Hazard registers are necessary — Mike Massaar

Is it the "hazard register" that is actually necessary? or is it the documentation of what has been agreed on - which could take many different forms. I agree with your points regarding worker participation and consultation in the process, but question if it should be seen as a backroom tool - it is an agreement based on what work needs to be done and what needs to be provided to do that work without excessive risk - not just a reference document to copy into further safety paperwork.
Now this could all just be misunderstandings of what is being meant by those terms, but I feel the bigger issue to first address is to nail down the actual purpose of the "risk register" rather than how it is used.
Risk registers do not manage risk - they are just a record of an agreement. They are not useful to front-line workers for day-to-day work as they have limited means to actual change how work is being done in the present (apart from simply stopping work altogether). They may be useful to those that plan and schedule work - to understand what resources are actually required for a given task, but that depends on the quality of the information recorded - simple "wear PPE" or even "wear safety boots / gloves" does not help those planning work - to actually manage they risk they will still have to delve deeper to understand the risk and what the actual controls should be, i.e. what "gloves" specifically. But too often it is a copy past exercise and then left to the front-line to "tell us what gloves you actually need" while they also have to get started and keep up with the work schedule.

Engagement is a real problem — Carol Tucker

What other engagement "touch points" do you have with your drivers? Do they have weekly/monthly/quarterly reviews with their team leaders or managers? in the non-H&S space how are work issues identified and handled? Find what existing processes you can leverage rather than creating entirely new ones specifically for H&S.
Flip-side - if there are no existing processes don't just focus on implementing something for H&S, work around how you can support the drivers as a whole not just H&S.

Your comment, though, on 11:55pm and 12:05 am potential timing for inspections is valid, although, as you say, absurd. Having inspections exactly seven days apart is ideal, but things like public holidays, pandemics, higher priority work etc. mean that it may not be feasible. Also, the day may not always be suitable for the client. — Dave McBeth

If the intention for weekly inspections was to be so prescriptive in the inspections of scaffolds, it should have been determined to occur 'every seven days' as opposed to weekly. I believe weekly is an indication of frequency, not an arbitrary measure. That way it allows for the vagaries of the workplace without putting undue pressure on those involved. — Dave McBeth

I get the feeling we're basically on the same line of thought but just coming from different directions - essentially "don't take the piss", or more (or less) elegantly put "comply with the intent of the requirement, not just the wording".
Interesting that AS/NZS4576-1995, which has different sections for Australian and NZ requirements, actually states the inspection frequency in both ways:

• Australia - At intervals not exceeding 30 days
• NZ - weekly while the scaffold is in use.

Although this does highlight the arbitrariness of the stated time frames as for essentially the same scaffold you would have to inspected it 4x more frequently in NZ than Australia (under the standard's requirements anyway). And this comes down to the key issue in play - miscommunication; If I say weekly (and I mean within 7 days of the last inspection) and you say weekly (and you mean anytime within the following week), but we don't say the quiet parts out loud then there is an issue. However if we do say the quiet parts that opens the conversation to understand and come to an agreement that both parties accept. In the case of these scaffold inspections I see it as:

• we want the scaffolds to be inspected on a regular basis every 7 days, or so,
• they want to comply with the GPG for scaffolds, without setting themselves up to fail.

then lets agree that inspections will be done approximately every 7 days, i.e. +/- 2 days, to allow for public holidays, pandemics, higher priority work etc. and that if there is a need to push any inspection outside of that time frame the scaffolder just has to let us know when it will be completed.

And this is why I was wanting to gauge the generally accepted "meaning" (hence the poll) - as if the scaffolder's position was more generally accepted (than mine) that would play a big part in the conversations I am currently having.

Good points Matt. You mention that the second part of the definition of a week is an 'additional qualifier' and that the definition of a week should be "a period of seven days". I'm not sure that cherry picking parts of a dictionary definition is great practice. If I was standing in front of a magistrate my sphincter might be giving me trouble at that point. — Dave McBeth

My point was that phrase "generally reckoned" implies there are also other accepted start/end days - e.g. the typical Mon-Sun week, but also that a week could be defined in a contract as beginning on the day the contract is signed and reoccurring on every 7 day after that, e.g. Wed-Tue.
Or in other words the second part of the sentence, "generally reckoned from and to midnight on Saturday night", is only providing an example to both clarify the definition and to provide information on the accepted norms (of the author).
Also this is only the definition "week", which when used in the definition of "weekly" you provided makes the start/end day irrelevant. Which is coincidentally analogous to the discussion on the scaffold inspection frequencies - we can either spend our time debating who's definition is right and who's is wrong (and not really getting anywhere) or we can try to understand the other-side's reasoning for their point of view and come to a mutually beneficial agreement. Which is what S34 of HSWA (PCBU must consult other PCBUs with same duty) is all about anyway.

