OHS Risk Management

Policy

The purpose of this policy is to provide schools with a risk management approach for maintaining health and safety in the workplace.

Summary

• The Occupational Health and Safety (OHS) Act (2004) (Vic) requires the department to provide or maintain, systems of work that are, so far as is reasonably practicable, safe and without risk to health.
• The principal and/or their delegate must identify, assess, control, monitor and prioritise OHS risks.
• The principal and/or their delegate must manage OHS risks in consultation with Health and Safety Representatives (HSR) and employees.
• Under the OHS Act 2004, employees while at work must take reasonable care for their own health and safety and the safety of others who may be affected by their actions or omissions.
• 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 local regional officers who can provide free advice on risk management.
• The Risk Management Procedure in the Procedure tab must be followed, and sets out the practical step-by-step instructions for implementing this policy.
• This policy forms part of the department’s OHS Management System. For more information, refer to OHS Management System (OHSMS) Overview.

Details

The principal and/or their delegate, in consultation with employees and HSR, must ensure that:

• hazards that persons may be exposed to in the workplace are identified
• a risk assessment is conducted to determine the risk (likelihood and consequence of injury or harm to a person) resulting from such hazard
• consideration is given to the means by which the risk is addressed through actions, known as controls, to eliminate, or if elimination is not reasonably practicable, to reduce, the risk.

The principal and/or their delegate must understand the school’s particular OHS risk profile in order to implement appropriate procedures to control hazards and risks.

Developing a register for OHS risks

The principal and/or their delegate must complete an initial review of the generic OHS Risk Register in which they identify the applicable hazards for their school and delete any entries that are not applicable. Additional hazards may be added as needed.

The review must be undertaken in consultation with the relevant people, including:

• the delegate, if available
• employees who either undertake the task, activity or work in the area or who may be affected by the outcomes of the risk assessment
• Health and Safety Representative (HSR)
• Health and Safety Committee (HSC) member/s, if available.

After reviewing the ‘Hazard Types’ the principal and/or their delegate must also review and update, as applicable, the risk rating and controls with reference to the OHS Risk Management Procedure.

Continual review

The principal and/or their delegate must review the workplace OHS Risk Register:

• on an annual basis with the review to be scheduled in the OHS Activities Calendar
• when hazards are reported
• when incidents or near misses occur
• when new hazardous chemicals and/or dangerous goods are introduced into the school, see: Chemical Management Policy, or plant and equipment, refer to: Plant and Equipment Policy
• when new or additional information regarding a hazard, relevant to the school, is made available or communicated via the regulatory authority, WorkSafe.

If a risk control has not been implemented by the intended completion date, the principal or their delegate must identify the reasons for the delay and, in consultation with the affected employees and their representatives and those tasked with implementing the risk control determine an alternate date and update the OHS Risk Register or equivalent.

Definitions

Risk
The likelihood of harm arising from exposure to any hazards and the consequence of that harm.

Risk Assessment
Process undertaken to identify the hazards, risk controls, and level of risk associated with a task or activity.

Risk Control
Describes the implementation of an action that eliminates, prevents, reduces or mitigates the harm from the potential exposure to a hazard.

Related policies

• Chemical Management
• OHS Management System (OHSMS) Overview
• OHS Planning
• Plant and Equipment

Relevant legislation

Occupational Health and Safety Act 2004 (Vic)

OHS Risk Management Procedure

The Risk Management Procedure must be followed, and sets out the practical step-by-step instructions for implementing this policy.

The Procedure contains the following chapters:

1. OHS Risk Register
2. Guidance on the Department risk management methodology
3. Legislation, codes of practice, standards and guidance

1 OHS Risk Register

Generic OHS Risk Registers have been developed for each of the four types of workplaces below:

• primary school
• secondary school
• specialist school
• corporate/regional offices

The principal and/or their delegate in consultation with the Health and Safety Representative (HSR) and employees can modify the generic OHS Risk Register(s) to meet the needs of the individual school.

2 Guidance on the department's Risk Management Methodology

2.1 General

The Department’s risk management methodology is represented in the steps below (please note, this is a simple representation of the risk management process from the International Standard ISO 31000:2009).

