Thought Leadership Article 4

Addressing a Potential Increased Injury Risk Due to Limited Supervision on Insurance Building Worksites

It was identified in the Brady Report to the Department of Natural Resources, Mines and Energy (DNRME) (2019), that a lack of training, supervision and appropriate controls accounted for the majority of fatalities in the mining and quarrying industry between 2001 and 2029 (Brady, 2019). Almost all fatalities studied (47 in total) were the result of systemic, organisational, supervision or training failures, either with or without the presence of human error. In 68% of fatalities analysed, the worker was required to be supervised when undertaking the task, i.e., it was not a routine task, like driving. 78% of these fatalities involved inadequate or absent supervision.

It has been observed that site supervision by Advanced Buildings and Restorations (ABR) Supervisors (as representatives of the Principal Contactor) is not guaranteed, due to multiple job allocations typically assigned to ABR Supervisors, at any given time. Works on job sites often commence, or works continue, across various project sites simultaneously (as many as 5-10 per week, per Supervisor), with a geographic spread that inhibits their capacity to be present at each site, or even a majority of sites.

Further, in the Brady report to the DNRME, it was identified that a lack of task specific training was a major contributing factor across 36% of the fatalities reported. In many cases this lack of training resulted in workers being unaware of specific hazards involved in completing a task, or the worker operated equipment in a manner that exposed them to hazards.

On insurance building industry job sites, while the PC Supervisor is not typically responsible for task-specific training, a low number of pre-commencement (pre-start) or toolbox-style meetings are able to be completed or are prioritised for completion by a supervisor in person, due to the factors mentioned above. This undermines the ability for planned in-person discussions which may be beneficial for identifying where such training is required.

It is assumed by the author that there is a similar correlation between lack of supervision and increased serious injury risk in industries outside the mining and quarrying industry. If this assumption is correct; then, based on the findings in the Brady Report, there is a potential for increased injury risk on insurance building industry job sites where the PC Supervisor is not present. This is due to:

  • the documented controls (captured in the SWMS) are not confirmed as being implemented by the Supervisor, as an independent party to the workers undertaking the task
  • a documented hazard identification process is not assured without the PC Supervisor present to lead it
  • a task analysis to identify where task-specific training or supervision is required is not guaranteed if the PC Supervisor are not present.

While there has been a relatively low incident rate at ABR job sites over previous years, based on the findings and recommendations of the Brady report, it has been identified that there is potentially an elevated risk of injury due to limited ABR Supervisor attendance at ABR work sites.

Reducing the Risk – Increasing Accountability through a National KPI Initiative

Key Performance Indicators (KPIs) are recognised as a means for increasing accountability against a set criteria. At the time if writing, a health and safety KPI process was being launched nationally at Advanced Buildings and Restorations (ABR). The aim is to improve Supervisor attendance during site works and increase prioritisation of health and safety-related activities on job sites. The KPI’s cover areas related to pre-commencement inductions, planning meetings and discussions, such as Pre-Start meetings and Toolbox Talks, and increase the rate of Supervisor health, safety and environmental inspections at sites.

KPI achievement is reported monthly, to the executive leadership team with the first round of reporting scheduled for 17 December 2024.
An initial launch period has been established which covers the first 3 months of KPI reporting, through until March 2025. During this period, feedback from ABR Supervisors will be used to tailor the program if necessary.

Following the initial 12 months of KPI reporting (Dec 2025), incident rates (medical treatments, lost time injuries and serious/notifiable incidents) on ABR worksites will be compared against the previous 12 month period, to identify any changes. It is hoped that the KPI program will result in a sustained low LTI rate with improved serious incident performance across the business.

Author – Adam Eyles

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Thought Leadership Article 3

Research Project Update – WHS in Construction Subcontracting

As part of the Enforceable Undertaking (EU), Advanced Buildings and Restorations (ABR) engaged RMIT to undertake a research project into subcontractor WHS compliance in the NSW construction industry.

The project aims to:

  • Contribute to the prevention of workplace harm and incidents through improved subcontracting arrangements and management in the construction industry
  • Understand the challenges and drivers for WHS compliance in subcontracting arrangements and identify effective solutions to achieve WHS compliance of subcontractors.