Thanks@David Sopp - just have to drop in here that you are a SARNZ Life Member and ex-board member just to put a bit more weight behind your reply.

Oxford defines a week as "a period of seven days generally reckoned from and to midnight on Saturday night". — Dave McBeth

My opinion is the first part of that definition is the important part - a period of seven days. The second part is just an additional qualifier that actually reinforces that the "start day" is arbitrary as it is only "generally reckoned", even more so when the other typical convention is a Mon-Sun week.

Other things to consider are that a 13-day gap between inspections would mean a shorter gap for the next inspection — Dave McBeth

Which could literally be done the next day to "tick the box" for the next week. Take this to the extreme and you could (based on a Sun-Sat week) inspect the scaffold at 11:55pm Saturday night for one week, go have a 10 minute smoko break and come back at 12:05am Sunday morning to complete the next weeks inspection. I know that is an absurd conclusion, but it is also a logical conclusion.

he scaffolding company is only one of the PCBUs responsible for scaffolds being 'safe'. — Dave McBeth

This is a key point for me too, and what I think is most important the main contractors (and any subcontractor that uses the scaffold) to understand - the weekly inspections (regardless of how you actually define the time-frames) are actually the back-up measure for a "more" competent person to regularly check that no issues with the scaffold are being missed in the daily checks.

The issue with focusing on developing leadership is that leaders come and go - but that is not to say you shouldn't do it. Train them well enough that they can leave, but treat them well enough that they will stay.

One issue with a reliance on "good leaders" for H&S is the how well is H&S managed in the interim period between filling a leadership role and developing that leader to a point you are comfortable with - this is where you need good systems in place.

but also want to explore temporary suspension of smoke detectors. — Brendon Ward

Best to also check with your insurance too - a lot of commercial policies require a process around the disabling of emergency detection systems.

In previous companies I have works with any disabling of a smoke / fire detection system required a work permit, and that permit required the consideration of; communicating what/how the system has been disabled and how long it was to be disabled for, and the temporary alternative controls to be in place during the system down-time (e.g. fire watch / spotter present at all times with suitable fire fighting equipment such as 2x extinguishers of fire hose).

They could lip read to a certain extent but were in no way good enough to do a whole meeting. — Jono Johnson

I can imagine that this would be even worse if the toolboxes had any sort of actual discussions rather than just the standard "supervisor's spiel and sign the page please" - being hearing impaired and keeping track of what is being said in a group discussion would be a nightmare, let alone being able to effectively be able to input into the conversation themselves.
@Venessa regarding things like meetings/toolboxes, as others have suggested talk to them about the best way for them to communicate, and one suggestion is to ensure that prior to the meeting they have a copy of the meeting/toolbox/etc. agenda or notes and an opportunity to provide written feedback/comments they would like to be raised or discussed. And to check in after meetings that they didn't miss anything being discussed.

This needs to be risk based. Ie: what are the risks if he is behind the tractor? I would break down each part of his expected duties - identify any risks and put controls in place. — Wayne Nicholl

I agree with you @Wayne Nicholl, and from @Venessa other threads/comments I am pretty confident that they will have the general risks/controls identified for the work, so it might be as simple as reviewing if the current controls are effective for someone who is hearing impaired, e.g. if the only warning signal is an audible alarm then additional controls will be needed.

In my experience it is far cheaper to replace nylon web slings than to have them re-certified — Stephen Small

The cost of testing small slings is greater than purchasing new certified slings — Don Ramsay

I think the main point of the post has been missed - as I understood it wasn't concerned for the cost, rather they were concern for the environmental impacts of using these web slings in a non-sustainable way (i.e. disposal of the slings after only one use when they are possibly still "good")

but the manufacture and disposal has an impact on the environment and sustainability. — Lee C

I have seen some companies (well not so much as a company policy but some workers) keep these slings and use them for non-load bearing uses - e.g. securing materials together. However the main issue is them getting accidentally mixed in with the lifting gear.

