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Contractor Safety Procedures

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Section 1 - Purpose and Scope

Introduction

(1) Southern Cross University is committed to providing a safe and healthy workplace for staff, students, stakeholders, contractors and others. 

(2) To meet its obligation under the Work Health and Safety Act 2011, Work Health and Safety Regulation 2017 (NSW) and the Work Health and Safety Regulation 2011 (QLD), the University ensures that its Workers and Contractors prepare for, safely perform and complete Works. 

(3) To achieve this, the University must ensure proper hazard identification processes are implemented, and risks are controlled as much as reasonably possible to avoid incident, near-miss and/or injury. This includes:

  1. developing and implementing safe work procedures and/or Safe Work Method Statements (SWMS);
  2. undertaking hazard identification processes, including completion and submission of Risk Assessments (RA);
  3. providing Safety Data Sheets (SDS) for any hazardous chemicals brought to the site;
  4. the use of appropriate and safe equipment, plant and machinery;
  5. provision and use of appropriate Personal Protective Equipment (PPE);
  6. providing adequate instruction, training and supervision for those engaged in performing work; and
  7. ensuring only qualified and certified Workers and Contractors perform work.

Purpose

(4) These Procedures establish the effective integration of health and safety requirements and legislation into the University Contractor Management activities.

(5) The purpose of the Contractor Safety Procedures is to:

  1. provide a practical and relevant system for University Officers responsible for overseeing the Work of all Workers and Contractors; 
  2. ensure the integration of work health and safety requirements into Contractor management procedures;
  3. provide a system that incorporates a systemic and holistic risk management approach;
  4. fulfill the University's work health and safety obligations;
  5. ensure that all those engaged or responsible for managing or undertaking Work at an SCU location understand their responsibilities and obligations; and
  6. assist in achieving the University’s obligations to provide a safe workplace as set out under the Work Health and Safety Act 2011 and legislation relevant to the state where the work is being performed.
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Section 2 - Definitions

(6) For the purposes of these Procedures, the following definitions apply:

  1. Contractor –  a person or PCBU engaged to supply materials, service, labour, professional advice or audit at a University Campus location. It does not include ‘Consultants’ subject to separate and specific consultancy agreement clauses.
  2. Work – Any work carried out in connection with construction, alteration, auditing, renovation, repair, maintenance, demolition, refurbishment, fitting-out or dismantling of a structure. 
  3. Hazard – A situation with the potential to harm the health and safety of contractors and others due to works or to damage buildings, plants or equipment.
  4. Incident – An unplanned event that caused, or could have caused, illness or injury to those working onsite or others. This includes “near-miss” events where no injury or illness actually occurred.
  5. University Officer – The nominated University representative responsible for the engagement, management and coordination of the contracted works.
  6. WHS – Workplace Health and Safety involves the assessment, management, and coordination of prevention measures for risks for the health and safety of all persons onsite.
  7. Worker – An individual who carries out work in any capacity for SCU and includes working as:
    1. an employee;
    2. a volunteer;
    3. an apprentice or trainee;
    4. an offsider;
    5. a student undertaking work experience (paid or unpaid);
    6. a subcontractor and their employees;
    7. labour-hire company employees.
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Section 3 - Selecting and Engaging a Contractor

Duties, Obligations and Responsibilities

SCU University Officer

(7) The University Officer is responsible for engaging, monitoring and managing the Contractor or Worker on behalf of the University, ensuring before commencing that the following has been completed and provided:

  1. a thorough hazard identification and risk control process applicable to the Work;
  2. relevant and current licenses, certificates, training, registrations and trade qualifications;
  3. certificates of currency for Worker's Compensation and Public Liability insurance (min $20 mil).
  4. safety documentation, e.g. Risk Assessments, Safe Work Method Statements; and
  5. SCU inductions and site-specific training as per the Contractor Safety Induction Policy.

(8) The University Officer must also ensure that a contractual agreement and approval is completed before commencing Work as outlined in the University Procurement Procedures.

Workplace Health and Safety Team

(9) The Workplace Health and Safety Team is responsible for:

  1. providing advice and support to the University Officer, when required, to suggest health and safety risk controls for the contracted work; and
  2. upon request, will assist with monitoring Contractor and Worker compliance with agreed health and safety risk controls through inspection and review of incidents and on-site inspections and audits (high risk works).
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Section 4 - Planning the Work

(10) The University Officer, in collaboration with the Contractor or Worker, must ensure all Work is adequately planned and scoped considering all risk factors and WHS legislation and University requirements.  

