Department of Defence
Description of the project
The WHS Act and associated WHS Regulations were adopted, by the Commonwealth, from the model WHS legislation and commenced on 01 January 2012. The former Occupational Health and Safety Act 1991 and Occupational Health and Safety (Safety Arrangements) Regulations 1991 were repealed. Hibbs & Associates Pty Ltd was engaged by Defence to conduct the review of the Defence WHS Manual, Vol. 2, Part 3A, Chapter 5 - Asbestos Management in Defence. The project was to be conducted in two parts:
Part 1: Review and gap analysis for Chapter 5 – Asbestos Management in Defence with respect to the Commonwealth Work Health and Safety Act 2011 (No. 137, 2011) and subordinate regulations; and
Part 2: Revise and update Chapter 5 – Asbestos Management in Defence. The purpose of the review was to:
- Ensure compliance with Commonwealth Work Health and Safety legislation;
- Consult with the stakeholders to ensure their requirements for asbestos management are adequately addressed by Chapter 5; and
- Update Chapter 5 to ensure asbestos management within Defence is in accordance current occupational hygiene and industry Best Practice.
Part 1 – Review and Gap Analysis
At the beginning of the project there were over 6,000 documents on the Defence Restricted Network (DRN) providing information about asbestos or outlining requirements for some aspect of managing asbestos and asbestos-containing materials. There was so much information on asbestos and asbestos management on the DRN that it made coordination, review and tracking of documentation an overly complex, if not impossible, task. One of the principal findings of the gap analysis for Chapter 5 was that the entire process for the management of asbestos within Defence be simplified and reduced to a centralised group of documents. To achieve this, Chapter 5 was expanded to become the definitive document outlining the policy objectives and protocols for managing asbestos within Defence. The amendments required to achieve this were made in conjunction with the rewrite of Chapter 5 to achieve compliance with the WHS legislation.
Part 2 – Revise and Update
Chapter 5 – Asbestos Management in Defence was rewritten to:
- Align it, and ensure compliance, with the Commonwealth WHS legislation;
- be the definitive document for management of asbestos in Defence. It establishes the requirements for management of asbestos in Defence, to which all other documents are referenced. It is a stand-alone document that contains all the relevant protocols, information, and procedures with respect to management of asbestos. It does not rely on referencing other documents for anything other than supplementary information; and
- Ensure asbestos management within Defence is in accordance current occupational hygiene and industry Best Practice.
The requirements for management of asbestos and asbestos-containing materials in the Work Health and Safety Regulation 2011 are specified in Chapter 8 – Asbestos. This chapter is set out in a relatively logical order. To assist with demonstrating compliance, Chapter 5 – Asbestos Management in Defence was restructured to align it with the Regulations. In addition to the modifications required for compliance with the WHS legislation, Chapter 5 – Asbestos Management in Defence was updated to include:
- General terms, abbreviations, and definitions used in Chapter 5 or relevant to the management of asbestos and asbestos-containing materials.
- Background information on asbestos: origins, properties, uses and historical perspectives.
- Summary of the health effects resulting from exposure to asbestos and information to put the exposure risks into context.
- Summary of the WHS legislative framework to establish the context for the management of asbestos and asbestos-containing materials within Defence.
Detailed definitions for terms used in the WHS legislation to make them specific to the management of asbestos and asbestos-containing materials in Defence, including:
- Competent Person
- Reasonably Practicable
- Summary of the responsibilities for PCBUs, office holders and key Defence personnel in relation to the management of asbestos.
- An overview of the risk management process with respect to the management asbestos and asbestos-containing materials in Defence.
Summary of the requirements for management of asbestos:
- Asbestos identification surveys
- Asbestos Register
- Health-based risk assessment
- Risk management strategies
- Asbestos Management Plan
- Requirements for refurbishment and demolition
- Management of naturally occurring asbestos (NOA)
- Asbestos related works
- Handling and disposal of asbestos waste
- Requirements for Health Monitoring and record keeping
- Sections for linkage to extant Defence documentation, e.g. DSG Strategic Asbestos Management Plan.
- Procedures for on-going consultation and communication with all the stakeholders regarding the management of asbestos and asbestos-containing materials in Defence.
- Verification: A table listing all the sections of the WHS Regulations specifying requirements for the management of asbestos and asbestos-containing materials, and the relevant sections in Chapter 5. This will assist with establishing compliance and updating Chapter 5 when changes are made to the legislation.
Details of any innovations on these projects
A proposed extension of this project was a review of how asbestos awareness training was provided across different groups within Defence.
Activities that provided value added options to the client, detailing any long term benefits
The addition of scientifically based information on the health risks posed by asbestos exposure to Chapter 5 would ensure that appropriate information is more readily accessible to Defence personnel. This will result in a more consistent understanding, reducing the need for reactive management of perceived asbestos issues.
One of the significant ongoing cost for Defence is the re-inspection of site containing asbestos and the updating of the register and risk assessment. The requirements for carrying out re-inspections, contained in Chapter 5, were rewritten to be in accordance with the current regulations. This allowed the time period for re-inspections of stable materials, not susceptible to damage, to lengthened, potentially resulting in significant cost savings.
The methodology for asbestos risk assessment was considerably expanded in the revision of Chapter 5. This will ensure a more consistent standard is taken across all Defence sites in future allowing a more focussed and prioritised use of resources in remediating asbestos hazards.