Contractor OHS Management

Policy

This policy outlines the occupational health and safety (OHS) requirements in schools associated with the management and monitoring of contractors engaged by the school or via central areas of the department and the works or services they undertake.

Summary

• Schools, so far as is reasonably practicable, are to provide and maintain a working environment that is safe and without risks to health, including when work is undertaken by contractors.
• Schools are strongly encouraged to engage contractors to undertake high-risk work within the school.
• The principal or their delegate must manage OHS risks associated with engaging contractors and ensure that contractors are provided with a relevant OHS induction.
• Except in the case of certain capital works projects managed by the Victorian School building Authority (VSBA), the principal or their delegate are responsible for ensuring that all contractors meet the requirements mentioned in this policy and that any OHS risks associated with the contractors’ activities are eliminated or reduced.
• All paperwork required by this policy must be completed by contractors prior to them commencing work on site.
• For all contactor engagements, principals or their delegates must also follow the Working with Children Checks and other Suitability Checks for School Volunteers and Visitors policy which includes information on all suitability checks including Working with Children Checks (WWCC), and any child safety related induction and training as outlined in the school’s Visitor’s policy, Child safety and wellbeing policy, and Child safety responding and reporting obligations policy.
• Records must be maintained and stored on the Asset Information Management System (AIMS), local computer networks or in hard copy in accordance with the Records Management policy.
• Central and regional offices provide a range of supports and services to assist principals and employees to be safe and well, including access to the OHS Advisory Service and the Statewide OHS Services Team who can provide free advice on managing risks related to contractors.

Details

A contractor is a service provider or individual who is not a direct employee of the department. Contractors provide services or works in relation to maintenance, construction and repair, or niche educational services such as cooking demonstrations, sports coaching and other activities.

Any contractor that is engaged by the school must be inducted and managed as per the process outlined in the procedure tab of this policy. Where contractors are engaged through the Victorian School Building Authority, refer to Chapter 1: Engaging Contractors and AIMS for more information.

Public Private Partnership (PPP) schools usually engage contractors through the facilities management contract of the private enterprise. If PPP schools wish to engage a contractor outside of the facilities management contract, this policy and procedure must be applied. PPP schools can contact the central PPP team for further advice (refer to the Resources tab).

Casual relief teachers (CRTs) are not included in this policy as their duties align with those who are directly employed in the teaching service. For information on CRT inductions and management, refer to the OHS Induction and Training Policy.

Roles and responsibilities for managing contractors on school sites

Under the Occupational Health and Safety Act 2004 (Vic), managing the risks related to contractors is a shared responsibility between the department, the principal or their delegate, the contractor and school staff.

Department roles and responsibilities

The department must maintain, so far as is reasonably practicable, a safe and healthy working environment for contractors that prevents and reduces the risk of injuries while working on school site.

The department, in consultation with the relevant school, is responsible for the engagement and management of VSBA-led projects including but not limited to:

• the induction and management of contractors
• maintaining oversight of contractor work.

Principal or delegate roles and responsibilities

The principal or their delegate, in consultation with school staff who are or are likely to be affected, and the health and safety representative (HSR), where elected, must manage the OHS risk associated with engaging contractors by:

• ensuring that contractors are provided with a relevant site specific OHS induction and information
• ensuring that all contractors meet the requirements mentioned in this policy and that any OHS risk associated with the contractors’ activities are eliminated, where possible, or reduced
• maintaining oversight of work or services being carried out ensuring it is performed safely and to the expected standard.

Contractor roles and responsibilities

Contractors must take reasonable care for their health and safety and the safety of others who may be affected by their actions or omissions while at work, which includes when working on school sites.

