Paul Breslin caused a stir in Australia’s OHS sector in 2013 with his costing of one element of managing high risk workplaces, the Safe Work Method Statement (SWMS). In 2014, an update of Breslin’s research was published in The Australian and New Zealand Journal of Health, Safety and Environment (only available through subscription), in which he states that
“Industry stakeholders claim that the SWMS Process is no longer manageable and that this document process has failed the industry and has basically outlived its usefulness” and
Recent “criticism has centred on the fact that SWMSs, which were intended to be easy to use documents, have often become so large and complex that they are impractical to use”.
(The latter statement was supported by speakers at a recent (poorly attended) Safety In Construction Conference in Melbourne, Australia.)
Some general industry criticism has been aimed at occupational health and safety (OHS) regulators such as the various WorkSafes and the Office of the Federal Safety Commissioner for accepting bloated and super-generic SWMSs but an equal amount of criticism could be laid at the feet of clients who often request a SWMS when, in fact they are seeking a construction or work methodology. This is lazy management but also indicative of ignoring the need to have OHS professionals in the contract assessment process from the conceptual stage of a tender process.
Several Australian States are embarking on a period of multi-billion dollar infrastructure construction and will be accepting tenders with bloated impractical SWMS. Due to the long length of construction projects, this acceptance will delay any substantial change to this SWMS debate and exacerbate the expensive cost base when issues of red tape, productivity and excessive government spending are hot topics.
Generic SWMS Templates
The situation is not helped by commercial opportunists that are selling SWMS templates of work tasks for which there is no legislative justification, an issue discussed in a previous SafetyAtWorkBlog article. Several OHS regulators have clearly stated that SWMS are required for high risk work. WorkCover NSW discusses SWMS and high risk construction work and defines what that work is. The Victorian Workcover Authority echoes the need of a SWMS for high risk construction work and adds:
“When an SWMS is being used for a site where there are multiple hazards, the SWMS needs to deal with the specific hazards and risks on the site.
For this reason, a generic SWMS is unlikely to meet the new requirements, unless it has first been reviewed in light of the hazards and risks on the specific site and amended as necessary.”
One Australian company, Safety Culture, is retailing SWMS templates for work that is not included in the categories of high risk work listed by Safe Work Australia under the model Work Health and Safety laws. This company lists a range of templates for work activities in retail, swimming pools, hospitality and other non-high-risk work activities. For instance, one template for operating a mobile photography booth is being sold for $A79.95. The site claims that the template “complies with current legislation in all States and Territories” but WHS/OHS legislation only requires SWMS for high risk work and operating a mobile photography booth is not listed in the Safe Work Australia categories of high risk work. How can the template “comply” when there is no legislative requirement for a SWMS for this task?
(Safety Culture responded to an earlier article on its SWMS templates, in December 2012)
Few templates, if any, can, or should, be used without modification and even though the site referred to above describes the templates as “ready to use”, the company does encourage purchasers to:
“… include any site specific details or risks ensuring it is specific to the task at hand.”
But one could argue that this type of modification can be done just as effectively on one of the blank safety checklists included in many of the free Codes of Practices or Guidances available in every State of Australia. This would save, (particularly small) businesses money, represent safety management more accurately and encourage communication with OHS regulators, advisers and inspectorates.
Anyone is entitled to sell anything but calling these templates “Safe Work Method Statements” can confuse the business sector about the extent of their OHS/WHS needs and obligations.
Also SWMS are often mentioned in relation to business red tape but this argument could only be made, perhaps, in industries of high risk work. Promoting SWMS into sectors where they are not required muddies business’, politicians’ and the public’s understanding of safety management, hazard control and injury prevention.
Amongst Breslin’s latest findings he says that “there is a perception that (SWMS) protects an organisation from potential prosecution.” Generic SWMS templates could further spread and strengthen such a perception diminishing the effectiveness of hazard control measures and provide a false sense of safety security.
Many years ago WorkSafe Victoria issued an information sheet on backbraces indicating that:
“…there is little scientific evidence of increased lifting power or lower rates of injury in workers wearing back belts. There is however, some evidence of potential harm from increased abdominal and blood pressure.”
It would seem time for one of the OHS regulators or Safe Work Australia to provide a similar document clarifying the role and use of Safe Work Method Statements in order to reduce unnecessary paperwork, streamline safety management and reduce (small) business costs.