Once completed, the project will include 4 phases. Three of the four phases have been completed as of February 2025. Firstly, the project was co-designed between RMIT and the Centre for WHS to identify a research plan and key milestones. The research project also involved the formation of an Industry Advisory Group, consisting of members of the NSW construction industry, the Centre for WHS and Advanced Buildings and Restorations.

Phase 2 was a comprehensive literature review, which identified a total of 38 factors that have the potential to influence subcontractor WHS compliance in the construction industry. These factors reflect five levels of influence, including:

  • regulatory effectiveness
  • industry context and supply chain environment
  • subcontractor management practices by principal contractors
  • workplace environment, and subcontractor knowledge, capability and attitude.

The third phase of the project involved conducting an online survey to:

  • assess the extent to which the factors identified in the literature review are currently being effectively addressed in the NSW construction industry
  • highlight areas that need to be focused on for improvement, and
  • identify aspects that warrant further exploration in the subsequent project stage of conducting interviews.

    The survey instrument consisted of four sections, including:

  • section 1 capturing participants’ demographic information
  • section 2 exploring participants’ general perceptions of subcontractor WHS compliance in the NSW construction industry
  • section 3 examining participants’ perceptions of how well each of the 38 identified factors is currently being addressed in the NSW construction industry
  • section 4 using one open-ended question to explore participants’ opinions on additional considerations for ensuring subcontractor WHS compliance in the NSW construction industry.

The target participants for this survey were principal contractors and subcontractors working in the NSW construction industry. The survey was conducted between 9 September and18 November 2024.

The online survey received a total of 203 responses, exceeding the minimum of 196, which was required for a valid sample size.

The final phase of the research project will involve interviews with construction industry stakeholders to gather more insight into their perceptions on subcontractor WHS compliance.  A system dynamics model and its validation through focus groups will form the remainder of Phase 4.

The final phase is currently scheduled to commence in late February 2025, culminating in the presentation of findings to industry stakeholders and SafeWork NSW.

Demographic information

The data set allows the research team to identify demographics, such as the job roles of those that completed the survey, as shown in Figure 1.

The data also allows the researchers to identify the job roles of the survey respondents. This is presented in Table 2.

Data Analysis and Preliminary Results

The following are preliminary results identified from the survey response data.

Figure 1 shows the responses to the question “How would you rate subcontractors’ WHS compliance performance in general”?

Figure 1 shows that the majority of respondents (75%) perceive that subcontractor compliance is good, very good or excellent while 25% feel that subcontractor compliance is poor, very poor or extremely poor.

Figures 2 – 6 provide some further insight into respondent perceptions of how well factors in relation to the following aspects are currently being addressed in the NSW construction industry:

  • Regulatory effectiveness
  • Industry context and supply chain environment
  • Subcontractor management practice by principal contractors
  • Workplace environment
  • Subcontractor knowledge, capability and attitude
Figure 2 – Regulatory Effectiveness
Figure 4 - Workplace environment
Figure 5 - Subcontractor knowledge, capability and attitude

The following additional data analysis has been completed as part of the research project, at the time of writing this paper.

  • Comparison of responses by type of organisation
  • Comparison of responses by construction sector
  • Comparison of responses by company size
  • Comparison of responses by respondents’ perceptions of subcontractor WHS compliance performance

The survey included an open ended question as follows: “Is there anything else that should be considered to ensure subcontractor WHS compliance in the NSW construction industry?”

There were 62 qualitative responses provided for this question, which have been analysed to identify any themes. The following is a summary of the 12 themes regarding additional areas that should be considered to ensure subcontractor WHS compliance, identified from the responses:

  1. training and education
  2. simplification of WHS management processes
  3. inspections and audits
  4. accountability, incentives and support
  5. collaborative WHS culture and shared responsibility
  6. differences in WHS attitudes and competency across the industry
  7. fostering regulatory trust
  8. insurance and legal compliance
  9. prompt payment
  10. clear WHS expectations in sub-contracts
  11. leveraging technology, and
  12. psychosocial impacts.

