WHS-PRO-002 WHS Risk Management Procedure
This procedure has been developed to describe how the Work Health and Safety (WHS) risk management process is applied at James Cook University (JCU). The intention of this procedure is not to reiterate the requirements of the legislation, standards and the codes of practice.
This Work Health and Safety Risk Management Procedure is a subsidiary of the Work Health and Safety Policy and aligns to the overall intent of the JCU Risk Management Policy and the JCU Risk Management Framework and Plan.
This Work Health and Safety Risk Management Procedure applies to all staff, students (including higher degree by research candidates), JCU affiliates and contractors involved in JCU business operations and activities.
This Procedure does not apply to the JCU Controlled Entities.
Except as otherwise specified in this procedure, the meaning of terms used are as per the Policy Glossary, and in accordance with Worksafe Queensland’s How to Manage Work Health and Safety Risks Code of Practice 2021.
Is a person (other than a staff member or student, including Higher Degree by Research candidates) who is affiliated with JCU by letter of appointment or invitation to work, research or study at the University for a particular activity and typically for a prescribed timeframe and who is bound to comply with the University’s policies during that period (e.g. visiting scholars, adjuncts and volunteers).
A situation or thing that has the potential to harm a person.
High risk construction work
Is construction work that—
The level of risk determined before controls have been considered.
A person who makes decisions, or participates in making decisions that affect the whole or a substantial part of a business or undertaking or has the capacity to significantly affect the financial standing of the business or undertaking.
A person is not considered an Officer under the Work Health and Safety Act 2011 (Qld), if they are only responsible for implementing or executing those decisions.
Holders of the following JCU positions are considered Officers:
Visitors to a JCU controlled site / campus and students not performing work experience or paid or unpaid work.
Person in Control of a Business or Undertaking
A business or an undertaking that is either conducted alone or with others, whether or not for profit or gain.
A PCBU can be but is not limited to:
Which is, or was at a particular time, reasonably able to be done to ensure health and safety, taking into account and weighing up all relevant matters including:
For the purposes of this WHS Risk Management Procedure, Risk is defined as the possibility that harm (death, injury or illness) might occur when exposed to a hazard.
A systematic process of evaluating the potential risks that may be involved in a projected activity or undertaking.
In the context of this Procedure, this is a process set out in the WHS Regulation to eliminate health and safety risks so far as is reasonably practicable, or if this is not reasonably practicable, minimise the risks so far as is reasonably practicable. It includes identifying hazards, assessing and implementing control measures, and reviewing and maintaining the control measures to ensure their ongoing effectiveness.
The person or entity with the accountability and authority to manage the risk.
A register of risk that identifies the hazards and what action needs to be taken to control the risk.
Risk remaining after control measures have been implemented.
Any person who is responsible for Workers, the allocation of tasks to Workers and / or the oversight of all JCU students during teaching and / or learning activities including field trips.
A person who carries out work in any capacity for JCU, and includes working as:
A Workplace is the place where work is carried out for JCU and includes any place where a Worker goes, or is likely to be, while at work.
1 Duty, Obligations and Responsibilities
Everyone associated with JCU activities or accessing JCU controlled campuses/sites has a responsibility to take reasonable care for their own health and safety and ensure that their acts or omissions do not adversely affect the health and safety of other persons.
The WHS-PRO-001 Work Health and Safety Responsibilities Procedure outlines these responsibilities in detail.
1.1 James Cook University
JCU as a person conducting a business or undertaking (PCBU), has a primary duty under the Act to ensure health and safety of Workers and Others. To fulfil this duty, JCU shall eliminate risks to health and safety, so far as is reasonably practicable and, if it is not reasonably practicable to do so, to minimise those risks so far as is reasonably practicable.
An Officer of JCU has a duty under the Act to exercise due diligence to ensure JCU fulfils its health and safety obligations under the Act. To satisfy this duty, Officer’s shall:
- Understand the hazards and risks associated with the JCU operations under their control;
- Allocate and use appropriate resources and processes to eliminate or minimise health and safety risks arising from the operations; and
- Ensure that appropriate processes are in place to receive and respond promptly to information regarding incidents, hazards and risks.
