Comments

  • The boundaries - a professional perspective
    There is no end to doing "all we can".Andrew
    Yes there is - and I clarified this in my reply, but did miss to mention that there will also be actions which don't actually minimise the risk an appreciable extent (especially when considered agajnst the cost/effort required or opportunity cost of other actions). If you are at the point if diminishing returns then you will have minimised the risk so far as reasonably practicable, i.e. done all you can to minimise the risk.

    This is the whole problem with certification - eg "OSH Forklift Licenses". People think they only have to prove their competence once every few years - when it should be assessed/monitored much more regularly. Despite NZ Land transport thinking you only ever need to be assessed once and you are good to go virtually forever from that point on.Andrew
    This is exactly what I meant though. Companies taking the bare minimum statutory requirement (or minimum ACoP guidance) and calling it a day because they have decided it is now an acceptable risk.
    While it is a nice sounding catch-phrase "acceptable risk" is not the same as "reasonably practicable", one is a business decision and the other a legal term. If WorkSafe are coming after you because they deem you have not minimised a risk so far as reasonably practicable they will not give a damn that you consider it an "acceptable risk".
  • The boundaries - a professional perspective
    Give much more attention to any credible likelihood of death from exposure to a hazard (an eruption - yes; an elevator - no)robert parton
    To expand on that - Give much more attention to any credible likelihood of death (or serious injuries) from exposure to a hazard associated with your business (or undertaking)
    an eruption on the island you're running tours on - yes
    an eruption on a island of the coast of the city you work in - no
    riding in an elevator (claustrophobia or not) - no
    supplying elevators - yes
  • The boundaries - a professional perspective
    The Act says the controls-test is reducing risk to "as low as reasonably practicable".PaulReyneke
    Going right back into the purpose of the act is "to provide for a balanced framework to secure the health and safety of workers and workplaces".
    Essentially the act is in place to limit true free-market / Laissez-Faire capitalism by putting in place additional duties that will not typically develop in a pure profit-motive based self regulated market (specifically regarding HSWA the additional duties relate to worker and workplace safety).
    ↪Aaron Marshall I like the idea of "acceptable risk" and your distinciton between hazard maangement and risk management.Andrew
    I personally hate the use of "acceptable risk", or at least how it is generally used in business. The main reason that I hate it is that those that are deciding on what is considered an "acceptable risk" are not normally the ones that are exposed to that "acceptable risk" - e.g. it is the company directors / boards / CEOs / MDs / etc. and that decision is usually one of "we have done enough" rather than "we have done all we can".
    And doing "all we can" isn't having to do everything possible - there will still be actions that are not practical to do immediately, but what can be done is to plan for ways to action these in the future (i.e. continuous improvement).
    Conversely "doing enough" sets a hard stop to managing the risk - nothing more needs to be done because we have already done enough.
    Take the Taxi driver / courier example - doing enough is making sure that their vehicle has a current WOF and rego (and unsafe items will be picked up annually), doing all we can is making sure that their vehicle has a current WOF and rego but also periodically inspecting the vehicles (e.g. monthly) to pick up on unsafe items between inspections. This literally happened in a number of companies when NZTA changed the WOF rules from 6 monthly to annual for "newer" cars, where some companies that had previously accepted that the bare minimum legal requirement of a current WOF was adequate risk management had to question the basis for that decision, and if statutory compliance was the same as managing risk so far as reasonably practicable.
  • Fit Testing of Powered Respirators and Clean Space Masks
    A PAPR has air provided to the wearer via a mechanically filtered pump or an external air supply, so how when these items are switched off, can the wearer inhale air either when fit-testing or when ensuring an airtight face seal.KeithH
    Most (if not all) PAPR supply air via a fan and not a positive displacement pump. When the fan is not operating air can easily bypass it and still be drawn through the filters and into the mask.
  • Fit Testing of Powered Respirators and Clean Space Masks
    A question here. How can a tight fitting respirator based on PAPR become a negative pressure respirator and have an adequate face seal for a person with a beard?KeithH
    It will not have an adequate seal.. Tight fitting respirators require a seal to work. So no beards. Refer to the CDC document below, that stipulates tight fitting PAPR respirators require fit testing. If you have a beard on a tight fitting powered air purifying respirator. (PAPR) you are not expected to pass a fit test.Stuart Keer-Keer
    I think it was a bit of a trick question - the actual answer is a PAPR can never become a negative pressure respirator, as it was not designed as a negative pressure respirator. So not matter how much a PAPR kind of looks like a negative pressure respirator, it should never be considered a negative pressure respirator and if it has stopped operating as a PAPR it should be removed from use and repaired/discarded.
    Edit: Supporting info relevant to the CleanSpace respirators:
    Use of CleanSpace PAPRs by workers with Facial Hair - Manufacture's Statement
  • Fit Testing of Powered Respirators and Clean Space Masks
    We have recently come across Clean space masks which are powered masks that resemble the fittings on the close fitting powered respirators.Stuart Keer-Keer
    I think the key detail that is getting confused here is that the CleanSpace RPE "resembles" a close/tight fitting negative pressure RPE.
    The CleanSpace RPE are being supplied as a Powered Air Purifying Respirator (PAPR), not a negative pressure respirator. Treat it as such when developing your RPE procedures.