Sustainability wise - I see this more as a supply chain issue rather than a "re-use" issue, as there will likely be a finite limit to how many slings you can re-use before you just end up collecting a large pile of slings that don't get used but still need to be "maintained". Even those workers that I knew that would keep some slings only had a handful at a time and would still bin those frequently to be replaced when the next load of materials was delivered (so not really solving the actual sustainability issue).
From the suppliers' position, as these slings are normally left on site with the load until it is unpacked/split, accepting returned slings they would take on a fair bit of risk as they have no control of how the slings have been stored (or used) when the slings are "out-of-their-hands", which they would then be using to secure more materials during transport. Maybe your suppliers would be on-board with reducing this waste and the associated environmental impact - but I would expect them to not be keen as safety will likely trump environment in this case.

That really leaves you with the "re-use for other purposes" like 's suggestion, or if someone is making up-cycled kids swing sets.

They only wear the one glove on the non dominant hand. — Venessa

Is this a reasonable compromise? Without great knowledge of the process I would assume it is hard to cut the hand the you are holding the knife with, are the majority of cut injuries to the non-dominant hand holding the produce?

The option to have them sign a waiver is not a viable one as you cannot contract out of your H&S duties (S28 of the Act). However also under the act (S45) an employee has the duty [paraphrasing] to comply with any reasonable instruction from the employer, and to co-operate with any reasonable policy or procedure with regards to H&S. I would assume that the 2-3 employees would be a very small percentage of the total workforce required to wear gloves, and that would be some evidence that the "glove policy" is reasonable - but as says the HR route should be considered as the last resort (and it sounds like you want to avoid going that way too).

It is a fast paced environment and that is one of the issues. To slow down the process for individuals, more staff have been employed . — Venessa

This shows that you have also been considering the other factors leading to this risk, and implemented other measures to reduce the risk (rather than just reaching for the PPE). Have you seen a reduction in cut injuries from this increase in employees / slowing down individual productivity requirements? It may be hard if the gloves were introduced at the same time, but this could be from a discussion with the workers with them providing details on how often they consider the gloves prevented a cut injury, or how quickly the gloves are being damaged or need to be replaced (or a increase in knife sharping frequency if chain-mail gloves are being used). To work with the remaining workers hesitant on the gloves, and to show continual improvement in H&S too, can they work with you to propose alternatives measures to reduce the risk of cut injuries from the task - and if they are feasible and eliminate the need to rely on PPE then you can start looking to remove the requirement for the gloves.

There are 2 or 3 employees who refuse to wear the cut resistant gloves. The employees have been educated in the use of PPE given and discussions held in the toolbox meetings, health and safety meetings as well as speaking to the individuals separately. They are still not wearing the gloves. — Venessa

Non-compliance with a reasonable safety practice can often be not due to the requirement itself but because of a perceived lack of autonomy, input into the requirements or control over the workplace practices. I understand you have worker engagement procedures in place, but are those procedures practical and effective? (both regarding the cut-resistant glove issues, but also possibly unrelated issues).

I would caution about applying the AS4024.3410 standard to a band saw as you would be outside of the scope of that standard.

Taking that clause to mean we are to apply ISO 13857(equivalent to AS/NZS4024.1801), Table 3 states the 550mm distance referenced is only applicable for openings <120mm (square, round, or slot). From Table 5, openings larger than 180mm slot or 240x240 square or round will allow whole-body access. — James

My understanding is when the openings are larger than those allowed for in the tables, etc. for reaching through either; close guarding can be installed with the appropriate sized mesh or similar, or distance guards installed to prevent a person from being able to reach into the "danger zone" from behind the guard.

But without having more of an understanding of the exact setup and operation of the band saw (and copies of the standards) it is difficult to provide any other advice. As the others have said engaging a guarding design expert is likely the best bet. From memory this is usually a TÜV NORD CMSE certification, commonly through Pilz in NZ. Typically the first step would be a machinery guarding risk assessment which should identify the actual hazards/risks associated with the equipment and the level of safeguards required.

....company vehicles and trailers — Roger Claessens

.....especially one that is being towed — Roger Claessens

I would guess one of the main points is that there is no assessment of competency for towing trailers or any other "work related" uses of vehicles in the NZ Driver Licence testing scheme.
As the WorkSafe article says, the trailer's locking handle was not engaged and the safety chain was not attached - two simple safety features that many would consider just "common sense" but unless someone has been taught about these things (either from their company or their parents/family/etc.) they can be completely unknown to someone who has never hitched a trailer.