Note: This Procedure deals specifically with WHS risk management responsibilities. Officers have other responsibilities under the Act.
Officers should be conversant with WHS-PRO-001 Work Health and Safety Responsibilities Procedure .
1.3 WHS Risk Assessment Approvers
Risk assessments are required to be reviewed and approved by the supervisor of the staff member/student creating the risk assessment where the risk rating is medium or low. Risk assessments with a residual rating of ‘high’ shall be escalated to the Dean/Director for approval.
All JCU risk assessment approvers are responsible for ensuring:
- The context of the risk assessment is clear and accurate;
- All foreseeable hazards and risks have been identified;
- The assessed risk levels are accurate;
- The control measures are reasonably practicable; and
- The risk owner is competent and has all available resources to implement the risk controls.
JCU risk assessment approvers may seek advice from subject matter experts where their knowledge/experience in the subject is limited, prior to approving a risk assessment.
A Worker shall follow the requirements outlined in this Procedure to effectively manage health and safety risks, which may arise out of the conduct of the University’s activities. In practice, this means to:
- Report hazards when identified;
- Participate in the risk management processes when required; and
- Comply with all risk controls that have been implemented to prevent or minimise incidents and injuries.
1.5 Work Health and Safety (WHS) Unit
The WHS Unit is responsible for the overall maintenance and implementation of the Health and Safety Management System (HSMS).
As part of the implementation of the HSMS, the WHS Unit has an advisory function in relation to the WHS risk management process at JCU. This is conducted through the:
- Development and implementation of this Work Health and Safety Risk Management Procedure across JCU;
- Provision of support, guidance and training to assist the JCU community with risk assessments, selection of appropriate risk controls and the maintenance of the Work Health and Safety Risk Register;
- Development, implementation and review of WHS risk management tools;
- Consultation with stakeholders to ensure the risk management process is meeting the needs of the University;
- Reporting of health and safety hazards and risk management to the Work Health and Safety Advisory Committee (WHSAC); and
- Review of all risk assessments with a residual risk rating of high
1.6 Risk Owner
Risk Owners are responsible for the implementation of risk management processes within the work area to which they have been authorised.
Specific responsibilities include:
- Documenting information about how work health and safety risks will be managed in the Risk Register, Riskware or other JCU risk management tools;
- Consulting with all Workers and Others who may be impacted by the activity to which the risk assessment is being prepared;
- Reassessing activities/hazards if the hazards/risks change; and
- Monitoring and reviewing risk assessments to ensure all hazards have been identified and the controls that have been applied are effective in eliminating or minimising the risk to as low as reasonably practicable.
Others are to comply so far as is reasonably practicable, with any reasonable instruction that is given by JCU. This means to:
- Report hazards when identified;
- Participate in the risk management processes when required;
- Comply with all risk control / risk management processes that have been implemented to prevent or minimise incidents and injuries.
2 Commitment to Risk Management
JCU recognises that risk management is an integral part of good governance and management practice.
JCU’s overarching Risk Management Policy and the JCU Risk Management Framework and Plan provide the foundations and organisational arrangements for designing, implementing, monitoring, reviewing and continually improving risk management throughout the University.
The Risk Management Policy establishes a mandate and commitment to managing risk. The Risk Management Framework and Plan provides a formal, structured approach to risk management that is appropriate to JCU’s activities and operating environment.
Health and safety related risk management is further defined and implemented via JCU’s Work Health and Safety Management System (WHSMS). The WHSMS defines the minimum standards for which health and safety hazards and risks are managed, aligning to the overarching risk management framework.
3 Risk Management Process
Risk management is a four-step process:
- Identifying hazards;
- Assessing risks;
- Eliminating or minimising the risks so far as is reasonably practicable; and
- Reviewing the control measure.
