Chapter 2.1.1 – Consultation and Communication

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Purpose and Objectives

It is the policy of Company that the CEO and Senior Management have the overall responsibility to ensure that the Obligations and Responsibilities Statements in this procedure are issued and followed.

Scope/Coverage

This policy applies to the Chief Executive Officer and Executive Management.

What this procedure describes

How everyone at Company is involved in sharing information and making decisions about Health,Safety, Environment and Quality (HSEQ) management through consultation and communication.

Why it is required

  • For Company to achieve Zero Harm, everyone needs to communicate and share information with each other. This communication involves identifying hazards and risks, talking about any health and safety concerns and working together to find solutions. This includes communication between the people who manage the work (leaders) and people who perform the work (team members).
  • Effective consultation and communication is required to manage environmental and safety‐related matters for Company activities, products and services. It is also required by legislation and Australian Standards for maintaining management systems.
  • To help Company meet its consultation requirements specified in the Work Health and Safety Act 2012 and its Regulations.

Who it applies to

This procedure applies to everyone working for or on behalf of Company.

This procedure relates to consultation and communication processes for managing Company HSEQ issues only and does not replace the consultation requirements provided for in the enterprise agreement.

Background

A Zero Harm workplace is more easily achieved when everyone involved in the work communicates with each other. Company is committed to consulting with its team members when planning to introduce changes in the workplace. Consultation allows us to seek and understand differing views and encourages co‐operation, collaboration and engagement. It identifies opportunities, assist decision making and helps ensure any workplace changes are effective in practice. Consultation demonstrates our principles of caring for our team members, collaboration and working as one business, as well as promoting the development of trust.

Legislative requirements and best practice

Consultation is an essential part of health, safety and environmental risk management and a legal requirement under the Work Health and Safety Act 2012 and the Fair Work Act 2009.

Sections 46 to 49 of the WHS Act set out precisely what consultation means and when it is required, this procedure is based on these sections.

Consultation

What is consultation?

Consultation is a two‐way process between leaders, team members, contractors and visitors. Consultation involves:

  • exchanging opinions
  • raising concerns and paying attention to those concerns
  • actively listening
  • seeking and sharing views and information, and
  • considering what has been said before making decisions.

When is consultation required?

Consultation is required when:

  • identifying hazards and assessing risks arising from the work we do or could do (i.e. through toolbox talks, meetings, safety observations, surveys, etc.);
  • making decisions about ways to eliminate or minimise those risks;
  • making decisions about the adequacy of facilities (i.e. such as deciding on or changing the number and location of toilets, drinking water, washing facilities, dining areas, change rooms, personal storage and first aid);
  • proposing changes that may affect health and safety at work. For example, changing work systems, developing or purchasing new products, equipment, substances or projects. Refer to the HSEQ Change Management Procedure for more details. Some of these matters may also require further consultation under the Aurora Agreement 2011 and Transend Networks Enterprise Agreement 2011.
  • making decisions about the process and procedures for consulting with Team Members;
  • resolving health, safety, environment and quality (HSEQ) issues;
  • monitoring Team Members health or workplace conditions; and
  • providing Team Members with information and training.

Who do we consult with?

In most cases, where a change only affects a team, the Leaders will only need to consult their direct team members and their Health and Safety Representatives (HSRs) about HSEQ matters, with support from HSE Advisors. Leaders may also be required to consult with other duty holders, such as Leaders from Company and other businesses. Leaders are required to consult within the scope of their control. Team members we need to consult with about HSEQ matters will vary depending on the work and its hazards, the availability of team members and how urgently a decision is needed. Where the HSEQ matter is broader than a team, a member of the health, safety, environment and technical competency team can help decide who should be consulted.

How to consult on HSEQ matters?

We can consult with Team Members individually, through a HSR or HS Committees―depending on the situation. There are many ways consultation can occur. Consult HSRs and contract leaders to decide the best method of consultation (for instance, tool box, forums, committees, etc.). Information about the Company committees is available in the HSEQ Committees Procedure.