I am just about to go through an annual review of our SOP and Policy for work vehicles use and am wondering if I am missing something here. — Roger Claessens

Regarding your review, consider what the vehicle-related tasks your employees are required to do. If it is literally just driving to/from locations then the steps you list above, ensuring they have a current licence and monitoring of poor driving (with additional training where necessary), is a likely proportional response to the risk.
However if they are doing other vehicle-related tasks, those outside of what the standard NZ Driving Licence Test assesses competency for, then a separate method of assessing competency for these tasks would be reasonably practicable. For example if towing a trailer is required for work, assessing competency for both the hitching of the trailer and for driving a vehicle towing a trailer (e.g. knowing the speed limit is reduced to 90 km/h for light vehicles towing trailers). Having procedures for these additional vehicle-related tasks would be useful to ensure what is assessed and who is deemed competent is consistent.

Maybe I could have articulated that better. I would like to see a definition that also considers how we store/stack items at height. — Chris Hyndman

I probably could have articulated it better too (or just not been so facetious) :wink:
I agree with you that there isn't enough focus of "work at heights" regarding things other than humans falling.

although it could provoke more focus on things falling and not just people — Chris Hyndman

Is that such a bad thing though?

Every person would get a copy of S190 of the Act. — Andrew

Even though section 190 is specifically related to what other regulatory agencies functions can be, rather than WorkSafe's functions (which the Act S189 effectively just says your function are this Act), I completely agree with you that section is a better guide for WorkSafe to gauge itself against.

I would add to your list to take another look at the Health and Safety at Work Strategy (required under S195) with MBIE (currently for 2019-2028, so we're half way through this period already). The current strategy is baiscally just a list of aspirations rather than a strategic plan, and where there are any actual "strategic" aspects they focus on how the strategy should be developed rather than what the strategy actually is (making the current Health and Safety at Work Strategy effectively pointless).

And get rid of the stupid we're going to cut fatalities/injuries/ill health/etc. by ??% by year 20XX "goals" - create an actual strategy, set specific actions that need to happen to implement that strategy, and then make sure WorkSafe are hitting those actions. They can then look at the data to make sure the actions they expected to improve H&S (in NZ as a whole or under a specific scope) are actually improving H&S - and then review and revise the stragety...

Unfortunately working at height courses tend to only deliver training around harness safety systems, which then somewhat implies that all work at height requires a harness. You can buy a 15m extension ladder and a 9m fixed portable ladder - that's a long way to fall! - but when does a course actually discuss, train or assess ladder safety. Should that be covered on a course, or is that up to the employer to train in house? — Alex P

If they are assessing against NZQA Unit Standard 25045 (which any of the height safety course I look up are) then they should be instrcuting and assessing more than just harness safety systems, as it is pretty clear in the assessment criteria that the course is to cover the common types of height safety equipment employed on height work in the workplace (which to your point specifically includes ladders) - Outcome 1 & 2 > https://www.nzqa.govt.nz/nqfdocs/units/pdf/25045.pdf

I believe if you interpret it in the way of the hierarchy of controls, then it starts to make sense to people. Offering 'controls' for various at height activities could be a good place to start. — Alex P

That is kind of my point, but a bit wider scope - enable workers to be able to assess their workplace task for risks and controls. This will more the likely include needing to consult with them on the common risks and controls for the type of work they are employed to do, but also how to assess and adapt to unusual/uncommon situations, and when/how to defer to others for more guidance.

However that will be less effective if there are other factors in play that is shifting the workers focus from adequately planning work to just getting stuck in and getting it done. These could be direct instructions from the company - e.g. expectations that if you they should be working from the time the clock in to the time they clock out, or indirect instructions - e.g. production schedules that are based on best-case scenarios with no allowance for delays or other issues, or unintended consequences - e.g. incentives for hitting/exceeding production targets / schedules.

From my experience, giving examples alongside the definition is the best way for people to understand what it means in an everyday work context. E.g.
- using a ladder, podium, and temporary work platform
- working on scaffolding
- using an EWP
- standing on a chair/desk to change a light bulb
- working on a flat deck - trailer, ute, etc
- standing at the top/edge of a bluff/cliff/pit — Alex P

This illustrates what I think the issue most have with the broad definition of "work at height", the implication that it is all the same risk and therefore can be manage similarly. But from the examples you see that there are many different scenarios all requiring different risk management approaches.
The working on ladders / scaffold is a classic example - these are commonly listed as examples of working at heights but they are also actually controls for working at heights, confusing the workers even more.

(who are motivated to get the job done) — Matthew Bennett

This is the crux of the matter though - if you are concerned that workers are not spending adequate time to assess the risks of their work because they are motivated to get the job done, then succinct definitions / controls for specific risks is likely to only manage those risk to a limited point. Classic example is workers following the company rules/policies to wear a harnesses when working at height, only to find that on the job that harnesses are either attached to unsuitable anchor points (or not at all) or that the workers would hit the ground before the harness stopped them falling.

