8. Operation
8.1 Operational Planning and Control
8.1.1 General
Clause 8 is where the planning gets translated into running operations. The actions identified in clause 6 — risk treatments, legal compliance steps, control plans — become live operating criteria with documented procedures, defined controls and evidence that the work is being executed the way it was designed.
1
Set clear operating criteria — what "done correctly" looks like for each high-risk process
2
Run the process under those criteria, with controls actively applied (permits, isolations, supervision, monitoring)
3
Keep enough records to show, after the fact, that the work was carried out as planned
4
Design the work around the worker — workstation, task sequence, tooling, shift length — instead of forcing the worker to compensate
Adapt the work to the worker:
Ergonomic load, mental demand, shift fatigue, repetitive strain — these are designed in or designed out at the workstation level. ISO 45001 expects work to fit human capabilities, not the reverse. That covers physical layout, tooling, task pacing and cognitive load.
Ergonomic load, mental demand, shift fatigue, repetitive strain — these are designed in or designed out at the workstation level. ISO 45001 expects work to fit human capabilities, not the reverse. That covers physical layout, tooling, task pacing and cognitive load.
Where operational controls are needed:
Controls are applied wherever a missing rule, procedure or check could let the work drift away from the OH&S policy:
- Tasks where unwritten knowledge could vary by shift or by individual
- Operating limits that, if exceeded, push the work into a higher-risk band
- Activities held under controlled conditions through procedures, work instructions, permits and JSAs
Coordination with Contractors and Other Organizations
On multi-employer sites, coordinate the OH&S system with other employers — interface meetings, shared permit systems, joint risk assessments, integrated emergency plans
Run procurement under defined OH&S controls so contractors and suppliers don't import risk that the system can't see (covered in 8.1.4)
8.1.2 Eliminating Hazards and Reducing OH&S Risks
Hazard elimination and risk reduction follow a strict order — the controls hierarchy. Controls are selected starting at the top (elimination), and PPE only carries the load when nothing higher up is feasible. A control plan that defaults to PPE is a control plan that hasn't been thought through.
Hierarchy of Controls Application
Hierarchy of Controls (in order of priority):
1
Elimination: Physically remove the hazard entirely
2
Substitution: Replace the hazard with something less hazardous
3
Engineering Controls: Isolate people from the hazard using physical barriers or systems
4
Administrative Controls: Change the way people work to reduce exposure
5
Personal Protective Equipment (PPE): Protect individual workers (least effective, last resort)
Practical Examples by Hazard Type:
Manual Handling Hazard:
- Elimination: Automate the process completely, no manual handling required
- Substitution: Use smaller containers or lighter materials
- Engineering: Install mechanical lifts, conveyors, or trolleys
- Administrative: Train workers in proper lifting techniques, rotate workers
- PPE: Back support belts (least effective)
Chemical Hazard:
- Elimination: Change process to eliminate need for the chemical
- Substitution: Use less hazardous chemical (e.g., water-based vs. solvent-based)
- Engineering: Enclosed system, local exhaust ventilation
- Administrative: Limit exposure time, implement safe handling procedures
- PPE: Gloves, respirators, protective clothing
Machine Hazard:
- Elimination: Remove hazardous operation from production process
- Substitution: Replace with safer machine design
- Engineering: Install guards, safety interlocks, emergency stops
- Administrative: Lockout/tagout procedures, restricted access
- PPE: Safety glasses, hearing protection
Why the order matters:
Controls higher in the hierarchy don't depend on human compliance to work. A removed hazard can't expose anyone. An engineering control runs whether the operator is paying attention or not. Administrative controls and PPE only protect when the worker uses them correctly every time — and that's where most exposure happens.
Controls higher in the hierarchy don't depend on human compliance to work. A removed hazard can't expose anyone. An engineering control runs whether the operator is paying attention or not. Administrative controls and PPE only protect when the worker uses them correctly every time — and that's where most exposure happens.
Control Effectiveness
Weigh sector best practice, available technology, and operational and financial constraints when selecting controls
Test whether existing and new controls actually work — not just whether they're installed
Where multiple controls overlap, evaluate the combined effect rather than treating them in isolation
Plan for control failure — what happens if the interlock is bypassed, the LEV trips, the supervisor is absent
8.1.3 Management of Change
Change is where new hazards appear and where existing controls quietly stop working. A formal Management of Change (MOC) process catches both planned changes (new plant, modified procedures, restructure) and the unplanned ones (breakdowns forcing a workaround, weather disruption, sudden staff shortages). No change goes live without an OH&S risk review and an approval signature.
