sale work nstm||sChief Executive OfficerMr Rex Hoy

COAG Reporting StudyProductivity CommissionPO Box 1428CANBERRA CITY ACT 2601

Dear Sir/Madam

Thank you for the opportunity to provide a submission for inclusion in the Commission's draftdiscussion paper for the report on the 'impacts and benefits' of the COAG reform agenda.

Safe Work Australia is a statutory agency with responsibility for developing national policy onwork health and safety and workers' compensation. Safe Work Australia consists ofrepresentatives from the Commonwealth, state and territory governments, employer andemployee organisations and is jointly funded by the Commonwealth, state and territorygovernments.

Safe Work Australia has a lead role in implementing the COAG reform agenda in the area ofharmonised occupational health and safety legislation under the National PartnershipAgreement to Deliver a Seamless National Economy.

Under the COAG agreed timeframes for this reform as set out in the IntergovemmentalAgreement for Regulatory and Operational Reform in Occupational Health and Safety, theharmonised work health and safety (WHS) legislation is due to be implemented on 1 January2012. An update on our progress with this reform is provided at Attachment A and includeslinks to relevant documents where available. The expected impact and benefits of the reformare discussed in the Decision Regulation Impact Statements (RIS) for the model WHS Act andRegulations and will be measured in part by the proposed evaluation plan for theharmonisation of work health and safety in Australia which is provided at Attachment B.

We would welcome the opportunity to discuss the draft discussion paper and our submissionin more detail with you and will contact the Commission in the near future to organise asuitable meeting time.

Yours sincerely

Rex HoyChief Executive OfficerSafe Work Australia

13 October 2011

SSfO WOrk UStm|iS ATTACHMENT A

Model WHS Act and relateddocuments (includingExplanatory Memorandum,Transitional Principles,Interpretive Guidelines andDecision RIS)

1 January 2012 On 11 December 2009, the WorkplaceRelations Ministers' Council (WRMC)endorsed the Model Work Health andSafety (WHS) Act.

As of 13 October 2011 NSW, QLD andthe ACT have all passed their respectiveWHS Acts. Other jurisdictions are invarious stages of progress with enactingtheir legislation.

Consultation RIS for Mining

National Compliance andEnforcement Policy (NCEP)

Remaining Codes of Practice

Model WHS Regulations andCodes of Practice for Mining

Decision RIS for the modelWHS Regulations and firststage Codes of Practice

1 January 2012

1 January 2012

From 1 January 2012to31 December 2012

1 January 2012Model WHS Regulations andfirst stage model Codes ofPractice

Model WHS Act and related documentsThe model WHS Regulations and firststage model Codes of Practice wereapproved in principle by WRMC on 10August 2011 and are currently withMinisters for their final approval followingclearance of the Decision RIS by theOffice of Best Practice Regulation(OBPR)Model WHS Re qulations and first staqe_model Codes of PracticeThe Decision RIS for the model WHSRegulations and first stage model Codesof Practice has been cleared by OBPRand will be published on the Safe WorkAustralia website on approval of theRegulations and Codes of Practice byMinisters.The draft model WHS Regulations andCodes of Practice for Mining werereleased for public comment on 15 July2011. Public comment closes on 14October 2011.

Model WHS Re qulations and Codes ofPractice for MiningThe Consultation RIS for the coreprovisions for Mining was cleared by theOBPR on 7 October 2011 and releasedfor public comment on 10 October 2011.The NCEP was approved by WRMC on10 August 2011.

National Compliance and Enforcement

Fifteen additional Codes of Practice werereleased for public comment on26 September 2011.

It is anticipated that these codes will beapproved by WRMC for implementationin early 2012.

Additional Codes of Practice for publiccomment

SSiO Wrk sustmH|a ATTACHMENT B

PROPOSED EVALUATION PLAN FOR HARMONISATION OF WHS IN AUSTRALIA

Introduction

The evaluation plan on pages 4-19 of this attachment was approved by Safe WorkAustralia Members at their meeting on 29 July 2011 and is designed to provideinformation to:

a) meet reporting requirements on progress towards achieving the objectives set out inthe Intergovemmental Agreement for Regulatory and Operational Reform inOccupational Health and Safety (IGA) and the Model Work Health and Safety Act(Model WHS Act)

b) assist in completing required annual reports to the Council of AustralianGovernments (COAG) on IGA requirements

c) assist the 2015 review of Safe Work Australia Act and functions and the IGA byCOAG,

d) assist in the review of the Model WHS Act in 2017, ande) assist jurisdictions in their implementation of the legislative framework and inform

them of the impact of changes.

The evaluation plan aims to answer four over-arching questions that align largely withthe objectives of the IGA and the Model WHS Act:

f) Has model legislation resulted in greater uniformity and consistency in regulatory andoperational approaches to work health and safety across Australia?

g) In what ways has model legislation impacted on regulatory burden for businesses ofdifferent sizes and operating in one, or more than one, jurisdiction?

h) In what areas has model legislation created efficiencies for Commonwealth, stateand territory governments in provision of regulatory and support services, and how?

i) What changes have occurred in the health and safety performance of Australianworkplaces since the introduction of the model legislation, and to what can thesechanges be attributed?

