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1.1 Who Has Responsibility for Managing Work Health And Safety Risks?

Duty holders who have a role in managing work health and safety risks include:

• Persons conducting a business or undertaking (PCBUs)
• designers, manufacturers, importers, suppliers and installers of plant, substances or structures, and
• Officers.

Workers and other persons at the workplace also have duties under the WHS Act, such as the duty to take reasonable care for their own health and safety at the workplace.

A person can have more than one duty and more than one person can have the same duty at the same time.

Person conducting a business or undertaking

A PCBU must eliminate risks in the workplace, or if that is not reasonably practicable, minimise the risks so far as is reasonably practicable.

The WHS Regulations include more specific requirements for PCBUs to manage the risks of hazardous chemicals, airborne contaminants and plant, as well as other hazards associated with the workplace.

PCBUs have a duty to consult workers about work health and safety and may also have duties to consult, cooperate and coordinate with other duty holders.

Examples of where a PCBU will have a health and safety duty include when:

• The PCBU engages workers to carry out work
• The PCBU directs or influences workers in carrying out work
• Other people may be put at risk from work carried in their business or undertaking, and
• The PCBU manages or controls a workplace or fixtures, fittings or plant at the workplace

Officers

Officers, such as company directors, have a duty to exercise due diligence to ensure the PC-BU complies with the WHS Act and WHS Regulations. This includes taking reasonable steps to gain an understanding of the hazards and risks associated with the operations of the business or undertaking, and ensure the business or undertaking has and uses appropriate resources and processes to eliminate or minimise risks to health and safety.

Further information on who is an officer and their duties is available in the Interpretive Guideline: The health and safety duty of an officer under section 27.

Designers, manufacturers, importers and suppliers of plant, substances or structures

Ensure, so far as is reasonably practicable, the plant, substance or structure they design, manufacture, import or supply is without risks to health and safety. This duty includes carrying out testing and analysis as well as providing specific information about the plant, substance or structure.

The WHS Regulations include a number of specific requirements for consultation and information sharing to assist in meeting these duties, for example:

• Manufacturers to consult with designers of plant
• Importers to consult with designers and manufacturers of plant, and
• The person who commissions construction work to consult with the designer of the structure

Workers

Workers have a duty to take reasonable care for their own health and safety and to not adversely affect the health and safety of other persons. Workers must comply with reasonable instructions, as far as they are reasonably able, and cooperate with reasonable health and safety policies or procedures that have been notified to workers. If personal protective equipment (PPE) is provided by the business or undertaking, the worker must so far as they are reasonably able, use or wear it in accordance with the information and instruction and training provided.

Other persons at the workplace

Other persons at the workplace, like visitors, must take reasonable care for their own health and safety and must take reasonable care not to adversely affect other people’s health and safety. They must comply, so far as they are reasonably able, with reasonable instructions given by the PCBU to allow that person to comply with the WHS Act.

1.2 What is Involved in Managing Risks?

Management Commitment

Effective risk management starts with a commitment to health and safety from those who operate and manage the business or undertaking. You also need the involvement and cooperation of your workers, supply chain partners, and other businesses you work with. Management commitment is about demonstrating you are serious about health and safety and influencing other duty holders in the workplace.

To demonstrate your commitment, you should:

• Get involved in health and safety issues so that you understand the hazards and risk associated with your operations
• Consult workers and other duty holders on the hazards and risk, and how to control them
• Invest time and money in health and safety
• Ensure you and your workers clearly understand health and safety responsibilities and have the knowledge and skill to do tasks safely, and
• Apply health and safety values and behaviours to your own work practices

A Step-by-Step Process

A safe and healthy workplace does not happen by chance or guesswork. You have to think about what could go wrong at your workplace and what the consequences could be. Then you must do whatever you can (in other words, whatever is ‘reasonably practicable’) to eliminate or minimise health and safety risks arising from your business or undertaking.

This process is known as risk management and involves the four steps set out in this Code (see Figure 1 below):

• Identify hazards – find out what could cause harm.
• Assess risks, if necessary – understand the nature of the harm that could be caused by the hazard, how serious the harm could be and the likelihood of it happening. This step may not be necessary if you are dealing with a known risk with known controls
• Control risks – implement the most effective control measure that is reasonably practicable in the circumstances and ensure it remains effective over time
• Review hazards and control measures to ensure they are working as planned

This process will be implemented in different ways depending on the size and nature of your business or undertaking. Larger businesses and those in sectors where workers are exposed to more or higher risks are likely to need more complex, sophisticated risk management processes.