Consultation with Workers is required throughout the risk management process.
3.1 Identify hazards
JCU strives to adopt a proactive approach to WHS risk management. To achieve this, JCU has implemented processes to identify reasonably foreseeable hazards and associated risks.
Hazards are identified in a number of informal and formal methods at JCU including, but not limited to:
- Hazard / near miss reporting;
- Incident reporting;
- Audits and inspections; and
- Consultation with workers.
3.1.1 Hazard / near miss reporting
The JCU Riskware system allows Workers to report incidents and hazards. Hazard and near miss statistical data is used as a positive performance indicator by management.
Hazards and near miss reporting allows JCU to improve processes, procedures, training and equipment. Hazards and near miss reporting allows trends to be identified.
3.1.2 WHS Incident reporting
Reporting incidents allows the University to:
- Prevent the same type of incident from reoccurring;
- Identify where improvements are required in processes, procedures, training and equipment; and
- Identify trends.
3.1.3 Audit and inspections
Hazards are identified during workplace audit and inspections processes. Audits and inspections results are also used to identify system improvements.
3.1.4 Consultation with workers
Refer to WHS-PRO-003 Consultation and Participation Procedure for further information on the JCU consultative framework.
3.2 Assess the risk
3.2.1 JCU Risk Assessments
When do I need to conduct a risk assessment?
|Assess risks (not required if knows risks and controls)|
As shown above in 'Figure 1: The risk management process' Source: How to manage work health and safety risks Code of practice 2021.
As many hazards and their associated risks are well known and there are well established and accepted control measures, the requirement to ‘assess risks’ may not be required.
To determine if a risk assessment should be completed, the following questions should be asked:
- Are the risks / hazards and their controls well known and understood?
- Legislation requires some hazards or risks to be controlled in a specific way;
- A code of practice or guidance sets out a way of controlling a hazard or risk that is applicable to your situation;
- There are well-known and effective controls that are in use in a particular industry; or
- There is a minimum standard in the form of a SWP, procedure, guideline, risk assessment already be in place at JCU.
- Can the well-established controls be implemented?
- Well-established controls may not be able to be implemented in all situations. If the controls cannot be implemented, the risk needs to be assessed to determine if there are alternate acceptable controls.
If the answer is ‘no’ to either of these questions, a risk assessment should be completed in Riskware.
A risk assessment is also mandatory for specific activities stipulated by legislation. This includes but is not limited to:
- Entry into confined space;
- Diving work; and
- Electrical work on energised electrical equipment.
3.2.2 How does JCU manage changing hazards and risk?
Risk assessments that are completed in Riskware (or similar) are generally completed days / weeks prior to the commencement of the activity as part of the planning phase. Risks and hazards can change between the time the risk assessment was completed and the time when the activity commences. To ensure any variables to existing risks and new hazards are identified and managed, the activity leader may determine that there is a need to conduct a quick on-the-spot risk assessment of the variables factors only. This on-the-spot risk assessment should be conducted in conjunction with the activity team members.
The following template has been developed to assist activity leaders to conduct on-the-spot risk assessments.
3.2.3 JCU specific risk management strategies
JCU has a number of activity specific WHS risk management strategies. Some of the JCU WHS risk management strategies are detailed in activity specific procedures. Appendix 1: JCU Specific Risk Management Strategies lists the activity types, applicable procedure and clarifies if a Riskware risk assessment and approval is required. Any activity that falls outside of the list below should be managed in accordance with the general principles listed in this procedure and recorded in Riskware where applicable.
3.2.4 Conducting a Risk Assessment in Riskware Risk Assessment Module
For activities that JCU does not have an activity specific strategy, the following principles apply and should be followed.
Riskware WHS Risk Assessments shall be completed prior to commencing the activity.
Key points to produce a high quality risk assessment:
- Establish the context. Clearly define the context for the risk assessment. Be specific about what you are assessing;
- Resources required. Are there standards, data sheets or operating instruction that need to be considered?
