Review of the Workplace Health and Safety Strategy for New Zealand to 2015 (WHSS)
Rautaki mō te Haumaru me te Hauora o te Wāhi Mahi mō Aotearoa ki te 2015
Review Report - August 2009
Appendix 2: Key Findings from Engagement Activities
1. What progress has been made in workplace health and safety in New Zealand over the last three years?
a. Increased awareness of workplace health and safety
There was strong agreement from more than half of the stakeholders that general awareness of workplace health and safety has increased since the launch of the Strategy in 2005 - for both workers and employers. Some saw that health and safety is becoming the norm and more integrated into core business rather than being seen as an additional task. Others noted the role of large business or industry leaders in leading and achieving culture change, in some instances, stating that small businesses are still struggling by comparison. Conversely, there was also a range of feedback that cited the low profile of workplace health and safety in New Zealand as a barrier.
b. Highlighting occupational health and psychosocial issues
A group of stakeholders indicated that the Strategy has gone some way towards raising the profile of occupational health and disease. However, it was also signalled that an ongoing emphasis on occupational health and psychosocial issues (stress, bullying and fatigue) was needed.
c. Better collaboration and relationship building
A significant group of stakeholders cited improved collaboration on a number of different levels - between government agencies, between government and industry, within industry and within workplaces (between management and employees). A range of activities were provided as evidence (Puataunofo project, Forestry Safety Culture, Construction Safety Focus Group in Taranaki, partnership reference group forums).
The continuation and expansion of collaboration between government agencies to achieve common goals in the health and safety space and reach a wider audience was a common theme among submissions received from other government agencies.
d. Directing the Strategy at high-risk sectors/hazards
A small group of stakeholders noted that the Strategy has resulted in improved efforts (and associated gains) in particular high-risk industries, notably forestry, agriculture and construction, among others. ACC's Priority Industry programmes are one example in this regard.
Similarly, the introduction of health and safety best practice guidelines for high-risk areas and leadership by some employers in high-risk industries, including the introduction of senior health and safety roles in some large businesses, was seen as progress and should be continued.
e. Appropriate leadership in health and safety from the Department of Labour
A number of stakeholders commented that the Department of Labour should continue leading and working alongside industry to facilitate improved health and safety outcomes. Focus groups and fora such as the safety leadership summit and Construction Safety Focus Group in Taranaki were cited as examples. Specific projects such as that occurring in forestry were also commended.
A small number of stakeholders suggested that the Department needed to take a stronger leadership stance, presenting clear positions on issues rather than taking a more consultative approach.
f. Establishment of Workplace Health and Safety Council
The establishment of an overarching strategic high-level body to provide a forum for promoting and discussing health and safety issues was considered to be an important aspect of the progress under the Strategy by some stakeholders.
a. Employee participation and health and safety representative training
There was strong agreement that the growth in the number of health and safety representatives to approximately 25,000 and their training was a key area of progress under the Strategy. Consequently, building on the progress made in the area of employee participation was a common theme.
There was strong support for ongoing health and safety representative training. Some stakeholders recommended that this training be expanded to include managers/supervisors and that more funding be allocated. Providing more opportunities for health and safety representatives to be part of a wider network, supporting each other and sharing ideas (beyond training) was also advocated.
A smaller group of stakeholders advocated an expansion of the role of the health and safety representatives to become an integral part of any investigation undertaken by the Department of Labour and to have increased powers in the workplace. There was also a small group of submitters calling for an approved code of practice for employee participation.
b. Industry-specific initiatives and programmes
The development of industry-led, government-supported programmes in high-risk sectors - such as FarmSafe, Site Safe, Operate Safe and FishSAFE - were outlined as positive steps. In a related manner, some stakeholders noted initiatives and programmes tailored to the needs of specific high-risk sectors as progress. However, some also qualified this by outlining implementation difficulties, particularly for smaller businesses.
There was a related call by a group of stakeholders to improve capacity in businesses by supporting the encouragement and extension of integrating health and safety through all levels in the workplace, from senior management down.
c. Workplace health and safety in education
There was a range of commentary from stakeholders on the value of introducing education programmes targeting school students, Pacific peoples and migrant workers. The importance of ensuring that education and training programmes provided participants with a good grounding in health and safety issues was a common theme. Some noted that industry training and apprenticeships were providing this in some instances and called for it to continue. Other stakeholders outlined the value of introducing health and safety to students while still at school so they are well equipped to become future workers.
A number of stakeholders mentioned basic level on-the-job training in particular industries, with Site Safe commonly cited. Expanding these programmes to encompass managers/supervisors was seen as a way to increase effectiveness.
d. Making links between health and safety and productivity
Work demonstrating the links between effective health and safety and higher workplace productivity was cited as progress by a small group of stakeholders.
a. Increased access to (and development of) resources to support health and safety
There was a strong theme regarding continued information provision to raise awareness and support businesses to meet their obligations. Some focused on the various channels for communication to be expanded, such as the website, contact centre, social marketing campaigns, regular newsletters/updates for business and reality television programmes. Some noted the recent development of electronic options for reporting, risk assessment or training as showing promise.