Contractors must:

• sign into and out of the site (school reception or dedicated work area)
• comply with the school’s local visitor’s policy and if required by that policy comply with wearing the visitors pass or alternative identification as required
• complete required documents prior to beginning works or services (that is, induction documents)
• for high-risk work, complete and provide to the principal/delegate/worksite manager any required Safe Work Method Statements (SWMS) and Confined Space Entry Permits – principals/delegates/worksite managers must sign these as sighted
• consult with the principal/delegate/worksite managers on the works or services being undertaken and report on progress as necessary
• raise any safety concerns, hazards, incidents or near misses immediately to the principal/delegate/worksite manager
• follow the reasonable direction of the principal/delegate/worksite manager and any other related local school policy or department policy (for example, but not limited to, Working with Children Checks and other Suitability Checks for School Volunteers and Visitors, Outdoor Activities and Working Outdoors, Prevention of Falls When Working At Heights).

Key requirements to manage contractors

Schools must:

• ensure contractors engaged by the school are selected by verifying relevant details (as per the Contractor OHS Management procedure in this policy) prior to the commencement of works or services
• inform all school-engaged contractors that prior to the commencement of any works or services, they are to report to the general office upon arrival at the school and sign in and sign out as per the school’s local Visitors policy (staff login required)
• record details of approved contractors engaged to complete any asset, buildings or grounds maintenance or construction work in AIMS, the Contractor Register or an equivalent template
• record all other approved contractors in the Contractor Register or an equivalent template
• call an immediate halt to any work or services that is being performed unsafely or not in line with any provided Safe Work Method Statements (SWMS)
• ensure all reported incidents involving contractors are logged on eduSafe Plus (staff login required) and investigated as per the Managing and Reporting School Incidents (Including Emergencies) policy.

Prior to the works or services beginning, the principal or delegate must review, sign off on, and keep record of:

• workers’ compensation and public liability insurance – refer to Insurance for Schools for more details
• relevant suitability checks in accordance with the department’s policy on Working with Children Checks and other Suitability Checks for School Volunteers and Visitors and local school policy requirements for those contractors who are to work with children
• any Safe Work Method Statements (SWMS), where required
• any Confined Space Entry Permits for any work or services in confined spaces.

The Contractor OHS Management Procedure (in the procedure tab) provides further detail for each of the above requirements.

Department supports for schools

Central and regional offices provide a range of supports and services to assist principals and employees to be safe and well. This includes access to the OHS Advisory Service and the statewide OHS services team, who provide free advice and onsite or remote support in relation to contractor OHS management in schools.

Definitions

Asset Information Management System (AIMS)
A web-based, centralised portal that has replaced schools’ existing asset information management systems. Approved tradespeople engaged to complete any asset, buildings or grounds maintenance or construction work can be recorded, viewed and managed in AIMS. Items such as Working with Children Checks, licence details and company certificates and documents such as Public Liability can be added to contractor profiles, and schools are automatically notified of upcoming documents expiry dates.

Contractors
Contractors include any service providers or individuals who are not direct employees of the department who are providing services or works in relation to maintenance and repair work and other contracted services engaged by schools such as cooking demonstrations, sports coaching and other activities including workshops and excursions.

eduSafe Plus
eduSafe Plus is the department’s online hazard and incident reporting and management application, accessible on the intranet. Staff log on to eduSafe Plus using their employee number and password. Note: Contractors do not have access to eduSafe Plus, however, can report issues to the principal or their delegate for entry into eduSafe Plus. eduSafe Plus also has an induction management function, where completed contractor inductions can be uploaded or digitally completed and stored.

High-risk work
Otherwise known as ‘high-risk construction work’, the following is mandated as high-risk work by the department. For assistance on any unlisted tasks, please contact the OHS Advisory Service. Please note that this does not include work that could be considered ‘high-risk’ from a Child Safe Standards perspective:

• where there is a risk of a person falling more than 2 metres
• on or next to roadways or railways used by road or rail traffic
• in, over or next to water or liquids where there is a risk of drowning
• at workplaces where there is any movement of powered mobile plant
• where there are structural alterations that require temporary support to prevent collapse
• in an area where there are artificial extremes of temperature
• on or near energised electrical installations or services
• involving a trench or shaft more than 1.5 metres deep
• on or near pressurised gas distribution mains or piping
• involving demolition
• involving a confined space
• on or near chemical, fuel or refrigerant lines
• involving tilt-up or precast concrete
• on telecommunications towers
• involving diving
• involving removal or disturbance of asbestos
• in an area that may have a contaminated or flammable atmosphere
• involving the use of explosives
• involving a tunnel.

