You may need to manage hundreds of events each day on a construction site, but safety is still the number one priority. All workers, including the sub-contractors, should have a good understanding of the safety procedures before work starts. It is difficult to manage and you may incur penalties without a proper WHS management plan.

The level of detail required will depend on how complex the workplace is (in particular, the number of contractors at the workplace at any one time) and the risks involved in the work. So what does the Work Health and Safety (Construction Work) Code of Practice 2015 say about what a WHS management plan should include?

Key components of safety management plan

1. The People

The positions or roles that involve specific health and safety responsibilities must be identified in the plan. For example, the list should include WHS managers, first aid officers and project managers. Their responsibilities should be described. Health and safety representatives do not need to be listed, unless they have a coordinating role separate to their role as health and safety representatives.

2. Arrangements for consultation, cooperation and coordination 

The principal contractor must include in the plan how the persons conducting a business or undertaking at the workplace will consult and cooperate with each other. There should be ongoing consultation and cooperation between all duty holders so that when work overlaps, each person is aware of other construction activities and can control any associated hazards and risks. Some identified examples include:

  • Conducting pre-commencement WHS meetings with all contractors and sub-contractors.
  • Holding regular contractor/sub-contractor WHS meetings.
  • Holding toolbox WHS meetings.
  • Establishing a WHS construction project committee.
  • Distributing regular WHS newsletters.

In many cases, people who have WHS responsibilities are not always on site. It is recommended that consultation arrangements for communicating with people off-site also be included in the WHS management plan.

3. Arrangements for managing incidents

The principal contractor should consider the types of health and safety incidents that might occur. The plan should document the actions to be taken and who will represent the principal contractor (i.e. the responsible person). In particular, the following should be included:

a. Incident management 

  • Arrangements to stabilise and evacuate any injured person after ensuring safety of rescuers.
  • Arrangements for isolating the incident scene.
  • Arrangements for making the workplace safe after the incident.
  • Arrangements for preserving the incident site.
  • Arrangements for notifying the principal contractor.
  • Notification of the relevant regulator and emergency services as necessary.
  • Arrangements for the investigation of an incident.

b. Emergency situations

  • The emergency plan for the construction project.
  • Arrangements for testing the emergency plan.
  • Arrangements for training and instruction requirements.

c. First aid arrangements

  • The facilities and first aid equipment that will be provided by the principal contractor.
  • Arrangements for training in first aid.
  • First aid equipment that will be provided by contractors and sub-contractors.

4. Site-specific health and safety rules

The safety plan must detail any site-specific WHS rules as required by the principal contractor and the arrangements for ensuring that all persons at the workplace are informed. The rules should be simple and clear, detailing to whom each rule applies.

The nature of the work, hazards, size and location of the workplace, and the composition of the workers can assist in determining the site-specific rules.

Once finalised, the principal contractor should communicate the rules to everyone in the workplace, for example by:

  • Holding toolbox meetings or face-to-face discussions.
  • Posting them in a prominent position at the workplace.
  • Distributing copies to everyone at the workplace.

A construction project management tool can help principal contractors keep track of the required communications with a full audit trail.

5. Arrangements to collect and assess, monitor and review SWMS

The safety management plan must detail arrangements for the preparation, collection, assessment, approval, monitoring and review of SWMS at the workplace. The principal contractor should ensure the activities does not conflict with control measures being used by other contractors or sub-contractors working in the same location or create additional risks for others.

You should also include arrangements to ensure that SWMS are followed by all affected workers (including contractors and sub-contractors), and that work is ceased if the SWMS is not strictly followed.

Compliance with the WHS management plan is governed under the Work Health and Safety Regulation 2011 of your state/territory, and may involve hefty penalties for non-compliance. Not providing a written WHS management plan before project commencement for example may attract a maximum penalty of $30,000 in NSW, and in Queensland may cost you up to 60 penalty units. Please remember to keep the WHS management plan filed or within your construction software for at least 2 years after a notifiable incident occurs to avoid further penalties.

For more references on this subject, see https://shulman-hill.com/construction-site-safety/.