• Simon Lawrence
    107
    My Safety Myth Post #8 concerns Hazard Registers. I think they are important and that if they are properly done, they should sit at the centre of the safety system generating a lot of activity. In reality, they are half-hearted, generic and largely symbolic. Symptomatic of the once-over-lightly/tick-and-flick approach of many employers

    Any comments?
  • craig christie
    2
    Simon, we do have a general hazard register but I totally agree they really don,t serve accurate risk management. In saying that there are some generic hazards that would appear on every site.We would normally work though site specific risks via safe work method statement with the people doing the work to achieve accuracy
  • Mandy Gudgeon
    1
    Simon absolutely!
    Hazard/Risk registers are pivotal to a sound safety management system. I also agree with the comment of Craig's regarding generic hazards, they do exist. The challenge is for multi site operations to ensure site specific hazards and risks are captured as well. The gem here is employee involvement and ownership of their site's challenges/issues - from their its is much easier for employees to grasp the bigger picture and to obtain their buy in. Our data management program supports and enables this activity of continuous improvement that divisional and line managers can monitor and maintain.
  • Rowly Brown
    14
    Simon, I agree with you that Hazard Registers are important and if properly done are central to a lot of health and safety activity. I also agree that they are generally poorly constructed, generic, symbolic, and generally exist because someone heard somewhere that a business had to have one.
    Hazard Registers are not legally mandated, but it is a legislated requirement to identify and assess hazards. Proving that this has been done to a Worksafe Inspector or a judge is most easily achieved by having some form of record of those identified hazards, and a Hazard Register is probably what they would be looking for. There are other ways of recording hazards, such as JTA’s, WMS’s, SOP’s etc, and in fact they could all collectively constitute a hazard register, but a comprehensive record called a Hazard Register is probably the most practical.
    Previously businesses were required to identify hazards, and then assess whether or not they were a Significant Hazard, i.e. an actual or potential source of Serious Harm (as defined). Under the HSAW Act wording of the requirement has changed slightly; hazards must still be identified but now “a PCBU, in managing risks to health and safety, must identify hazards that could give rise to reasonably foreseeable risks to health and safety”.

    Based on the way that most HS practitioners and commentators, and consequently employers use the terms hazard and risk clear that they have not discerned the difference between “hazard” and “risk” and when this confusion/lack of understanding is manifested in Hazard registers the result is the epitome of our opening comments. (See the article “Lost in the Matrix ” in the July/August 2020 edition of Safeguard Magazine).

    A hazard register should have at least 4 components, but to be really useful and effectual at least an additional 3.
    1. A description of the identified source of harm/damage;
    2. A Rating of the level of risk the raw hazard presents based on an assessment of Severity, Frequency of Exposure, and Probability of Occurrence. These components are best expressed numerically using large numerical groups, e.g. S – 50; F/E – 20; P – 20.
    3. A description of the practicable controls to be applied to risk.
    4. A Revised Rating of the level of risk anticipated when all the available practicable controls are in place.
    There may be many elemental controls available, some able to be implemented collectively, and some implemented in the alternative. Where alternative controls might be possible/available alternative control should be rated separately and then the ratings compared]. Breaking down (analysing) the definition of Reasonably Practicable and applying it to the available control options the most practicable control can be identified by the attendant reduction in risk.

    Additional components to a hazard register might include (5) a description of the location where the hazard exists, (6) roles/tasks/persons exposed, and(7) the frequency with which the effectiveness of the controls/reassessment of risk should be reviewed.

    If hazard registers aren’t able to show a reduction in risk when controls are applied then the argument that “reasonably practicable steps” have been taken will be a difficult one to win. In such instances the register pretty much represents a simple form filling exercise.
  • Andrew
    298
    The "risk register" is probably my number one most important resource.

    Its where I keep, for each separate work area:
    - all our identified risks - so it keeps growing as we find more and shrinking as we get rid of some.
    - visibility of how the risk is rated relative to other risks (Using the patented FARK scale)
    - A summary of each decision point on how the risk is managed - eg why it can't be eliminated and what controls such as engineering changes have been decided on. Down to the required PPE
    - A repository of relevant, reference and related documents eg Worksafe guides, SDS and SOPs

    Most importantly, for me, every employee has access to all this information - firstly for their own work area, but they can also see every other work area.

    It also helpful for inventory management. For example if I want to know what all me chemicals are or where all my "noisy" areas I can easily grab this information
  • Sheri Greenwell
    190
    YES!! But somehow very few safety people even really know how to go about creating a meaningful and useful risk register.