Changes Requiring OH&S Review
Types of Changes Requiring Assessment:
- Work Organization: New shifts, staffing levels, work schedules, organizational structure
- Processes and Procedures: New work methods, operating procedures, maintenance practices
- Materials and Substances: New chemicals, raw materials, consumables
- Equipment and Machinery: New equipment, modifications to existing equipment, technology upgrades
- Infrastructure: New facilities, building modifications, layout changes
- Products and Services: New product lines, service offerings
- Legal Requirements: New regulations or changes to existing requirements
- Knowledge and Information: New understanding of hazards or better control methods
- Temporary Changes: Shutdowns, maintenance activities, construction projects
Management of Change Process
1
Hazard identification and risk assessment for the proposed change before it goes live — not after the first incident
2
Planned, controlled changes to the OH&S system itself when policies, procedures or organisational structure shift
3
Review of unintended changes — equipment failures, supplier substitutions, emergency workarounds — and corrective action where they introduced new risk
4
Mitigation steps where any change has eroded existing controls
Management of Change Steps:
1Identify and describe the proposed change
2Conduct hazard identification and risk assessment for the change
3Identify legal requirements applicable to the change
4Determine control measures using hierarchy of controls
5Consult with affected workers on the change and controls
6Update procedures, work instructions and training
7Provide training on new hazards and controls
8Approve the change before implementation
9Implement the change with controls in place
10Monitor effectiveness of controls after implementation
Talk to the people doing the work:
Workers who run the affected process see things a desk-based MOC review will miss — quirks of the equipment, informal workarounds, the way the procedure actually plays out on shift. Consultation before implementation isn't a courtesy; it's how the change avoids creating hidden hazards.
Workers who run the affected process see things a desk-based MOC review will miss — quirks of the equipment, informal workarounds, the way the procedure actually plays out on shift. Consultation before implementation isn't a courtesy; it's how the change avoids creating hidden hazards.
Unintended Changes:
Organizations must also review and control the consequences of unintended changes. Examples include:
- Equipment breakdowns requiring different work methods
- Material shortages requiring substitution
- Staffing changes affecting supervision or competence
- Weather conditions affecting outdoor work
- Customer demands changing work pace or methods
8.1.4 Procurement
8.1.4.1 General
Procurement is a recognised entry point for OH&S risk. Equipment with the wrong safety rating, chemicals without proper SDS, contractors without competent supervision — these arrive through procurement and become the organisation's problem the moment they cross the gate. Procurement controls keep that risk out.
8.1.4.2 Contractors
Contractors are not someone else's problem:
Under section 37(2) of the OHS Act and the Mine Health and Safety Act, the principal employer carries responsibility for contractor work on its premises. Coordination starts at procurement: identifying contractor hazards, agreeing controls, verifying competence and ensuring contractor work doesn't import risk to other workers on site.
Under section 37(2) of the OHS Act and the Mine Health and Safety Act, the principal employer carries responsibility for contractor work on its premises. Coordination starts at procurement: identifying contractor hazards, agreeing controls, verifying competence and ensuring contractor work doesn't import risk to other workers on site.
1
Defined contractor processes that cover:
- Communicating OH&S requirements before tender award
- Identifying and controlling hazards introduced by contractor work
- Verifying that contractors and their workers meet the same OH&S standard as own employees
2
Procurement OH&S requirements set and signed off before any contractor mobilises to site
3
OH&S system conformance verified during contractor selection — not assumed from a low tender price
Contractor Management Process:
Pre-Qualification:
- Assess contractor OH&S performance history
- Verify OH&S competencies and qualifications
- Review contractor OH&S management system
- Check insurance and legal compliance
Pre-Start Requirements:
- Communicate site-specific OH&S requirements
- Conduct contractor induction and orientation
- Review and approve contractor work plans and risk assessments
- Verify worker competencies and authorizations
- Ensure appropriate PPE and equipment available
During Work:
- Monitor contractor OH&S performance
- Conduct regular inspections and observations
- Coordinate activities with own workers
- Investigate contractor incidents and near-misses
- Address non-conformances promptly
Post-Work Review:
- Evaluate contractor OH&S performance
- Document lessons learned
- Update contractor records for future reference
8.1.4.3 Outsourcing
Outsourcing transfers the work but not the OH&S accountability. The provider has to operate under controls consistent with the organisation's legal duties and OH&S outcomes — and the organisation has to be able to prove that's happening.