Examples demonstrating how to manage work health and safety risks in consultation with workers are at Appendix B.

Determining what is ‘reasonably practicable’

Deciding what is ‘reasonably practicable’ to protect people from harm requires taking into account and weighing up all relevant matters, including:

• The likelihood of the hazard or risk concerned occurring
• The degree of harm that might result from the hazard or risk
• Knowledge about the hazard or risk, and ways of eliminating or minimising the risk
• The availability and suitability of ways to eliminate or minimise the risk, and
• After assessing the extent of the risk and the available ways of eliminating or minimising the risk, the cost associated with available ways of eliminating or minimising the risk, including whether the cost is grossly disproportionate to the risk.

Further information is available in the Interpretive Guideline: The meaning of ‘reasonably practicable’. The process of managing risk described in this Code will help you decide what is reasonably practicable in particular situations so that you can meet your duty of care under the WHS laws.

Many hazards and their associated risks are well known and have well established and accepted control measures. In these situations, the second step to formally assess the risk is unnecessary. If, after identifying a hazard, you already know the risk and how to control it effectively, you can implement the controls without undertaking a risk assessment.

Risk management is a proactive process that helps you respond to change and facilitate continuous improvement in your business. It should be planned, systematic and cover all reasonably foreseeable hazards and associated risks.

Consulting workers

A PCBU must consult, so far as is reasonably practicable, with workers who carry out work for the business or undertaking and who are (or are likely to be) directly affected by a health and safety matter.

This duty to consult is based on the recognition that worker input and participation improves decision-making about health and safety matters and assists in reducing work-related injuries and disease.

The broad definition of a ‘worker’ under the WHS Act means a PCBU must consult, so far as is reasonably practicable, with contractors and sub-contractors and their employees, on-hire workers, outworkers, apprentices, trainees, work experience students, volunteers and other people who are working for the PCBU and who are, or are likely to be, directly affected by a health and safety matter.

Workers are entitled to take part in consultations and to be represented in consultations by a health and safety representative who has been elected to represent their work group.

Consultation with workers and their health and safety representatives is required at each step of the risk management process. By drawing on the experience, knowledge and ideas of your workers you are more likely to identify all hazards and choose effective control measures.

You should encourage your workers to report any hazards and health and safety problems immediately so that risks can be managed before an incident occurs.

If you have a health and safety committee, you should engage the committee in the risk management process as well.

Consulting, cooperating and coordinating activities with other duty holders

The WHS Act requires that a PCBU to consult, cooperate and coordinate activities with all other persons who have a work health or safety duty in relation to the same matter, so far as is reasonably practicable.

There is often more than one business or undertaking involved in the same activities or who share the same workplace who may each have responsibility for the same health and safety matters, either because they are involved in the same activities or share the same workplace.

In these situations, each duty holder should exchange information to find out who is doing what and work together in a cooperative and coordinated way so risks are eliminated or minimised so far as is reasonably practicable.

For example, if you engage labour hire workers as part of your workforce you share a duty of care to these workers with the business that provides them. In these situations, you must discuss the hazards and risks associated with the work and what precautions will be taken with the labour hire firm.

Never assume that someone else is taking care of a health and safety matter. Find out who is doing what and work together with other duty holders in a cooperative and coordinated way so risks are eliminated or minimised as far as reasonably practicable.

When entering into contracts you should communicate your safety requirements and policies, review the job to be undertaken, discuss any safety issues that may arise and how they will be dealt with. Remember that you cannot transfer your responsibilities to another person.

Further guidance on WHS consultation is available in the Code of Practice: Work health and safety consultation, cooperation and coordination.

