The article below is a guideline of how anyone can implement effective safety procedures and health and safety within the workplace.
The Occupational Health and Safety Act’s primary objectives and intention and what employers need to implement and try to achieve
Occupational Health and Safety Act – No 85 of 1993:
‘To provide for the health and safety of persons at work and for the health and safety in connection with the use of plant and machinery; the protection of persons other than those at work against hazards to health and safety arising out of or in connection with the activities of persons at work; to establish an advisory council for occupational health and safety; to provide for matters connected therewith’
There are 50 sections in the Occupational Health and Safety (OHS) Act, each with its own rules and regulations and 23 different regulations with some being applicable to all companies (General Administration Regulation) and some being applicable to certain industries (Construction Regulation).
These different sections and regulations dictate how and what the employer, employees and the whole company needs to adhere to and implement to ensure compliance and create sound health and safety practices in the workplace and building solid safety procedures.
Health and safety practice is the actual performance of OHS related tasks and activities by all employees. Safety procedures are the actual documents and protocols, organogram and appointment letters of the OHS teams and OHS Committee.
OHS 16.2 Appointee / OHS Manager / OHS Supervisor
In terms of Section 16(1) of the Act, the Chief Executive Officer (CEO) is charged with certain specific accountability in relation to the implementation of the OHS Act on behalf of the employer / company. Clearly, a CEO will not have either the time or thorough knowledge to implement the requirements on his own and so delegation has been allowed for. The persons in the workplace to whom certain specific tasks have been assigned, are referred to as Section 16(2) delegatees, or OHS Manager or OHS Supervisor. This appointee is responsible for assisting in driving OHS compliance and implementing acceptable and good health and safety practise in the workplace by all employees within the company.
What needs to be clearly understood in this regard is the contention that a CEO may not delegate his responsibility and accountability that is placed upon him in terms of Section 16(1). Delegation and appointment in terms of Section 16(2) can only be a delegation of duties and the CEO retains the burden of ensuring that compliance with the OHS Act is maintained.
Such insurance can be achieved by building into any and all safety policies and safety procedures and a system of reporting back, coupled with regular scheduled meetings. In this way the CEO not only stays abreast of what is happening in the workplace in terms of health and safety, but ensures that he has regular input into compliance. Failure to do so could well have dire consequences in the event of an accident or incident, especially where lives are involved.
Section 16(2) delegates may not make further delegations in terms of this section. Their terms of reference in their appointment form may well require that they make certain other appointments such as safety representatives, stacking supervisors and the like to assist them in implementing health and safety practice within the workplace.
The appointment of Health and Safety Representatives (sometimes known as OHS Reps or H&S Reps or SHE Reps) is made in terms of Section 17 of the Act and allows the organization to build and expand on the safety procedures. Their functions are detailed in terms of Section 18. Appointments would ordinarily be made by the CEO. However, where a Section 16(2) appointment has been made, this could well form a specified function therein, and the safety representative appointments are then completed by that delegatee. Appointment criteria may be summarised as follows: –
- appointments are compulsory where there are more than twenty employees in the workplace;
- appointments should not be made arbitrarily by management but should be negotiated in good faith with the relevant stakeholders;
- shops and offices require one Safety Representative per 100 employees. In other areas the ratio must be 1:50;
- the appointees should be full time employees, conversant with their workplaces
- their appointments must be for a stipulated time frame and for a specified area
- their activities, including training and inspections, must take place during normal working hours
The OHS Manager, OHS Supervisors together with the OHS Representatives, form the OHS Committee which is the continual driving force of successful OHS and effective health and safety practise within the workplace.
Developing the right health and safety practices and programme within your organisation
A solid and clear health and safety practice and program is one of the requirements on which the successful implementation of any business requirement rests and on which the foundations are aligned, to enable that system to be implemented, monitored and controlled. The need for a good, solid, health and safety procedures and looking after the health, safety and preparedness of a working environment and its employees.
The principles of good health and safety practise and effective safety procedures does not change from one company requirement or department to another. However, it is possible to re-phrase these principles in such a way so as to either personalize them, or to make the headings more applicable to your particular business or industry. The following is suggested as being the basis of a good health and safety structure:-
Commitment by management has a fundamental obligation to health and safety in terms of Section 8(1) of the OHS Act. This obligation should preferably be converted into a solid commitment, characterized by action as well as word, backed by an OHS Policy that clearly displayed commitment to sound health and safety practices within the workplace.
Planning to ensure that the safety procedures are workable and that they can expand and grow with future needs as they arise. This would include setting standards for policies and delegating accountability.
Implementation of that which has been planned, agreed upon to ensure compliance and making the health and safety procedures and system function.
Measurement and evaluation of procedures, standards and requirements to ensure compliance to the agreed standards set and effective functioning of the entire safety structure.
Review the safety procedures and policies set to ensure only compliance, but to also ensure a philosophy of continued improvement of the health and safety practice within the workplace. Keep abreast of new trends, additional legislation, changing methodology and Company profiles.
If health and safety system is being designed from scratch, then it is imperative to convene an OHS Interim Steering Committee. The task of this committee would be, on behalf of the CEO, to take the company through the Planning Stage and to ensure that a sound basis has been developed to allow for the Implementation Stage to continue and gain momentum thereafter.This committee can however meet at any time to check and ensure compliance and progress.