Step 1: Identify the hazards within the workplace

Step 2: Assess the risk (risk analysis/evaluation)

Step 3: Eliminate or control the risk

Step 4: Review controls (monitoring and review)

2.2 Step 1 – Identification of hazards

The principal and/or their delegate may need to review the OHS Risk Register at least on an annual basis or as part of or after any of the following:

• identifying hazards prior to purchasing substances or plant and equipment which may include the hazard of storing and handling flammable paints, entanglement hazard associated with workshop machines like lathes and mills (OHS Purchasing Policy)
• reviewing audit results
• reviewing results of workplace inspections (Workplace Inspection Policy)
• consultation with the HSR and employees (OHS Consultation and Communication Policy)
• reviewing hazard reports from eduSafe Plus (staff login required) (Reporting and Managing School Incidents — Including Emergencies)
• reviewing health monitoring reports
• observations during work
• task analysis (OHS Risk Management Policy)
• incident reporting and investigation (Reporting and Managing School Incidents — Including Emergencies)
• when implementing specific hazard management policies, for example Manual Handling Policy.

Following the review, the principal and/or their delegate must list all newly identified hazards in the OHS Risk Register. The hazard description needs to be clearly articulated on the register for a correct assessment of the risk level and subsequently the proper identification of the required controls needed to reduce the risk level.

Associated risk management and hazard identification forms (for example Plant and Equipment Risk Management Form, Workplace Inspection Checklists and so on) are to be used for specific hazards identified.

2.3 Step 2 – Assessing the risk

Risk Assessment is the process of determining the ‘level of risk’ associated with a hazard. It is recommended to use the risk rating to prioritise the implementation of risk control actions.

The principal and/or their delegate must ensure that risk assessments are conducted in consultation with the Health and Safety Representative (HSR) and affected employees, including:

• the Health and Safety Committee (HSC), when available
• other relevant employees, contractors, volunteers and visitors
• with the use of relevant reference material, for example Safety Data Sheets for chemicals.

In determining the level of risk, the following must be taken into account:

• the experience of the person exposed to the hazard
• the frequency and/or duration of the person’s exposure to the hazard
• any existing controls
• contributing environmental conditions
• pre-existing hazards.

Where a hazard is similar for different work areas a single generic assessment of one representative work situation may suffice, for example using whiteboard cleaner in various classrooms at a school. In this case, it is the responsibility of the principal or their delegate to ensure that the risk assessment is valid for each of the work areas to which it is intended to apply.

The principal and/or their delegate must ensure that risk assessments are documented using the hazard-specific risk management forms outlined in each OHS procedure. If no specific risk management form is specified, the Risk Assessment Template may be utilised using the following risk matrix to assign a risk level to each hazard.

2.3.1 Using the Risk Matrix

1. Evaluate the consequences of a risk occurring according to the ratings in the top row.
2. Evaluate the likelihood of an incident occurring according to the ratings in the left hand column.
3. Using the Risk Matrix, calculate the level of risk by finding the intersection between the likelihood and the consequences.

Risk level/rating and actions

Based on the level of the risk (the risk rating) the following actions must be undertaken:

• Extreme risk: Notify principal immediately. Corrective actions should be taken immediately. Cease associated activity.
• High risk: Notify principal immediately. Corrective actions should be taken within 48 hours of notification.
• Medium risk: Notify principal. Nominated employee, HSR/HSC is to follow up that corrective action is taken within seven days.
• Low risk: Notify principal. Nominated employee, HSR/OHS Committee is to follow up that corrective action is taken within a reasonable time

For every hazard that is added to the OHS Risk Register, risks associated with that hazard are assessed in two stages, using the steps and the matrix above. Firstly, the inherent risk is assessed, then the residual risk after the controls are applied.

The inherent risk assessment which is completed initially involves scoring the risk level of the hazard without considering any OHS controls. The second assessment (residual risk rating) involves scoring the OHS risk level of the hazard after considering current existing risk controls that are in place. The residual risk rating should be regularly reviewed as new controls are identified and implemented.

Comparing the inherent risk rating to the residual risk rating you would be able to demonstrate to relevant parties (for example the Department, WorkSafe, external auditors and so on) that the controls in place are effective in reducing residual risk levels to a tolerable level.