- Who are the key stakeholders in the risk assessment? Consider inviting subject matter experts to peer review or be involved in the development of the risk assessment. Request a review from the WHS Unit, if required. Consider completing the risk assessment with a team.
The risk assessment shall be approved by the student / staff members supervisor / lecturer.
3.2.5 Safe Work Procedures (SWP)
A SWP is a written instruction outlining JCU’s approved method of performing an activity.
There are two types of SWP’s used at JCU, endorsed and local SWP’s.
Local SWP’s are developed and maintained for a local process / activity. The SWP may be approved by the relevant manager / supervisor for the activity. Local SWP’s will not be added to the JCU WHS website.
Endorsed SWP’s can be found on the JCU WHS website and should be used as a minimum standard. Endorsed SWP’s are developed to provide clear guidance to staff and students on ‘acceptable controls’ for core JCU activities. Endorsed SWP’s are developed in a systematic way. The endorsement process ensures that the correct personnel are consulted to determine a set of reasonably practicable controls for an activity.
Where an endorsed SWP for an activity has been developed, staff and students are not required to conduct a RiskWare risk assessment for the activity if all controls in the SWP can be implemented. Please note: a pre-activity on the spot risk assessment (i.e. Stop, Look, Assess, Manage SLAM) will still be required to manage the variable risks and any unforeseen hazards (e.g. wind / rain on the day of activity).
The advantages of Endorsed SWP’s include:
- Subject matter experts determine safe and practical controls measures for core / common JCU activities;
- They provide an induction document that workers shall read and understand before starting the activity;
- They meet legal responsibilities for hazard identification, risk assessment and risk control as well as being a tool to provide instruction, information and training; and
- They help in the planning of the activity by detailing the resources required, skills / competence requirements of workers.
The WHS-PRO-SWP-002g Safe Work Procedure template is managed by the WHS Unit.
3.3 Controlling the Risk
If it is not reasonably practicable to eliminate the risk, the risk shall be minimised by implementing controls. JCU requires all Workers to use the hierarchy of controls as part of this process. The diagram below illustrates the hierarchical order in which the control options are to be implemented to manage the WHS risk.
In many cases, it will be necessary to apply more than one control method. Personal protective equipment shall only be used as a last resort or to complement other control measures.
3.3.1 What is reasonably practicable?
To determine reasonably practicable, ask the following two questions:
- What can be done?
- What is reasonable in the circumstances?
All approvers of risk assessments need to understand the term ‘reasonably practicable’ when determining if risk controls should be approved.
Likelihood: The more likely the risk, the more that is required to be done to eliminate or minimise it.
Consequence: The greater the degree of harm, the more that is required to be done to eliminate or minimise it.
Choosing a low cost option that provides less protection, simply because it is cheaper, is unlikely to be considered a reasonably practicable means of eliminating or minimising risk. If JCU cannot financially afford to implement a control measure that should be implemented after considering the risks, the activity should not proceed.
Practical questions to assist the Approver of a risk assessment in making a decision include:
Considering the consequence and likelihood of the risk:
- If someone were to be injured as a result of this activity, would there be more that you would wish had done?
- Would a ‘reasonable person’ consider that more could or should be done?
- Are there controls higher in the hierarchy of controls that should be applied?
- Should the activity temporarily cease until more suitable controls become available?
- Should the activity cease altogether?
Other considerations include:
- As a minimum, have all standards and codes of practice been followed?
- Is good industry practice being followed?
3.3.2 High risks
For activities that need to be conducted and the risk level is high, escalate the approval to Dean/Director for direction or acceptance of the risk.
3.4 JCU Risk Assessment Reviews
All risk assessments in the RiskWare system are automatically allocated a review date based on the current risk level.
All risk assessments that have not been created using the RiskWare system (including SWP’s, SWMS’s, etc.) shall be reviewed as per the table below.
