The FINAL WHS Regulations and COPs – sit down and take a break for a moment and read where it is now at …
By Graham Dent – republished from Linkedin Here:
My understanding of the latest status of the release of:
► the Regulation Impact Statement
► the "final" approved WHS Regulations; and
► the "final" approved first phase of COPs (which will NOT include the Facilities for Construction Sites draft COP)
is that we are not likely to see them prior to 23 September – and possibly not even then, as the final approvals from relevant Ministers are sought and (hopefully) obtained.
For anyone who likes rounded numbers that means that by 23 September – with just on:
► 100 DAYS to Big Harmony Day (1 January 2012) we may actually see, the possibly
► 1000 or more pages (RIS, Regulations and COPs) that we are required to respond to.
I include the RIS page count in that because for many, in the absence of the Regulators releasing guidance on the variation between the current and new requirements in each jurisdiction, that will provide a quick insight into the material differences. Lets hope all jurisdictions will follow the approaches demonstrated to varying degrees by Queensland, Victoria and NSW on guidance on the differences.
So in that 100 or less days – you will need to:
► do a gap analysis
► identify policies, processes and plant, equipment and facility changes required;
► IMPLEMENT (with associated training) the processes which will need to be there from DAY ONE – these include the obvious ones which are:
– INCIDENT NOTIFICATION and
– DUE DILIGENCE
both of which you should be addressing NOW.
► OTHER IMPORTANT ISSUES
Make sure you understand the Transitional principles for the WHS Act – and the yet to be announced equivalent for the WHS Regulations. Then, with that in mind prioritise what needs doing now for 1 January, and what can wait – eg. changes to HSR and Work Group processes.
See the summary of the Transitional Principles for the Act see the link below. Note however – once each jurisdiction passes its WHS Act (only NSW and Qld to date) you should look for the specific transitional provisions in the relevant Act for each jurisdiction – these Acts are the law and will implement, or modify the approved principles and are likely to vary between jurisdictions.
WHS Essentials – Transition to new WHS Laws (DCL).pdf box.net
Summary (with links to the full requirements) of the Transitional Principles for how the new WHS ACT requirements will effectively come into operation, and what happens to existing processes and arrangements on 1 January 2012.
Do you have any thoughts? Please share them below