Consultation under this procedure involves:

  • sharing relevant HSEQ information (i.e. policies, procedures, hazard reports, risk assessments, HSEQ data and any proposed changes);
  • giving Team Members a reasonable opportunity to express views, raise concerns and contribute, including the Team Member’s health and safety representative;
  • taking their views into account, Leaders are required to decide the outcomes of consultation and advise Team Members in a timely way.

Consult regularly to fix problems early. Refer to the HSEQ Issue Resolution Procedure for information about how to resolve HSE issues.

How to consult:

Provide information

  • why the change is being introduced (business needs, benefits)
  • the detail of the changes (what)
  • the impact of the change (how it will affect individuals)

Discuss

  • communicate change, business needs (team meetings, newletters, email, intranet site, provide training, etc)
  • seek feedback (views, opinions, ideas, issues), from teams and their representatives (team/ individual meetings, intranet, surveys etc)
  • encourage two‐way flow of information
  • record discusions and feedback

Review

  • consider ideas and information received
  • assess against business requirements and decide what is reasonably practicable
  • record any decisions or changes and the reasons why
  • communicate back to teams and their representatives

Implement

  • plan and implement change
  • from time to time, ask for feedback to improve the next consultation process

What records do I need to keep?

Keep records to demonstrate you have consulted on HSEQ matters and issues. The records can be brief and simple, and cover who is involved, the issue/matter, the decision made, actions arising and when the actions are completed.

The method of record keeping from consultation depends upon the reason for and method of consultation. Some common methods are:

  • Informal face to face consultation – maintain diary notes including all persons present, and where appropriate follow up the conversation with an email or other document that reflects the discussion.
  • Formal face to face discussion (e.g. during toolbox and other meetings, or during Safety Interactions) – keep and circulate meeting agendas and minutes or detailed diary notes, including attendees at the meeting.
  • Meeting agendas – should be circulated to the participants prior to the meeting. Where this cannot be achieved due to urgency of the meeting, an agenda should be provided or agreed at the start of the meeting. Agenda documents shall be stored with the meeting minutes.
  • Meeting minutes – Where a HSEQ meeting is held, minutes are to be kept. These minutes are to be distributed to all attendees of the meeting. The minutes must be stored in a location where employees can gain easy access to the minutes and could include digital storage on the Company intranet or physical display on a notice board. The minutes shall include who attended the meeting, any actions and due dates, decision made and any agreed responsibilities.
  • Zero Harm Leadership Interactions – Leaders who have been informed they are required to record monthly Zero Harm Leadership Interactions need to send them by email to HSE Risk Analyst or record them in RMSS. Leaders also need to ensure conversations about WHS are recorded in meeting minutes or diary notes.
  • Consultation via Email or Other Electronic Means – all emails and associated responses should be saved in the same location within The ZoNe within the “HSEQ Management Collaboration Zone‟. Placing documents in this location allows files to be easily located and maintained in the future.
  • Consultation on Changes – regardless of the method of consultation, where this involves a change the Managing HSE Change Procedure and associated plans should be used. Management of change plans and consultation and communications plan shall be stored in The ZoNe and located with all other related documentation.

Communicating HSEQ performance

HSEQ objectives and targets

The HSEQ Group has consulted with management to establish environmental and safety‐based objectives and targets with the Zero Harm Strategy − a strategy defined each year. The strategy’s performance indicators are reported and discussed with Leaders through a range of consultation mechanisms.

HSE matters are discussed at the following meetings:

  • Board Meetings;
  • Company Leadership Team Meetings;
  • Zero Harm Leadership Team Meetings

HSEQ performance

The HSEQ Dashboard is used to collect data from a wide range of sources and it provides a portal to the data and presents information on HSEQ performance. Leaders can access HSEQ data and information to understand the Company HSEQ performance. The Dashboard is the Company ‘one source of truth’ for HSE data and performance. For information about data inputs and outputs, refer to the HSEQ Dashboard Data Map.

The dashboard provides information on:

  • injury data and trends;
  • notifiable and significant incidents;
  • Zero Harm leadership interactions; and
  • Number of LifeSafe observations i.e. behavioural based safety

Consulting and communicating with service providers

Contractors and subcontractors need to be communicated with regarding HSEQ matters as we would consult and communicate with Company team members.