(11) The planning process of risk and hazard identification, assessment and controls must be submitted and recorded on the University's internal file management system.

(12) The planning assessment needs to classify the Work considering the hazards associated with the work, activities to be conducted, location of the work and complexity of work management.

(13) High risk permits must be completed on the job with the recipient prior to the job commencing and ensuring all risks are managed. All relevant stakeholders to sign off prior to commencement of works.

Work Classification

(14) The University classifies Work into four categories which guide the risk management approach to contract management. Refer to Works Classification Table. 

Low Risk Works

(15) Low-risk work includes light physical tasks and the supply of goods, including consultants, visitors, auditors, and work experience candidates. This includes very low-risk work such as but not limited to photocopy repairs, presenters, external consultants, and auditors.

Routine Work: Contract Labour, Scheduled and Routine Maintenance

(16) Most contract labour is considered to carry a low risk of workplace injury or illness from the scope of operations. Contract labour should not involve and will not be connected to any construction work.

(17) Contract labour can be labour-hire, contracts for cleaning, basic maintenance, professional services, security personnel, vendors or stall operators.

Minor Work: Modifications and Refurbishment Works

(18) Work is classified as ‘minor’ if it involves ad hoc services such as minor construction, building maintenance, various trade or technical work, modifications and refurbishments.

High Risk Work

(19) Work is classified as ‘High Risk Work’ if it involves permits to work for construction, building maintenance, various trade or technical work, modifications and refurbishments.

Major Work: Construction and High-Risk Work

(20)  Work is classified as ‘major’ if it poses a significant risk of serious injury, illness or damage and/or is of value higher than $250,000. Typified by high-risk licensed work, high-risk construction, and Principal appointed works.

(21) Typically connected with construction or new plant installation, but can also include moderate to major refurbishments and facility extensions.

(22) May also be classified as Major Work if significant risk is identified through the hazard identification process or as outlined in Australian or state legislation.

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Section 5 - Contractor Responsibilities

Duties, Obligations and Responsibilities

(23) The Contractor must:

  1. take all reasonable steps to ensure the ongoing health and safety of Workers;
  2. ensure the provision and maintenance of safe systems of work, safe plant and the safety of any job site under the Contractor’s management or control; 
  3. provide information, instruction, training and supervision to Workers;
  4. ensure the services are provided in a safe manner, without risks to the health of those occupying the space during and following the Work;
  5. ensure all safety documentation (permits, SWMS, RA etc.) are onsite during the work and everyone working understands these documents and has signed off prior to commencement of works;
  6. take all reasonable steps to ensure that Workers engaged by the Contractor to conduct work on its behalf comply with the WHS requirements, are qualified to perform the Work, and comply with Australian and State regulations; and
  7. immediately notify the University Officer of any accident, incident, injury, property or environmental damage that occurs during or associated with the provision of the Work.

(24) A Contractor must take reasonable care for their own health and safety and that their acts, omissions and services do not adversely affect the health and safety of others. Specifically, a Contractor must:

  1. comply with relevant legislation and University specific contract and WHS requirements;
  2. demonstrate that they have an effective WHS management system of safe processes;
  3. provide information to the University Officer on how hazards and risks have been eliminated or minimised so far as reasonably practicable before Work commences;
  4. receive any permits onsite on the jobsite prior to commencing high risk works;
  5. consult, co-operate and coordinate with the University Officer and any other stakeholders to ensure all are aware of the Work and can actively contribute towards a safe and successful outcome;
  6. ensure that all essential service providers/suppliers (i.e. dial before you dig) are notified before commencing Work which will or may cause an outage, require excavation or lift work near service lines; and
  7. (if undertaking construction work) ensure that those working onsite provide copies of their general construction induction card (White Card) during their induction or pre-start meeting with SCU and retain copies on their person for inspection, if necessary.

(25) If supplying goods:

  1. the supplier must ensure that all products with Australian Standards, are fitted with the necessary guards and are fit for commercial use which are designed and manufactured to eliminate or minimise risk so far as is reasonably practicable;
  2. ensure safe installation, commission and construction of plant or structures; 
  3. provide information and training on the safe operation, handling, storage, maintenance and disposal of the product; and
  4. provide Safety Data Sheets (SDS) for goods of a hazardous nature.

