if there is a notifiable incident(s)

(e.g. serious injury, dangerous incident or death)

WHS issues

A WHS issue exists when materials, construction methods, plant or equipment, temporary work,

protective systems, work practices, work site conditions or other work activities do not meet WHS

requirements. WHS issues also include incidents and near misses. It is essential that WHS issues

are documented and rectified, with monitoring of trends to identify root causes.

Corrective action

WHS inspections, audits and reviews, incidents, illness/injury, and near misses provide definite

pointers to unsafe work practices and processes.

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Incidents, near misses and illness/injury and their causes should be recorded, investigated and

analysed. The results should be used to bring about improvements in policies, standards,

procedures, processes and work practices, and progressively lift WHS performance.

Procedures should be established and used for recording and implementing corrective actions.

These procedures should include consultation with personnel and advisers so that their views on

any proposed measures can be considered before implementation.

Corrective action should not only arise when an inspection, audit or review is carried out or an

illness/injury or incident occurs. Work site activities should be regularly assessed for WHS issues

and potential risks to health and safety, and action taken to minimise risks by the contractor, in

consultation with affected workers and service providers, to avoid illness/injury and incidents.

Contractors must establish procedures for recording the results of these assessments, and the

corrective action taken.

With the reviewing of past errors and issues, and anticipating possible future errors and issues,

contractors and their service providers should continue to improve the level of WHS performance

achieved.

Workplace injury management

Workplace injury management encompasses all measures for facilitating an early and safe return

to work of workers who have been injured or become ill.

An injury management and return to work program is a requirement of all employers under the

Workplace Injury Management and Workers Compensation Act. The return to work program

should address:

 Treatment of injury and illness

 Rehabilitation and return to work

 Retraining

 Claims management

 Employment management practices.

7.2 Evaluation criteria

A potential contractor’s WHS management capability would be assessed in a tender evaluation

process, using the identified evaluation criteria. Evaluation criteria may include:

 the status of their WHSMS certification

 the nature of the WHS management implemented on current and/or recent comparable

contracts.

 assessment of a potential service provider’s past WHSMPs.

 Notification of any current or past prosecutions related to WHS performance

7.3 Contractor performance

Agencies should follow the minimum performance requirements set out in the table below in

assessing a contractor’s capability and performance. Minimum processes for monitoring a

contractor’s WHS performance are provided below.

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Table 2: Principal contractor requirements

Contract

category

Preparing the

tender

During tender

review

Post award of

contract – before

work begins

During contract

Contract below

$1 million

Include safe

design report and

asbestos register

(if refurbishment /

demolition)

Identify known

Safety risks

relating to the site

where the

construction work

is to be carried out

Confirm contractor

has demonstrated

satisfactory WHS

management

Review WHSMP Review the

contractor’s

implementation of

their WHSMP

Review

contractor’s WHS

management

monthly reports

Investigate any

reported Notifiable

WHS Incident.

Report WHS

performance using

Contractor

Performance

Reporting System.

8 Documents and records

Agencies will maintain records of the WHS performance of their service providers, including

WHSMS review reports, WHSMP review and performance reports, and comments by service

providers on review and performance assessment findings.

Contractors are required to keep and maintain documents and records including:

 WHSMPs

 SWMS, including high risk construction work as defined in the WHS Regulation (2017)

 Safe work procedures

 First aid treatment records

 Emergency procedures

 Hazard identification and risk assessments

 Incident and illness/injury reports

 Plant and equipment records

 Work permits and training records

 Safety Data Sheets

 Hazardous chemicals records

 Inspection, testing and servicing records

 Details of qualifications held by individuals

 Internal review reports

 Minutes of workplace WHS meetings and toolbox talks

 Safety equipment records

 WHS design review records

 Audit reports

 Injury and workers’ compensation management records.

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Appendix A: Terms and definitions

Term Definition

Agency NSW government department, authority, corporation or entity established by

an Act of the NSW Parliament. The terms ‘government agencies’, ‘agency’ or

‘agencies’ are used interchangeably in these Guidelines.

Consultant

Professional party that contracts with a client to provide design, management

or other professional services related to construction.

Construction All organised activities concerned with demolition, building, landscaping,

maintenance, civil engineering work, process engineering, mining and heavy

engineering. It includes infrastructure projects.

Notifiable incident

An incident involving the death of a person, or serious injury or illness of a

person or a dangerous incident, (as defined in the WHS Act 2011) that must be

notified to SafeWork NSW.

Person conducting a

business or undertaking

(PCBU)

May be an individual person or an organisation conducting a business or

undertaking (as defined in the WHS Act 2011).