Safe Work Method Statement (SWMS)
A document that describes the high-risk work being performed, the health and safety risks associated with the work and the risk control measures that will be applied to ensure the work is carried out in a safe manner. a document that describes the high-risk work being performed, the health and safety risks associated with the work and the risk control measures that will be applied to ensure the work is carried out in a safe manner.

Related policies

• Asbestos Management
• Asset Information Management System (AIMS)
• Asset Management Roles and Responsibilities Framework
• Buildings and Grounds Maintenance and Compliance
• Capital Building Projects in Schools
• Confined Spaces
• Contractors – Insurance and Contract Arrangements
• Managing and Reporting School Incidents (Including Emergencies)
• Occupational Health, Safety and Wellbeing Management in Schools
• OHS Consultation and Communication
• OHS Risk Planning and Management
• Prevention of Falls when Working at Heights
• Working with Children Checks and other Suitability Checks for School Volunteers and Visitors

Relevant legislation

• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)

Contractor OHS Management procedure

This Contractor OHS Management procedure sets out the practical step-by-step instructions that principals and delegates must follow to implement the Contractor OHS Management policy. This procedure must be implemented in consultation with the health and safety representative/s (HSR), school staff and the health and safety committee or OHS working group (if established).

The procedure contains the following chapters:

1. Engaging contractors and AIMS
2. Contractor OHS induction
3. Required task documentation
4. Communication and supervision of contractors
5. Hazard, incident and near miss reporting
6. Record keeping

1. Engaging contractors and AIMS

Engaging contractors

Schools are strongly encouraged to use contractors for any high-risk work instead of volunteers or school staff. Schools will be required to request a quote for services, where relevant as per the Procurement – Schools policy.

Schools should use the department’s standard form contracts in the Contractors – Insurance and Contract Arrangements policy for engaging contractors for any of the following works and services:

• gardening, maintenance or painting services
• cleaning services
• school canteen licence
• hiring school premises by third parties
• personnel, financial and administration services and student and curriculum services
• school uniforms
• pre-school licence.

As part of the engagement process, it is best practice for schools to provide school site specific OHS information to potential contractors, including sub-contractors, to ensure awareness of department and school requirements prior to commencing work or services. This includes the requirement to sign in and out of the site via reception.

The department has provided an OHS induction handbook template (DOCX) for schools to tailor to their environment to assist with easily providing the required information to contractors. This template also includes a letter/email template for use when sending this handbook to a contractor.

Contractors engaged by the school/school council

The Asset Information Management System (AIMS) is a web-based, centralised portal that has replaced schools’ existing asset information management systems to manage all school-led trades-based contractor works.

Prior to the commencement of works or services, all pre-checks and documentation must be verified by the principal or delegate. This includes:

• workers’ compensation and public liability insurance. For further information, refer to Insurance for Schools and Contractors – Insurance and Contract Arrangements
• relevant suitability checks in accordance with the department’s policy on Working with Children Checks and Other Suitability Checks for School Volunteers and Visitors and any other local school policy requirements if contractors are being engaged to work with children
• Safe Work Method Statements (SWMS) for any high-risk work (refer to Chapter 3 – Safe Work Method Statements).

The principal or their delegate must record approved trades-based contractors in AIMS, the OHS contractor register (XLSX) or equivalent template. The AIMS knowledge centre (staff login required) is a central repository of practical information to help schools use AIMS. It also includes information about managing contractor certificate compliance in AIMS.

