This article is a guideline of how employers or organisations can implement effective health and safety procedures and structures within their workplace. The Occupational Health and Safety (OHS) Act 85 of 1993 is one of the legislative drivers, that is responsible for enforcing and creating a healthy, safe, and prepared working environment for all employees, visitors, and suppliers within the workplace.   

Coat_of_arms_of_South_Africa.Department of Labour

REPUBLIC OF SOUTH AFRICA

Occupational Health and Safety Act No. 85 of 1993

ACT

To provide for the health and safety of persons at work and for the health and safety of persons in connection with the use of plant and machinery; the protection of persons other than persons at work against hazards to health and safety arising out of or in connection with the activities of persons at work; to establish an advisory council for occupational health and safety; to provide for matters connected therewith.

Signed by The State President

________________

There are 50 sections in the Occupational Health and Safety (OHS) Act, each with its own rules and regulations and 21 different regulations with some being applicable to all companies (General Administration Regulation) and some being only applicable to certain industries (Construction Regulation).

These different sections and regulations dictate how and what the employer, employees, and whole company need to adhere to and implement, to ensure compliance and create sound OHS related practices and structures within any organization. 

What does an OHS management plan entail?

An OHS management plan is the organisation’s overall plan, in the form of a detailed OHS Policy document which dictates and guides the organizations in OHS-related requirements and strategy. This comprehensive and detailed OHS Policy document can be structured in any format and contain any content, but it must address the important sections and applicable regulations of the OHS Act. The policy must be communicated to all employees within the organization, who must be made aware of specific and general OHS related content and requirements. Listed below are important elements which should be included in any OHS Policy document:  

  • OHS policy

The OHS Act states the following with regards to a Health and Safety Policy: 

Section 7 – Health and Safety policy

(1)    The chief inspector may direct

         (a)    any employer in writing; and

         (b)    any category of employers, by notice in the Gazette, to prepare a written policy concerning the protection of the health and safety of his employees at work, including a description of his organisation and the arrangements for carrying out and reviewing that policy.

(2)    Any direction under subsection (1) shall be accompanied by guidelines concerning the contents of the policy concerned.

An employer shall prominently display a copy of the policy referred to in subsection (1), signed by the chief executive officer, in the workplace where his employees normally report for service.  

The company must ensure that its OHS Policy Statement (1 page document) is signed by the CEO, framed and placed in the reception area of the workplace. This shows executive management support and commitment to OHS within the workplace. 

The detailed OHS Policy document must be published on an internal communication resource platform and be communicated to all employees and relevant external parties. The policy must be reviewed and maintained on an annual basis or if significant organizational changes occur in order to ensure its continuing suitability, adequacy, and effectiveness. 

2. Structures and Organogram

OHS team structures and organograms should be reviewed and updated regularly / every quarter to ensure that there are no non-compliances, vacancies, or gaps within the structures.  This review function can be performed by the OHS supervisors or management for each office within the organization. The OHS structure in each office location should include an OHS supervisor, OHS representatives, first aiders, fire wardens, and evacuation marshals. The OHS team members must receive training, then be appointed in writing, and then sign their appointment letters, which are to be stored on the employee’s employment file. When the OHS organogram is completed and all OHS team vacancies are filled then the organization or region or department has a thorough OHS structure within the workplace.      

3. Appointments

OHS team member appointments are a critical element of any OHS Policy and structure, as these appointees assist in managing and driving OHS generally as well as where specific matters and challenges are required. OHS team vacancies should be communicated to all employees in the offices where vacancies exist and employees requested and encouraged to volunteer and forward nominee name for the vacant positions. Management should also have input into appointing appropriate staff to attend first aid training, firefighting training, and evacuation planning training, but the OHS representatives must be appointed by fellow employees and not management. The OHS team appointment letters should be valid for a 

4. OHS committee

The OHS committee is one of the primary driving forces mandated by the CEO and management team, to assist in developing the OHS strategy and successfully managing OHS on behalf of the organization. Through communication and teamwork, the OHS committee creates and establishes documents, processes, systems, mechanisms and outputs that contribute to the success of OHS. The success of OHS is directly related to the success of the OHS committee.  

5. OHS training

All companies need to send some of their staff on OHS related training, as this is an OHS Act requirement. Employees must nominate their OHS representatives through a nomination process and the nominated representatives then represent their OHS interests at the quarterly OHS committee meetings. The employer or management may not nominate the OHS representatives. Employees are encouraged to volunteer, or suggest suitable nominees as OHS team members, who are then trained and appointed into the various OHS disciplines, namely First Aiders, Firefighters, Evacuation Marshals, and OHS Representatives. Once trained, each OHS team member is appointed in writing and together take an active role in implementing and managing OHS in each office within the organization. The duration of the OHS training is as follows:

  • First Aiders – 2 days;  
  • Firefighters – 1 day;
  • Evacuation Marshals – 1 day;  
  • OHS Representatives – 1 day;
  • OHS Supervisor – 2 days;
  • OHS Specialist / Officer.