    All respirators (PAPR and NP) are required to fit the user, e.g. selecting the correct size (and sometimes brand/model), and confirming it fits as per the manufacturers instructions/requirements.
    Negative Pressure RPE are also required to check that the seal between the face and mask is not leaking to confirm that incoming air is passing through the filters and not bypassing through a leak in the seal. PAPR do no require this as their design ensures that air is drawn through the filters (and will blow out through any gaps between the RPE and the users face/body).

    However critical for PAPR is to ensure that the are working correctly when in use, such as making sure that;
    • Masks / hoods fit as per the manufacturers requirements - the initial (and periodic) fit-check above
    • Fans operate continuously (batteries, breakdowns) - periodic maintenance and incident reporting
    • Filters are changed out when required - filter replacement program.

    So to answer your question of "The question is has anyone any views on testing the Clean Space masks, if so do they do it in the powered on mode or power off mode?"
    They are designed as PAPR, so issue them as PAPR.
    Asking if you should test them powered on or off is somewhat illogical because this has no bearing on if the mask (i.e. the shape/size) fits the users face - so I guess my answer is both, do a general fit with the power off to make sure the mask is comfortable, but also power on to check for any large leaks or disruptive leaks (such as around the bridge of the nose directing a flow of air into the eyes). Make sure they fit as per the manufacturers instructions/requirements.
    But critically if you are using PAPR make sure your RPE procedures manage the risks associated with PAPR. And finally don't assume that just because they look like a negative pressure respirator that they can continue to be used as a negative pressure respirator if the batteries die or the fans break down.
    Edit: Added references:
    Respiratory Protection for Workers with Facial Hair - Australia
    Note: CleanSpace actually recommends in the (Australian specific) guidance for demonstrating compliance with employer’s legal obligations a "protection factor" test following the US OSHA regulations (rather than the AS/NZS standard) in power-on mode. This conflicts with OSHA 1910:134 as the fit testing requirements specifically states to test in power off mode, however the testing is only required for tight fitting masks (negative or positive pressure). Therefore the way I would interpret CleanSpace's guidelines is that while OSHA 1910:134 fit testing is not legally required for the CleanSpace respirators (as they are not consider to be tight-fitting masks that rely on the seal between the mask and face to function properly), a fit test should be completed to confirm the respirator does provide the employee with the required level of protection (i.e. Protection Factor / required reduction in airborne contamination)... i.e. ass-covering if I am being facetious.
    PAPR typically are assigned a Protection Factor of 50, while cleanSpaces studies have resulted in an average Workplace Protection Factor of over 8000, with the lowest ever result of 105 (i.e. the worst ever result was still twice as good as the assigned protection factor). Given the operation and CleanSpace studies data I would be comfortable forgoing the recomended "protection factor" test as long as the general fitting was being monitored for effectiveness.
  • Prescription cannabis - how to deal with it?
    All D&A policies should have a clause for employee disclosure of the use of prescribed drugs which have the potential to affect the employee's ability to perform their assigned tasks safely / effectively, and therefore "the issue of people taking prescribed cannabis" is really a moot point as it should already be accounted for, the same as someone taking strong painkillers would be.
  • Health & Wellbeing Allowances
    Our staff asked for an allowance, several figures were mentioned, and after some research we agreed on $400. The uptake has been good, no red tape or hoops to jump through.Stuart Oakey
    It is good to hear that you have had good uptake on the allowance, and that barriers to participating seem to be low. Have you had / ask for feedback from those that have not decided to participate? (just out of interest in why they wouldn't).