Principal Contractor

(26) It is a requirement of WHS legislation that a Principal be appointed to a place of work where:

  1. any construction work that is undertaken that exceeds the cost of $250,000
  2. any high-risk construction work undertaken; whether or not costs exceed $250,000.

(27) The University requires a Principal to be appointed for any works where essential services will be interrupted or stopped.

(28) The University will be the Principal for work that it commissions unless it engages another PCBU (person conducting a business or undertaking) and authorises them by allocating the Principal appointment to them.

(29) The Principal Contractor is responsible for the contracted work and job site at all times until the work is completed and responsibility is handed back to the University; including but not limited to hazard identification, inductions and permits.

Hazard Identification, Assessment and Safe Method Procedures

(30) A Risk Assessment and safe work procedure, job safety analysis or Safe Work Method Statement must be completed for all contracted activities. They must comply with relevant legislation and WHS requirements and be prepared, complied with, reviewed and subsequently stored until the work to which it relates is completed.

(31) These hazard identification, assessment and safe method procedures must be provided to the University Officer prior to work commencing.

WHS Documentation and the Management Plan

(32) WHS legislation requires that the Principal of a construction project greater than $250,000 in value, prepares a written WHS Management Plan for the workplace before work on the project commences.

(33) The WHS Management Plan should outline the Principal’s WHS structure, roles, responsibilities and authorities, methods of consultation, induction and training, risk management process, subcontractor’s management, injury management and continuous monitoring and review.

(34) If Property Services have any concerns or questions regarding the risks identified, management responsibilities or controls these can be raised with the Principal (external) who should be able to provide evidence of a risk assessment that outlines the identification, assessment and selection criteria for controls.

(35) The Plan should also include a Safe Work Method Statement, together with any other risks and hazards, and is to be implemented onsite.

(36) A copy of the Safe Work Method Statement must be understood by all workers and available onsite should anyone need to review or reference the method and controls.

(37) Where the works are assessed as being of lower value or risk, the University Officer should refer to the University’s WHS Risk Management Procedures and direct the Contractor to manage risk following these Procedures.

Permits to Work

(38) Permits to Work are required for the following tasks:

  1. Asbestos removal or working where asbestos can be disturbed (i.e. replacing light fittings etc.);
  2. Lead paint removal;
  3. Working at heights (including scaffolding, use of EWP, works at the height of 2m and above risk);
  4. Working in confined spaces;
  5. All excavation and ground penetration work;
  6. Hot works (including welding);
  7. Dust works (creating excessive dust); and
  8. Crane or mobile lift works (including crane lifts and truck crane mechanisms).

(39) A Permit to Work must be completed onsite prior to the commencement of Work.

(40) The University Officer will determine the frequency, format and review of any Permit to Work.

(41) Application forms are available on the Property Services Contractor Hub Website.

(42) Where the University has permit forms or systems available, they must be used unless otherwise directed by the University Officer.

Lock-Out Requirements

(43) The SCU Lock Out and Tag Out Procedures are required when Work carried out on plant, equipment or services has one or more energy source that creates a potential hazard.

(44) A black and yellow out-of-service tag must be placed on any equipment, plants or machinery that is faulty or out of service. 

Isolation

(45) Isolation involves disconnecting equipment or plant from all possible sources of supply to prevent equipment/plant from becoming live or operational during Work. Do not rely on another’s danger tag for isolated equipment; always check, test and ensure it is de-energised and isolated before commencing Work.

Certificates of Currency

(46) Contractors must have valid Worker's Compensation coverage and Public Liability insurance to the value specified by the University Officer and/or state legislation.

(47) Current copies of all Certificates must be made available to the University annually, before expiration.

(48) When required, Professional Liability and/or Product Liability insurance in the amount of $10,000,000 during the agreement term and for five years after the agreement is terminated or expires must be provided.

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Section 6 - Carrying out the Work

(49) In managing Work, the University Officer is required to fulfil the University’s obligation of health and safety requirements with a duty to identify hazards, eliminate risks, implement the hierarchy of control to minimise any identified risks as far as reasonably practicable and maintain and review any relevant controls that have been identified for the works being carried out.

(50) Contractors must provide adequate supervision to Workers to satisfy legislative requirements and the University. A suitably trained and qualified supervisor must be appointed, available and always contactable with all safety paperwork onsite.

(51) Directions and explanations given by the University to the Contractor must be communicated to Workers.