Principal Party inviting and receiving tenders and letting contracts.

Principal contractor The entity that contracts with an agency, as the client, and is appointed as

principal contractor (as defined in WHS Regulation 2017) for nominated work.

Project An undertaking with a defined beginning and objective by which completion is

defined. A project may be completed using a single contract or multiple

contracts.

Service providers Includes principal contractors, contractors, subcontractors, consultants and

suppliers.

Subcontractor PCBU that contracts with a contractor as the client to carry out construction

and related services.

Supplier PCBU that contracts with a client to provide a product and/or service.

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Appendix B: Preparing a WHS Management Plan

What is a WHS management plan?

A WHSMP sets out the arrangements to manage work health and safety on a construction project.

The intention of the plan is to manage the risks associated with a construction project, as there are

usually many contractors and subcontractors involved and circumstances can change quickly from

day to day.

The WHSMP must be in writing, accessible and easily understood by workers on the site. It may

not be necessary to communicate the entire WHSMP to all workers; including contractors and

subcontractors, however, they must be made aware of the parts that are applicable to the work

they are carrying out.

The WHSMP must be implemented, maintained and kept up to date during the work on the site.

Preparing a WHS management plan

The level of detail required for a WHSMP will depend on how complex the workplace is

(particularly the number of contractors at the workplace at any one time) and the risks involved in

the work.

The hazards associated with each work activity must be identified and the associated risks

assessed. Measures for eliminating, or controls for minimising and monitoring the risk are to be

developed, documented and implemented.

The WHSMP must include:

 A project-specific risk assessment, identifying hazards and assessing the risks associated

with the work, and documenting the risk control measures to be taken

 The names, positions and health and safety responsibilities of all persons at the workplace,

whose positions or roles involve specific health and safety responsibilities in connection

with the construction project

 The arrangements in place between any persons conducting a business or undertaking at

the workplace for communication and consultation, cooperation and coordination of

activities in relation to compliance with their duties under the WHS Act and Regulations

 The arrangements in place for managing any work health and safety incidents that occur

 The arrangements for preparing and implementing any site-specific health and safety rules

and for ensuring that all persons at the workplace are informed of these rules

 The arrangements that will be in place to ensure that all persons receive the appropriate

WHS training before commencing work on site.

 The arrangements to collect and assess, monitor and review the SWMS.

Further details regarding the minimum range of topics to cover in a WHSMP are included in

Section 7 and Appendix B.

The WHSMP may also include, for example:

 A list of contact details for the client, the contractor and their representatives

 Details of the construction project, for example address of the workplace, anticipated start

and end date and a brief description of the type of construction work that the WHSMP will

cover

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 How subcontractors will be managed and monitored, including how the contractor intends

to implement and ensure compliance with the WHSMP such as checking on the

performance of subcontractors and how non-compliance will be handled

 How the risks associated with high-risk construction work that will take place on a

construction project will be managed

 The provision and maintenance of a hazardous chemicals register, safety data sheets and

hazardous chemicals storage

 The storage, movement and disposal of construction materials at the workplace

 The safe use and storage of plant

 The development of a construction project traffic management plan. It must consider traffic

in the vicinity of the workplace that may be affected by the construction work

 Essential services, including underground/hidden electrical and gas and overhead power

lines.

 Workplace security and public safety

 Licences and training required to undertake the work.

People with health and safety responsibilities

The statement of responsibilities must list the names and positions of the people on the work site,

who will be responsible for WHS management, including:

 Identifying hazards and assessing the risks associated with the work, and documenting the

risk control measures to be taken

 Managing compliance with WHS workplace injury management and workers’ compensation

legislation, Regulations, standards and codes, SWMSs and the Site Safety Rules

 Assessing and monitoring the capability of subcontractors and other service providers in

the supply chain, and verifying that they meet WHS requirements

 Displaying and making Site Safety Rules available to personnel on, and visitors to, the work

site

 Making sure that the WHSMP is prepared and kept up to date, is assessable to all persons

working on site and that the people work on site are aware of the content of the WHSMP

 Managing the WHS communication and consultation provisions in accordance with the

regulatory and other requirements

 Conducting site-specific induction, and other training

 Making sure that before starting work on site all personnel attend suitable induction training

courses)

 Preparing, maintaining and making accessible the register of hazardous chemicals

 Managing workplace injury management processes to suit procedures

 Maintaining first aid stocks and providing first aid

 Managing illness/injury and emergency processes to suit procedures

 Keeping WHS records.

Communication and consultation

The contractor must include details in the WHSMP about how the persons conducting a business

or undertaking at the workplace will consult and cooperate with each other, referring to relevant

SafeWork NSW Codes of Practice.