The OHS training must be completed through an HWSETA and Department of Labour accredited training company like SEIFSA and Absolute Health Services. This will ensure that the OHS team knows how to implement and perform their duties correctly and assist in creating a healthy, safe, and prepared workplace. 

6. OHS equipment

OHS and emergency equipment must be strategically placed in all office locations of the entire organization, to be utilized by the OHS teams in emergencies or evacuation drills. This equipment is a critical element of an effective OHS strategy. The OHS team members must check the equipment at 3-monthly intervals and ensure that all the equipment such as:

  • first aid boxes, 
  • firefighting equipment, 
  • evacuation plans, 
  • loud and clear devices or hailers etc.

are serviced and in a good condition. This equipment may not be tampered with or used unnecessarily by anyone. When the OHS strategy is developed, there must be funds allocated for the purchase of OHS equipment. The OHS Act states the following with regards to OHS equipment: 

Section 15 – Duty not to interfere with, damage or misuse things

No person shall intentionally or recklessly interfere with, damage or misuse anything which is provided in the interest of health or safety.

What determines the complexity of implementing OHS within the workplace? 

The complexity of the OHS Policy and structure is determined by different factors of the business, department, or organization, such as: 

  • Organizational Infrastructure

The organizational structure and location of the branches and offices – if the business structure is large or has a national infrastructure, then the OHS team needs to accommodate the large structure and service all the office locations. The larger the OHS structure the more challenging successful OHS management of that large structure is.    

  • Service Offerings

The type of services offered i.e. administrative or industrial – If the business does not operate within a high-risk environment, such as an administrative business, then OHS implementation and management may be simple and easy. However, if the nature of the business is a high risk such as industrial or mining, then the OHS Policy and detail needs to be complex to address the higher risk factors. 

  • Employee Numbers

The number of employees i.e. 50 or 1500 which is similar to organizational infrastructure. If the organization is small in staff numbers then there is only a need for a small OHS structure and cost. An example of this is with less than 20 staff, there only needs to be 1 person trained in OHS training disciplines such as first aid, firefighting, evacuation marshal and OHS representative. With larger companies of over 100 employees then, for every 50 employees someone needs to be trained in these OHS disciplines and courses.      

  • Financial Implications

If the organization is financially sound and successful then the sooner OHS could be implemented, as the OHS related costs would not really have an impact. If the organization is not financially sound and struggling in a challenging environment then OHS would need to be implemented over a longer period i.e. 2 years. The financial implications are also similar to organizational structure and employee numbers, as the larger these elements then the larger the financial budget needs to be.       

The correct procedure for implementing successful OHS within the workplace

It is important to follow a procedure or process when implementing OHS. Listed below is an example of such a procedure and process management or the OHS team could utilize: 

  • Policy

Management must develop the OHS Policy ideally in consultation with the employees and their OHS representatives. This policy will detail the OHS direction/aims/objectives and commitment by management and all employees.   

  • Organising

To promote a positive OHS culture within the organization and determine the OHS roles and responsibilities and resources required, use the 4C’s method:

  • Competency of employees – knowledge, ability, training, and experience;
  • Commitment and control – allocating responsibilities, accountabilities;
  • Co-operation internally and externally – between individuals and clients;
  • Communication systems – orally, written, visible or example.

  • Planning / Implementation

Conduct an initial documented review of the organization to establish the status of the OHS systems in the organisation and then identify the hazards and risks. Thereafter set objectives and targets and set standards such as design specifications for equipment, products and services, safe systems of work, purchasing policies, emergency procedures etc to achieve the required OHS status and objectives.

  • Measurement of performance (evaluation)

Develop procedures and systems to monitor, measure, and record the OHS performance, on a regular basis at different levels within the organization. This can be achieved by “active monitoring” which includes monitoring of organisational achievements to prevent accidents and ill-health e.g. systematic inspections of equipment and premises, or “re-active monitoring” which monitors failures that have occurred e.g. accidents and near misses and dangerous occurrences, enforcement action, etc. Through this evaluation, the organization has a benchmark to strive in improving year by year.  

  • Review

This is the annual review and evaluation of the overall OHS Policy and structure by management and the OHS committee, to ensure the performance objectives have been met. There is always room for improvement in the overall structure and policy when looking after the wellbeing of all of the employees!