Risk assessment still vital under new Victorian regulations

By Pilz Australia
Friday, 21 September, 2007

The new Victorian Occupational Health and Safety Regulations are designed to simplify safety but, in the case of risk assessments, their release has caused real confusion.

For years, employers have been told to systematically identify workplace hazards, assess the risks associated with each hazard and put controls in place to eliminate or minimise the risks. All that changed with the introduction of Victoria's new Occupational Health and Safety Regulations 2007, which no longer mandate the risk assessment. Or did it?

Pilz staff members recently returned from a training session where the trainer was sure risk assessments were no longer required. The reality is that in the case of almost every piece of machinery Pilz's clients deal with, from press brakes to brick stackers, risk assessments are still absolutely essential.

When a risk assessment is a must

WorkSafe Victoria's guidelines say that the only time risk assessments are unnecessary is when "a risk is well known and the solution is obvious" and that they should be performed whenever:

  • there is only limited knowledge about a hazard or risk or how the risk may result in injury or illness
  • there is uncertainty about whether all of the things that can go wrong have been found
  • the situation involves a number of different hazards that are part of the same work process or piece of plant and there is a lack of understanding about how the hazards may impact on each other to produce new or greater risks

New industrial machinery generally fits at least two of these three criteria.

The spirit of the new regulations: a greater focus on fixing the problem

The new regulations are not designed to water down safety by eliminating mandatory risk assessments but, instead, to throw the emphasis on controls.

In WorkSafe Victoria's response to the regulatory impact statement, the regulator said: "...mandating risk assessments may be a barrier to the implementation of risk controls. For example, where hazards and risks are well known and there are universally accepted control measures, a duty holder may identify the hazard and implement the appropriate control without doing a risk assessment. In these cases, a risk assessment would yield no new knowledge and would be likely to delay the implementation of controls."

In other words, if the way to deal with the hazard is obvious, don't wait for a formal risk assessment before you make the workplace safe. This commonsense approach has long been taken by most employers, irrespective of the law.

The risk assessment's place in plant safety standard AS 4024.1

The value of a risk assessment lies in its systematic approach to identifying:

  • the levels of harm that can occur
  • how harm can occur
  • the likelihood that harm will occur

These are very basic questions and, without answering them (whether you document those answers or not) it is impossible to know which, if any, controls are appropriate for a hazard.

Australia's principal machinery safety standard, AS4024.1, draws on this logic. The controls are chosen based on the frequency of exposure to the hazard, the ability of the worker to avoid the hazard and the severity of any injuries.

When in doubt, assess the risk

The bottom line is that if there is any doubt at all about whether a risk assessment is needed, it certainly is. Risk assessments do not need to be long and wordy documents "” a checklist with tick boxes is perfectly adequate in most cases "” but they are invaluable aids in making sure safety has been carefully considered: great for workers and employers alike.

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