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There should be ongoing consultation and cooperation between all duty holders so that when work

overlaps, each person is aware of other construction activities and can control any associated

hazards and risks.

Managing incidents

The contractor should consider about the types of health and safety incidents, near misses and

illness/injury that might occur. The WHSMP should document the actions that will be taken and

who will represent the contractor.

The procedures should address:

 Incident Management, including notifying SafeWork NSW and client and emergency

services as necessary

 Emergency situations, including arrangements for testing of the Emergency Plan

 First Aid arrangements, including facilities and first aid equipment and the arrangements for

training in first aid

Site safety rules

Contractors must prepare and implement Site Safety Rules, display them on noticeboards and

other suitable locations on the work site, and provide them to all personnel who may work on the

site and visitors to the site.

The Site Safety Rules, complying with SafeWork NSW Codes of Practice must cover and include,

but are not limited to, the following:

Alcohol and Drugs

 The consumption of, or being under the influence of, alcohol or illegal drugs on the site is

prohibited.

Demolition, excavation, formwork and other structural frames

 All demolition, excavation, formwork and work with other structural frames will be done in

accordance with the relevant legislation, regulations, standards, codes and procedures

Elevated work

 All work at heights will be done in accordance with the relevant legislation, regulations,

standards, codes and procedures

Electrical work, overhead wiring, installations and equipment

 No working live

 All electrical work, plant and equipment must comply with WHS and electrical safety

legislation, regulations, standards, codes and procedures, including inspection and tagging

of leads and power tools

 The presence and location of all electrical cables will be identified before commencing

adjacent work

Hazardous chemicals and dangerous goods

 A register of hazardous chemicals must be kept and maintained for all hazardous

chemicals brought onto the work site

 All hazardous chemicals and dangerous goods must be used, handled and stored in

accordance with requirements.

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Illness/injury and emergency procedures

 All first aid facilities and illness/injury and emergency procedures will be clearly identified

and used, including reporting illness/injury and incidents

Induction and safety training

 Before starting work on site all workers must attend induction training in health and safety

aspects of general construction work

 Before starting work on site all workers must attend adequate site-specific induction training

and induction training for the work activity being undertaken

 All workers must attend appropriate refresher training and be involved in regular discussion

of work site WHS matters

 All visitors when on the work site must be accompanied by a person who has received the

above training.

Personal protective equipment

 All workers and visitors must wear appropriate personal protective equipment (PPE) when

on the work site

Protection of all workers and the public

 Effective barricades, fencing and overhead protection will be used

Safe working

 Fire prevention, housekeeping and other site safe working procedures should be included.

Site access and security

 Ensure, so far as is reasonably practicable, that the workplace is secured from

unauthorised access

 All entry to, movement on, passage adjacent to, and exit from, the work site of workers and

other persons, vehicles and equipment will be controlled in accordance with required

procedures

WHS training

Induction training

Before any person commences work on site, they must be provided with WHS induction training.

This must cover WHS matters associated with:

 General construction work

 The specific work activities to be undertaken

 The specific worksite.

Site-specific induction must explain Site Safety Rules, content of the WHSMP, relevant SWMS,

risk management and emergency procedures and consultative arrangements at the work site.

Safe work method statements

The WHSMP must include details of the arrangements for the preparation, collection and any

assessment/approval, monitoring and review of SWMS at the workplace.

The WHSMP must also include arrangements to ensure that SWMS are followed by all affected

workers (including contractors and subcontractors), and that work is ceased if the SWMS is not

being followed.

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Prepare and implement a safe work method statement

SWMSs must be prepared and implemented for all high-risk construction work activities.

The primary purpose of a SWMS is to enable supervisors, workers and any other persons at the

workplace to understand the requirements that have been established to carry out the high-risk

construction work in a safe and healthy manner so they can implement them.

When preparing a SWMS, the workers who are to follow them must be consulted and involved.

This will help improve, and encourage their ownership of, the required actions and procedures in

the Statements.

The SWMS must be able to be easily read by those who need to know what has been planned to

manage the risks, implement the control measures and ensure the work is being carried out in

accordance with the SWMS.

The SWMS must:

 Identify the work that is high risk construction work

 Specify hazards relating to the high-risk construction work and risks to health and safety

associated with those hazards

 Describe the measures to be implemented to control the risks

 Describe how the control measures are to be implemented, monitored and reviewed

A SWMS should also include the following information:

 The name of the person conducting a business or undertaking, their address and ABN (if

they have one)

 Details of the person(s) responsible for ensuring implementation, monitoring and

compliance with the SWMS

 If the work is being carried out at a construction project, the:

o name of the contractor

o address where the high-risk construction work will be carried out

o date the SWMS was prepared and the date it was provided to the contractor

o review date (if any).

