Contractor newsletter

Welcome to the third edition of DHA's contractor work health and safety (WHS) newsletter.This edition will provide you with information on the importance of hazard reporting, further guidance to assist you with completing your WHS survey, an update to our asbestos management and some suggestions as to what you could consider discussing at your next safety briefing.

Hazard reporting

Before we get into reporting, it's important to understand exactly what a hazard is. A hazard is defined as any event, situation or object that may pose a risk of an employee being injured, either physically or psychologically. 

Most hazards in a workplace can be mitigated by implementing appropriate methods. These methods often lead to the development of safe work processes, for example, the requirement to wear personal protective equipment or clothing. In the event of high risk work, safe work method statements can identify the appropriate hazard mitigation methods. Sometimes, however, hazards don't come in a form where a process or the addition of protective clothing is sufficient. 

Since 11 March 2022, when DHA provided an opportunity for our contractors to report hazards to us at the completion of a job in Online Services, we have received 116 hazard notifications. These hazards range from unrestrained animals, mould growth, faulty fence issues, deteriorating gyprock and cornice and ceiling insulation connecting with downlights. These reports are highly useful to us in knowing what hazards we are not seeing and what we need to attend to; please keep it up!

We are seeing a lot of reports for items that relate to how you completed the job safely. This is great, but please do not use the ‘Hazard Reporting’ tool to report on the activity that you have been engaged to complete. Reporting that it was safer to complete the job while wearing PPE is a safe work process or procedure,  which is different to identifying and rectifying a hazard. The option to report a hazard in Online Services is strictly for any hazards you observe at a residence or workplace while you are completing your work order. 

By remaining vigilant and reporting hazards and maintenance issues, we can work together to prevent an incident from occurring at one of our sites or properties.

We are working hard to provide opportunities for you - our contractors - to consult, cooperate and coordinate work health and safety issues with our team. We have a shared interest in providing safe residences for our Defence members and safe workplaces for DHA employees and contractors. If you have any feedback or questions relating to the hazard reporting system please get in touch with whs@dha.gov.au

Psychological hazards

DHA's WHS team recently attended the 2022 Comcare Conference held in the ACT. This conference had a strong focus on the psychological aspects of work, health and safety, This is referred to as 'psychological wellbeing'. Hazard reporting doesn't just apply to the fault of an object. Hazards can come in the form of a physical or psychological hazard. There are increasing efforts industry-wide to raise awareness that mental health affects of an event may also be reported as a WHS incident. It was shown that most incident claims relating to a psychological hazard or incident result in a greater recovery time, meaning that it takes the employee longer to return to normal working duties if they are effected by a psychological event as opposed to a physical one. We encourage you to review your processes for how your company handles bullying and harassment, trauma from injuries or the impacts of a serious injury to a colleague and implement changes if required.

WHS reviews

DHA is committed to a structured approach to workplace health and safety to achieve a consistently high standard of safety performance. Since the development of our contractor guidance material, which coincided with the release of our latest WHS survey in March 2022, we have progressed a total of 94 WHS reviews. These reviews are generally completed by 2 dedicated members of the WHS team and they aim to complete the initial review of your submission within 72 hours. While the WHS team endeavour to meet this time frame, if our review identifies deficiencies in your submission (information is not present, inadequate documents, etc) the time frame for completion of the review will be delayed.

In the last WHS newsletter released in April, we addressed a series of identified frequently asked questions for completing WHS reviews. Since that release, we've developed the following further advice to help you complete your reviews and meet your legislative requirements in a timely manner. 

How to read the scope of works and provide relevant information

While some WHS reviews can be generic in nature, DHA assess your WHS documentation based on the works you have been contracted to undertake. Therefore, when conducting a review we look to ensure that you have assessed the tasks to be performed, identified hazards and the level of risk associated with carrying out the tasks. We also assess whether you have referred to your state or territory’s Regulations and/or Codes of Practice and provided information that aligns with the regulated safe practices.

Importance of relevant legislative citations (and providing the correct documentation)

Providing references from the legislation (Act, Regulations and Codes of Practice) identifies and demonstrates an understanding of legislative requirements under which a contractor must operate in a compliant manner. Additionally, it provides greater confidence that a contractor has knowledge of safe practices of work.

Asbestos management

DHA has worked diligently over the years to develop a good grasp of where we have asbestos in our housing portfolio. If you have worked in a DHA property  containing asbestos, you will no doubt have seen our 'Asbestos pop-up' feature on the work order. Once acknowledged the pop-up reverts into the work order itself and stays visible for your information.