2.4 Step 3 – Eliminate or control the risk

Once hazards have been identified and risk assessed, the principal and/or their delegate must ensure a control strategy to either eliminate or control the risk is to be documented in the OHS Risk Register and implemented. The hierarchy represented in the diagram below identifies control strategies from the most effective at the top to the least effective strategy at the bottom.

All school personnel must consider control strategies in the order of the hierarchy of controls appearing below.

Hierarchy of controls

When selecting controls for the hazards identified in the OHS Risk Register, ensure the Hierarchy of Control is considered.

Please note, not all strategies, when implemented in isolation, will reduce the residual risk to a tolerable level. In such circumstances, the principal should consider the implementation of two or more risk controls in conjunction to achieve the best possible risk reduction. For example, in science labs where hazardous chemicals are used, ventilation (engineering control) might be required, as well as, a review of hazardous chemical safe handling procedure and training (administrative control) and providing respiratory protection (Personal Protective Equipment). An example of each level of the hierarchy is given below:

• Elimination - Completely remove the hazard e.g. eliminating hazards associated with working at height by relocating air conditioning units and other equipment which requires ongoing maintenance from the roof to the ground level
• Substitution - Change a work practice, chemical or piece of equipment to provide a safer environment, for example substitute old, non-adjustable office chairs with ergonomic chairs to reduce the risk of injuries or substitute acoustic drums with electronic drums with volume controls
• Engineering - Modify the design of the workplace or plant and/or environmental conditions, for example the use of a fume extraction system to remove fumes generated by hazardous chemicals used in school laboratories, or installing interlocks on workshop machines which can be used to prevent unsafe access to moving parts and sharp edges when the machine is in operation using automatically lockable guards.
• Administrative - Develop procedures and systems to control the interaction between people and hazards, for example reducing the time of exposure to noise by requiring people to be remote from equipment during operation, providing manual handling training to persons so they are better able to identify / report / control / avoid hazards in the workplace.
• Personal Protective Equipment (PPE) - Implement PPE to prevent physical contact between a person and a hazard e.g. appropriate footwear, gloves, safety glasses and so on.

The principal and/or their delegate must ensure that prior to implementing risk controls the proposed risk control measures should be reviewed to ensure they do not create new and seemingly unrelated hazards — for example, installation of barriers and guarding for equipment may restrict access and means of escape in case of an emergency.

The effectiveness of risk controls must be tested prior to implementation — such as, residual risk. Refer to section above. A single control will generally affect either the likelihood or consequence of a risk occurring. The difference between the inherent risk and residual risk ratings (with controls applied) will demonstrate the effectiveness of controls.

The principal and/or their delegate must inform all affected employees about the risk controls being implemented and in particular, the reasons for the changes. This can be achieved as part of staff meetings and by sharing the updated OHS Risk Register with all affected employees. Also, ensure that adequate information, instruction, training and supervision is provided to employees, contractors, volunteers and visitors at all times during the implementation of controls to ensure their correct application.

Ensure that any relevant administrative controls, such as forms and/or safe work procedures, relating to hazards are updated — for example, if a new item of equipment is purchased, existing workplace inspection checklists and/or safe work procedures should also be updated.

2.5 Step 4 – Monitor and review controls

The final step in the process is to monitor and review the effectiveness of risk controls that have been implemented. The principal and/or their delegate must ensure that implemented risk controls are reviewed at regular intervals to ensure that they have had the desired impact in reducing the likelihood and/or consequences of a hazard occurring. Consultation with, and feedback from employees will provide information on the application and effectiveness of risk controls in the school.

3 Legislation, codes of practice, standards and guidance

• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)
• Australian and New Zealand Standard Risk Management Principles and Guidelines AS/NZS ISO 31000:2009

Resources

Templates relevant to this policy and procedure

• OHS Activities Calendar (Excel) — for scheduling reviews on an annual basis.
• OHS Risk Register (Excel) — the principal and/or their delegate must complete an initial review of this, in which they identify the applicable hazards for their school and delete any entries that are not applicable.
• Plant and Equipment Risk Management Form (Word) — to be used for specific hazards that are identified.
• Plant and Equipment Maintenance Form (Word)
• Risk Assessment Template (Word)
• Safe Work Procedure Template (Word)