1.3 When Should a Risk Management Approach Be Used?

Managing work health and safety risks is an ongoing process that needs attention over time, but particularly when any changes affect your work activities. Examples of when you should work through the steps in this Code include:

• Starting a new business
• Expanding or purchasing an existing business
• Changing work practices, procedures or the work environment
• Changing organisational structure or job roles
• Introducing new workers or returning workers to the workplace
• Purchasing new or used equipment or using new substances
• Working with a new supplier or new commissioner of your services
• Planning to improve productivity or reduce costs
• New information about workplace risks becomes available
• Responding to workplace incidents (even if they have caused no injury)
• Responding to concerns raised by workers, health and safety representatives or others at the workplace, or
• Required by the WHS regulations for specific hazards.

It is also important to use the risk management approach when designing and planning products, processes or places used for work, because it is often easier and more effective to eliminate hazards before they are introduced into a workplace by incorporating safety features at the design stage.

The risk management process outlined in this Code should be applied to both physical and psychological risks. Further guidance specific to psychological risks is available in the Guide: Integrated approach to work-related psychosocial health and safety and the Guide for preventing and responding to workplace bullying.

Identifying hazards in the workplace involves finding things and situations that could potentially cause harm to people. Hazards generally arise from the following aspects of work and their interaction:

• Physical work environment
• Equipment, materials and substances used
• Work tasks and how they are performed, and
• Work design and management.

Table 1 below lists some common types of workplace hazards. Some hazards are part of the work process, such as mechanical hazards, noise or toxic properties of substances. Other hazards result from equipment or machine failures and misuse, chemical spills and structural failures, or where work demands exceed a worker’s ability to cope.

A piece of plant, substance or a work process may have many different hazards. Each of these hazards needs to be identified. For example, a production line may have dangerous moving parts, noise, hazards associated with manual tasks and psychosocial hazards due to the pace of work.

Table 1 Examples of common hazards
Hazard	Example	Potential harm
Manual tasks	Tasks involving sustained or awkward postures, high or sudden force, repetitive movements or vibration	Musculoskeletal disorders such as damage to joints, ligaments and muscles
Gravity	Falling objects, falls, slips and trips of people	Fractures, bruises, lacerations, dislocations, concussion, permanent injuries or death
Psychosocial	Excessive time pressure, bullying, violence and work-related fatigue	Psychological or physical injury or illness
Electricity	Exposure to live electrical wires	Shock, burns, damage to organs and nerves leading to permanent injuries or death
Machinery and equipment	Being hit by moving vehicles, or being caught in moving parts of machinery	Fractures, bruises, lacerations, dislocations, permanent injuries or death
Hazardous chemicals	Acids, hydrocarbons, heavy metals, asbestos and silica	Respiratory illnesses, cancers or dermatitis
Extreme temperatures	Heat and cold	Heat can cause burns and heat stroke or injuries due to fatigue Cold can cause hypothermia or frost bite
Noise	Exposure to loud noise	Permanent hearing damage
Radiation	Ultra violet, welding arc flashes, micro waves and lasers	Burns, cancer or blindness
Biological	Micro-organisms	Hepatitis, legionnaires’ disease, Q fever, HIV/AIDS or allergies

2.1 How to Find Hazards

Inspect the workplace

As a person conducting a business or undertaking (PCBU), regularly walking around the workplace and observing how things are done can help you predict what could or might go wrong. Look at how people actually work, how plant and equipment are used, what chemicals are around and what they are used for, what safe or unsafe work practices exist as well as the general state of housekeeping.

Things to look out for include the following:

• Does the work environment enable workers to carry out work without risks to health and safety (for example, space for unobstructed movement, adequate ventilation, lighting)?
• How is work performed, including the physical, mental and emotional demands of the tasks and activities?
• How suitable are the tools and equipment for the task and how well are they maintained?
• How do workers, managers, supervisors and others interact and how are inappropriate behaviours or conflicts dealt with?
• Have any changes occurred in the workplace which may affect health and safety?

Hazards are not always obvious. Some hazards can affect health over a long period of time or may result in stress (such as bullying) or fatigue (such as shiftwork). Also think about hazards that you may bring into your workplace with new, used or hired goods (for example, worn insulation on a hired welding set).

As you walk around, you may spot straightforward problems and action should be taken on these immediately, for example cleaning up a spill. If you find a situation where there is immediate or significant danger to people, move those persons to a safer location first and attend to the hazard urgently. Follow up on why the situation occurred to identify additional hazards and risks.

