The place of Good Practice in safety.
As a safety professional, I am often asked to carryout reviews of procedures, SSSP’s and SWMS in preparation for work activities, and sometimes by clients wanting opinions of their contractors proposed activities.
After 22 years I am still left wondering why some contractors in our industry struggle with getting it right. I am still getting responses like” this is just the way we do things here” or “doing all this paper work is so over the top, we just follow a common sense approach”.
As an accredited safety professional and auditor, I base my findings on the practices viewed, against the “Good Practice” for the topic and the quality of preparedness by the PCBU for work activities.
A “good practice” is not only a practice that is good, but a practice that has been proven to work well and produce good results, and is therefore recommended as a model. It is a successful experience, which has been tested and validated, in the broad sense, which has been repeated and deserves to be shared so that it becomes “the recipe” on how to undertake the tasks involved.
It also serves business well in the training of staff about how to safety undertake a task or activity in a way which reduces the exposures of risks, so far as is reasonably practicable, to its lowest acceptable level, whilst still allowing the activity to be undertaken.
Good practice guidelines give advice – they are not legally binding. However by following these documents, a PCBU can demonstrate that they have taken reasonably practicable steps to ensure the safety or workers.
However, if a duty holder deviates from good practice they should have well thought out reasons for this and be able to provide appropriate alternative evidence equal to or exceeding the good practice document.
Good practice guidelines may sometimes be cited by WorkSafe as an expected standard of practice if poor practice is being alleged. They have formerly also been called best practice guidelines.
All of our construction based activities carry risk, and the PCBU has the obligation to manage these risks to the lowest possible acceptable level. Using the good practice document as a guidance, allows Safe Work Method statements (SWMS) to be prepared for site work, and serves also as an induction tool for new starts as well as a pre site meeting tool to ensure everyone understands how things will be done.
Worksafe New Zealand, have created a library of these documents, saving the need for a PCBU to prepare one from the beginning. It however does not mean that because there is not one already created, that the PCBU can opt out. In this case the PCBU must create a SOP/SWMS as a means of controlling practices.
Creating a “Good Practice” document requires input from Worksafe , Industry, specialists, and practitioners to formulate a series of guidance practices, which is then put out to industry as a draft for comments. Once the document has been reviewed it is issued and put into the Worksafe Library on their website.
Some Good practice documents relate to general practices and some are industry specific.
Lets look at roofing for example( as an extract from the current published document).
The Good Practice Guidelines for Working on Roofs is not industry-specific and gives general advice for working on roofs. If those working on roofs are from a specific industry (for example, electrical industry), the safety guidance from that industry should also be consulted.
These guidelines are not intended to provide all information relating to safe working on roofs. Detailed information on safety equipment used for working at height is covered in the Good Practice Guidelines for Working at Height in New Zealand and other WorkSafe NZ guidance on working at height.
For example: (an extract from the Good practice guideline on use of safety nets) outlines safety net requirements and the safe use of safety nets.
A fall from a height is likely to result in a serious injury. By installing safety nets below a high-level work area, there is less likelihood that the person will be injured if they fall.
Regardless of the time spent on a roof, the risk of falling is high. Any fall is likely to result in a serious injury. Safety nets installed below a high-level work area reduce the distance that a worker can fall. They absorb the impact of the fall and provide a ‘soft landing’ to reduce the likelihood of a person being injured.
The documents create a level of understanding and comfort for a PCBU in ensuring the safety of workers on their site or work.
Some industries have guidelines that deal with specific problems faced in their working environments, such as the electricity sector or plant and machinery hire. When deciding how to do a job safely, make sure to check any industry-specific guidance.
It has been said that if a PCBU follows the good practice principles and is still found wanting by the Regulator, then is the PCBU at fault, or is the guidance document in need of a review.
The New Zealand Safety Council, advocates PCBU’s to ensure that all their practices are in line with good practice documents, and on behalf of Industry has regularly made submissions to Worksafe on upgrades to practices or changes in technology or for new practices.
To bring a sense of consistency to our industry, all the players must communicate, collaborate and communicate with each other and do the right thing, because it is the right thing to do.
It has been sometimes said that “safety is something we can copyright”.
Instead we should view safety as something we should embrace and openly share with each other, as a good or better way of doing something. You never know, the life it saves could be your own.
Kevin is a Registered Safety professional with 22 years construction based experience.
He is the Current Chief Executive Officer of the New Zealand Safety Council, and a member of the Governance Board of the Health and Safety Association of New Zealand HASANZ ).