Health and Safety legislation imposes a primary duty on employers to provide and maintain a workplace that is safe and without risk to health so far as is reasonably practicable. This duty is broad, but it requires a business to have a clear understanding of the hazards that exist due to its operations. A business must also be able to demonstrate due process in relation to the controls established to mitigate the risk associated with these hazards. One of the most effective ways to prioritise and track risk management activities is via the use of a risk register. A risk register enables a business to compile operational hazards into the one concise document for the purpose of prioritizing action based on risk consequence level and tracking the short, medium and long term actions taken (including timeframes for implementation) to control such risk. In this article, we will explore how to establish a health and safety risk register and how to use this register to guide your work health and safety risk management strategy.
Confined space entry, hazardous energy sources, crushing/cutting/entanglement plant risk, work at height, traffic management, asbestos, manual handling, noise. These are some of the hazards that we may encounter. So, where do we begin? How do you go about establishing a health and safety risk register? Let’s explore this in some detail.
Establishing a health and safety risk register;
A risk register must list the specific operational hazards associated with the manufacturing businesses operations. Each item listed on the register must be allocated:
- An identification number (i.e. ID #1 or 19-01 (year and item number));
- A hazard category (confined space, hazardous energy, manual handling);
- An item description (brief description of hazard);
- An initial risk rating. Risk is most commonly quantified via the use of a risk matrix such as ISO31000 (2009): Risk Management – Principles and Guidelines. Using this matrix, risk is quantified in terms of likelihood of occurrence and seriousness of impact or consequence. A risk rating (extreme, high, medium or low) is then assigned which enables the prioritisation of action according to the level of risk.
Tip: When interpreting the items on the risk register, give careful consideration to risk items listed on the register that are assigned a low likelihood of occurrence but high potential consequence outcome (i.e. risk of fatality or several fatalities). These low potential, high consequence risks represent activities such as entry into a confined space, isolation of hazardous energy sources, plant and equipment set-up/operation/maintenance, operation of mobile plant/equipment and working at height. Although the potential likelihood of occurrence is low with these activities, the outcome may disastrous should a severe incident occur. Such items must have well documented risk control actions assigned, including sound systems of work.
- Detailed Risk Control actions that are in accordance with the risk control hierarchy (elimination, substitution, engineering/isolation, administration, training/personal protective equipment).
Tip: Consideration should be given to the establishment of short (administrative/procedural based controls), medium (engineering based controls) and longer term actions (elimination/engineering/isolation based controls) when assigning risk control actions.
- Be assigned a date of commencement. Control methods must be established with a sense of urgency, especially for high-risk items;
- Be assigned a residual risk score. The residual risk score (extreme, high, medium, low) is the risk rating assigned to an item following the implementation of a risk control.
- Be assigned a proposed date of completion. Specific dates of proposed item completion must be assigned and these dates must be realistic to achieve.
Tip: Wording such as ‘in-progress’, ‘not-started’ or ‘on-hold’ must not be tolerated on the register. Specific dates must be used.
- Establishing a strategy to manage the risk associated with the risk items identified on the risk register.
Following the establishment of the health and safety risk register, a strategy should must be developed to:
- Set the organisational goals in terms of the management and control of the organisations top five high-risk health and safety items. In the case of manufacturing plants such high-risk items are generally:
- Plant related risk (i.e. entanglement, entrapment, cutting, crushing);
- Work at height (use of elevating work platforms, work on ladders);
- Mobile plant (i.e. forklifts) and potential interaction with pedestrians (i.e. internal movements of forklifts inside a manufacturing plant, loading/unloading of vehicles);
- Confined space entry (i.e. interaction with hazardous atmospheric contaminants, hazardous energy sources, works undertaken in the space).
- Allocate organisational responsibility and accountability. Specific leadership performance guidelines must be established in accordance with the businesses governance structure;
- Allocate a demonstrable budget that matches the risk controls required to mitigate the businesses high risk health and safety items;
Tip: Consideration must be given to sourcing any available technologies that may be utilised in relation to upgrading existing control measures.
- Establish positive performance measures, including:
- Number of high risk items listed on register for a defined reporting period;
- Number of high-risk items closed out or downgraded (reduced residual risk rating) for a defined reporting period.
- Officers of the business must ensure that a sound oversight process is established to enable scrutiny of plan progression. Minutes must be kept and any variance against the plan must be justified by managerial/operational/health and safety personnel with new timeframes agreed.
In closing, the measurement/quantification of risk can be very subjective. As such it is vital to ensure that operational risk is quantified objectively in a way that can be measured. A risk register can provide such objectivity. Specific timeframes and sound oversight measures must be established to ensure that actions taken to control risk are reasonable given the level of risk assigned to each item.