Make a list of the hazards you find, including the ones you know are already being dealt with, to ensure that nothing is missed. This list can be kept and updated next time you do an inspection. You may use a checklist designed to suit your workplace to help you find and make a note of hazards.

Good work design and safe design

The best chance to find ways to eliminate hazards and minimise risks is during the design phase.

Effective design of ‘good work’ considers the work tasks, work systems, the physical working environment, and the workers and others in the workplace. For more information on good work design principles, see Principles of good work design: A work health and safety handbook.

Safe design of buildings, structures, equipment and vehicles accounts for the hazards and risks present at all stages of the product’s lifecycle. For more information on safe design principles and how to achieve safe design, see Guidance on the principles of safe design for work and the Code of Practice: Safe design of structures.

Consult your workers

Ask your workers about any health and safety problems they have encountered in doing their work and any near misses or incidents that have not been reported.

Worker surveys may also be undertaken to obtain information about matters such as workplace bullying, as well as muscular aches and pains that can signal potential hazards.

Consult your supply chains and networks

Talk with your suppliers or those commissioning your services to understand each other’s needs and identify any hazards and risks. For example, hazards may relate to frequent pressure to deliver services in very tight timeframes or to delay service delivery for long periods which reduce workers’ opportunities to rest. Other hazards may relate to packaging products in ways that increase workers’ risks of musculoskeletal injury or exposure to hazardous chemicals.

When people within a supply chain act cooperatively they can exert greater influence on health and safety than when acting alone.

Review available information

Information and advice about hazards and risks relevant to particular industries and types of work is available from regulators, industry associations, unions, technical specialists and safety consultants.

Manufacturers and suppliers can also provide information about hazards and safety precautions for specific substances (safety data sheets), plant or processes (instruction manuals).

Analyse your records of health monitoring, workplace incidents, near misses, worker complaints, sick leave and the results of any inspections and investigations to identify hazards. If someone has been harmed doing a particular task, then a hazard exists that could hurt someone else. These incidents need to be investigated to find the hazard that caused the injury or illness.

A risk assessment involves considering what could happen if someone is exposed to a hazard and the likelihood of it happening. A risk assessment can help you, as a person conducting a business or undertaking (PCBU), to determine:

• How severe a risk is
• Whether any existing control measures are effective
• What action you should take to control the risk, and
• How urgently the action needs to be taken.

Many hazards and their associated risks are well known and have well established and accepted control measures. In these situations, the second step to formally assess the risk is not required. If after identifying a hazard you already know the risk and how to control it effectively, you may simply implement the controls.

A risk assessment can be undertaken with varying degrees of detail depending on the type of hazard and the information, data and resources that you have available. It can be as simple as a discussion with your workers or involve specific risk analysis tools and techniques developed for specific risks or recommended by safety professionals. For some complex situations, expert or specialist advice may be useful when conducting a risk assessment.

When Should a Risk Assessment Be Carried Out?

A risk assessment should be done when:

• There is uncertainty about how a hazard may result in injury or illness
• The work activity involves a number of different hazards and there is a lack of understanding about how the hazards may interact with each other to produce new or greater risks, or
• Changes at the workplace occur that may impact on the effectiveness of control measures.

In some circumstances, a risk assessment will assist to:

• Identify which workers are at risk of exposure
• Determine what sources and processes are causing the risk
• Identify if and what kind of control measures should be implemented, and
• Check the effectiveness of existing control measures.

A risk assessment is mandatory under the WHS Regulations for certain activities that are high risk such as, but not limited to, entry into con-fined spaces, diving work and live electrical work.

Some hazards that have exposure standards, such as noise and airborne contaminants, may require scientific testing or measurement by a competent person to accurately assess the risk and to check that the relevant exposure standard is not being exceeded (for example, by using noise meters to measure noise levels and using gas detectors to analyse oxygen levels in confined spaces).

A risk assessment is not required when legislation requires a hazard or risk to be controlled in a specific way – these requirements must be complied with.

A detailed risk assessment may not be required in the following situations:

• A code of practice or other guidance sets out a way of controlling a hazard or risk that is applicable to your situation.
• There are well-known and effective controls that are in use in the particular industry that are suited to the circumstances in your workplace.

In these situations, you may be able to simply implement these control measures.