For further information on AIMS, refer to the Asset Information Management System (AIMS) advice page on PAL.

Contractors engaged by the department (Victorian School Building Authority)

Where contractors have been engaged by the Victorian School Building Authority (VSBA) (that is, for VSBA-led projects), schools can expect the VSBA to contact them to inform them of:

• who the contractor(s) are
• what works they will be undertaking
• when and for roughly how long they will be on the school site
• who is responsible for their OHS induction and managing the site (that is, the school or the VSBA).

Additionally, the VSBA should consult the school on:

• whether the work area needs to be cordoned off to the rest of the school with temporary fencing
• traffic management for the contractors
• any risks to the site (such as heavy equipment brought on site, work processes that may impact other areas such as fumes or noise).

The principal or their delegate must give any contractors an OHS induction as described in Chapter 2: Contractor OHS induction, and are responsible for reviewing required task documentation (for example, SMWS) as per Chapter 3: Required task documentation. However, if the VSBA cordons off the area and creates a separate worksite (such as for capital works projects), the VSBA site project manager is responsible for the review and approval of task documentation, including SWMS), not the principal or their delegate.

Should the VSBA not contact the school regarding an engaged contractor, the principal or their delegate can contact the VSBA to confirm what arrangements are in place. Queries should be directed to the relevant VSBA project contact if one has been assigned, or via email at schoolasset.leadership@education.vic.gov.au

All approvals, recording information such as public liability, workers compensation or trade licences for VSBA engaged contractors is managed by the central team.

Contractors engaged in Public Private Partnership schools

In Public Private Partnership (PPP) schools, contractors engaged in project delivery or facility management activities as part of the PPP agreement are managed by the facilities management company. PPP schools are not required to manage PPP contractors but may request contractor documentation from the facilities management company as required.

If PPP schools wish to engage a contractor for approved facility works or other educational purposes outside of the facilities management contract, this policy and procedure must be applied.

For support on PPP related matters contact the central PPP team (refer to the Resources tab for contact details).

2. Contractor OHS induction

Prior to arrival at the school, the Contractor OHS induction handbook (DOCX) can be used to ensure the contractor is being provided all required information on school-specific and department OHS requirements they need to be aware of prior to commencing work or services, as part of the OHS induction process. This includes, but is not limited to the requirement to sign in and out of the site via reception, and the need to follow the schools local Visitor policy (staff login required) including keeping on their person any visitor identification issued to them. A letter/email template is available within the template handbook for schools to use to communicate with the contractor.

The principal or their delegate must provide an onsite induction for all contractors prior to the commencement of works or services using the Contractor OHS induction checklist (DOCX) or equivalent template. The only exception to this is for contractors engaged by the VSBA where a separate worksite has been established (refer to Chapter 1: Engaging contractors and AIMS).

If an equivalent template is used, it must collect or include the following details as a minimum:

• workers’ compensation and public liability insurance
• Working with Children Checks (if applicable)
• a specific Safe Work Method Statement (DOCX) if high-risk work is being undertaken, as frequently (follow the SWMS requirements in the relevant policy)
• completed confined space entry permit(s), if required (follow the requirements in the relevant policy)
• links to the department’s Health, Safety and Wellbeing Policy
• OHS procedures and requirements
• emergency procedures
• asbestos management processes
• hazardous substance or dangerous goods management processes
• hazard and incident reporting
• first aid and infection control procedures
• security and access.

These inductions are valid for 12 months, but it is best practice to re-induct or provide relevant updated information if there are any significant changes to the school’s environment or OHS processes, or if contractors don’t often service the school. Schools may choose to consider inducting their contractors mid-year as contractor licences tend to expire around this time.

Records of completed contractor inductions must be kept per the School Records Retention Guide. Trades-based contractor inductions can be stored in AIMS. Where a contractor is engaged for purposes other than school asset repairs and facilities maintenance, eduSafe Plus (staff login required) can store OHS inductions electronically (refer to Chapter 6: record keeping for more information).

