Over the years Safe Work Method Statements (SWMS) seem to have taken on a life of their own. They have not only grown into unmanageable behemoths, but are frequently being used where they are not required, on the assumption that as long as the risk is documented, all is good.
SWMS are required for all high risk work.
SWMS are specifically required for high risk construction work as set out in the WHS Regulation (s) 291, which lists 18 types of construction work. Construction work itself is clearly defined in section 289. Whilst it may not be a breach in legislation to adopt SWMS for non-High Risk Construction work, using this approach not only makes some simple activities overly complex, it waters down SWMS for when they are specifically required by legislation.
SWMS must contain risk assessments.
Legislation does not require that a SWMS contains a risk assessment. The Work Health and Safety Regulation s.299 states that a SWMS must—
(a) identify the work that is high risk construction work; and
(b) state hazards relating to the high risk construction work and risks to health and safety associated with those hazards; and
(c) describe the measures to be implemented to control the risks; and
(d) describe how the control measures are to be implemented, monitored and reviewed.
The factor that most inhibits the effectiveness of SWMS is to be found in the complexity of the process. As SWMS are now perceived to be an unmanageably complex system of risk assessments, so that many organisations simply purchase or develop generic SWMS that can be easily replicated and used on multiple sites. The danger here is that critical hazards and risks specific to the work location are not included. There is often no review of the SWMS, nor the application of other controls, and in many cases the point-of-risk workers do not read the document but merely sign the last page before commencing work: all of which undermines the effectiveness of the SWMS.
A lengthy document that inhibits credibility, uptake and understanding may in fact be interpreted as being in contravention of WHS Regulation s.39 Provision of information, training and instruction, which states, ‘information, training and instruction is to be provided in a way that is readily understandable by any person to whom it is provided.’ Giving a tradesperson a 48 page SWMS during a 15 minute induction, for example, would not constitute compliance with this requirement.
Breaking the myths
The solution lies in ensuring that SWMS are specifically developed in line with legislative requirements. This means that they must simply:
1. identify the work that is high risk construction work;
2. Set out the steps of the work or job;
3. List the hazards and associated risks;
4. Describe the measures to be implemented to control the risks; and
5. Describe how the control measures are to be implemented, monitored and reviewed.
This can be done in a simple (and short!) tabular format using language that intended end-users can understand and relate to.
Please contact QRMCContact Us for more information.