A risk assessment may be appropriate to reuse in situations where all the hazards, tasks, things, workers or circumstances are the same and no worker or other person will be exposed to greater, additional or different risks. However, as stated above, if there are any changes at the workplace, a new risk assessment should be performed.

How to Do a Risk Assessment

Hazards have the potential to cause different types and severities of harm, ranging from minor discomfort to a serious injury or death.

For example, heavy liquefied petroleum gas (LPG) cylinders can cause muscular strain when they are handled manually. However, if the cylinder is damaged causing gas to leak, which is then ignited, a fire could result in serious burns. If that leak occurs in a storeroom or similar enclosed space, it could result in an explosion that could destroy the building and kill or injure any-one nearby. Each of the outcomes involves a different type of harm with a range of severities, and each has a different likelihood of occurrence.

The risk will increase as the severity and likelihood of harm increases.

Work Out How Hazards May Cause Harm

In most cases, incidents occur as a result of a chain of events and a failure of one or more links in that chain. If one or more of the events can be stopped or changed, the risk may be eliminated or reduced.

One way of working out the chain of events is to determine the starting point where things begin to go wrong and then consider: ‘If this happens, what may happen next?’ This will provide a list of events that sooner or later cause harm. See the example in Appendix C.

In thinking about how each hazard may cause harm, you should consider:

• The effectiveness of existing control measures and whether they control all types of harm
• How work is actually done, rather than relying on written manuals and procedures, and
• Infrequent or abnormal situations, as well as how things are normally meant to occur.

Consider how harm could be caused during maintenance and cleaning, as well as breakdowns of equipment and failures of health and safety controls.

Work Out How Severe the Harm Could Be

To estimate the severity of harm that could result from each hazard you should consider the following questions:

• What type of harm could occur (for example muscular strain, injuries due to fatigue, psychological injury, burns, laceration)? How severe is the harm? Could the hazard cause death, serious injuries, illness or only minor injuries requiring first aid?
• What factors could influence the severity of harm that occurs? For example, the distance someone might fall or the concentration of a particular substance will determine the level of harm that is possible. The harm may occur immediately if something goes wrong (for example injury from a fall) or it may take time for it to become apparent (for example illness from longterm exposure to a substance or to excessive work demands).
• Do you need to use specific tools or processes to assess how severe the harm could be? This could include sending samples to a lab for testing or arranging noise exposure level testing.
• How many people are exposed to the hazard and how many could be harmed in and outside your workplace? For example, a mobile crane collapse on a busy construction site has the potential to kill or injure a large number of people.
• Could one failure lead to other failures? For example, could the failure of your electrical supply make any control measures that rely on electricity ineffective?
• Could a small event escalate to a much larger event with more serious consequences? For example, a minor fire can get out of control quickly in the presence of large amounts of combustible materials.

Work Out the Likelihood of Harm Occurring

The likelihood that someone will be harmed can be estimated by considering the following:

• How often is the task done? Does this make the harm more or less likely?
• How often are people near the hazard? How close do people get to it?
• Has it ever happened before, either in your workplace or somewhere else? How often?

Table 2 contains further questions that can help you estimate likelihood.

