23 April 2025 posted by Safety Partners
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If you enjoyed reading this blog post on ‘Early Warning Signs: When Duty Holders and Officers Must Take Action’, you may want to check out:
What indicators should trigger Directors and Board members to increase scrutiny and participation in a particular area of WHS Management to meet their obligations to “ensure that the PCBU has, and implements, processes for complying with any duty or obligation the PCBU has under the WHS Act” Section 27(5) WHS Act 2011 (NSW).
Indicators that Trigger Further Investigation
Injury Data
- Trends or Cycles shown in past injuries, illnesses and other incidents data on the rise
- A sharp increase in Injury/illness by category of at-risk body location, e.g. lower Back
- Sharp Increase in Injury/illness outcomes by the mechanism of injury, nature of the injury, e.g. Workplace Violence
- Indicators of hazardous exposure (e.g. No. chemical spills or Asbestos )
Hazard, accident and incident reporting
- The number of WHS hazards, incidents and accidents reported from the same period in the previous year or Quarter decreased.
- Near Misses.
- Increase in Severity and frequency of injuries and comparative data for preceding periods.
- Increase Notifiable Incidents.
- Bullying & Harassment complaints – Number, type, area.
Training Data: In-house, External, Online or Toolbox Talks
- Increased number of workers Non-Compliant with mandatory Job training
- Increase in Incidents after Training in particular Hazard area, e.g. Manual Handling, Plant & Equipment
WHS Plan
- No actions completed or reviewed of High-Risk items on the Risk Register
- WHS Plan not reviewed at SLT or WHS Committee Meetings
- Hazard or Risk has increased on the Action Plan
- Re-occurring incidents – Types, Person or Area/Department
- Action Plan is out of date or not updated and shared
Contractors
- Number of Incidents not being reported
- Generic SWMS, Risk Assessments
- Notifiable Incidents
- High-Risk Activities – Correct Licenses or Certifications
- History of High Workers Compensation Claims
- Lack of Consultation between PCBU to Contractors and Sub-Contractors
- Lack of observation of work and work practices
Number of Corrective actions from audits and accident, incident and hazard reports completed
- Increase in the number of corrective actions open.
- Corrective actions set timeframes have been extended multiple times on outstanding actions.
- Corrective Actions are being bottlenecked, waiting for decisions with the same Department or person.
Lost Time Injuries
- Increase in Lost time injuries in a particular area, Team, Building
- Re-occurring injury type or person
- Average Time Lost Rate (ATLR) above Industry norms
- Lost Time Injury Frequency Rate (LTIFR) above Industry norms
- Ensuring the right source of industry standards is used, i.e., national if the organisation is Australia-wide or relevant state or territory.
Workers Compensation
- Increase in Open Worker’s compensation claims from past YTD, MTD
- Increase in Worker’s compensation claim costs
- Comparisons to the Past year show an Increase in Claim Type or area, age, e.g. Psychological, aging workforce, young workforce.
Leave Data
- Increase in Personal Leave in particular areas or Team
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Increase in Absenteeism or resignation in specific regions or Team (These can be indicators of the result of Psychosocial incidents)
Complaints Received
- Increase in type of Complaint, e.g. Sexual Harassment, Workplace violence
- Increase of complaints from particular Departments or site
- Increase in Complaints about particular Manager or Worker, Client or Customer
Workplace Inspections
- The same Hazard being reported over multiple inspections
- Workplace inspections only being completed Annually – can be broken down into Areas for each month
By looking for these indicators, officers and duty holders should be triggered to ask further questions, further investigations, and additional actions to ensure that any programs or processes implemented or implemented meet their obligations under the WHS Act.
Disclaimer – these articles are provided to supply general safety information to people responsible for OHS in their organisation. They are general in nature and do not substitute for legal and/or professional advice. We always suggest that organisations obtain information specific to their needs. Additional information can be found at https://www.safeworkaustralia.gov.au/
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