The evaluation plan will cover the first four years following implementation of thelegislative framework up to the review of the IGA in 2015.

The evaluation plan includes detail on indicators, data sources, methods and timing fordata collection, analysis and reporting. Where possible it will use existing data sources tomeasure the impact of any changes against the objectives of the IGA. These datainclude workers' compensation statistics, fatalities data, the Australian Bureau ofStatistics Work-related Injuries Survey, and the 2008 National Hazard Exposure WorkerSurveillance Survey. Some surveys will be developed and administered in 2011-12 toestablish baselines. These surveys/data collections will be repeated at various intervalsover the planned timeframe to ascertain what changes have occurred.

The evaluation plan also covers areas for which data gaps currently exist or for whichdata may exist within jurisdictions but has not been made available previously to SafeWork Australia. To address gaps in existing data quality and availability, the plan alsoincludes alternative data sources/research strategies.

Sa|8 WOrk austrai|a ATTACHMENT B

Purpose

The evaluation plan has been designed to report on the progress made and changes whichhave occurred in achieving a harmonised approach to work health and safety in Australia. Inparticular, the plan is designed to evaluate the implementation of the harmonisation of thework health and safety legislative framework against the objectives outlined in theIntergovernmental Agreement for Regulatory and Operational Reform in OccupationalHealth and Safety (IGA).

BackgroundIn 2008 the IGA was signed by the Council of Australian Governments (COAG). Theobjective of this reform was to "produce the optimal model for a national approach to OHSregulation and operation which will:

1. enable the development of uniform, equitable and effective safety standards andprotections for all Australian workers

2. address the compliance and regulatory burdens for employers with operations in morethan one jurisdiction

3. create efficiencies for governments in the provision of OHS regulatory and supportservices, and

4. achieve significant and continual reductions in the death, injury and disease in theworkplace."

The Research Evaluation and Data (RED) Advisory Group was asked to advise on thedesign of an evaluation plan which would enable reporting to COAG on progress againstreform objectives. The RED Advisory Group has tripartite membership which has enabledthe development of an evaluation plan that reflects the different perspectives of governmentsand social partners. This is the first time that an evaluation plan has been developed inAustralia to capture data and report on regulatory and operational approaches to work healthand safety and their outcomes from a national perspective.

ReportingThe IGA requires:

reporting to COAG at least annually against progress made in relation to the IGAobjectives

the Chief Executive Officer, Safe Work Australia to provide an annual report toParliament, to Safe Work Australia Members and to the ministerial council which 'willinclude progress of the jurisdictions in implementing OHS reform', and

a review of the operation of Safe Work Australia and the IGA. The Safe Work AustraliaAct requires a review of Safe Work Australia's ongoing role and functions to becommenced in November 2015 (that is, six years after the commencement of the Act).This review is to be completed within six months, that is, by May 2016.

Work undertaken as part of this evaluation plan will enable Safe Work Australia to meet theannual reporting requirements and will provide information which can be used in the reviewof Safe Work Australia and the operation of the IGA in 2015-2016.In addition, Safe Work Australia will receive regular updates and reports as specific projects,data analysis or measurements are developed or completed and at least annually.

Evaluation DesignThis evaluation is designed to:

• determine whether the key objectives of the harmonisation of the work health andsafety legislative framework have been met, to what extent, where and how

SSfO WOrk austmH|a ATTACHMENT B

address the problem of attribution of observed outcomes to the harmonisation process(that is, to identify whether there is evidence that the harmonisation process contributedto the observed outcomes or whether those outcomes result from other factors)

provide policy-useful lessons about harmonisation in general (that is, to capitalise on theevaluation by treating the Model Legislation and associated processes as a case studyfrom which to derive lessons for other instances where a similar harmonisation strategymay be used to achieve policy outcomes)

monitor and evaluate outcomes as they emerge over time, while at the same timepreserving flexibility to respond to unexpected contingencies

monitor for significant risks to the harmonisation process in order to contribute toplanning and implementation over time

minimise additional burdens for jurisdictions in their contributions to the evaluation whilemanaging the costs and burden of the evaluation for Safe Work Australia as an agency,and

reflect that pragmatism must dictate the extent of the evaluation, particularly in the shortterm due to non existence or inadequacy of current data and/or resource constraints.This does not rule out that attempts will be made over time to improve and expand onthe information collected.

There are four over-arching questions for the evaluation which largely mirror the four IGAobjectives for harmonisation of work health and safety. The question for Objective 1 hasbeen narrowed to only deal with the uniformity and consistency in regulatory and operationalapproaches. The aspect of effectiveness of safety standards and protections is dealt withunder the question for Objective 4 which has been broadened to encompass improvementsin health and safety performance more generally. These overarching questions are:

Objective 1: Has model legislation resulted in greater uniformity and consistency inregulatory and operational approaches to work health and safety across Australia?

Objective 2: In what ways has model legislation impacted on regulatory burden forbusinesses of different sizes and operating in one, or more than one, jurisdiction?

Objective 3: In what areas has model legislation created efficiencies for Commonwealth,State and Territory governments in provision of regulatory and support services, andhow?