Next stage of the research project

The project aims to progress with Phase 4 (interviews of construction industry stakeholders) in late February, 2025. A system dynamics model will be developed from analysing t the interview data and focus groups will be conducted to review and validate the system dynamics model.

Once this phase is completed, findings and recommendations will be present to SafeWork NSW.

A further article will be provided once the research project is completed, in October 2025.

Author – Adam Eyles

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Thought Leadership Article 2

Reflections on the Value of Work Placement and Cadetship Programs During Execution of an Enforceable Undertaking

One of the key areas of focus regarding an Enforceable Undertaking (EU) is to decide what the goals are, for the business and the regulator. The Advanced Buildings and Restorations (ABR) Health, Safety and Environment (HSE) team identified that one of our goals for the successful completion of the EU should be a meaningful and lasting benefit to the work health and safety industry and (if possible) the wider community, through a positive impact on future health and safety practitioners in the construction industry.

ABR progressed this line of thinking and decided that one way to provide a strong, positive influence on the future of our industry was through the inclusion of student placements and cadetships in our EU strategy. The goal being to assist future WHS professionals to gain a positive experience and exposure to the health and safety challenges presented by the construction industry, under the leadership of our seasoned and professional HSE team. ABR proposed that this approach would provide a high level of value at the right time in a HSE professionals’ career to result in a lasting benefit.

To best execute this strategy, students were selected from universities offering higher level safety qualifications (Undergraduate degrees and Post Graduate Master’s qualifications). The Student Placements and Safety Cadets would be paid positions and would be based in the ABR head office in NSW, were they were able to receive direct management and guidance from the NSW HSE Advisor.
ABR provided the successful work placement students 100 hours of office and site-based contact time to allow a sufficient introduction to the construction industry. The program aimed to compliment the students’ studies and assist ABR in meeting its goal of promoting positive health and safety experiences for emerging HSE professionals. The student placement and Cadetship program was planned to run for the entirety of the two-year duration of the EU.

Placement students spent one day per week at either the ABR corporate office or on construction sites, or a combination of both. During their time as a placement student, ABR sought feedback from them regarding their experiences. This allowed ABR to gauge the success of the initiative. Through the feedback gained, ABR confirmed that placement students found the allocated time to be sufficient to gain a valuable level of exposure to the industry, and to gain useful insights into the organisational tools used for the management of health and safety in a high-risk industry.

The students provided feedback that they predominantly benefited from experiencing how procedures and work methods were used in real life scenarios, on various construction projects. This experience was facilitated through time in the corporate office, site visits and mentoring from the HSE Advisor and wider HSE team. Students reported that they gained particular value from their exposure to ABR’s implementation of a modern site safety management system. The adoption of the site safety management system demonstrated how technology can be utilised to provide consistent health and safety compliance.

Students also reflected that they acquired an improved ability to communicate effectively across different levels of an organisation. They felt they had gained valuable experience in effective communication, from sub-contractor trades to supervisors and managers.
Whilst the work placement program was deemed to be very successful, one opportunity for improvement identified from early student feedback is a greater opportunity for site attendance
during the allocated 100 hours.

Students felt that this would better allow them to gain awareness of how safety procedures, developed in the office, are applied in the field.
Similar to placement students, Safety Cadets were allocated weekly contact hours at ABR’s Head office in NSW; however, Cadets were assigned three days per week as opposed to the 1 day per week for 16 weeks assigned to placement students. At the time of writing this paper the second of three Cadetships are yet to commence their time with ABR. Feedback from the first Cadet is that her experiences have been highly beneficial to her development as a HSE professional, finding her time at work sites to be very rewarding and the implementation of HSE procedure to be a key development opportunity.

The Cadet was able to apply the theoretical knowledge gained from her studies to the practical setting, learning real world examples of how to achieve work health and safety compliance, in a challenging industry. She was further able to apply her learnings and insights to gain a more comprehensive understanding of the subjects she was completing at university. This has allowed her to understand the nature of the various safety roles more clearly in the field and gain useful insights into the Australian work culture.