Table 2 Questions to help estimate the likelihood of harm occurring
Questions	Explanation and examples
How often are people exposed to the hazard?	A hazard may exist all of the time or it may only exist occasionally. The more often a hazard is present, the greater the likelihood it will result in harm. For example: Meshing gears in an enclosed gearbox can cause crushing only if the gearbox is open during maintenance, and therefore the potential for harm will not occur very often. Continuously lifting heavy boxes has the potential to cause harm whenever the work is done.
How long might people be exposed to the hazard?	The longer that someone is exposed to a hazard, the greater the likelihood that harm may result. For example: The longer a person is exposed to noisy work, the more likely it is that they will suffer hearing loss.
How effective are current controls in reducing risk?	In most cases the risks being assessed will already be subject to some control measures. The likelihood of harm resulting from the risk will depend upon how adequate and effective the current measures are. For example: Traffic management controls have been implemented in a warehouse to separate moving forklifts from pedestrians by using signs and painted lines on the floor. These controls may need to be upgraded to include physical barriers.
Could any changes in your organisation increase the likelihood?	The demand for goods or services in many organisations varies throughout the year. Changes in demand may be seasonal, depend on environmental conditions or be affected by market fluctuations that are driven by a range of events. Meeting increased demand may cause unusual loads on people, plant and equipment and systems of work. Failures may be more likely. For example: Inner city restaurants and bistros are very busy in the period prior to Christmas, placing extra demands on kitchen and serving staff. The increase in volume of food to be prepared and serving a larger number of patrons increases the potential for human error and the likelihood of harm.
Are hazards more likely to cause harm because of the working environment?	Examples of situations where the risk of injury or illness may become more likely: Environmental conditions change. For example, work performed in high temperatures in a small space increases the potential for mistakes because workers become fatigued more quickly; wet conditions make walkways and other things slippery. People are required to work quickly. The rate at which work is done (e.g. number of repetitions) can over-stress a person’s body or make it more likely that mistakes will be made. There is insufficient light or poor ventilation.
Could the way people act and behave affect the likelihood of a hazard causing harm?	The possibility that people may make mistakes, misuse items, become distracted or panic in particular situations needs to be taken into account. The effects of fatigue or stress may make it more likely that harm will occur.
Do the differences between individuals in the workplace make it more likely for harm to occur?	Workers are not all the same and individual variability should be considered, for example: People respond to stress at work in different ways, which means some workers are more susceptible to harm. People with disabilities may be more likely to suffer harm if the workplace or process is not designed for their needs. New or young workers may be more likely to suffer harm because of inexperience. People who do not normally work at the workplace will have less knowledge than employees who normally work there, and may be more likely to suffer harm. These people include contractors, visitors or members of the public.

You can rate the likelihood as one of the following:

• Certain to occur – expected to occur in most circumstances
• Very likely – will probably occur in most circumstances
• Possible – might occur occasionally
• Unlikely – could happen at some time
• Rare – may happen only in exceptional circumstances.

The most important step in managing risks in-volves eliminating them so far as is reasonably practicable, or if that is not reasonably practicable, minimising the risks so far as is reasonably practicable.

In deciding how to control risks, as a person conducting a business or undertaking (PCBU), you must consult your workers and their representatives who will be directly affected by this decision. Their experience will help you choose appropriate control measures and their involvement will increase the level of acceptance of any changes that may be needed to the way they do their job.

There are many ways to control risks. Some control measures are more effective than others.

You must consider various control options and choose the control that most effectively eliminates the hazard or minimises the risk in the circumstances. This may involve a single control measure or a combination of different controls that together provide the highest level of protection that is reasonably practicable.

Some problems can be fixed easily and should be done straight away, while others will need more effort and planning to resolve. Of those requiring more effort, you should prioritise areas for action, focusing first on those hazards with the highest level of risk.

4.1 The Hierarchy of Control Measures

The ways of controlling risks are ranked from the highest level of protection and reliability to the lowest as shown in Figure 2. This ranking is known as the hierarchy of control measures.

The hierarchy of control measures can be applied in relation to any risk. The WHS Regulations make it mandatory for duty holders to work through this hierarchy when managing certain risks.

You must always aim to eliminate the risk, which is the most effective control. If this is not reasonably practicable, you must minimise the risk by working through the other alternatives in the hierarchy.

The lower levels in the hierarchy are less effective because controls that change the hazard or minimise exposure to the hazard can only minimise the risk. You cannot eliminate the risk without eliminating the hazard.

Administrative controls and personal protective equipment (PPE) are the least effective at minimising risk because they do not control the hazard at the source and rely on human behaviour and supervision. These control measures should only be used:

• To supplement higher level control measures (as a back-up)
• As a short-term interim measure until a more effective way of controlling the risk can be used, or
• When there are no other practical control measures available (as a last resort).

Elimination

The most effective control measure involves eliminating the hazard and associated risk. The best way to do this is by, firstly, not introducing the hazard into the workplace. For example, you can eliminate the risk of a fall from height by doing the work at ground level. Eliminating hazards is often cheaper and more practical to achieve at the design or planning stage of a product, process or place used for work. In these early phases, there is greater scope to design out hazards or incorporate risk control measures that are compatible with the original design and functional requirements. For example, not using a noisy machine will be more effective than providing workers with personal hearing protectors.