Under work health and safety law, this is subject to how much Company can influence and control their activities. For instance, Company will have less capacity to influence contractors performing a specialist role, such as asbestos removal work because we are not an expert in how to work safely with asbestos, therefore our process effects them less, reducing the level of consultation required. However, if the work involves general building maintenance of a non‐specialised nature, such as general cleaning and replacing light globes, then Company will have more influence and control over the work activities being undertaken. Where Company ability to influence their operations increases, so does the level of consultation required.

When does Company need to consult with others?

Company needs to consult, co‐operate and co‐ordinate activities with other duty holders when we share a duty for the same matter. This may include:

  • Shared work sites;
  • Contracted obligations;
  • Landowner requirements; and
  • Other legal instruments, including Memorandum of Understanding with Parks and Wildlife, Public Authority Management Agreement, etc.

For example, to protect our Team Members at the same site or job. This needs to be done when we become aware contractors will be involved in the work. Company addresses this requirement in contractual arrangements and ongoing consultation and communication.

Consultation should commence during the planning of the work, to ensure that HSEQ measures are identified and implemented from the start.

When entering into contracts, the contracts Leader needs to communicate HSEQ requirements, review the goods or services to be supplied or undertaken, discuss any issues that may arise and how they will be dealt with.

A need for further consultation may arise when circumstances change over the period of the work, including the work environment and the people involved in the work.

Co‐operation and co‐ordination with other duty holders is an ongoing process, contract leaders and owners need to consult about the following:

  • Identifying the Team Members that are or will be involved in the activity and who else may be affected by the activity;
  • What each will be doing, how, when and where and what plant or substances may be used;
  • What each knows about the hazards and risks associated with their activity and whether the activities of others may introduce or increase hazards or risks;
  • Ways in which the activities of each duty holder may affect what others do, the work environment, including the safety of other people such as visitors and the public;
  • What information may be needed by another duty holder for health and safety purposes and what each will be providing for health and safety, particularly for controlling risks;
  • Who has control or influence over aspects of the work or the environment in which the work is being undertaken, identifying when and how each control measure is to be implemented and ensuring control measures complement each other;
  • Deciding how all affected Team Members will be advised of controls;
  • What procedures or arrangements may be in place for the consultation and representation of Team Members, and for issue resolution;
  • What further consultation or communication may be required to monitor health and safety or to identify any changes in the work or environment; and
  • Deciding how to respond to reasonable requests from other duty holders to assist them in meeting their duty.

The outcomes of consultation need to be recorded/minuted and shared. The Company HSEQ procedures will help identify how to manage risks.

Further information about consultation expectations is provided in the Your Guide to Managing Contracts and Contractors on The Zone.

Communication by the HSEQ team

Internal communication

Key topics of internal communication include, but are not limited to:

  • HSEQ policy, objectives and targets and performance against them;
  • New and changes to existing procedures, work practices and instructions; and
  • Organisational notices and alerts.

Methods of internal communication

HSEQ information is communicated internally in a variety of ways, including:

Face to face communication:

Example: Face to face communication occurs at Zero Harm Days, HSE committee meetings, senior management forums, depot meetings, toolbox meetings, induction and meetings between contractors/subcontractors and Company staff.

Company Intranet The Zone:

  • The integrated HSEQ management system is accessible through The ZoNe.
  • The Business News section on the ZoNe homepage displays HSEQ news.
  • Reporting of incidents through RMSS.
  • Report safety observations through LifeSafe.

Company News:

For high‐level communications with Company‐wide audience.

Email:

Global emails are used for critical Company‐wide priority HSE news. Audiences are also targeted through email groups, including circulating relevant safety matters to the distribution business, contractors and subcontractors only.

Global text (SMS):

For succinct messages that require immediacy and are of a business‐wide priority.

Phone and teleconference facilities:

For consulting with individuals or groups on specific HSE matters.

Bulletin boards:

For posting HSE announcements, achievements, performance, safety and environment notices, procedures and work instructions.

SmartTrack:

For employees to communicate directly with HSEQ management from vehicles in emergency situations.