    It is so helpful to start with understanding what you want the risk register to do for you and who is the intended audience - so often that gets lost at the start, and they end up with a jumbled mess that no one can use.

    I am very fortunate to be working with a company at the moment that really gets this. They have a Master Risk Register that covers the entire organisation, and from which site risk registers are created - already that keeps everything strategically and operationally well aligned. Potential consequences are identified, but assessment of likelihood and risk score are kept in the background for the H&S Team to manage. Controls are identified in two main categories - engineering controls and administrative controls. Administrative controls list relevant SOPs, regulatory or industry standards, or elements such as training, The details are in the references listed under the controls. I have seen too many risk registers with a whole list of instructions that should rightly be in a relevant SOP or work instructions. Otherwise you end up with a document that is too complicated for workers to use and too cluttered for executives to use.

    Site managers and HSRs are trained how to use the risk registers as a tool for incident investigation, hazard identification and risk management. They are responsible for reviewing and maintaining their own site register as well as their site H&S Plan, which is also aligned / a subset of the organisation's strategic H&S Plan.

    Site risk registers and H&S Plans are accessible to all via the company's intranet.
  • Mark Kenny-Beveridge
    24
    Following on from this; how are we all keeping our registers? i.e. excel sheets, software etc and what are people finding useful (i.e. easily accessible and meaningful)
  • MattD2
    128
    I have to admit when I read your thread title I can't help myself from singing the second and third lines of "War"... but that's just my facetious tendencies creeping out :wink:
    I do want to throw out an auxiliary question to the Brains Trust - does a hazard/risk register have to be a register at all?
    If the methods that you use to do business includes the identification, assessment, control and monitoring of risks - do these need to be transferred into a single central list of all hazards?
  • Tim Beach
    6
    Hazard records are generally one of the most poorly completed aspects of H&S in my view - because they are not understood. They are a technical document and most employees, unless trained, don't understand them and in most cases don't care anyway.
    For me a lot of years ago adopted the use of Hazard / Risk reports - that Aussie had adopted. These reports are formulated by forming small work teams (incl. Workers, Managers & Specialists) to identify and record the hazards and their associated risks (before and after controls). Each report includes all identified hazards is for a specific task / process or area in a systematic process - reports are usually 2-4 pages long so are a manageable size. The work teams review these regularly (3/6/12 monthly dependant on risk) and ensure they are kept up to date.
    This information including controls are then written into Safe Working Procedures for the relevant workers to incorporate into how they work - including checking that controls are in use. It is the SWP's that are relevant and managers then must ensure the workers are trained and the SWP's are followed.
    With the SWPS it is also important that the required equipment and engineering controls are also in place.
    It is a lot of work recreating the documentation, however once created it is easy to review each one to ensure they are current.
  • Jim at SAMs
    2
    We have a standard document for our sites which lists all the common risks. Risks that are unique to a site are then added to the register. We identify the risk via a matrix from 1-20. Then list the controls which gives us a residual risk. All risks with an initial rating of 20 and irrespective of their residual risk generally have a SWP document.
  • Aaron Marshall
    48

    Where does the information for the Safe Work Method come from?
    If everything is working as it should, your risk controls (from the register) should be feeding information into the SWMS. Think of it as your WIKI: everything you know about your companies risks should be located here.
  • Mark Taylor
    18
    There is no legal requirement to rate risks or hazards in the Act, the only requirement is to manage the risk to eliminate or minimise harm to a reasonably practicable level. The use of a risk matrix is very subjective and if used wrongly can increase risk if factors such as experience, training, knowledge, human factors and the environment are not considered when evaluating the likelihood of the possible injury.
    The hazard or risk register should also include the hierarchy of controls for each hazard as per the General Risk Workplace Management Regs 2016 for Eliminating the risks or if if this not possible, using as many of the other categories (substitute, isolate, engineering, admin and ppe) to mitigate harm to a safer level.
    Also, actual and potential health risks should be included in all hazard registers, something that is often overlooked
  • Sheri Greenwell
    190
    Our master risk register has a risk score but this is hidden when the site registers are created from the master version - for these very reasons. Sites are then provided with risk management training, which provides them with the tools and knowledge to take charge of managing risks relevant to their site and to use the site risk register for their site incident management and investigations. The H&S Team act as coaches and support site personnel to take ownership and learn (noting that there is a very fine line between empowerment and abandonment!!).
  • Andrew
    298
    While there may be no legal requirement for a "risk Rating" (I hope we do this stuff for reasons other than the law tells us to) I have a rating in my reGRegister.