    However the main point I was attempting to make is that when the value that an employee adds to a company vs the remuneration that they receive for adding that value is compared, that the value of these additional allowances are effectively a drop in the ocean and could be a lot more - but that is going to take a major (societal level) rethink of how our economic system values work/workers and how the benefits from that work is allocated to best benefit society as a whole.

    agree but we already give discretionary leave, flexible working conditions where roles allow, wellness days and the organization is moving towards the living wage. Staff get lots of benefits and giving them tokens to contribute towards their health means they actually spend that money on their health which has benefits for them and us. It might be this week they can spend that money they would have spent on a GP visit to pay for extra living costs.Jaylene Barwick
    It's hard to argue the point because there is an element of truth that "well at the bare minimum they are better of with this allowance in place than without it", however it goes back to the question - who has the right to dictate what an individual spend their money on? Unless you are more genuine with the reasoning behind it, as you said your company gets the benefit of healthier workers (e.g. more productive / less "waste" / etc.) - again not denying that the workers also get benefit, but that's not really the sole purpose if we really get down into it.
    Again my main point isn't that these allowances are bad, it is that they are masking what could be done to address the growing social issues in NZ (and most other "western" countries). As an example, should it really be hard that for a company with an average wage 1.7x the living wage to move towards paying at minimum a living wage to all their workers? The C-Suite of most companies (that are not owner/operator) could probably finance the extra $0.95 per hour to those currently on minimum wage (or even more) out of their own paychecks without any noticeable change in their own standard of living. Or it could be funded out of a company's net income - however for For-Profit companies this would likely have a negative affect on the company's value / shareholder dividends / etc. and therefore not be an attractive option to Boards / Senior Management that want to keep their jobs.

    To clarify, I'm not saying that those that have made these small gains/wins for their employees should be doing more, or that they shouldn't be celebrated. What has been done is important and should continue. What I am saying is to be open to thinking more broadly about how companies are operated and for who's real benefit - after all when we have a company, that makes (a global average of) NZ$16,000 of profit each year out of every one of its workers, needing to take the time to figure out if giving those workers an extra $400 a year is not enough / too much it starts to become clearer who that company is really focused on benefiting.
  • Health & Wellbeing Allowances
    Id be somewhat cautious about where you are getting your data from.Andrew
    I was referring to this older 2020 article in Stuff referencing a survey done by Finder (first somewhat recent source that came up). A more recent Newshub article this year refers to a survey that found 39% of NZ'ers could not cover a $5000 unexpected cost within a week without going into debt, and of the 1/4 of NZ'ers that do not current save any of their income nearly half is because the are living paycheck to paycheck.

    And lets not forget the unseen Working For Families which tops up every workers pay if they have kids.Andrew
    Not every worker with kids, it is means tested. And what was the point of even bringing this up?

    You may be surprised with just how much Leave without Pay our people take.Andrew
    Have you asked why so many are taking leave without pay? When I see stats like that I am curious as to why, instead of chalking it up to employees who just don't want to turn up for work.
    An example is if the current minimum leave entitlements in NZ re reflective of what life in NZ is actually like nowadays for a lot of families - common point on this is with most families needing 2 working parents, how does 8 total weeks of paid annual leave cover 12 weeks of school holidays, let alone actually getting to spend time with the whole family being together.