Others were more concerned with specific topics, with suggestions including:
- wearing of personal protective equipment (PPE)
- the aged care sector
- psychosocial issues
- noise-induced hearing loss.
Information provided by ACC relating to injury prevention and safe return to work for injured employees was also mentioned as successful initiatives. There was also reference made to the increased emergence of individuals and organisations providing workplace health and safety services.
b. Recognising and celebrating success
Providing support and sponsorship to health and safety conferences and the annual Safeguard awards helps to raise the profile of health and safety by recognising excellence. Although this was mentioned by only a small number of stakeholders, it is linked to the common theme noted earlier under leadership about raised awareness.
c. Improved state of health and safety knowledge
The establishment of Statistics New Zealand's national plan for the collection and management of injury prevention data was considered a positive development in being able to more accurately describe the size and scope of the health and safety problem. However, this was qualified with a range of views indicating considerable room for improvement still remains.
The establishment of the National Occupational Health and Safety Advisory Committee (NOHSAC) and its many reports was widely seen as a positive contribution to New Zealand's state of health and safety knowledge. Some stakeholders noted the wealth of knowledge gained about health and safety from research undertaken by NOHSAC in years past and urged that this knowledge be utilised and expanded on to improve health and safety outcomes.
Health and safety infrastructure
a. ACC levy discount programmes have provided a strong incentive to improve health and safety practices
Programmes offering a reduction in ACC levies in exchange for evidence of health and safety systems and processes (such as the Partnership Programme, Workplace Safety Management Programme and Workplace Safety Discounts) were seen by a number of stakeholders as being a key mechanism in affecting change in businesses.
However, there was qualified support in this regard, with difficulties for small businesses, a need for expansion to other industries and issues of quality assurance being cited as areas for ongoing consideration.
Building on the incentive effect caused by ACC levy discount programmes was advocated by some stakeholders. Some suggested these should be measured based on the performance of businesses in reducing injury claims over time, not just processes.
b. Deterrents and profile-raising effect of prosecutions
There was a range of stakeholder agreement that high profile prosecutions and a higher level of fines have had a positive effect on public awareness and levels of business investment in health and safety. These views suggest that some employers are now starting to take workplace health and safety more seriously.
c. Balancing proactive and reactive inspector functions
Feedback about the role of the Department inspectorate covered a range of views.
Some stakeholders felt there should be more advisory visits to business by health and safety inspectors with the aim of suggesting and supporting improvements in practice. However, others felt that more enforcement visits were needed in order to effect change.
2. What are the main barriers to achieving healthy people in safe and productive workplaces?
a. The Strategy isn't pitched at the right level to encourage engagement across or within the sectors it is seeking to influence
A group of stakeholders expressed the view that the Strategy was addressed mainly at government agency level - not at sector or hazard level - and, as such, was pitched too high. They suggested that this made the Strategy hard to relate to and to apply meaningfully at the sector level or in individual levels where it is intended to make a difference.
Some suggested that the Strategy could be restructured at a level that is more immediate to those expected to put it into place. Various stakeholders proposed focusing on more sector- or hazard-specific goals or initiatives aimed at more easily identified workplace harms, rather than the current high-level descriptors and goals used by the Strategy.
b. The Strategy doesn't set appropriate directions and goals for occupational health and safety
In general, there was agreement on the broad outcomes sought by the Strategy, but some commented that there was a lack of more clearly stated objectives or directions to achieve change.
Some proposed the Strategy be phrased as one or more targets or measurable changes in outcomes that agencies and businesses could measure progress against.
Others asked for more direction-setting or priorities in terms of the wide range of activities described in the Strategy.
c. The Strategy isn't directed at industries/sectors with high rates of injury and disease
Feedback from some health and safety specialists and researchers commented that the Strategy is not having an impact on accident and rates of injury and disease because it is trying to be all things to all people, rather than targeting industries/sectors with high rates of injury and disease. They argued that only by reorienting the Strategy towards industries/sectors with high rates of injury and disease would the Strategy make the best use of scarce resource and have the greatest impact on accident and injury rates.
d. The Strategy doesn't pay adequate regard to Māori
Te Puni Kōkiri made extensive submissions on the need for the review of the Strategy to engage more directly with Māori groups and individuals.
e. The Strategy doesn't give enough emphasis to occupational health and psychosocial issues
This was one of the most commented on aspects of the Strategy. There were comments from most categories of stakeholders, but particularly from health and safety professionals and unions.