Complying with a SWMS

All contractors who are involved in high risk construction work must develop and implement

arrangements to ensure the work is carried out in accordance with the SWMS.

Arrangements may include a system of routine or random workplace work activity observations, for

example, observing workers and supervisors to see if the control measures outlined in the SWMS

are being implemented.

If the work is not being carried out in accordance with the SWMS, then the work must stop

immediately or as soon as it is safe to do so.

Work must not resume until the work can be carried out in accordance with the SWMS.

Reviewing a SWMS

A SWMS must be reviewed (and revised if necessary) if relevant control measures are revised.

The review process should be carried out in consultation with workers (including subcontractors)

who may be affected by the operation of the SWMS and their health and safety representatives

who represented that work group at the workplace.

When a SWMS has been revised, the person conducting a business or undertaking must ensure:

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 All workers involved with the high-risk construction work are advised that a revision has

been made and how they can access the revised SWMS. The contractor should be given a

copy of the revised SWMS

 All workers who will need to change a work procedure or system because of the review are

advised of the changes in a way that will enable them to implement their duties consistently

with the revised SWMS.

 All workers that will be involved in the high-risk construction work are provided with the

relevant information and instruction that will assist them to understand and implement the

revised SWMS.

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Appendix C: Auditing a WHS Management Plan

General principles

There must be a clear understanding between the audit team and the contractor about the scope

and terms of the audit.

The audit team should:

 have a right of access at all reasonable times to the contractor’s WHS records,

 be entitled to get from the contractor any information and explanations the audit team

needs for the audit.

If the audit team observes any dangerous or life-threatening situation in the course of an audit, the

issue must be raised immediately with the contractor’s local supervisor to enable corrective action

to take place as a matter of urgency.

A consistent approach

Audits should be carried out by the agency (and contractor):

 at least once within three months of the start of site work.

 at least twice in the life of a project or as otherwise determined by an agency to suit the

level of risk during a project.

The audit results will be included, by agencies, in the Contractor Performance Reports.

The objective of an audit

The objective of an audit is to verify formally that the documented procedures in a WHSMP are

being followed. The audit process should focus on checking whether the contractor’s workers and

service providers are implementing the WHSMP.

Responsibilities of the parties

Agency

Action Description

Reviewing the plan The agency will review the contractor’s WHSMP to determine whether key

elements of the WHSMS are addressed.

Scheduling audits

The agency will schedule, arrange and participate in WHSMP audits with the

contractor.

Following up The agency will follow up to confirm that the contractor has completed all the

necessary corrective and preventive actions within the required timeframes.

Audit teams

The audit team will conduct the audits scheduled by the agency with the contractor.

The audit team must carry out a WHSMP audit:

 with fairness and honesty

 with full regard to confidentiality

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 in a timely manner.

When carrying out an audit, the audit team must acknowledge that contractors have a

responsibility to protect the health, safety and welfare of their workers and others and service

providers in the supply chain from any WHS risks arising out of the work.

A member of the audit team must not participate in a WHSMP audit if he or she is:

 in debt to the contractor or its service provider

 a partner or other business associate of the contractor or its service providers

 a worker, agent or consultant of the contractor or its service provider

 a relative of one of the contractors or its service providers, or

 has any other conflict of interest.

(See Appendix C - Auditing a WHSMP)

Qualifications

The audit team must collectively have the following qualifications:

 Successful completion of a Management System auditing course covering:

o BSBAUD501A Initiate a quality audit

o BSBAUD502A Prepare a quality audit

o BSBAUD503A Lead a quality audit

o BSBAUD504A Report on a quality audit.

 Demonstrated knowledge of WHS Acts, regulations, Codes and Standards as they apply to

the construction industry

o Demonstrated knowledge can be either formal WHS qualifications or the accepted

equivalent

o Such criteria must be acceptable to senior management in the accrediting authority

o Knowledge of the contract, project work site, and site WHS requirements.

Task and responsibilities for auditing

This table provides an overview of the tasks and responsibilities for auditing a WHSMP.

Refer to Appendix D - Sample WHSMP audit report

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Review and planning

Task Responsibility Description

Review the WHSMP to

establish whether it

addresses key elements

Agency The WHSMP is submitted by the

contractor / principal contractor

before work commences on site.

It must be reviewed by the

agency to establish that it

addresses key elements of the

WHS Management Systems and

Auditing Guidelines.

Plan the audit schedule Agency and contractor

Prepare the audit schedule and

consider the order in which the

key elements will be audited.