    But we fully subsidize the insurance and there are quite a number of employees who get significant benefit form it.Andrew
    Yes those employees got the benefit of the health insurance being in place, but would it be fair to say the main benefit of that insurance cover is to minimise the risk to the company of employees taking extended leave due to injuries/medical issues covered by the policy (i.e. save on costs of overtime/temp cover, retraining for other roles, recruitment costs, etc.).
    Honestly is the question you and your management ask when you sit down really "should we just give them the money we'd be spending on health insureance for them", or is it more "is it better for our bottom line to cover the health insurances for our workers (all things considered)"?
  • Health & Wellbeing Allowances
    Companies choice what package options are includedJaylene Barwick
    They can spend on things that improve their wellbeing e.g. gym memberships, sportswear/equipment, medical/health expenses etc.Ange White
    Wellness extends to house insulation, sportswear, chiropractors etc. Equipment for hunting allows clothing and hiking/camping equipment but not firearms.Alex
    Are these examples of what Andrew was referring to as
    an employer moving into an employees private life.Andrew

    What in the company give them better knowledge and understanding of hiw their employees "best spend" their money?

    What's to say making their rent payment this week or being able to afford more than beans on toast for their family's dinner doesn't "improve wellbeing"? You know - the stuff that paying them a decent wage would already account for, without the need for a household to have over 2 full time jobs to support.

    If you want to go further to support your employees past paying them what they need for a decent life, provide them with the information and opportunities to improve their lives rather than a $XXX wellbeing allowance token gesture. How about providing employees information
    , suppport and access to courses on things like general household budgeting, or providing them with discretionary leave for important home-life appointments that have to be done during the workday (including stuff like actually getting to see their kids school performances / assemblies / sporting events / etc.).
  • Health & Wellbeing Allowances
    If you have $500 to spend on employees I'd recommend subsidizing health insurance.Andrew
    With over a third of NZ'er living pay check to pay check I wonder how much employee wellbeing would be improve by just giving them the $500 extra to spend on unexpected costs or just the day-to-day expenses they face rather than dictating how they should spend their money.

    Employee claims the benefit via an expense claim (so they make the purchase, keep receipt and claim the expense back).Ange White
    Has the possibility for some employees to be "missing out" on using their benefit because they can't afford to bridge the gap between the purchase and when they are reimbursed been considered?

    ...ask people what it is about their work that leaves them feeling unwell (physically or mentally) and then work with them to experiment on making changes to work to address their concerns?Peter Bateman
    Our people asked for the allowance, which our leadership team support.Stuart Oakey
    I would have to assume they have asked for what they expected they could get, rather than what they really want/need to improve their wellbeing. $400 a year (which most workers likely won't actually take up due to the effort and hoops to jump through to get it) is minuscule when compare to the surplus value of their labour that is shared around to those whose only effective contribution is "having an excess of money" rather than those workers actually adding value to the company. However I would also assume that no self-preserving board / C-suite would support an initiative that would be really detrimental to the shareholders, and so the token gesture of wellbeing allowances will continue.

    It might mean hiring more people to spread the workload, for example.Peter Bateman
    This could lead to some unintended consequences - while most workplaces could probably do with additional workers to improve safety (less stress, less fatigue, etc.), a good number of workers I talked to rely on the overtime pay just to get by (or at least live a little bit more comfortably). Take that overtime away and I would expect those in this situation's overall stress to actually go up and well-being to go down. Essentially we have a large amount of our workforce that basically have to run themselves into the ground just to (ironically) survive.
  • Risk review timeline
    Further to your points re: "old school thinking" does the Plan-Do-Check-Act cycle that a lot of management systems (and standards) are based around exacerbate this thinking by continuing a focus on a set frequency of the management reviews, e.g. monthly / 6-monthly / annually (which may or may not be adjusted to a unique frequency for each identified risk such as is referred in the OP), rather than considering reviews when there is a change to the risk or how the risk is being effectively managed.