Currently this pop-up only shows where asbestos has been confirmed on a particular house or property. Work is underway to also show all the locations checked for asbestos at the same property even if the test was negative. This will provide you as a contractor with more information should you question if a location has been checked. We also intend to provide a link to the asbestos report on the pop-up so that you can download the full report when needed for full reference.

Occasionally you may question whether a product is asbestos (or another hazardous material) without any pop-up having appeared on the work order. If this happens, assume the product is asbestos etc. Ensure you work to a safe work method statement, and alert the WHS team at DHA for further consultation.

Any contractor who has a risk of disturbing asbestos - such as carpenters, electricians and plumbers - must only do so after forming a safe work method statement. For further information see this guidance from Safe Work Australia.

Occasionally the reports are a Hazardous Materials report and contain other hazardous building materials such as lead, PCBs, HFCs or Silica etc. Further work will be undertaken to make the information we have accessible to you on the work face. Should you have any questions or wish to discuss asbestos or other hazardous building materials, please email whs@dha.gov.au in the first instance.

Get talking

Toolbox talks, also known as a safety briefing or a 'take 5', are a informal way to discuss health and safety topics relating to your job or workplace. These talks often cover topics such as: the condition of the worksite and the impact of weather on the site; appropriate PPE; and manual handling guidance. We understand that sometimes these talks appear to become mundane and there may be a need to explore a range of additional topics, so we've provided some suggestions of safety topics to be explored ...

Emergency response plans

When was the last time you completed an emergency drill? It's recommended that businesses test the effectiveness of their emergency response plans at 6 month intervals, with a minimum of an annual drill. Emergency preparedness plans don't just cover fire evacuations, depending on the nature of the work you undertake it may be useful to discuss the option of completing a drill of a plant rollover, collapse of a trench, or even just as simple as additional egress options.

Safe driving 

Generally speaking, trades workers drive to and from site each day and you may therefore overlook the need of a site safety briefing about motor vehicles. However, given that the conditions on a construction site vary to public roads, we encourage you to to raise safe driving in your toolbox talk.

Appropriate trailer hitching and reversing could also be a topic of interest.

Welcome to the second edition of DHA's contractor work health and safety (WHS) newsletter. This edition will provide you with information on:

• DHA's statement of commitment to work health, safety and wellbeing
• changes made to DHA's contractor WHS survey - Managing a safe and healthy workplace.
• the process DHA follows in reviewing the evidence submitted by contractors in completing a WHS survey (a WHS Review)
• the requirement for a contractor to declare that work undertaken on behalf of DHA was completed in a safe and compliant manner (declaration made when invoicing through Online Services), and
• an update to the contractor induction module.

Statement of commitment

DHA is committed to providing and maintaining a safe and healthy work environment for our people—workers, visitors to our workplace and those who have the potential to be affected by our activities. Our goal is to ensure, as far as reasonably practicable, there is no harm to anyone at any time while working at DHA. DHA workers include DHA employees, contractors and contractors' workers.

DHA and its workers must maintain a safe and healthy work environment to prevent injuries/illness and to enhance physical and psychosocial wellbeing of workers. We are committed to consultation, coordination and cooperation to deliver safe programs and services.

As a contractor, you are a person conducting a business or undertaking (PCBU) under state/territory WHS legislation. As a PCBU we encourage you to review DHA's Statement of commitment and consider making a similar commitment to work health and safety in your documentation and/or processes.

Guidance to complete a WHS survey 

Prior to commencing work for DHA, all contractors must complete a WHS survey - Managing a safe and healthy workplace and provide evidence as requested in the survey. The current WHS survey may be accessed here. To help contractors complete the WHS survey, guidance information is now available for reference purposes see Contractor WHS survey - Guidance to complete a WHS survey.

The guidance information will also help contractors who are required to complete a WHS survey every 18 months through their Online Services account.

If you have any questions in relation to completing a WHS survey please email DHA WHS at whs@dha.gov.au. Please note that DHA is not able to provide technical WHS advice in relation to safety and risk management. Technical advice is available through your State/Territory WHS regulator, see Safe Work Australia's webpage that provides links to all WHS regulator websites.

WHS review

What is a WHS review?

A WHS review is the process by which DHA conducts an assessment of the safety and risk management evidence provided by a contractor for the scope of work being undertaken on behalf of DHA. The evidence is provided when completing a WHS survey.

In completing a WHS review, DHA considers how a contractor (as a PCBU) will support DHA to fulfil its WHS obligations and how the contractor's safety and risk management evidence assures the contractor (as a PCBU) will fulfil their WHS obligations with reference to the scope of work to be undertaken on behalf of DHA. DHA may consult with contractors to clarify aspects of the evidence submitted for review.

Why are WHS reviews completed?