As for the placement students, the Cadet reflected that visiting the construction sites was an effective way to enhance her understanding of how risks are identified and controlled in a practical sense, such as through site toolbox talks and safety supervision provided by ABR as the Person Conducting a Business or Undertaking (the PCBU).

The Cadet concurred with ABR’s proposal that the Cadetship program would produce a more knowledgeable HSE professional, who could then go on to generate a stronger positive impact on the health and safety industry.

There is no doubt that the student placement and Cadetship programs incorporated into our EU execution strategy have benefitted ABR; however, the program has more importantly provided a strong platform for students and emerging professionals to develop practical skills that complement their academic learnings. ABR believe that this has allowed us to provide future health and safety professionals with a strong foundation, and a lasting legacy of improvement to how the safety challenges of the construction industry are managed.

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Thought Leadership Article 1

Developing an Enforceable Undertaking Strategy

Advanced Buildings and Restorations (ABR) is a National Company with offices across the Eastern Seaboard of Australia. We operate in the insurance building space, an industry with a heavy reliance on subcontractors and exposure to high risk. The reliance on subcontractors provides an added complexity in managing WHS and ensuring that a safe workplace is provided.

ABR experienced this complexity firsthand in February 2019, when we engaged subcontractors to undertake roofing work on two industrial buildings. The job required the workers to remove asbestos roof sheets and replace them with Colorbond metal sheets. The roof of the building gave way whilst workers were undertaking the removal of asbestos roof sheets. Four workers fell approximately four meters from the roof. Two of the workers who fell from the roof were injured and required medical attention.

Following the incident, ABR was faced with the confronting realisation that our processes had placed workers at serious risk. Whilst we always took WHS seriously, like many other employers, we never thought this would happen to us. ABR faced another dark day when we learned the fate of the incident and SafeWork NSW advised us they would be prosecuting. Facing a fine in the vicinity of $600.000,00 along with massive reputational damage and a potential impact of loss of work due to a WHS prosecution, ABR engaged in an exercise of exploring the option of an Enforceable Undertaking (EU).

The first crucial step of entering into an EU, is getting the commitment of the business to the EU. We were fortunate to receive backing from the entire business starting from our Directors, CEO and the ELT to all workers. We all saw the benefit of the EU option and the impact this will have on the business. This commitment gave us the confidence to approach SafeWork and request an EU, which was granted subject to a comprehensive set of strategies.

In building the strategies, the Safety group brainstormed the main aims of an EU and considered ‘what do we want to achieve?’. After careful consideration and an in-depth analysis of the requirements, the team arrived at the following desired outcomes of the EU:

  1. We wanted to tackle the EU head on and not shy away from the fact that we have engaged in one,
  2. We wanted to ensure that we improve and overhaul our HSE management system,
  3. We wanted to give something back to the industry and the community to ensure that we leave a legacy which will make our industry safer.

We then progressed our work in developing the final high-level strategies, being the following:

  1. Providing a public notice and notification to all subcontractors which we engage, advising we are subject to an EU and the details surrounding this.
  2. Ensure our staff are kept up to date with the EU and the process we are engaged in.
  3. Undertake a complete review of our HSE management system and implement recommendations as per external Auditor reports.
  4. Implement an automated WHS Management System to assist us in managing our HSE responsibilities.
  5. Work with the Centre for WHS to undertake research on contractor management with the intended outcome to identify and implement appropriate solutions and strategies to better manage subcontractors.
  6. Provide a community contribution via WHS student placements, cadetships, and scholarships to assist a new wave of WHS professionals.

The proposed strategies resulted in Advanced Buildings (NSW) Pty Ltd entering into an Enforceable Undertaking on Thursday 20 April 2023 with SafeWork NSW.

While the initial incident in February 2019 resulted in significant injuries to several workers and could potentially have had much more serious consequences, the option to enter into an EU agreement has already resulted in many positive outcomes for our business. In the first 6 months of our EU, our workplace is starting to see the benefits from the robust strategies we have commenced and it is our hope that the improvements being undertaken at ABR will allow other businesses’ to learn and benefit from our experience, and this will subsequently improve the safety of workers more widely across the industry.

Author – Adam Eyles

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Adam Eyles

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