There are other times when a review may be required prior to the next scheduled review. These include:
- When the control measure is not effective in controlling the risk;
- Before a change at the Workplace that is likely to give rise to a new or different health and safety risk that the control measure may not effectively control;
- If a new hazard or risk is identified;
- If the results of consultation indicate that a review is necessary;
- If a Health and Safety Representative requests a review.
In addition, the WHS unit will periodically monitor and review the effectiveness of applied risk control strategies through a range of scheduled and unscheduled activities, including but not limited to:
- Observations, audits and inspections;
- Workplace monitoring where necessary (hazardous noise or chemicals); or
- Review of incidents and hazards.
4 Communication and Consultation
Underpinning the entire process of risk management is the need to consult with Workers and Others with duties under the Act.
JCU is required under the Act to consult with its Workers, so far as is reasonably practicable at each stage of the risk management process.
JCU has established mechanisms that enable Workers to report hazards and health and safety issues immediately to encourage proactive risk management practices and Worker involvement in the risk management decision-making process.
In addition, when deciding how to eliminate or minimise WHS risk as part of the HSMS, JCU management shall consult with Workers and their Health and Safety Representatives (HSRs) when they/their work group are directly affected or are likely to be directly affected by the decisions made. The agreed consultation process is outlined in the WHS-PRO-003 Consultation and Participation Procedure.
5 Change Management
The risk management process shall be undertaken or current controls reassessed when a change is introduced to JCU that affects the health and safety of Workers or Others. This is to identify the hazards brought about by the change, assess the risk and either eliminate or minimise the risk associated with the hazards.
Examples of change that require a risk management approach include, but are not limited to:
- Changes to systems of work;
- Use of plant or equipment (both temporary use and permanent installation);
- Planning to improve productivity or reduce costs;
- Introduction of new or different material or chemicals; or
- Responding to workplace incidents.
6 Training Requirements
The WHS unit provides training and information to assist employees to identify, assess and manage WHS risk at JCU. Refer to WHS-PRO-004 Training and Competency Procedure .
6.1 Mandatory Training
All new JCU employees, including volunteers and students undertaking work experience, shall complete the WHS Staff Induction within 48 hours of commencing work. The induction includes a risk management component.
WHS Risk Management Fundaments and Riskware System training is available online via the JCU Safety website. All JCU employees are required to and students are encouraged to complete the WHS risk training programs.
6.2 Role Specific Training
Supervisors are responsible for ensuring that Workers under their supervision are provided with suitable WHS training to establish and maintain the competencies necessary to perform their work safely.
Supervisors should refer to the WHS-PRO-004 Training and Competency Procedure and contact the WHS unit if they require more information about how to create a work health and safety skills profile of all staff under their supervision by conducting a Training Needs Analysis.
7 Risk Register
All risk assessments shall be recorded in RiskWare. RiskWare is the approved Risk Register of JCU.
All work health and safety records shall be retained in accordance with JCU’s Records Management Policy.
9 Review of the Work Health and Safety Risk Management Process
In order to ensure WHS risk management processes are effective throughout the University, this WHS Risk Management Procedure will be reviewed every three years.
Reviews may be required outside the nominated three-year cyclic review period, due to:
- Legislative changes;
- System failures reported or identified during incident investigations;
- Suggestions from employees directly or via consultation arrangements;
- Industry best practice; or
- Changes to the JCU parent risk management framework.
Consequently, any changes to WHS risk management will initiate a review and an amendment of all related documents and processes to ensure consistency at all levels of business.
Related policy instruments
Snorkelling Procedures for Large Groups
Other related documents and legislation
NOTE: Printed copies of this procedure are uncontrolled, and currency can only be assured at the time of printing.
Deputy Vice-Chancellor, Services and Resources
Date for next Major Review
Major Review. Amended to provide additional guidance and tools for managing WHS risks.
Principal Technical Advisor, WHS Unit
Nomenclature changes due to unit name change, renumbering of Procedure from HSE-PRO-011 to WHS-PRO-002
WHS Administrative Officer
HSE Project Officer
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