As an Australian Government Business Enterprise (AGBE), DHA is required to adhere to the Work Health and Safety Act 2011 (Cth) (WHS Act). As part of this requirement DHA must ensure, so far as is reasonably practicable, the health and safety of all workers undertaking work on behalf of DHA – and that the work of DHA workers does not affect the health and safety of others in the workplace. A DHA workplace is anywhere a worker is engaged to work on behalf of DHA and includes, construction, development and/or heritage sites, DHA managed properties, and/or DHA offices.

A review of a contractor's safety and risk management evidence will provide DHA with a reasonable level of assurance that a contractor (as a worker and PCBU) will work in a safe and compliant manner for the scope of work being undertaken on behalf of DHA. A WHS review process verifies a contractor's capacity and capability to work in a safe and compliant manner.

Comcare (Commonwealth WHS regulator) instruct Commonwealth entities (including AGBEs) to verify that contractors have appropriate evidence to ensure both DHA and the contractor (As a PCBU) fulfil their respective and concurrent WHS duties. 

Identified frequently asked questions for completing WHS reviews

What do I need to include in my policy?

Generally speaking, DHA cannot inform contractors of specific information, however, the following key focus areas should be considered:

• Is the policy current? i.e. addressing current legislation, signed and dated and COVID-19 management plans
• Consultation processes (both incident notification and how workers are consulted on issues)
• Emergency plans/policies

My business conducts high risk works what further documentation should I provide?

When assessing high risk works DHA must see evidence of previously implemented practices. Some examples of evidence are:

• SWMS for recently completed high risk DHA works
• Evidence of relevant licenses/permits to engage in high risk works
• Control methods which match the Codes of Practice for your State and/or Territory

What should I include in a training matrix/register and why are they necessary?

Employers have a responsibility to provide instruction and training, such as a training matrix/register is a method used to plan and track employee training skills/qualifications linked to specific scopes of work. Refer to the Guidance to complete a WHS Survey for more information.

A training register should include the workers names, course name, date of attendance, training provider name, accreditation certificate number and expiry date (if applicable).

Where can I locate the COVID-19 controls I should be using?

Government Health websites for each state and territory should include the control methods businesses should be applying to prevent employees contracting the virus and prevent the spread of COVID-19.

Why does the documentation need to be recent and signed?

DHA request recently completed documentation to confirm that:

• All workers have been consulted regarding identified hazards/risks and their controls; and
• Senior management ensure that the safe management systems are being adhered to at DHA sites.

Contractor induction module

DHA has revised the contractor induction module.  The revised version will be accessible via DHA's internet in the first instance. Further work will be completed by DHA to make the revised version accessible through Online Services (we will let you know when this change is effective). DHA has changed the requirement for completion of the contractor induction module, from all workers to one person from the contracting business entity (PCBU) to complete the induction. This person may be a director or WHS manager/contact. DHA has made this change in requirement in recognition that each PCBU is obliged under applicable State/Territory WHS legislation to ensure all workers are inducted/trained. DHA will review each contractor's WHS Review evidence to ensure appropriate induction and training is being provided to workers in compliance with applicable State/Territory WHS legislation.

Changes to work, health and safety reporting

To ensure DHA and its contractors comply with duties associated with managing WHS hazards/risks in the workplace, as of Friday 11 March 2022 the following changes will be present in your Online Service portal:

• When an MITM is allocated, the work details document will confirm the requirement to work in a safe and compliant manner, and to report all workplace incidents to DHA.
• When processing an invoice, you will be required to complete a series of Yes/No questions relating to WHS issues identified while completing the work(s).
• Should any WHS issues be identified, you will be prompted to complete three free text fields for ‘Issue’, ‘Actions Taken’ and ‘Further Recommended Action.’
• On completion of the invoicing process, a declaration must be made to confirm the work undertaken was completed in a safe and compliant manner, and workplace incidents were reported to DHA. This declaration will be in the form of a mandatory check box.

DHA is obliged to ensure all work undertaken by its contractors is completed in a safe and compliant manner. DHA as a Commonwealth entity must comply with the Work Health and Safety Act 2011 (Cth). Each contractor is obliged to comply with the State/Territory WHS legislation applicable to the location in which they operate.

Thank you for your contribution to assuring the DHA workplace, your workplace, is as safe as it is reasonably practicable to be.

Be informed: Silica dust

Silica dust has been known to cause serious illness to workers in a short amount of time with the issue hitting the news on many occasions over recent times. The on-site installation of engineered stone is considered high risk construction work if the processes used to install, modify or repair the engineered stone such as, cutting, grinding, trimming, drilling, sanding, or polishing generate silica dust and contaminate the work area. As a high risk construction activity a Safe Work Method Statement for work in a contaminated atmosphere must be in place that identifies the risk and places proper controls in place. For advice on Silica head over to Safe Work Australia to view the Model Code of Practice: Managing the risks of respirable crystalline silica from engineered stone in the workplace  

Silica is found in many common construction products, apart from the more obvious engineered products like kitchen benchtops, silica is also in products such as bricks and roof tile pointing; check the product safety data sheet for silica content and manage the risk.