Outsourcing Considerations:
- Define OH&S requirements in outsourcing contracts
- Ensure outsourced provider has adequate OH&S controls
- Monitor performance of outsourced activities
- Maintain ultimate responsibility for OH&S outcomes
- Ensure workers performing outsourced work are competent
- Include OH&S requirements in service level agreements
Procurement of Products and Services
OH&S Considerations in Procurement:
- Equipment and Machinery: Safety features, guards, emergency stops, compliance with standards
- Chemicals and Materials: Safety data sheets, hazard information, safer alternatives
- PPE: Appropriate for identified hazards, certified to standards, proper sizing
- Services: Provider OH&S competence, legal compliance, insurance coverage
- Design Services: Incorporate safety in design principles
Workers feed procurement decisions:
The end-users of PPE, tooling and equipment know what works and what doesn't on the actual job. Their input on fit, comfort, ergonomics and reliability translates directly into whether procured items get used correctly — or worked around.
The end-users of PPE, tooling and equipment know what works and what doesn't on the actual job. Their input on fit, comfort, ergonomics and reliability translates directly into whether procured items get used correctly — or worked around.
8.2 Emergency Preparedness and Response
The emergency scenarios identified during hazard work (clause 6.1.2.1) need a planned response, trained personnel and tested capability. Emergency preparedness is judged on what happens in the first ten minutes — if the plan only exists on paper, those ten minutes are lost.
Emergency Preparedness Requirements
a
A planned response for each credible emergency, including first aid arrangements
b
Training for everyone with a role in that response — wardens, first aiders, incident commanders, evacuation marshals
c
Drills and exercises run on a defined schedule — varied scenarios, varied shifts, occasional unannounced
d
Performance review after every drill and every real event, with the plan updated when gaps are exposed
e
Workers told what to do — not just what the procedure says, but what their personal role is during the emergency
f
Coordination with contractors, visitors, emergency services, regulators and — where the operation can affect them — neighbouring communities
g
Plans designed around the actual capabilities of the people who'll execute them, with input from those people during development
Types of Emergency Situations:
- Fire and Explosion: Fire outbreaks, gas explosions, electrical fires
- Medical Emergencies: Serious injuries, heart attacks, allergic reactions
- Hazardous Material Incidents: Chemical spills, gas leaks, toxic releases
- Natural Disasters: Earthquakes, floods, severe storms, extreme weather
- Security Threats: Violence, threats, unauthorized access
- Infrastructure Failures: Power outages, structural collapse, equipment failures
- Environmental Emergencies: Major pollution incidents, environmental damage
- Workplace Specific: Confined space rescue, working at heights rescue, machinery entrapment
Emergency Response Planning
Emergency Response Plan Components:
- Emergency Contacts: Internal response team, emergency services, management contacts
- Alarm Systems: How to raise the alarm, types of alarms for different emergencies
- Evacuation Procedures: Evacuation routes, assembly points, accountability procedures
- Emergency Roles: Fire wardens, first aiders, emergency coordinators, search teams
- Communication Protocols: Who to notify, how to communicate, emergency announcements
- Response Procedures: Specific actions for different emergency types
- Emergency Equipment: Location and use of fire extinguishers, first aid kits, emergency equipment
- Site Information: Site plans, hazardous material locations, utility shut-offs
- Coordination with External Services: Fire brigade, ambulance, rescue services
Training and Drills
Provide emergency response training to all workers appropriate to their role
Train emergency response team members in specialized response skills
Ensure first aiders have current first aid qualifications
Conduct regular emergency drills and exercises (e.g., fire drills, evacuation drills)
Test emergency equipment and systems regularly
Review and improve emergency response based on drill results and actual incidents
Emergency Drill Best Practices:
- Conduct drills at varying times (different shifts, days of week)
- Include scenarios for different emergency types
- Test both planned (announced) and unannounced drills
- Measure and record evacuation times
- Debrief after each drill to identify improvements
- Involve emergency services in complex scenarios
- Test communication systems and backup procedures
- Document drill results and corrective actions
Post-Emergency Actions
Evaluate emergency response performance after incidents or drills
Revise emergency plans based on lessons learned
Provide support to affected workers (medical, psychological)
Investigate root causes of emergencies
Communicate outcomes and improvements to all stakeholders
Documentation Requirements:
Maintain documented information on emergency preparedness and response processes
Emergency response plans and procedures
Training records for emergency response personnel
Emergency drill and test records
Emergency equipment inspection and maintenance records
Post-emergency evaluation reports
Workers shape the emergency plan:
The people on the floor know which exit gets blocked when a particular line is running, where the radio dead-spots are, and how long it actually takes to muster from the back of the warehouse. That ground truth has to inform the plan — and they have to be in the drills, not watching from the office.
The people on the floor know which exit gets blocked when a particular line is running, where the radio dead-spots are, and how long it actually takes to muster from the back of the warehouse. That ground truth has to inform the plan — and they have to be in the drills, not watching from the office.