3. Required task documentation

The contractor must submit a Safe Work Method Statement (SWMS) to the principal or their delegate prior to the commencement of works, for the following high-risk work:

• where there is a risk of a person falling more than 2 metres
• on or next to roadways or railways used by road or rail traffic
• in, over or next to water or liquids where there is a risk of drowning
• at workplaces where there is any movement of powered mobile plant
• where there are structural alterations that require temporary support to prevent collapse
• in an area where there are artificial extremes of temperature
• on or near energised electrical installations or services
• involving a trench or shaft more than 1.5 m deep
• on or near pressurised gas distribution mains or piping
• involving demolition
• involving a confined space
• on or near chemical, fuel or refrigerant lines
• involving tilt-up or precast concrete
• on telecommunications towers
• involving diving
• involving removal or disturbance of asbestos
• in an area that may have a contaminated or flammable atmosphere
• involving the use of explosives
• involving a tunnel.

A new SWMS is required for each high-risk task as scope of works change. For detailed SMWS requirements related to specific high-risk work, follow the relevant policies.

The SWMS must be reviewed and signed (as sighted) by the principal or their delegate before any work commences, and a copy kept for records (refer to Chapter 6: Record keeping). This includes where contractors are engaged directly through the school, smaller capital works projects and through PPP school facility management companies.

If contractors are engaged through the VSBA where a separate site has been established (refer to Chapter 1: Engaging Contractors and AIMS), then principals or their delegates are not required to review and sign the SWMS.

Principals and delegates are not expected to be experts in reviewing and understanding a SWMS but they are expected to understand the risks that are reasonably foreseeable during the work being undertaken. The Contractor hazard identification and control guide (DOCX) available on the Resources tab, can be used to aid in assessing the quality of a SWMS submitted prior to work commencing.

When the work is not categorised as high-risk, and the relevant policy does not specifically require a SWMS, a Job Safety Analysis (JSA) or equivalent may be used if it contains the same information. The OHS Advisory Service and the statewide OHS services team can support with the review of Safe Work Method Statements and equivalent templates.

4. Communication and supervision of contractors

The principal or their delegate should ensure clear communication with contractors to manage OHS issues associated with works and services on school grounds.

Typical considerations contractors and schools may need to discuss before work commences, depending on the work or services the contractor is providing, can include but is not limited to:

• the effect of work and services on school activities (for example, use of heavy machinery, noise, dust or fumes)
• safety arrangements the contractor will have in place
• access arrangements while on site
• vehicle and equipment movement on school grounds (traffic management)
• timing of activities (for example, can work or services be done when students have left?)
• what areas will be affected (for example, barricading of work areas, safe access around the site)
• maintaining essential services (for example, water, sewerage, electricity, telephone)
• protocols for communication between the school and contractor (for example, regular meetings, toolbox talks)
• removal of excess materials and waste by the contractor at the end of the project (for example, unused mulch, building supplies)
• handover process at the completion of the work or services.

With contractors engaged through the school/school council, it’s important that the principal or their delegate retain a general supervisory power over work or services undertaken by the contractor, that is, that they are aware of who is onsite and the work or services being undertaken.

Contractors working unsafely

The principal, their delegate or any other school staff have the power to stop/halt work where they believe work is unsafe, relevant SWMS are not being followed or there are potential safety risks with how the contractor is working. It is their duty to raise this with the contractor or their management, the department (if VSBA engaged) or the facility management company (if PPP).

All incidents involving contractors, including unsafe work, are reported on eduSafe Plus and investigated as per the Managing and Reporting School Incidents (Including Emergencies).

The SWMS may need to be revised before works may recommence. If required, the principal or delegate can follow up with the contracting company to address issues formally, or the Victorian School Building Authority (VSBA) for centrally run projects.