It was commonly stated that, although there was already some emphasis on occupational health and psychosocial issues in the Strategy, there needs to be more, as a better reflection of where the hazards and harms are located.
Health and safety professionals commented that the Strategy needs to be recast to place more emphasis on occupational health hazards for it to be effective.
There were extensive reference to the prevalence and significance of psychosocial hazards and the impact they have on all aspects of health and safety practices, and, even more significantly, workplace cultures in support of health and safety.
f. The Department of Labour needs to take a more active role in leading the Strategy
The important leadership of the role of the Department in leading the Strategy was commented on indirectly or in passing in many submissions. Whilst no stakeholders suggested the Department of Labour was not the best agency to lead the Strategy, some were critical of the level of leadership shown by the Department and its management. Others suggested there needs to be better alignment between the Department's programmes and interventions and the goals of the Strategy.
The discontinuation of 'OSH' as a brand name was also seen by some as adding to a perceived drop in visibility of the Department.
g. Ensure policy initiatives reach the 'coal face'
Employees and unions suggested that inspection rates and the resourcing of the health and safety inspectorate had fallen to an unsatisfactory level and that this, in turn, undermined the impetus for employers and others to make improvements in health and safety practice and engage with the Strategy.
a. There are no reliable competency standards for health and safety consultants and intermediaries
Many businesses, employer organisations and health and safety consultants noted the business challenges in accessing reliable advice on health and safety management, the appropriate hazard controls and the requirements to meet their legal duties. This was particularly the case with respect to small and medium-sized enterprises (SMEs).
The absence of a reliable accreditation process for consultants to benchmark themselves against and businesses to use as they purchased consultancy services was a related and significant impediment to businesses accessing necessary knowledge and/or services in health and safety. This view was reflected by a number of industry groups and specialists.
b. Health and safety representatives are unable to take an active role in the workplace
A group of stakeholders said that, although there had been a great deal of progress in the ability of health and safety representatives to take an active role in the workplace over recent years, there was a danger that this would not be fully utilised if there was not more encouragement for employers and representatives themselves to make more of employee participation processes in workplaces.
Some felt this encouragement could be by legislation or other means (such as an approved code of practice) while others proposed incentives and positive messaging to encourage employers to make more use of employee participation.
c. There is a shortage of training for managers and supervisors in workplace health and safety
A lack of capability at the enterprise level amongst managers and supervisors was pointed out by some stakeholders. This barrier was seen as an impediment to, among other things, employee participation and effective hazard management in workplaces.
There was extensive comment on the need for managers and supervisors in businesses to have access to useful and concise education and training to make them more conversant and comfortable with their health and safety management responsibilities.
Others suggested that the training barrier for managers and supervisors is with the education and training programmes outside the workplace, with gaps in tertiary, secondary and other forms of training.
d. Workplace cultures do not support improvements in health and safety
There was clear recognition across all stakeholders of the need to improve workplace health and safety cultures for any sustainable improvement to workplace health and safety. Some suggested that New Zealanders, and therefore workplaces, have qualities that can work against a positive health and safety culture and that, to make progress, the Strategy would need to provide additional emphasis on encouraging the workplace attitudes and practices that will sustain positive health and safety cultures.
e. Smaller businesses have difficulty accessing health and safety knowledge and guidance
There was extensive reference to the difficulties of SMEs in gaining access to meaningful health and safety knowledge and guidance. Some suggested that there need to be new materials produced specifically to meet the needs of SMEs, and others emphasised the need to improve their access to health and safety information.
f. Capability within the Department of Labour
There was a range of comments on the lack of technical health and safety expertise in the Department of Labour and issues relating to the skills and sustainability of the inspectorate. There was related feedback from some stakeholders on the inadequate resourcing of government agencies working on health and safety, especially in relation to HSNO enforcement.
a. Standards and guidance published by the Department of Labour are often incomplete or out of date
There was extensive comment on this subject from all categories of stakeholders, but there was particular comment from several employers and health and safety practitioners. Issues raised included a lack of up-to-date guidance and fragmentation across HSNO, HSE and ACC standards and guidance.
b. Businesses cannot access information on causes of accidents or solutions to problems or hazards as they arise
Related to a perceived lack of standards and guidance, some employers in particular referred to a need for timely information to be made available on the causes of accidents as they are made known to the Department and on the steps that employers and others could take to manage hazards in response to this knowledge.
c. Businesses cannot access data to benchmark their own performance
There was extensive comment on the lack of data on occupational safety and health performance. Businesses expressed most interest in being able to access data that would allow them to benchmark their own performance.
d. There is a lack of health and safety surveillance
Health and safety practitioners and agencies, particularly those with a health focus, referred to a lack of comprehensive or even indicative health and safety surveillance data, resulting in the extent of the problem remaining unknown.