For example, the first audit may

assess compliance with

requirements pertaining to the

key elements of Management

Responsibility, Risk Management

and Incident Management and

Corrective Action.

The first audit should occur soon

after the commencement of site

work – generally within the first

three months.

Engage the audit team Agency Engage audit leader to manage

audit and, if applicable, form audit

team

Notify the contractor of the

audit

Agency Discuss audit schedule with

contractor and agree on date for

the audit.

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Preparation and conducting the audit

Task Responsibility Description

Prepare for the audit

Agency and/or audit leader

Audit leader and audit team

Audit leader, audit team,

contractor’s representative,

agency

Develop program for audit and

assign responsibilities to audit

team members.

Discuss scope and objectives of

audit.

Develop itinerary for audit.

Agree on communication to be

used throughout the audit

process.

Review contractor’s WHSMP.

Review any other relevant

documentation, for example,

previous audit reports,

contractor’s actions to address

any Corrective Action Requests

from previous audits.

Meet with agency and contractor

to confirm scope and objectives

of audit and approach to be

taken.

Audit leader allocates

responsibilities to team members.

Conduct the audit

Hold entry meeting

Follow audit methodology

Audit leader and audit team Meet with agency and contractor

to enable the audit team to

explain the audit process and the

approach to be taken.

Review and assess the

implementation and effectiveness

of the WHSMP.

Visit the specific areas of the

contractor’s operation covered by

the audit scope, and review and

evaluate conformance to the Plan

(see Appendix D for an Audit

Checklist).

Document any non-

conformances.

Request the contractor’s

representative to confirm the non-

conformance by signing a record

of the non-conformance.

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Task Responsibility Description

Hold final audit team meeting Audit leader and audit team

Meet to review audit findings.

Identify and discuss areas where

the contractor is performing well.

Clarify and discuss issues and

areas of concern.

Discuss any non-conformances.

Prepare an audit report

containing non-conformances and

completion dates for corrective

actions.

The audit report should be written

and provided on the day of the

audit and explained to the

contractor at the exit meeting. If

this is not possible, then the non-

conformances must be

documented so they can be

provided to the contractor at the

exit meeting. The audit report

should then be submitted within

one week of the audit to the

agency, who should then

immediately forward it to the

contractor.

Hold exit meeting Audit leader, audit team, agency,

contractor

Meet with agency and contractor

to discuss the audit report,

corrective actions, and

timeframes for completion by the

contractor.

The non-conformances should be

documented and provided to the

contractor at the exit meeting.

If the audit report is available, the

agency will provide the contractor

with a copy. If not, the audit

report will be provided as soon as

possible thereafter. The

contractor will be given the

chance to comment on the audit,

and the comment will be properly

considered.

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Follow up actions

Task Responsibility Description

Follow up on implementation

of corrective and preventive

actions

Record

Agency and contractor

Make sure the required corrective

action and preventive actions are

carried out within the agreed

timeframes.

Audit reports and comments by

the contractor will be managed

within each agency for its

projects.

The results of audits and

contractor performance will be

included, with other matters, in

Contractor Performance Reports.

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Appendix D: Sample WHSMP Audit Report

Introduction

Principal contractor

Reviewer / auditor

Contract name and number (if applicable)

Review / auditor signature

Date

Yes No N/A

ACCEPTABILITY REVIEW

Contractor Accreditation Recommended

Acceptability not supported, further detail required

PRE-START REVIEW

WHSMP

AUDIT TOOL

WHSMP

Recommendation / Non-conformances

Insert description

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WHSMS/WHSMP – General

Is/does the WHSMS/WHSMP: Page number or evidence of implementation

1. Actively maintained and up to date

2. An easily understood document

3. Accessible to all workers

4. Clearly describe organisational

responsibilities (in a chart)?

5. Clearly describe the contractor’s WHS

policies and objectives?

6. Clearly describe training records and other

documents that must be kept?

7. Clearly describe position descriptions?

8. Clearly describe WHS Procedures

FINDINGS

Insert findings

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Checklist 1 - Senior management commitment

This element is about defining the contractor’s policies, objectives, responsibilities and

commitments to WHS, as well as identifying and providing the resources needed for

implementation and verification.

Does this element of the WHSMS/WHSMP

clearly describe:

Page number or evidence of implementation

1. Specific senior management responsibilities

and commitment to continual improvement?

2. Specific responsibilities of management and

other personnel responsible, their

qualifications and accountabilities to deal

with WHS matters, including the names of

staff in the WHSMP?