Identifying workplace risks and hazards and appropriate safety procedures
Begin with a risk assessment of the workplace
By conducting a risk assessment or Hazardous Incident Risk Assessment (HIRA) the following possible positive impacts and results may occur within the organization :
- Increases awareness of workplace hazards
- Provides an opportunity to identify and control workplace hazards
- Can lead to increased productivity
- Likely to prevent an Occupational Injury or Illness
We can draw a circle round any piece of equipment, process, building, or organisation and apply the risk management process to identify hazards, assess risks, and select appropriate safety procedures and control measures.
Identify all possible hazards
Hazards surround us in every aspect of our lives. There are hazards in the air we breathe, the food we eat, and the places we live in, through to the most hazardous sport, occupation or location we can think of. Almost every aspect of life has a hazard attached to it. To survive we all carry out a constant process of hazard identification, risk assessment, risk control, and review. This process is collectively referred to as the risk management process. Every organisation should invest an appropriate amount of time and resources in relation to risk management in order to ensure its own health and safety within the workplace.
To illustrate the concept of risk management we could look at the simple process of crossing the road. The rule is ‘Look right, look left, look right again, and if the road is clear move quickly across’. This rule is extremely simple (although not always observed) and understood by even quite small children. Unless a study is made of the subject, what is not always understood is the process by which this simple rule was arrived at. In applying risk management to the task of crossing a road we first identify that a hazard exists in the form of vehicles which could strike and injure us. When assessing the risk, in terms of the speed, current location of approaching vehicles and our own location and mobility, we recognise that the consequences and likelihood of an accident occurring are too great to ignore. We therefore develop a procedure of looking, to ensure that we only cross the road at a time when the likelihood of an accident is removed.
If you do not know what the hazards are, you cannot manage them and implement safety procedures and health and safety within the workplace. You must identify as many hazards as possible to ensure the effectiveness of loss control in the organization.
Types of hazards you should identify when conducting risk assessments could include Safety Hazards, Health Hazards, Environmental Hazards, Behavioural Hazards and Fire Hazards. Two methods you can use to identify hazards include:
- Walk around Method – Conduct a physical inspection of the workplace by walking around in all departments and noting as many hazards that you can identify on the register.
- The inspection checklist – Commonly used by the OHS Representative to comply with their functions according to Section 18 (Functions of OHS Representatives) of the Occupational Health and Safety Act 85 of 1993. The Risk Assessor can use the information in this inspection checklist to identify possible hazards that can and will lead to injury, damage and/or loss.
What safety procedures and controls to put in place to address the hazards
The four T’s of risk control are popular and used often:
- Terminate – This is what should be done when the hazard pose to great a threat to the company or the business can use another process to reach their goals.
- Tolerate – This should only be done when the risk do not pose an adverse risk to the health and safety of employees or assets.
- Transfer – This is undertaken when you transfer your risk upon a third party, like a contractor.
- Treat – This is the most common thing to do when controlling workplace risks. You will set remedial measures in place to reduce the risk to such an extent that it does not pose a threat to the immediate health and safety of a person.
Follow up and review procedures
Review is an important aspect of any risk management process. It is essential to review what has been done to ensure that the safety procedures and controls put in place are effective in ensuring health and safety within the workplace. Methods of reviewing a risk assessment may include inspections, follow up risk assessments, interviews with staff, generated reports, extra training, internal and external audits.
Establishing long term health and safety practices, structures and supplier support structures
It is important to understand the reason for the existence of a Health and Safety or OHS Committee. Any such committee is formed with the specific intention of reviewing, assessing and discussing matters of health and safety practice within the workplace and the effectiveness of the safety procedures and to then make recommendations to the CEO (employer). As discussed previously, the three categories of membership are allowed for within the Act, and these are: –
OHS Representatives –
All safety representatives will automatically sit on a OHS committee. However, where there are two or more committees in a particular company (either due to size or locality) then each representative must sit on at least one of those committees, but not necessarily both.
Management representatives –
are those persons appointed by management such as OHS Manager and OHS Supervisors, but may not exceed the number of OHS representatives.
Specialist members –
Who are co-opted onto the committee by virtue of their specialist knowledge or expertise, such as Absolute Health Services. Such members do not have voting rights when it is required to take a vote on an issue e.g. the election of a Chairman.
An integrated systems approach to OHS is required. Through the integration of OHS committee, OHS teams in each office, risk management process, incident investigation, emergency response procedures and safety procedures, an organization will ensure that their OHS performance is managed efficiently, effectively and that the health and safety within the workplace is continuously improved upon.
OHS workplace risks need to be identified, evaluated, and controlled across the entire workplace as low as reasonably practicable. Incidents need to be reported by all employees, investigated correctly and corrective and preventative actions implemented. The emergency response plan must be practised by evacuation drills being conducted at each office where all employees and the OHS teams work together to improve on OHS.
The organization’s procurement and legal departments must ensure that all external parties and stakeholders who engage with the organization, sign a “Contractor and Supplier Agreement in terms of Occupational Health and Safety” (contractor agreement) to ensure the wellbeing of their and the organization’s employees, whilst supplying services. Through signing the contractor agreement, they are aware of the OHS culture, safety procedures and health and safety requirements, their OHS obligations, responsibility, accountability and liability.