A construction safety management plan outlines how health and safety risks will be managed on a construction site and is a legal requirement under WHS legislation in Australia and many other countries. While you may need to manage hundreds of activities each day, safety must always remain the top priority.
All workers, including contractors and sub-contractors, must understand site safety procedures before work begins. Without a proper WHS management plan in place, managing safety becomes far more difficult and may expose you to serious penalties.
The level of detail required in a construction safety management plan depends on how complex the workplace is. In particular, the number of contractors on site at any one time and the risks involved in the work will influence the plan’s scope. As a result, the Work Health and Safety (Construction Work) Code of Practice 2015 clearly outlines what a WHS management plan should include.
Key Components
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Construction Safety Management Plan – Roles and Responsibilities
The plan must clearly identify all positions or roles with specific health and safety responsibilities. For example, this may include WHS managers, first aid officers and project managers. The plan should also clearly describe each person’s responsibilities.
Health and safety representatives do not need to be listed unless they perform a coordinating role separate from their duties as representatives.
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Consultation, Cooperation and Coordination Requirements
The principal contractor must explain how persons conducting a business or undertaking at the workplace will consult and cooperate with one another. In addition, ongoing consultation between all duty holders is essential to manage overlapping work activities safely.
This approach ensures everyone understands other construction activities on site and can control associated hazards and risks. Common consultation methods include:
- Conducting pre-commencement WHS meetings with all contractors and sub-contractors
- Holding regular contractor and sub-contractor WHS meetings
- Running toolbox WHS meetings
- Establishing a WHS construction project committee
- Distributing regular WHS newsletters
In many cases, people with WHS responsibilities are not always on site. Therefore, the WHS management plan should also include arrangements for communicating with off-site personnel.
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Incident and Emergency Management Arrangements
The principal contractor should consider the types of health and safety incidents that could reasonably occur on site. The plan must clearly document the actions to be taken and identify who will represent the principal contractor as the responsible person.
In particular, the plan should address the following:
Incident Response and Investigation
- Stabilising and evacuating injured persons while ensuring rescuer safety
- Isolating the incident scene
- Making the workplace safe after the incident
- Preserving the incident site
- Notifying the principal contractor
- Contacting the relevant regulator and emergency services where required
- Investigating incidents
Emergency Planning and Response
- The emergency plan for the construction project
- Arrangements for testing the emergency plan
- Training and instruction requirements
First Aid Facilities and Training
- First aid facilities and equipment provided by the principal contractor
- Arrangements for first aid training
- First aid equipment provided by contractors and sub-contractors
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Site-Specific WHS Rules and Safety Procedures
The safety management plan must clearly set out all site-specific WHS rules required by the principal contractor. It should also explain how everyone at the workplace will be informed of these rules. To remain effective, rules should be simple, clear and specify who they apply to.
The nature of the work, identified hazards, workplace size and location, and workforce composition can all help determine appropriate site-specific rules.
Once finalised, the principal contractor should communicate these rules by:
- Holding toolbox meetings or face-to-face discussions
- Posting rules in prominent workplace locations
- Distributing copies to all workers
A construction project management tool can help principal contractors track these communications while maintaining a full audit trail.
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Managing Safe Work Method Statements (SWMS)
The construction safety management plan must detail arrangements for preparing, collecting, assessing, approving, monitoring and reviewing SWMS. The principal contractor should also ensure that activities do not conflict with control measures used by other contractors or create additional risks.
In addition, the plan should explain how all affected workers, including contractors and sub-contractors, will follow approved SWMS. If workers do not strictly comply with a SWMS, work must cease immediately.
WHS Compliance Requirements and Penalties
Importantly, compliance with a WHS management plan is governed by the Work Health and Safety Regulation 2011 in each state or territory of Australia. Failure to comply can result in significant penalties.
For example, not providing a written WHS management plan before project commencement can attract a maximum penalty of $30,000 in NSW. In Queensland, penalties may reach up to 60 penalty units.
Finally, remember to retain the WHS management plan on file, or within your construction management software, for at least two years after a notifiable incident occurs to avoid further penalties.
For more information on construction site safety requirements, see https://shulman-hill.com/construction-site-safety/.