You can also eliminate risks by removing an existing hazard, for example, by removing trip hazards on the floor, disposing of unwanted chemicals, or not working in an isolated or remote area.

It may not be reasonably practicable to eliminate a hazard if doing so means that you cannot make the end product or deliver the service. If you cannot eliminate the hazard, then you must minimise as many of the risks associated with the hazard as reasonably practicable.

Substitution, isolation and engineering controls

If it is not reasonably practicable to eliminate the hazards and associated risks, you must minimise the risks using one or more of the following approaches, so far as is reasonably practicable:

If PPE is to be used at the workplace, you must ensure the equipment is:

• Selected to minimise risk to health and safety, including by ensuring that the equipment is suitable for the nature of the work and any hazard associated with the work and is of suitable size and fit and reasonably comfortable for the worker who is to use or wear it
• Maintained, repaired and replaced so that is continues to minimise risk to the worker who uses it, including by ensuring that the equipment is clean and hygienic, and in good working order.

If you direct the carrying out of work, you must provide the worker with information, training and instruction in the proper use and wearing of PPE, and the storage and maintenance of PPE.

A worker must, so far as reasonably able, use or wear the PPE in accordance with any information, training or reasonable instruction and must not intentionally misuse or damage the equipment.

4.2 How to Develop and Implement Control Options

Information about suitable controls for many common hazards and risks can be obtained from:

• Codes of practice and guidance material
• Manufacturers and suppliers of plant, substances and equipment used in your workplace, or
• Industry associations and unions.

In some cases, published information will provide guidance on the whole work process. In other cases, the guidance may relate to individual items of plant or how to safely use specific substances. You may use the recommended control options if they suit your situation and eliminate or minimise the risk.

Developing specific control measures

You may need to develop specific control measures if the available information is not relevant to the hazards and risks or circumstances at your workplace. This can be done by referring to the chain of events that were recorded during the risk assessment.

For each of the events in the sequence, ask: ‘What can be done to stop or change the event occurring?’ An example of this approach is shown in Appendix C.

Working through the events in the sequence will give you ideas about possible ways to eliminate or minimise the risk. There may be more than one solution for each of the events. The control option you choose should be:

• One or more controls that provide the highest level of protection for people and is the most reliable – that is, controls located towards the top of the hierarchy in Figure 2
• Available – that is, it can be purchased, made to suit or be put in place, and
• Suitable for the circumstance in your workplace – that is, it will work properly given the workplace conditions, work process and your workers.

Where the hazard or risk has the potential to cause death, serious injury or illness, more emphasis should be given to those controls that eliminate or reduce the level of harm, than those that reduce the likelihood of harm occurring.

Make sure that your chosen solution does not introduce new hazards. If this is not possible, any new hazards or risks introduced will also need to be managed.

You may prepare a risk register that identifies the hazards, what action needs to be taken, who will be responsible for taking the action and by when. An example is provided at Appendix D.

Cost of control measures

All risks can be controlled and it is always possible to do something, such as stopping the activity or providing instructions to those exposed to the risk. There will normally be a number of different options between these two extremes. Cost (in terms of time and effort as well as money) is just one factor to consider when determining the best control option.

The cost of controlling risk may be taken into account in determining what is reasonably practicable, but cannot be used as a reason for doing nothing.

The greater the likelihood of harm occurring or the greater the extent of that harm, the less weight should be given to the cost of controlling the hazard or risk.

If two control measures provide the same level of protection and are equally reliable, you can adopt the less expensive option.

Cost cannot be used as a reason for adopting controls that rely exclusively on changing people’s behaviour or actions when there are more effective controls available that can change the risk through substitution, engineering or isolation.

For further information, see the Interpretive Guideline: The meaning of ‘reasonably practicable’.

Implementing controls

The control measures you put into operation will usually require changes to the way work is carried out, for example, working with new or modified equipment or processes, new or different chemicals or new personal protective equipment. In these situations, it is necessary to support the control measures with the following:

4.3 How to Ensure Controls

Remain effective

An important part of controlling risk is ensuring that your chosen control measures are maintained after their initial implementation. The following actions may help you monitor the control measures you have implemented and ensure that they remain effective.