SafeWork NSW is holding an industry webinar on the 28 March 2022. We encourage you to attend to learn about this serious risk to the health of workers. Head over to Managing the risks of respirable crystalline silica from engineered stone in the workplace | SafeWork NSW to find a link to the webinar and also a practical risk management tool for offsite silica dust control.

To consult further please email whs@dha.gov.au.

Welcome to the first edition of our contractor newsletter which you can expect to receive on a quarterly basis. We are committed to maintaining a safe and healthy working environment for our workers, visitors to our offices or work locations and those who have the potential to be affected by our activities (property, tenants and members of the public).

Importance of regular communication

When you are performing work for us, we each have regulatory obligations to ensure, so far as is reasonably practicable, there is no harm to anyone at any time. We must take all reasonable steps to maintain a safe and healthy working environment, to reduce injuries/illness and enhance physical and psychosocial wellbeing. We must be committed to participation, consultation and cooperation to deliver safe programs and services.

We also share obligations to consult, collaborate and cooperate in regards to work health and safety (WHS) matters. This quarterly newsletter supports our compliance with those obligations. We have adopted the mantra work safe, go home safe. This, combined with the house and tick icon, aims to remind everyone to work safe every day, so you go home safe.

Hazards and risks

Complacency is a hazard

After years of experience on the job, returning to work after a break or during peak periods, it’s easy to become complacent and blindsided. Complacency is extremely dangerous—it can literally be a killer—or at very least put you and, potentially, others at risk of injury and/or illness.

The only way we can fight complacency is to always be vigilant and adopt processes and behaviours to avoid it. Here are a few ideas:

• Add variety—while routines are a necessary part of the job, changing up tasks helps to reduce day-to-day repetition.
• Support observation—encourage your workers to observe the actions of each other. This makes it easier to identify risks in the workplace and will help raise awareness of their own actions.
• Correct errors—training, education and mentoring programs should be in place to help workers both identify and change dangerous practices and mitigate potential problems.

Animal encounters 

Sounds like a great TV documentary doesn’t it? In all seriousness, in recent months we have seen an increase in the number of animal encounter incidents reported, particularly dog bites. We have issued a Safety alert: Your safety around dogs which includes safety advice, safety actions and links to resources. These types of incidents are generally preventable. We strongly encourage you to take the time to read this alert and take all reasonable steps to prevent incidents occurring.

Weather

Our peak work period aligns with summer, meaning that you and your workers will likely be exposed to warmer weather conditions and related hazards. There is a number of great resources available, such as Heat - Working in extreme heat | SafeWork NSW, to help identify these hazards and mitigate the risks associated with working in extreme heat. And don’t forget to be sun smart

Healthy reporting culture

Timely incident reporting

It’s essential that you report WHS incidents and near miss events which occur on our work sites in a timely manner:

• You must notify us immediately in the event of a notifiable incident.
• All other incidents must be reported to us as soon as practicable. 

Our Guide to WHS incient notification outlines what to report how and when to notify and why it is important to notify DHA. We have also developed a WHS incident notification flowchart to assist in determining if a incident should be reported.

We strongly encourage you to review these documents to ensure you understand the timeframes associated with reporting specific incident types. And, if in doubt, always report it!

Incident Analysis

We analyse all WHS incidents to identify trends and determine if there are hazards or risks that warrant corrective action to assure our workers’ safety.In the past 12 months (1 November 2020 to 31 October 2021), we received a total of 48 incident reports involving contractors. Of these, 43 required further investigation. The top three recurrent incident types and root causes are listed below with relevant information for your review.

Slips, trips and falls

Poor lighting, distracting noises, wet conditions and lack of situational awareness all contributed to a number of slips, trips or falls. Guides such as Slips, trips and falls prevention by WorkSafe QLD provides guidance on how to manage the risks associated with this hazard. We strongly encourage you to review this information and implement any corrective controls to make your work environment safer.

Unsafe work processes

Too often, our incident investigation found that workers had failed to follow safe work methods. We are increasing our surveillance program to ensure all contractors that we engage are maintaining a compliant safety management system and implementing it effectively. We also suggest you hold regular toolbox talks or safety briefings with your workers to ensure your expectations are understood.

Complacency

We found complacency to be the root cause of a number of incidents including manual handling, moving plant or equipment and being struck by an object. Refer to the previous information on complacency for tips on how to combat this risk.