External communication

Company may communicate HSEQ matters externally with the following parties:

  • The Federal Government;
  • State Government departments;
  • Union representatives;
  • Local councils;
  • Other electricity industry entities;
  • News media;
  • Service providers;
  • Customers;
  • Landowners;
  • Environmental and community groups; and
  • Members of the general public.

Methods of external communications

  • Face to face communication: Face to face communication while working in public spaces.
  • Company Internet site :For providing access to the Zero Harm (HSEQ) Policy, communicating Company sustainability practices and conveying safe practices to members of the public.
  • Mail and email :
  1. Incident reporting
  2. Providing members of the public with access to Company documents such as the Health, Safety, Sustainability and Environment Policy.
  3. Liaising with Energy Networks Association, Work Safe Tasmania, Environmental Protection Authority and other stakeholders.
  • Television and radio:
  1. Providing safety advice about risks associated with electricity and the network
  2. Provide update on current power outages.
  3. Refer to 6.1 for details of who is authorised to speak to the media.
  • Social Media
  1. Public safety messages
  2. Provide update on current power outages.

Specific HSE matters for external communication

Public Surveys on HSE Issues

The Stakeholder Engage Leader and the Health, Safety, Environment and Technical Competency (HSE&TC) Group Leader may conduct periodic public surveys on HSE matters to gauge public awareness and perceptions. The frequency, timing, and relevant issues to be included are decided by the Stakeholder Engage Leader, in conjunction with the HSE&TC Group Leader if necessary, and are based on needs and priorities at the time.

Annual Report

The Company Annual Report is made available to the general public through the Strategy and Stakeholder Relations Team.

Property Access

Consultation with landowners to ensure access to property where required in accordance with the Electricity Supply Industry Act 1995, the Tasmanian Electricity Code and National Energy Customer Framework arrangements.

Other Communications

Other external communications concerning significant Company HSE issues are made through the External Engagement Team Leader and other leaders as required.

Recording Communications

Sent and received records of communications must be recorded in accordance with the Company Information Management Policy.

Responsibilities in relation to this procedure

We all have responsibilities to ensure that Company is a Zero Harm workplace. How everyone contributes to managing health safety and environmental matters in general is provided in Company HSEQ Responsibilities procedure.

Responsibilities regarding external communication are outlined in the Company Delegations Manual.

Glossary

Duty holders – Everyone has a role to play to ensure that health and safety is a priority in the workplace. The Work Health and Safety Act 2012 (WHS Act) and Work Health and Safety Regulations 2011 require persons who have a duty to ensure health and safety to ‘manage risks’ by eliminating health and safety risks so far as is reasonably practicable, and if it is not reasonably practicable to do so, to minimise those risks so far as is reasonably practicable.

The principal duty holder under the Work Health and Safety Act 2012 (WHS Act) is a ‘person conducting a business or undertaking’ (PCBU). Company is a PCBU. Other PCBUs include, Commonwealth and State Authorities, and principal contractors. In some cases, there may be multiple PCBUs who share responsibilities under the WHS laws.

Leaders and team members are also duty holders under the WHS Laws.

HSEQ – Health Safety Environment and Quality

HSR – Health and Safety Representative ‐ a person elected in accordance with the WHS Act 2012 to represent Team Members in a workgroup on work health and safety matters. In Company this person will also represent Team Members on environmental and sustainability matters.

RMSS – is the Company Safety Health and Environment Incident and Risk management system.

Contractor – a person engaged by a third party to perform work for Company, including team members on labour hire contracts, subcontractors and their employees. This does not include Company Team members.

Team member – is a worker who carries out work in any capacity for Company (WHS Act 2012 s.7). It includes leaders, Board Members, employees, people on individual employment contracts, apprentices, trainees, students gaining work experience, outworkers, volunteers, employees of a labour hire company, contractors or subcontractors, and their employees.

Leader – a team member who has responsibility for the supervision or coordination of a work group(s), department or work team, including delegated authority to direct the work of team members within each work group. It includes the Chief Executive Officer, Board Members, General Managers, Group Leaders, Regional Leaders, Leaders, Team Leaders and Leads