Accountability for health and safety

Managers and supervisors should be provided with the authority and resources to implement and maintain control measures effectively. Ac-countability should be clearly allocated to ensure procedures are followed and maintained.

Maintenance of plant and equipment

This will involve scheduling and performing regular inspection and testing, repair or replacement of damaged or worn plant and equipment. It includes checking that any control measures are suitable for the nature and duration of work, are set up and used correctly.

Further information on maintaining plant and equipment is available in the Code of Practice: Managing the risks of plant in the workplace.

Up-to-date training and competency

Most control measures depend on workers and supervisors having the appropriate competencies to do the job safely. Training must be provided to maintain competencies and to ensure new workers are capable of working safely.

Up-to-date hazard information

Information about hazards, such as plant and substances, may be updated by manufacturers and suppliers and should be checked to make sure controls are still relevant. New technology may provide more effective solutions than were previously available. Changes to operating conditions or the way activities are carried out may also mean that control measures need to be updated.

Regular review and consultation

Control measures are more effective where there is regular review of work procedures and consultation with your workers and their representatives.

If maintenance processes reveal new hazards, or existing hazards that are not being addressed, you will need to perform a review of your control measures.

The control measures you, as a person conducting a business or undertaking (PCBU), put in place should be reviewed regularly to make sure they work as planned. Don’t wait until something goes wrong.

The WHS Regulations require a risk management process for specific risks. That process includes circumstances where you must review your control measures for those risks and, if necessary, change them. A review is required:

• When the control measure is not effective in controlling the risk
• Before a change at the workplace that is likely to give rise to a new or different health and safety risk that the control measure may not effectively control
• If a new hazard or risk is identified
• If the results of consultation indicate that a review is necessary, or
• If a health and safety representative requests a review.

In any case, as part of your ongoing duties as a PCBU, you should regularly review your control measures, including in the above circumstances. Managing work health and safety risks is an ongoing process that needs attention over time, but particularly when any changes affect your work activities.

You may use the same methods as in the initial hazard identification step (Chapter 2 – How to identify hazards) to check controls. Consult your workers and their health and safety representatives and consider the following questions:

• Are the control measures working effectively in both their design and operation?
• Have the control measures introduced new problems?
• Have all hazards been identified?
• Have new work methods, new equipment or chemicals made the job safer?
• Are safety procedures being followed?
• Have the instruction and training provided to workers on how to work safely been successful?
• Are workers actively involved in identifying hazards and possible control measures? Are they openly raising health and safety concerns and reporting problems promptly?
• Are the frequency and severity of health and safety incidents reducing over time?
• If new legislation or new information becomes available, does it indicate current controls may no longer be the most effective?

If problems are found, go back through the risk management steps (Chapter 4 How to control risks), review your information and make further decisions about risk control. Priority for review should be based on the level of risk. Control measures for high risks should be reviewed more frequently.

If you design, manufacture or supply products used for work, quality assurance processes may be used to check the product effectively minimises health and safety risks. Obtain feedback from users of the product to determine whether any improvements can be made to make it safer.

Keeping records of the risk management process demonstrates what you have done to comply with the WHS Act and WHS Regulations. It also helps when undertaking subsequent risk management activities, including reviewing your control measures.

Keeping records of the risk management process has the following benefits. It:

• Allows you to demonstrate how decisions about controlling risks were made
• Assists in targeting training at key hazards
• Provides a basis for preparing safe work procedures
• Allows you to more easily review risks following any changes to legislation or business activities, and
• Demonstrates to others (regulators, investors, shareholders, customers) that work health and safety risks are being managed.

The detail and extent of recording will depend on the size of your workplace and the potential for major work health and safety issues. It is useful to keep information on:

• The identified hazards, assessed risks and chosen control measures (including any hazard checklists, worksheets and assessment tools used in working through the risk management process)
• How and when the control measures were implemented, monitored and reviewed
• Who you consulted with
• Relevant training records, and
• Any plans for changes.

There are specific record-keeping requirements in the WHS Regulations for some hazards, such as hazardous chemicals, plant and equipment. If such hazards have been identified at your workplace, you must keep the relevant records for the time specified.

You should ensure that everyone in your workplace is aware of record-keeping requirements, including which records are accessible and where they are kept.