In a related manner, there was a sense from stakeholders that there was a lack of evidence-based interventions and acknowledged need for improved decision-making around research priorities and funding.
e. Businesses need access to information and resources to promote workplace health and safety internally
A common theme from stakeholders was a failure of the Strategy to engage at the workplace level. Employers and others referred not only to the structure and content of the Strategy in that respect, but also to a lack of resources for individual workplaces to base their own health and safety promotions and programmes on. They said that failure to provide materials in support of this work created a barrier to progress and prevented the Strategy from being more positive and proactive.
Health and safety infrastructure
a. There is confusion about the respective roles of the Department of Labour and ACC in the framework
The respective roles of the Department of Labour and the injury prevention functions of ACC within the legislative framework were the subject of a considerable number of comments. Several stakeholders referred to the confusion between the two organisations and some inconsistency of approaches and resourcing.
This issue is significant given the number of stakeholders that said the administration of health and safety legislation by the Department provided the foundation on which the Strategy is built.
Further to this, some said that low levels of enforcement by the Department of Labour undermined the Strategy and provided a disincentive for businesses to improve workplace health and safety.
b. HSNO enforcement is not integrated and there are low levels of compliance
The issue of HSNO enforcement emerged from consultation across government agencies and some industry associations. Enforcement capacity, uncoordinated guidance and legislative complexity were seen to undermine progress in health and safety.
c. The role of industry accreditation/endorsement programmes and processes is unclear
Some commented that there was confusion concerning the place of industry accreditation programmes such as Site Safe or Operate Safe in the health and safety framework. There was some uncertainty expressed concerning the place of these programmes and the Department's, ACC's and individual employers' ability to maintain their own health and safety management initiatives.
3. What should the current and future priorities for workplace health and safety in New Zealand be?
Three priorities for leadership of the Strategy stood out:
a. Rejuvenate the Strategy
There was consistent feedback that suggested there is a need to clarify the Strategy's direction and goals, including targeting high-risk sectors or hazards as appropriate.
b. Increase the emphasis on occupational health and psychosocial issuesc. Department of Labour to show more leadership
Almost all stakeholders indicated a support for the Department to affirm and strengthen its leadership of the Strategy and reinforce it through the Department's policies and programmes.
Increasing capability was suggested as a priority area by many stakeholders. Three key priorities emerged:
a. Improved utilisation of health and safety representative training
There was extensive positive comment on what has already been achieved through health and safety representative training and employee participation processes implemented in New Zealand workplaces in recent years.
Numerous stakeholders said that there is a need to ensure the good work is not lost, but rather better utilised in workplaces. The priorities were therefore described as enhancements or refinements rather than new initiatives. They tended to be suggested by unions or employees. Unions in particular said it was a priority to complete development of an approved code of practice for employee participation.
b. Improved business capability and workplace health and safety cultures (especially for managers and supervisors and SMEs)
Businesses and employer groups also commented extensively on the need to improve health and safety capability in workplaces. Their suggestions focused particularly on the need to increase the availability and quality of health and safety education and training for supervisors and managers, as well as increasing its inclusion in pre-employment training and education.
Other areas seen as a priority to improve capability within businesses were better supporting SMEs and improving workplace health and safety cultures, including a move away from a compliance culture view.
c. Improving the competency of health and safety consultants and intermediaries
There was considerable feedback from stakeholders, particularly health and safety practitioners, about the need to improve cross-discipline communication on workplace health and safety. In a related manner, improving the competency of health and safety consultants and intermediaries, including the technical health and safety expertise within the Department of Labour, was identified as a current priority.
Two clear priorities emerged for building sector knowledge in occupational health and safety:
a. Improve standards and guidance
There was widespread agreement that the Department needs to give priority to maintaining and updating its standard-setting and guidance material, including sector-specific materials and tailoring it for SMEs. This also included improving the alignment of HSNO, HSE and ACC standards and guidance.
b. Improve health and safety surveillance and workplace data
Stakeholders strongly agreed that there should be improved surveillance and data on occupational safety and health, and causation data, including metrics that workplaces can use to benchmark their performance against.
Health and safety infrastructure
Three broad priorities emerged for maintaining the health and safety regulatory framework:
a. Improving government agencies' alignment
Better aligning ACC's, designated agencies' and other agencies' health and safety programmes with those of the Department of Labour, including HSNO enforcement
b. Department of Labour consistency in the workplace
Stakeholders felt that there should be a focus on maintaining the consistent application of the HSE Act in workplaces by the Department of Labour.
c. Maintaining an appropriate balance between incentives and deterrents
Maintaining an appropriate balance between incentives and deterrents was a recurring theme, although this priority was characterised by contrasting preferences. Employers and associations indicated an increased role for incentives and employees and unions wanted to ensure appropriate levels of inspection of workplaces.
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