(52) Any out-of-business hours Work must be approved by the University Officer. Those attending the site during these times at the Lismore or Gold Coast Campuses must report to Security before proceeding to the job site.

Monitoring Contractors

(53) It is the responsibility of the University to determine the appropriate level of monitoring activities required for the Work. Monitoring will be conducted to ensure the Contractor’s activities complies with:

  1. WHS legislation;
  2. SCU WHS requirements; and
  3. Work-specific safety and risk management plans.

(54) Monitoring of contractors may include:

  1. pre-start, site and contract meetings;
  2. site inspections and audits;
  3. contract documentation reviews;
  4. incident management follow-up (as required).

Contractor Audits

(55) The University Officer, at any time, may request information relating to the Contractor’s WHS management systems. The Contractor must make available copies of WHS inspection and audit reports when requested by the University.

(56) Contractors may request copies of their Worker's induction records at any time.

(57) The University Officer, at any time, may conduct inspections and audits per the University WHS Policy.

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Section 7 - Incident Management

(58) The University's WHS Risk Management Procedures sets out how incidents and hazards are reported. If an incident, hazard or near-miss occurs onsite, work must stop and it must be immediately reported to the University Officer for reporting and records via the online management system RiskWare. Work will not recommence until the University is satisfied that adequate controls are in place to avoid the risk of injury or further breaches.

(59) If a notifiable incident occurs in connection with the work, the person conducting the business or undertaking (PCBU) work must stop and must inform the University Officer and keep the statement for at least two years after the incident occurs.

Notifiable Incidents

(60) Any notifiable incident (fatality, serious injury/illness and dangerous incident – potentially resulting in injury, or a pollution incident with the potential to materially harm the environment) must be reported immediately in accordance with regulator requirements. After emergency services have been contacted (if necessary), the Contractor must:

  1. Inform Campus Security on 73333 for immediate incident response and first aid;
  2. Inform the University’s Director, Property Services and Manager, Workplace Health and Safety.

(61) Where a notifiable incident has occurred on site, the Contractor must ensure, so far as is reasonably practicable, that the incident is not disturbed and is barricaded until an inspector arrives or any earlier time that an inspector directs. However, this does not apply where interference is necessary to aid or revive any person involved in an accident or to prevent further injury to persons or property.

(62) Definitions of a notifiable incident can be found at NSW Safe Work ‘Notifiable Incidents’ and  QLD WorkSafe ‘Confirm if an incident is notifiable’.

Non-Compliance

(63) If a Contractor is found in breach of their contract or state or University WHS requirements, all work with regard to that activity will be immediately suspended. The Contractor will be alerted to the matter in writing by the University and will not recommence until the University is satisfied that adequate controls are in place to avoid the risk of injury or further breaches.

(64) Inadequate WHS performance, including one-off instances or continuous breaches, can lead to contract termination and failure to be awarded further work. Breaches should be reported to the Manager, Workplace Health and Safety for recording on the University Risk Register.

(65) Examples of WHS breaches may include non-compliance with legislation, SCU WHS requirements or not observing controls as stipulated in a safety document or permit to work.

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Section 8 - Completion of Works

(66) The University Officer will, at the completion of the works:

  1. determine whether an inspection is required. If so, conduct an inspection of the area where the Work was carried out to confirm it has been left free of hazards with all isolations removed;
  2. where applicable, complete the ‘Project Compliance checklist’ and provide a copy of the completed form to the Contractor;
  3. provide information to the Manager, Workplace Health and Safety, if required, for Risk Registers; 
  4. close out any Permits to Work;
  5. ensure all documentation relating to the Work has been provided; and
  6. ensure all handover, training, and commissioning have been completed.
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Section 9 - Records Management

(67) During the procurement and engagement of contracted works, the University Officer must establish a contract information record structure within the University’s systems with the correct access controls and keep key contract information updated as described in the University’s Contract Management Framework.

(68) All Contractor records must be retained in accordance with the relevant legislation.

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Section 10 - Review

(69) To ensure that these Procedures remain effective and applicable to the University, the Contractor Safey Procedures will be reviewed every 3 years by the University Officer and Director, Property Services in consultation with the Manager, Workplace Health and Safety and other key stakeholders. Conditions which may warrant a review of the Procedures on a more frequent basis include:

  1. reported hazards or injuries;
  2. non-conforming systems; and
  3. Health and Safety Representative concern.

(70) Following the completion of a review, the Procedures and Induction documents will be amended as necessary.