Clause 5.4: Consultation and participation of workers
Involvement of workers in the OH&S management system and the processes that support it is a key requirement of effective OH&S management as it enables the organization to make informed decisions.
There is an onus on the organization to:
- Provide processes, time, training and resources deemed necessary for consultation and participation;
- Provide, in a timely manner, access to clear, understandable and relevant information about the OH&S management system;
- Identify and remove obstacles to participation such as failure to respond to worker suggestions, language or literacy difficulties, policies that discourage worker participation, and minimize those that cannot be removed;
- Encourage consultation with non-managerial workers relating to a range of OH&S issues
- Encourage the participation of non-managerial workers in a range of OH&S activities and decisions.
It is up to the organization to determine the best way of ensuring effective consultation and participation and whether it needs to set up formal mechanisms such as health and safety committees. While consultation is about seeking workers’ views, and considering them, before making a decision, participation is about joint decision-making, e.g. jointly undertaking a risk assessment and agreeing actions or being involved in deciding the organization’s OH&S policy and objectives.
For small organizations it can be effective to include all workers in discussions and decision-making, whilst in larger organizations, it can be more effective to appoint one or more workers’ representatives. Other mechanisms for consultation and participation include focussed team meetings, workshops, worker surveys and suggestion schemes.
The organization should ensure that processes for consultation and participation of workers include contractors and other interested parties, e.g. people working in parts of the organization not covered by the management system, carrying out work under the organization’s control, where relevant. This can include, for example, consultation with contractors on issues such as dealing with hazards which might be new or unfamiliar to them.
Typical of the activities that workers can participate in include the following:
- Identifying hazards and assessing risks and opportunities;
- Determining actions to eliminate hazards and reduce OH&S risks;
- Determining competence requirements and conducting training needs analysis;
- Determining what needs to be communicated and how this will be done;
- Determining control measures and their effective implementation and use;
- Investigating incidents and nonconformities and determining corrective actions;
- Developing and reviewing of OH&S policies and objectives;
- Developing new or improved OH&S arrangements and procedures.
In considering the need for consultation, the organization should take account of the following:
- New or unfamiliar hazards (including those that might be introduced by contractors);
- New processes, procedures or work patterns;
- The construction, modification or change of use of buildings and facilities;
- The introduction of new or modified equipment;
- New or amended controls;
- The use of new chemicals or materials;
- Changes in emergency arrangements;
- Changes in legal and/or other requirements;
Topics for consultation include:
- Determining the needs and expectations of interested parties;
- Establishing the OH&S policy;
- Assigning organizational roles, responsibilities and authorities as applicable;
- Determining how to fulfil legal and other requirements;
- Establishing OH&S objectives and planning to achieve them;
- Determining applicable controls for outsourcing, procurement and contractors;
- Determining what needs to be monitored, measured and evaluated;
- Planning, establishing, implementing and maintaining an audit programme;
- Ensuring continual improvement