3. Responsibilities, including names and

positions for:

a) Allocating adequate resources to deal

with WHS matters.

b) Ensuring that WHS policies, Management

Systems and Plans are communicated to

workers

c) Managing compliance with WHS

legislation, regulations, standards and

codes?

d) The injury management and rehabilitation

of injured workers and others?

e) Ensuring WHS workplace consultation is

operating?

FINDINGS

Insert findings

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Checklist 2 - Communication and consultation

This element is about establishing the process for sharing relevant WHS information with workers and other

contractors such as subcontractors and consultants in the supply chain, providing them with an opportunity

to express their views on WHS issues and allocating adequate time to resolving such issues.

Does the WHSMS/WHSMP clearly describe how

the contractor plans to:

Page number or evidence of implementation

1. Facilitate the establishment of WHS Committee

or HSR or WHS Representative or other

arrangements for WHS consultation agreed by

management, workers and service providers.

2. Review site consultation arrangements with

workers and service providers.

3. Ensure that all workgroups will be represented

by either the WHS Committee or

Representative or are involved in the site

specific and other agreed arrangements.

4. Elect the WHS Committee or HSR or WHS

Representative, if applicable to the agreed site

communication and consultation arrangements.

5. Ensure that each member of the WHS

Committee, HSR or WHS Representative

undertakes WHS consultation training.

6. Record, publicise and encourage workers

representatives to participate in the work on a

regular basis.

7. Consult on the job through daily communication

between site managers, workers and service

providers.

8. Provide access to relevant WHS information

through notice boards, toolbox meetings,

circulars and safety alerts.

9. Liaise with their service providers to coordinate

WHS consultation and communication on work

sites.

FINDINGS

Insert findings

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Checklist 3 - Managing subcontractors and consultants

This element is about selecting and managing subcontractors and consultants, defining measures to assess

the capacity of all subcontractors and consultants in the supply chain to comply with specified WHS

standards and monitoring their compliance

Does the WHSMS/WHSMP procedure clearly

describe how the contractor plans to:

Page number or evidence of implementation

1. Assess and select its subcontractors,

consultants and other service providers in the

supply chain on their ability to comply with

WHS requirements?

2. Specify appropriate WHS requirements in all

contracts entered int, including the

subcontractors’ providing the principal

contractor with a copy of the SWMS for high

risk construction work activities?

3. Provide its subcontractors and other service

providers with access to the WHS Management

Plan and inform service providers of the content

of the WHS Management Plan

4. Monitor its subcontractors’ and other service

providers’ poor performance?

5. Manage any of its subcontractors or other

service providers’ poor performance?

FINDINGS

Insert findings

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Checklist 4 – Design

This element is about defining a process to identify and eliminate (or at least minimise) WHS risk

relating to design at any stage of a Project.

Does this WHSMS/WHSMP clearly describe how

the contractor plans to:

Page number or evidence of implementation

1. Consult with the client and designer(s)

about:

- Health and safety risks arising from the

design during construction work are

eliminated or minimised?

- Any information they have in relation to

hazards and risks at or in the vicinity of

the workplace where the construction

work is to be carried out?

2. Describe how safe design information will be

obtained from the client or designer?

3. Require a review of the safe design

information adopting a hazard identification

and WHS risk assessment approach?

4. Apply the hierarchy of hazard controls to

design out or otherwise manage hazards?

5. Include the process for consultation with

subcontractors’ and consultants’ end users

about hazards and WHS risk management?

6. Describe the communication and

consultation process for discussing with

workers and service providers WHS design

issues and risk control measures?

7. Aim to achieve reasonable and safe

constructability; safety with use; longevity of

‘product’; reduced, simplified and safe

maintenance; and safe disposal?

8. 8. Specify how the safe design information,

including outcomes from the review of this

information will be incorporated into the

WHSMP or WHS Management Plan?

FINDINGS

Insert findings

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Checklist 5 - Risk management

This element is about defining a process to identify WHS hazards, assess risks and plan work

processes to control those risks. It also covers Safe Work Method Statements and hazardous

management processes.

Are procedures clearly described for the

following activities:

Page number or evidence of implementation

1. For identifying WHS hazards, assessing risks

and devising risk controls that eliminate risks

where reasonably practicable or minimise risks

according to the Hierarchy of Controls?

2. For selection of the most effective risk control

measures.

3. For systematically reviewing the adequacy of

the risk assessment and the effectiveness of

the control measures and making

improvements?

4. For dealing with WHS hazards and related risks

in the event of an incident or illness/injury?

5. For developing and implementing Safe Work

Method Statements?

6. For reviewing subcontractors’ Safe Work

Method Statements?

7. To enable compliance with relevant WHS,

workplace injury management and workers’

compensation legislation, standards and

codes?