5. Hazard, incident and near miss reporting

The principal or their delegate must ensure all incidents involving contractors are reported on eduSafe Plus (staff login required) and investigated as per the Managing and Reporting School Incidents (Including Emergencies) policy.

It is the responsibility of the principal or delegate to lodge an eduSafe Plus report on behalf of contractors when required. To aid this process the contractors may fill out one of the relevant forms in the Resources tab or discuss the incident with the principal or delegate who can then log it via eduSafe Plus.

Schools must have a current Emergency Management Plan (EMP) that addresses site specific hazards and threats which have the potential to result in emergencies and critical incidents. For more information on school planning required to effectively respond to emergencies and incidents, please see policy: Emergency and Critical Incident Management Planning.

PPP schools report their incidents for school staff on eduSafe Plus, however for contractors they can raise it with the facility management company. For any questions, please contact the PPP team (refer to the Resources tab).

6. Record keeping

The principal or their delegate must ensure the following records are maintained in relation to contractor OHS management:

• copy of the contractor(s):
  • workers’ compensation and public liability insurance
  • Working with Children Check (if applicable)
  • Safe Work Method Statements (SWMS) completed template if high-risk work was undertaken
  • Job Safety Analysis (JSA) or equivalent templates
• completed confined space entry permit(s) if contractor has undertaken confined work
• completed contractor OHS induction checklist(s)
• record of approved contractors in the school, either on AIMS or using the available contractor register template or equivalent
• minutes of meetings/communications (where applicable)
• copies of all sign in and sign out sheets/registers for contractors that have come on school site.

Where a contractor is engaged for school asset and facilities maintenance by the school, records must also be maintained and stored on AIMS or available contractor register template or equivalent. The AIMS system provides a platform for the following records to be maintained:

• individual Working with Children Checks
• individual licences
• certificates at a company level such as labour hire license, public liability, company registration, Victorian WorkCover policy and so on.

Where a contractor is engaged for purposes other than school asset and facilities maintenance, eduSafe Plus can complete, store and maintain OHS inductions electronically in this digital platform. Guidance for creating or uploading OHS inductions can be found in the Managing OHS inductions how to guide in eduSafe Plus.

Please refer to the Records Management policy and included School Records Retention Guide for more details.

Legislation, compliance codes, standards and guidance

• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)
• Worker Screening Act 2020 (Vic)
• Worker Screening Regulations 2021 (Vic)

Resources

Guidance

• Contractor hazard identification and control guide (DOCX) – can be used to aid in assessing the quality of a SWMS submitted as part of a contractor approval process

Templates and forms

• Contractor OHS induction checklist (DOCX) – used to assist in conducting an OHS induction. Induction checklists can be digitally created or uploaded and maintained in eduSafe Plus (staff login required) (guidance available at Managing OHS inductions)
• Contractor OHS induction handbook (DOCX) – the department has provided a template for schools to tailor and provide to OHS contractors coming on site as part of their induction. This handbook provides school specific information and department OHS requirements to contractors. Schools are welcome to tailor these handbooks for tradespeople and non-tradespeople should they wish to
• Contractor register (XLSX) – provides a way to record and manage the induction details of the contractor companies, their employees including any sub-contractors who are providing services or undertaking works at the workplace, that may not be managed in AIMS
• Confined space entry permit (DOCX) – for contractors engaged to work in confined spaces
• Safe Work Method Statement (DOCX) – for completion where high risk work is being undertaken

Contacts

• OHS Advisory Service and the Statewide OHS Services Team

Public Private Partnership (PPP) schools:

• Partnerships Victoria in Schools (PViS) – Adam Richardson adam.richardson@education.vic.gov.au
• New Schools PPP (NSPPP) – Public.private.partnerships@education.vic.gov.au

Victorian School Building Authority:

• Email: vsba@education.vic.gov.au
• Phone: 1800 896 950
• You can contact the Victorian School Building Authority on weekdays from 9 am to 5 pm.