WHS management plan

The model work health and safety regulations require the principal contractor for a construction project to prepare a written WHS management plan before work on the project starts. The regulations also set out what it has to deal with, which is narrower and more practical than the documents most builders submit.

Responsibilities. The names, positions and health and safety responsibilities of everyone at the workplace whose position involves specific health and safety responsibilities.

Consultation, cooperation and coordination. The arrangements between the businesses working on the project for consulting and coordinating with each other, which is the clause that underpins interface management between trades.

Incident management. The arrangements for managing work health and safety incidents on the project, including who does what and how they are reported.

Site specific rules. Any site specific health and safety rules, and the arrangements for making sure everyone at the workplace is informed of them.

SWMS arrangements. The arrangements for collecting the safe work method statements for high risk construction work, and for assessing, monitoring and reviewing them.

The plan also has to be kept up to date, and the principal contractor has to make sure that each person carrying out construction work is aware of its content. A plan submitted once, accepted, and never mentioned again does not meet that last requirement.

Three documents with overlapping names sit at different levels, and clients regularly ask for one while meaning another.

The WHS management plan is the project level safety document. One per project, prepared by the principal contractor, addressing how safety is organised across the whole site.

A safe work method statement is the task level document. One per item of high risk construction work, prepared by the business doing that work, describing the hazards of that task and the controls for it. The WHS management plan explains how SWMS are collected and reviewed; it does not replace them.

A construction management plan is usually a planning document, not a safety one. It is commonly a condition of development consent, prepared for the council, and covers matters like hours of work, noise and vibration, dust, waste, deliveries, traffic and neighbour notification. Some of its content overlaps with safety, but its audience is the consent authority.

The corporate safety management system sits above all three. It is the company's standing system, and the WHS management plan is where that system is cut down to this project, this site and these people.

The trigger is a construction project, which the model regulations define as construction work where the cost of the work is $250,000 or more. On a project at or above that figure, the principal contractor must prepare the plan before work starts.

Below the threshold there is no specific plan duty, but the general duties do not change. The business still has to manage risks so far as is reasonably practicable, still needs SWMS for high risk construction work, and still has to consult and coordinate with the other businesses involved. Most builders keep a scaled down plan for smaller jobs simply because it is the only practical way to discharge those duties consistently.

Victoria sits outside the model framework, operating under its own Occupational Health and Safety Act and Regulations, and Western Australia has its own work health and safety regulations. The requirement to plan safety for a construction site exists in each jurisdiction, but the thresholds, the document names and the prescribed content differ, so a national builder should not assume one template satisfies every state.

Clients add their own requirements on top. Government and tier one private clients commonly specify the plan's structure, review periods and approval process in the contract, and those requirements are usually more demanding than the regulations.

Submitting the corporate system with a project name on the cover. The regulations ask for site specific content: these people, these rules, this site. A generic document answers none of it.

Missing the named responsibilities. The requirement is names and positions, not an organisation chart of job titles. When the people change, the plan changes.

No evidence anyone was told. The duty to make workers aware of the content is separate from the duty to prepare the plan. The induction record is usually the only proof that happened.

Writing it after mobilisation. The plan is required before work starts, and a plan dated two weeks into the job is a finding on its own.

Treating it as the safety system. The plan describes the arrangements. The SWMS, permits, inductions, inspections and incident records are what actually demonstrate they operated.

Leaving the SWMS arrangements vague. Saying SWMS will be collected is not an arrangement for assessing, monitoring and reviewing them. Name who reviews, against what, and how often.

Never revising it. Stages change, the trades change, the site changes. A plan that still describes the establishment phase halfway through the job has stopped being a control.