Crazy Stuff in the Workplace Health and Safety Codes of Practice

I have, in previous blogs, talked about some of my views on the way that workplace health and safety is being managed within Australia.  This is not a criticism of safety professionals who are diligently trying to prevent workplace accidents from occurring.  My biggest issue is with the legislation, and in particular the accompanying Codes of Practice for managing different types of “risks”.

In this series I will discuss what I think to be some of the craziest inclusions in the Codes of Practice and highlight why they are unhelpful in managing risk.

So, let’s start with the Model Code of Practice for Managing the risk of falls at workplaces.

There have been a number of falls reported at workplaces in the last 12 months and working at heights is definitely something that requires significant controls in order to prevent the risk of a worker falling from heights.  The Code of Practice highlights many of these controls, however, it was when I got to Chapter 4, which states:

Eliminating the need to work at height is the most effective way of protecting workers from the risk of falls. Examples of tasks that may be carried out on the ground to eliminate the risk of falls are:

• prefabricating roofs at ground level
• prefabricating wall frames horizontally then standing them up
• installing air-conditioning units at ground level

Sounds reasonable? If we don’t work at heights, we can’t fall from heights.  But let’s unpack this using the first of these suggestions – prefabricating roofs at ground level.

Most building sites for domestic housing I have seen are pretty cramped, which begs the question – where is there going to be sufficient room on site to build the roof?  Let’s suppose it is possible, once the roof has been constructed it needs to be lifted to be connected to the super-structure.  This introduces a completely new risk: Loss of control of a load being slung by a crane.  This then requires a significant number of controls to be introduced.  It could be also be argued that, if this risk was to occur, the consequences would be more substantial than a worker falling from heights, particularly if an exclusion zone has not been established and the roof falls onto the workers below.

But, hang on. Don’t we then need to connect the roof to the super-structure once it has been constructed on the ground and then positioned by a crane? Doesn’t that also require people to be working at heights?  So, in applying the most preferred of the hierarchy of controls – eliminate – we actually haven’t eliminated at all.  I would argue that the likelihood of a worker falling from heights has actually increased because securing the roof will involve having people working at heights with a slung load above them as it is being positioned in place.

But wait – there is more.

We have now introduced a new risk that doesn’t have safety consequences: Prefabricated roof does not fit/integrate with the super-structure.  Now we have a risk with financial and schedule impacts.

My point is there are a number of industries/activities that require people to work at heights.  Wouldn’t it be far better to ensure the controls necessary to manage the risk of a worker falling from heights are effective, rather than attempting to impose a control that doesn’t actually reduce the likelihood of the fall from heights, but instead increases its likelihood, not to mention adding additional risks?

We can get very wrapped up by trying to follow the hierarchy of controls and try to eliminate.  It needs to be recognised and accepted, however, by safety professionals, particularly those who develop the regulatory guidance upon organisations, develop their policies and procedures, that making a decision in isolation without consideration to the impact it has on increasing current risks and/or creating new ones is fundamentally flawed.

Stay tuned for the next instalment.