8. For preparing and communicating Site Safety

Rules?

FINDINGS

Insert findings

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Checklist 6 – Training

This element is about establishing the procedures and allocating resources to identify and provide

for the training needs of workers

Are procedures clearly described for the

following activities:

1. Identifying the training needs of management,

supervisors, workers, subcontractors and

visitors?

2. Providing site WHS induction training, task

training and refresher training?

3. Providing WHS Committee/WHS or HSR

representative with consultative training?

4. Providing specific training necessary to conform

with WHS requirements?

5. Providing training in emergency procedures?

6. Keeping appropriate records of WHS training?

7. Making sure all workers working on site have or

who will be on the project have completed

general construction induction training.

FINDINGS

Insert findings

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Checklist 7 - Inspection, testing and servicing

This element is about establishing procedures for planning and conducting WHS inspection, testing

and monitoring on work sites and for plant and equipment use, work processes and incoming

products. It also covers health surveillance and monitoring and the servicing of plant and

equipment.

7.1 Does the WHSMS/WHSMP clearly describe

the contractor’s procedures for:

Page number or evidence of implementation

1. Developing and maintaining a schedule of

inspection, testing and servicing for all projects

(before commencement of work) based on the

level of risk involved?

2. Maintaining records of inspection, testing and

servicing.

FINDINGS

Insert findings

7.2 Does the system/plan clearly describe

procedures covering inspection, and where

relevant, testing and servicing of:

Page number or evidence of implementation

1. Incoming products, such as materials, plant and

equipment?

2. Work site environment?

3. Work methods generally?

4. Access and exits?

5. Hazard and risk control measures?

6. Adherence to Site Safety Rules?

7. Electrical safety?

8. Plant and equipment:

FINDINGS

Insert findings

7.3 Do inspection and test plans: Page number or evidence of implementation

1. Specify the standards against which inspection,

testing and servicing will be conducted?

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7.3 Do inspection and test plans: Page number or evidence of implementation

2. Specify particulars of the inspection, testing and

servicing programs?

3. Assign responsibility for inspection, testing and

servicing?

4. Specify the competencies required by persons

conducting inspection, testing and servicing.

5. Specify arrangements for identifying the test

status of plant, equipment and materials.

6. Specify the requirements for the accuracy and

calibration of testing equipment?

7. Specify that the records are readily available

and will be kept according to the legislative

requirements?

FINDINGS

Insert findings

7.4 Health surveillance and monitoring Page number or evidence of implementation

1. Describe the process for identifying the work

activities where workers’ exposure to hazards

require health surveillance and monitoring.

2. Specify the requirements specified in legislation

regarding the nature and frequency for health

surveillance and monitoring.

FINDINGS

Insert findings

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Checklist 8 - Incident management

This element is about establishing procedures to manage incidents, to control the use of products

and work practices which do not meet WHS requirements and to address appropriately WHS

issues through corrective action and injury management procedures

8.1 Are procedures clearly described for the

following activities:

Page number or evidence of implementation

1. Detecting and documenting issues and

incidences of non-compliance and non-

conformance?

2. Quarantining and disposal of non-conforming

materials and substances?

FINDINGS

Insert findings

8.2 Is it clearly shown how the contractor will

communicate information about issues and

corrective action:

Page number or evidence of implementation

1. Throughout the organisation?

2. To clients?

3. To subcontractors and other service providers?

4. To the relevant authorities, including incident

notification to SafeWork NSW

FINDINGS

Insert findings

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8.3 Does the WHSMS/WHSMP clearly describe

the contractor’s procedures for:

Page number or evidence of implementation

1. Incident/illness/injury reporting and

investigation, including identification of the roof

cause?

2. Implementing corrective action?

3. Monitoring the effectiveness of corrective

actions, including keeping records?

4. Implementing injury management and return to

work plans?

FINDINGS

Insert findings

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Checklist 9 - Purchasing, handling, storage, packaging and

delivery

This element is about making sure that all materials, equipment and plant purchased or hired

conform to the required WHS standard and establishing procedures to facilitate compliance with

legislative and other requirements for handling, storage, packaging and delivery of products

including materials.

Does the WHSMS/WHSMP clearly describe the

contractor’s procedures for:

Page number or evidence of implementation

1. Pre-purchase identification of potential WHS

risks that may be introduced to the work site

from supplied plant and materials>

2. Assessing suppliers’ ability to comply with the

organisation’s WHS specifications for the

provision of plant, materials and services?

3. Verifying that client-supplied plant and

materials meet WHS specifications?

4. Checking that suppliers provide all relevant

WHS information for their plant and materials?