    I've seen this commonly materialise in "XYZ period" board / senior management risks review meetings, which (after reading through the risk register for the n'th time) end up just re-approving the status-quo without any deeper thought since; everything seems alright on the surface and there hasn't been any major incidents relating to the risk and nothing else seems to have prompted this review except for it came up for its "XYZ period" review. With more frequent reviews sometimes actually make the problem worst - after all if nothing has changed but they still have to review a risk every monthly meeting then a tick-n-flick mentality can easily develop.

    However if we look to the regulations instead for guidance they actually set-out a reasonably well defined list of prompts for when to review your risks and control measures in Reg 8 (of the General Risks and Workplace Management Regulations), in summary;
    1. if the control measure no longer controls the risk
    2. when there is a change to the workplace or how work is to be done
    3. if a new hazard/risk is identified
    4. if a health monitoring report indicates that there has been an unsafe exposure to a worker
    5. if exposure monitoring indicates that there has been a breach of a Workplace Exposure Standard
    6. due to consultation with the workers, H&S representative or H&S committee
    None of the above are set by a define time period, so (technically) if you are reviewing your risks only on the basis of a set frequency you could unintentionally run afoul of the law.

    #1 & #3 are probably the "hardest" to figure out when they actually are prompting a review is required, since it requires you to basically review the risks to know whether you should review the risks.
    #1 is where clarification of the Check aspect of the PDCA cycle is needed. This shouldn't be (re)checking the Plan, i.e. Check isn't periodically reviewing the risks and control measures on the risk register (as is common place in most senior management risk review meetings). It rather should be checking the plan is working, i.e. monitoring the control measures are in place and are still effectively managing their related risk. Effective monitoring programs are key to ensuring the relevant information filters up to management to inform them when making decisions regarding allocation of resources.
    #3 is very reliant on the other prompts - generally hazards/risks don't materialise out of nowhere, but rather when there is a change. Having a process to identify and manage these changes is key - which relies on the other points, specifically #2 and #6 (with #4 & #5 being essentially one of the means of monitoring control measures mentioned earlier for #1).

    So back to the question in the OP - my thoughts; start steering our boards, senior managers, etc. to re-frame the question from "how frequently should we review critical risks" to "how confident are we that we are managing critical risks", with leading them towards how they can establish that confidence by reviewing the information that comes from the monitoring of the control measures.
    This however requires that there is effective monitoring of the control measures to confirm they are in place as expected and they are managing the risk as expected. Essentially this is changing from a typical KPI regime focused on lead and lag indicators to one related to verification and validation. As an example; if you identify a risk of process upsets due to the miscommunication of process conditions during shift change-over, and you implement a 15-minute shift-handover debrief meeting between each two shifts to manage this risk - then you might verify the control is in place by recording the % of shift-changovers that these meetings are held each week/month, and validate it is actually working by recording the number of production upsets that occur each week/month (that could have been avoided if the shift had additional information from the previous shift). Reporting to management when either of these indicate the control measure isn't working as intended - so management can review and allocate additional resources as required (either to strengthen the control measure or implement an alternative).
  • AS/NZS 2865-2001 vs AS 2865-2009 Definition of a confined space
    Thanks for the extra info David.

    It's frustrating that, while it was an intentional move by Standards NZ to drop 2865 as a joint standard and leave Australia to solely take the reigns on it, they didn't take the final step and actually discontinue the 2001 joint standard version from their catalogue.
  • ISO 45001 Standard Document
    With all due respect, these are only $NZ300 each to purchase and download from here. The AS/NZS standards are slightly more expensive.KeithH
    They are only NZ$108.90 and $123.30 respectively for the AS/NZS versions from Standards NZ (AS/NZS ISO 45001:2018 & AS/NZS ISO 19011:2019/)

    For a company looking to be certified to these standards the cost of the actual standard will generally be a very small percentage of the actual overall cost of getting certified.
  • The Value Of A Life
    If people want to go down the path of valuing a human life they ought to at least try to do it accurately.Andrew
    But what is accurate in this endevour (and conversation) anyway - either source you choose from your figures is essentially just a thumb-suck, a somewhat arbitrary monitory value that (a sample of) society has placed on the cost it is willing to pay to prevent 1 additional death. Which is literally comparing the cost of saving lives with the opportunity cost of using that money for any other purposes.

