Documentation

This article provides an overview of the Documentation aspects of an OHS Management system. These include: Policies; Documented accountabilities, roles and responsibilities; Document control and review; Registers and records; and Safe work method statements and procedures.

Introduction
Documentation 
Documented accountabilities, roles and responsibilities 
Document control and review 
Registers and record 
Documented safe work method statements and procedures 

Introduction

 
A WHS management system commonly has 14 structural components. Allowing for academic debate, and the overlap of some components, these can broadly be categorised into documentation, risk management, and management processes, as follows:

Documentation:

  • Policies
  • Documented accountabilities, roles and responsibilities
  • Document control and review
  • Registers and records
  • Safe work method statements and procedures.

Risk management:

  • Hazard, near miss, incident and accident reporting, recording, investigation and analysis
  • Risk management
  • Training and induction programs
  • Purchasing control
  • Specific work health and safety programs.

Management processes:

  • Communication and consultation strategies
  • Supervision which ensures workers are not placed at risk
  • Monitoring, measurement and evaluation of WHS management system implementation
  • Management review including internal auditing and external auditing.
An overview of the documentation aspects of a WHS management system is provided below.
 

Documentation – policies 

 
WHS policies set out the commitment of the organisation and management to the implementation of work health and safety.
 
Management must identify what the organisation wants to achieve in work health and safety and document this as a policy statement. This should be done in consultation with workers.
 
A WHS policy demonstrates a company’s commitment to workplace safety and should be posted on a notice board in the workplace.
 
Examples of objectives in the WHS policy statement could include the elimination of all workplace injuries and a commitment to protect the human resources of the business. The policy statement could also include a recognition of the importance of the legislative requirement to protect the health and safety of people in the workplace.
 
Resources and activities for WHS improvement should be briefly summarised in the WHS policy, giving weight to management’s commitment. Examples of this include:
  • training programs 
  • time and staff for meetings to discuss WHS issues 
  • noticeboards for communication using notices, posters etc 
  • investigation of all hazards, incidents and injuries 
  • WHS consultation systems 
  • detailed analysis of legislative requirements and implementation, and
  • internal and external review of WHS management.

Information about the responsibilities of various groups within the workplace, such as management, supervisors and workers should also be noted.
 
A WHS policy statement should be signed by a senior manager, dated and reviewed approximately every two or three years. Some businesses like to have their health and safety committee chairperson sign the WHS policy as a demonstration of support for the consultation process.
 
In addition to a WHS policy, a WHS consultation statement is also advisable, outlining how consultation on WHS matters will be performed.
 
Larger organisations may also choose to prepare policy statements addressing specific issues such as manual handling, working with chemicals, workplace violence, smoke-free working environments, to name a few. These would be supported by procedures and other documentation.

Documented accountabilities, roles and responsibilities

 
In order to manage workplace health and safety, people need to be aware of their role. For example the role of a supervisor includes supervising staff on a daily basis to ensure they can work safely and are not placed at risk.
 
People need to be aware of their responsibilities for various tasks and processes. These responsibilities need to be documented so that people are clear about what is expected of them, in the same way that performance management uses documented position descriptions. 
 
Management must identify the responsibilities, document and communicate these. Keep in mind that this should be practical and realistic, for example, workers are responsible for reporting all injuries and identifying hazards to their supervisor.
 
Where accountabilities are documented, these can be used to measure and monitor performance. Management accountabilities may include ensuring WHS risk assessments are conducted where required, in consultation with workers.
 
Some organisations also use key performance indicators for WHS to measure the proactive implementation of various responsibilities. For example a supervisor identifying, assessing and controlling (and documenting) 10 WHS risks per month.

Document control and review

 
Documentation such as policies, procedures, risk assessment forms, safe work method statements, inspection checklists, training matrices, etc. should have some control, and businesses that have implemented a quality assurance system would be familiar with this.
 
This will include a document number, document title, date of release, authorising officer, and a date for review.
 
A register of documents that have been prepared and released for use should be kept, along with a list of recipients. This will help with circulation and distribution when documents are updated. Internal intranet systems have become a popular way of providing access to WHS documents within an organisation.
 
Documents that have been prepared should be reviewed periodically, for example every two or three years would be reasonable, as changes occur in organisations and documentation can become outdated.

Registers and records

 
A WHS management system will contain various registers and records, and this will depend on the type of work being conducted. The following registers and records should be considered. This list is not exhaustive but is a good starting point for records which may be needed.
 
Some of these are mandated under legislation.
 
Records of:
  • risk assessments (including general risk assessments as well as risk assessments specific to particular activities or processes) 
  • hazards that have been reported 
  • WHS consultation meetings with workers 
  • training conducted internally and externally, including attendance registers
  • investigations of near misses, incidents, and accidents 
  • people trained in first aid 
  • maintenance schedules and maintenance conducted 
  • WHS inspections conducted 
  • personal protective equipment issued 
  • emergency evacuation drills conducted 
  • health monitoring conducted, and the results of these 
  • workplace environmental monitoring 
  • confined space entry (including entry permits and risk assessments) 
  • hot work permits for hot work conducted 
  • WHS documentation prepared 
  • purchasing where WHS implications have been considered
  • subcontractors WHS management systems 
  • WHS system review (internal review and external review) 
  • registers: 
    • register of injury book 
    • hazardous chemicals held on site, which include safety data sheets (including registers of hazardous chemicals held by contractors or others on site) 
    • plant and equipment, including electrical equipment
    • dangerous goods held on site
    • people holding high risk work licences, certificates of competency and other skills.

Documented safe work method statements and procedures

 
Safe work method statements should be prepared for some types of tasks in the workplace. These are often prepared following a risk assessment that has identified a task containing some degree of inherent risk. Safe work method statements can then be used for training and to ensure tasks are performed consistently.
 
Safe work method statements contain a step-by-step description of a task, the hazards associated with each step and the control measures used to manage the risk of each hazard. An example of a safe work method statement would be how to safely operate an item of plant or equipment, or how to conduct the maintenance on an item of plant or equipment.
 
Procedures can be prepared for a variety of purposes, such as communicating a process to be followed when performing an activity. Examples of written procedures include:
  • The steps to take following an injury to a person in the workplace
  • How to investigate an accident
  • How to conduct risk assessments
  • WHS considerations prior to purchasing.
In summary, a work health and safety management system should be documented as there are many elements that need to be planned, implemented and reviewed. Whether the system is documented electronically or using hard copy materials, there will need to be common components as outlined above. This article has attempted to briefly explain these documentation requirements. Many of the state and territory WHS authority websites contain document proformas which are useful in this documentation process and are recommended.
[Last updated 12 February 2016]

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