5. Maintaining records of supplied plant and

materials identified as having potential WHS

risks?

6. Appropriate licensing, certification and

qualification of anyone who will be engaged in

hazardous processes?

7. Safe handling and storage of products,

including hazardous substances and dangerous

goods?

8. Assessment and control of manual handling

risks?

9. Assessment and control of materials handling

risks?

10. Identification of hazardous chemicals and

dangerous goods through appropriate

labelling?

11. Provision of information on hazardous

chemicals (such as through Safety Data

Sheets?

12. Maintenance of a register of hazardous

chemicals and dangerous goods and

associated records of risk assessments?

13. Checking compliance with registration

requirement of plant and plant design?

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Does the WHSMS/WHSMP clearly describe the

contractor’s procedures for:

Page number or evidence of implementation

FINDINGS

Insert findings

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Checklist 10 - Client reporting and project performance

measurement

This element is about establishing procedures for regularly monitoring performance against WHS

objectives and targets defined by the contractor at the corporate and project level. The element

defines the process for reporting WHS performance / issues to the Client

10.1 Does the WHSMS/WHSMP clearly describe

the contractor’s procedures for:

Page number or evidence of implementation

1. Establishing, monitoring and reviewing WHS

objectives and targets for corporate and project

level?

2. Require objectives and targets to be

incorporated into the WHSMP?

3. Specify how requirements in regards to

preparing regular WHS performance

reports/records, e.g. monthly?

4. Describe the process for collating WHS

performance reports from all projects and

benchmarking performance across the

contractor’s operations?

5. Require the review of the performance reports

by Senior Management, to consider and

provide feedback to the Project Team?

FINDINGS

Insert findings

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10.2 Does the WHSMS/WHSMP clearly describe

the contractor’s procedures for:

Page number or evidence of implementation

1. The timely reporting of WHS issues to the client

including:

- Worksite incidents, including such things as

near misses, contact with hidden services

- WorkCover NSW site visit

- WorkCover NSW Notices issues

- Visits by unions, FSC or similar to the site

- Results of internal reviews, site inspections

and implementation of inspection and testing

plans

- Results of audits, including non-conformances

and the implementation of corrective actions

FINDINGS

Insert findings

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Checklist 11 - Internal review

This element is about establishing procedures for planning and undertaking internal reviews,

including audits, to verify the on-site WHS processes and practice match the required plans and

procedures

Does the WHSMS/WHSMP clearly describe

procedures for systematically reviewing

(including auditing) WHS activities and

WHSMPs, including:

Page number or evidence of implementation

1. Carrying out reviews at regular intervals?

2. Identifying deficiencies in the WHS

Management System and Plans?

3. Specifying the responsibilities and competency

of those carrying out the review?

4. Documenting reviews?

5. Conducting regular audits of implementation

and compliance with the WHS Management

System and Plans?

6. Identifying the root cause of any breaches/non-

conformances and implementing corrective

actions?

7. Implementing follow-up procedures to assess

the effectiveness of any corrective action?

8. Communicating the results of reviews to Senior

Management and the status of corrective

actions?

FINDINGS

Insert findings

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Checklist 12 - Documentation and records

This element is about establishing procedures, for the control, approval, dissemination, withdrawal,

storage and disposal of WHS documents, data and other records

12.1 Does the WHSMS/WHSMP include

procedures for and detail the following records

for maintenance:

Page number or evidence of implementation

1. Document control procedures for WHS

documents and data, including their

identification, approval, maintenance,

dissemination, retention, withdrawal and

disposal?

2. Records management procedures for

maintaining WHS records, including their

identification, filing, retrieval and retention?

FINDINGS

Insert findings

12.2 Does the WHSMS/WHSMP clearly describe

record-keeping requirements for:

Page number or evidence of implementation

1. Induction and training records?

2. Skills, competency and license register?

3. Hazard identification, risk assessments and

associated safe working procedures?

4. Reports of incidents and illness/injury?

5. Illness/injury and incident investigation reports?

6. Illness/injury statistics, such as lost time

frequency rates and duration rates?

7. Maintenance, testing, servicing and repair of

plant and equipment?

8. Use of hazardous substances and associated

monitoring?

9. Inspection and test reports?

10. Particulars of qualifications held by individuals?

11. Internal review reports

12. WHS design reviews?

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12.2 Does the WHSMS/WHSMP clearly describe

record-keeping requirements for:

Page number or evidence of implementation

13. Minutes of WHS meetings?

14. WHS audit reports?

15. Worker injury management records?

16. Evidence of actions taken as a result of WHS

meetings?

17. Corrective action records?

18. Work safety records generally?

FINDINGS

Insert findings