    The real issue isn't that we a placing a specific value on a human life, rather it is that we live in a system that to function correctly has to place a specific value on a human life. As you mentioned in this system we should actually be directing more of the risk reduction to those that we value more in society (the workers that can command a higher wage because of their skills) - because those workers will create more growth and returns compared to the less valued workers (which is why they are valued more in the first place), which (as judged by the system) will create more benefits to society as a whole, e.g. rising standard of living, wealth creation, etc.
    [For clarity - these are my thoughts on the system, not my thoughts on how things should be].

    Maybe we should look after people simply because it is the right thing to do.Andrew
    I agree with this, but it will never really happen until we actually value all people equally irrespective of their skills or what benifits they can provide compared to others. If we continue to place a "market value" on each person, then there will always be justification to look after some people more than others. Whereas if we value that each person is contributing to society the best they can, it's hard to justify looking after one person more than another.
  • The Value Of A Life
    You could crudely use the QALY x remaining life expectancy for a more accurate figure.Andrew
    H&S Professional: I recommend we spend $XYZ to reduce the risk of fatality or life altering injuries' to our workers because it is less than the calculated "QALY x remaining life expectancy" value of our workforce.
    Board: Fire everyone under the age of 60 and our new hiring policy is only hire workers that are older than 60 and with existing medical conditions...

    While that is absurdly extreme (and illegal from a workplace discrimination standpoint) it is one path that the discussion of the "value" of a life can take us, one that the continual measures of success of a company being based on growth and shareholder value maximisation will inevitably take us down (although we may essentially be there already).
  • The Value Of A Life
    And at the same time, it increased an esoteric number called the VoSL – the Value of a Statistical Life – from $4.88m to a somewhat breathtaking $12.5m. That's an even bigger increase.Steve H
    I can't find any other sources stating that they have increased their VoSL to $12.5M - and from the section in the report it is referring to the 2021 VoSL which was still $4.88M (Social cost of road crashes and injuries June 2021 update.
    Damage costs in Table 9 have been calculated based on the 2021 value of life years (VoLY) derived from the 2021 value of statistical life (VoSL) of $12,500,000 (NZ$)...NZTA's Monitised benefits and costs manual V1.6
    That sentence is a bit ambiguous and the $12.5M might actually be referring to the value of life years (VoLY) which (from my understanding) is more of a health based value, which makes sense as the section it is referrenced in is regarding the costs of damage due to emissions (i.e. it is factoring in both fatalities and decreases in health outcomes into the cost).
  • D&A testing type
    When I was a NZDDA (TDDA now) tester, it was well known in our industry that saliva testing was the least reliable and only identified recent use.Mandy Gudgeon
    Shouldn't we only want to identify recent use? I.e. detect impairment?

    From some quick reading a article referring to a University of Sydney study reported that impairment from THC was generally around 4 hours after use (or 6-7 hours if high doses or complex tasks are being done), and another source stated that oral THC test can detect use up to 12 hours prior (or longer for heavy / long-time users). Other drugs such as amphetamines or MDMA were detected for around 2 days after use. Seems like the decently matched situation to use oral testing to check for the potentail for impairment, without overstepping into a workers home life. After all we should really be focusing on managing workplace health and safety risks - rather than morally judging our workers private lives.
  • HSR1 Courses
    Why not ask the rep what additional training they would like to do?Robb
    And also what they remember from the HSR1 training, if they can:
    • Explain the role and functions of the Health and Safety Representative under the Health and Safety at Work Act 2015 and its Regulations;
    • Explain the role of a Health and Safety Representative as an advocate for workers;
    • Identify the obligations of a PCBU and WorkSafe New Zealand towards the Health and Safety Representative;
    • Describe the risk management process and the importance of communication with workers and management;
    • Describe the purpose, procedures and obligations applicable to a Provisional Improvement Notice (PIN); and
    • Describe the rights and process for ceasing unsafe work.
    Then there is little real value in sending them on a HSR1 course again, if they can't then they likely would get value out of the course.