So what are those motivations to get started with the physical work ASAP even if that means insufficient planning is being done? Would stepping back to assess and manage these be more beneficial? And not the reinforcement of the "expectations that workers take time for safety", but actually investigating what is driving workers to not spend time really considering the risk of their work?

looking for something that people can read / hear, that then gets them directly to thinking about the influencing factors and options to resolve - I'm just struggling to be it succinctly. — Matthew Bennett

That's the contradiction though - asking workers to think for themselves, but only in the confined scope that has been defined as actual "work of height" so they don't have to think to much.

It works for us safety geeks, however I find it fails to engage the thinking of a lot of workers (who are motivated to get the job done), I suspect because it does expose all the nuance that you identified in the latter part of your response. — Matthew Bennett

I don't know if it even really works for the safety geeks - as in; is it actually that useful to have a set definition of "work at height". As it either is going to be too broad and be ridiculed/ignored because it's interpreted in the extreme - that fall restraint has to be worn to use a step stool; or too limited to not include all cases that it really should - you've set it as work over 3m, but what about working at 2.9m... what about 2.8m... ad absurdum

"Work where there is the potential to fall from one level to another which increase the risk of injury."
Curious though of the actual question behind your question...
My definition above is very broad and would even apply to walking up/down stairs, but the point is how you manage the risk should be proportional to the risk;
Just walking up down stairs, the stairs being well maintained and a handrail is fine - but carrying heavy boxes down the stairs needs more consideration,
Working in the middle of a flat roof 10m away from any edge, no additional controls required - accessing the roof from an unprotected edge, how will that be managed?

Ironically it's a natural human interpretation to interchange the words incident, accident and injury so a LOT of time is spent explaining what we actually mean by the 'belief'. — Rachael

This is why simplified "beliefs" / mantras can be more of a hindrance than a help - if you have to spend the majority of your effort explaining what "belief" actually means, rather than how that "belief" actually makes the situation better - then it likely needs to be either; articulated better (and likely no longer simplified) or just abandoned.

Plus corporate beliefs such as this do not provide any real actionable intent - just because you believe in something doesn't make that so (plenty of examples of this). Plus it doesn't actually ensure that the company takes accountability of their contribution towards an incident - it allows them to continue to pass the buck to others, e.g. the injured worker not following their procedures or more commonly these days the subcontractor.

"We believe all injuries are preventable" — Rachael

I was 25yo and dislocated my knee just bending down to pick up a shuttlecock during a badminton tournament. — Courtney

Even with the "corrected" belief the premise of the OP's question still exists.

There is no real need for corporate safety beliefs or mantras like these, as the only one that would really matter is that the company will provide the workers with the resources (equipment, workers, time, knowledge, practice, etc.) to not be put at unreasonable risk when working... but then all they are really doing is restated their duties under HSWA.

Pessimistically I (and a lot of workers) see these types of statements as a way for a company to look like they are doing something about workplace safety / care about workers' safety, without them having to actually do anything about workplace safety or actually care about workers' safety.

I was somewhat dismayed at MattD2's narrow analysis of the implications my comments alluded to, but conversely encouraged by the insight and understanding evinced by Andrew's responses. He displayed an excellent grasp of the subject matter. Experience certainly aids our understanding. — Rowly Brown

to be fair your original reply on face value was only related to the ACC implications for employers, and did not refer to any other post or detail in this thread, or to it being a secondary consideration to be aware of. In fact the post starts with a statement that the ACC cost implications are an important and significant fact.
I agree that misunderstandings/misinterpretations are easy to occur when context is missing.

The intent of my original reply was just to widen the scope of your comment - and to put it into context that while it is reasonable to have policies in place to limit secondary employment to manage the H&S risks that secondary employment may create for an organisation, that to be cautious if you are only considering the cost implications from ACC when determining if secondary employment should be limited.

After all, the ACC cost implications of workplace accidents are a carrot (or stick) to encourage organisations to manage H&S risks in their workplaces - and therefore the focus should be on managing the H&S risks (i.e. manage the fatigue risks), rather than a direct focus on managing the ACC cost risk (i.e. blanket policies limiting secondary employment without individual consideration).

I know that for some owners / boards / executives seeing the (potential) financial shock of what a workplace injury could mean for their ACC liability can be a driving force for change/improvement - you just have got to be cautious that those changes/improvements are focused in the appropriate direction and not towards unintended consequences.