    Two main reasons.
    I reckon it actually does give the risk a more objective view, than a subjective one - we need to think a bit harder about it and actually think more about 'real risk" than "ercieved risk"

    It also gives me a sense of priority. Eg "Paper Cuts" score very low and I give them zero amount of attention., Where as losing a finger rates very high so this gets loads of attention.

    The risk rating is "public" that way everyone gets to see the "priorities" or really dangerous stuff. And the reason why.

    There is also two sides to risk. There is the pre-management side where we know something has a certain level of danger with no controls. And the other side is hopefully a whole lot less dangerous once we have implemented out controls. The "risk rating" can help measure the two.
  • Jan Hall
    38
    Every commercial construction site I've ever worked on has had a comprehensive Hazards Register included in its master Site Specific Safety Plan. Tucked tastily between the voluminous pages. Nobody reads it. Client, auditor, etc, just looks to see if it's there.

    The most useful and practical hazard IDs are Site specific hazards identified in the Hazard Board at site entry, kept up to date and changed as the project does, and in TAs for particular tasks and particular trades, and sitewide pre-start/toolbox talks..
  • Wayne Nicholl
    21
    we have set up a safety hub to replace folders of paper. The current SWMS, training reg etc sits in that for better visibility. The risk register also sits there but not used as well as I was hoping. I find that the hazard board gets more talk time. I use the hazard board to look at the accumulated risk on a site and when I see too many high scores I check in to make sure the Site Manager has enough resource on site to manage the risk
  • Chrissy Roff
    4
    Interestingly almost all of our incidents could be prevented if our team followed all the hazard controls on our Hazard and Risk Register. The issue we find as if you do a thorough job of creating your register (which I believe we have, it is a living document which is always being adjusted after feedback from team members or incidents) it ends up as a lot of reading which most team members just glaze over. We do go over the hazard controls of one of our hazards at each toolbox meeting and have tried to make the format of our register as easy to read as possible. Has anyone come up with a more engaging way of sharing this information?
  • Mallory Dawes
    0
    Our company hazard/risk register is a living excel document which is is used widely throughout our business and regularly reviewed. As well as identifying the risk, what the potential harm is and the controls we have put in place, it includes the risk rating prior to and after controls (including what the likelihood and consequence level was used to come to each rating). It also identifies any risks to health associated to it and what, if any, health monitoring is required.
  • MattD2
    128
    The issue we find as if you do a thorough job of creating your register... it ends up as a lot of reading which most team members just glaze over.Chrissy Roff
    I think this is one of the key problems in how risk registers are developed/used, which then tends to lead to risk registers that sacrifice specific detail for (and attempt at) ease of use, and in doing so end up not being very useful at all.
    If you have a single company/division/section/site wide risk register consider it as a management tool, the single place to keep the overarching risk management decisions - for ease of use during "actual" work consider keeping all the information required for each specific task/job/tool in a single place (document) that includes not only the safety requirements but other information such as (for a tool) the specifications, required tools for maintenance, spare parts stock numbers, etc. That way if someone needs to refresh themselves on the tool/job they just need to refer to the specific details, not try and find it in the risk register, and the folder of manuals, and the spares catalogue, and the...
  • Jan Hall
    38
    In commercial construction, with my clients, every 'good' SSSP has a hazard register. Sitewise demands one, Prequal demands one. On site, NOBODY uses them, nobody reads them. The best, most immediate and most useful hazard register is an up to date site hazard board. After that TAs and regular individual sub-contractor or site wide pre-start/toolbox talks.

    Sadly: TAs used to be conducted on site with the personnel concerned in the task; a useful collaborative health and safety tool. Now someone in an office types them up and the eyes of the users glaze over as they look at a daunting bunch of typing they had nothing to do with and they simply 'sign on the dotted line'. What a PITY such organisations as Prequal do not actually DEMAND that TAs are scruffy, hand scribbled,clearly Collaborative works; that pre-starts and toolbox talks are the same. As it is, a competent person can do absolutely EVERYTHING required for passing Prequal (besides collecting a few signatures) from the keyboard and the sites could all be as dangerous as a war zone.

    Too many health and safety persons want to equate H&S documentation with accounting documents or even lawyers' briefs. They do not equate. It is quite possible to have the most labyrinthine, convoluted, complicated h&s documents in the world and STILL have a damn great fire on a site in the heart of a city. Documents don't create safety: culture does!
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