Objective 4: What changes have occurred in the health and safety performance ofAustralian work places since the introduction of the model legislation, and to what canthese changes be attributed?

There are two or three areas of focus underlying each key question.

For question one (uniform and consistent regulatory and operational approaches), these are:

Uniform and consistent documents: this will examine the extent to which the jurisdictionsadopt Acts, Regulations and Codes of Practice consistent with the model WHSlegislation and codes of practice, and

Uniform and consistent application: this will examine the extent to which legislation andpolicy are consistently applied across each jurisdiction.

For question two (impacts on regulatory burden), these are:

Impacts for businesses: analysis of the impacts for businesses operating in multiplejurisdictions, for which positive impacts are anticipated, as compared to those operatingin only one. There may be increased regulatory burden for some businesses operatingin only one jurisdiction, and

sale work ustm||a ATTACHMENT B

° Aggregate cost-benefit: an analysis of whether the benefits for some businessesoutweigh the costs to others.

For

o

question three (efficiencies for governments), these are:

Nature of efficiencies, for whom: examining the specific areas in which efficiencies areand are not created, the nature of those efficiencies (decreased costs or increasedoutputs) and to whom the benefits accrue, andHow efficiencies are generated: examining the processes by which efficiencies aregenerated and/or the processes which prevent anticipated efficiencies from beinggenerated.

For question four (health and safety performance), these are:

• Incidence of death & injury: analysis of changes in rates of work-related serious injury1and death. These are the final outcome measures for effectiveness of theharmonisation process

. Exposure to and control of hazards: analysis of changes to levels of self-reportedexposure to hazards and changes to the level and adequacy of controls of hazards inthe workplace

• Compliance with duties: examining perceptions of different stakeholder groups inrelation to duties, due diligence, consultation and other matters included in the ModelWHS Act. Compliance with duties is expected to contribute to improved health andsafety outcomes, and

,, Contribution analysis: this is a summary analysis that examines the extent to which it isreasonable to believe that harmonisation has contributed to observed outcomes.

The relationships between the IGA objectives, research questions and their areas of focusare demonstrated in Figure 1 below. It provides the goal and objectives of the harmonisationprocess quoted from the IGA, the lead question for the evaluation for each objective and thekey focus areas for evaluation in each area.

IGA Reform Objectives and the Evaluation Design

IGA OBJECTIVE LEAD QUESTION FOR EVALUATION

............(a) enable the development of

uniform, equltable and efferÿ¢esafety standards and proteÿonsfor all A.ustrellan wed:ere

Has model legislation resulted Ingreeter unlfomlltj and consistent/Inregulator:t and operational approachesto work health and safeti acrossAustralia?

[ 4.4 The fundamentalObJectivÿ of therefonÿ coveted by

I Ibis agreemsnllsteproduce the optimal

I model for a nationalt approach to OHS

reguleuon and[ operaUo,,, d, w!,:

(b} address the compliance endregulatory burdens foremployers with operations inmore than one Judsd!d!0n

(c) create effidences forgo'¢ernments In the proÿlslon ofOHS regulator), and supportear, tees; end ....

1 ! In what ways has model legislation| ÿ, Impacted on regulatorÿ' burden

..... ÿ businesses of different sizes and| I operating In one, or more than one,1 ÿ. Judsdlction?

lln what areas has model legislation

created effidencles forCommonwealth, State end Terdtory'governments In provision of regulator)'and support servt!:es, and how?

KEY FOCUS

Uniform andconsistent documents

Unlfon'n endconsistent application

Impacts forbusinesses

Cost Benefit Analjsls

Ileture ofeffidencles, for whom

How effidencles aregenerated

(d) achieve slgnlticant andcontinual reductions In the __.Inddence of death, InJurÿ' enddisease In the weft:place

I ÿ:ÿet ÿhangea hÿ'ÿ'e ocÿ,r;ed in the,,ÿ health and safetÿ'tiertom'ÿance of'j Australian wori,:places since the[ Introduction of the model legislation?

Itote - Direct quotes from the IGA

InJurl

Compliance withduties

.... lExposure to and

control of haÿ'erds

\-( ContdbutJon1analysis

Figure 1' IGA Reform Objectives and the Evaluation Design

Serious injury has been selected as the key indicator because national data for serious injury aremore reliable than that for minor injury (that is, injury where there is less than one week of absencefrom work). There are no reliable data for work-related disease, however work continues on gatheringdata on hazard exposure and health outcomes. These data will contribute to this evaluation.

7

The evaluation will draw on four main data sets. These are:

Documents: Acts, Regulations, Codes of Practice, policies and procedures, guidancematerials and so on;

Administrative data: information generated through the normal operations of thejurisdictions as they administer the legislation and court records where applicable;

Existing surveys and data sets: These include the Workers' Compensation NationalData Set, Notified Fatalities, and coroner's data; National Hazard Exposure WorkerSurveillance data, ABS Work Related Injuries Survey and so on;

New surveys: three new surveys are proposed: one related to regulatory burden foremployers (with additional questions for those operating in multiple jurisdictions in orderto identify their perspectives on remaining inconsistencies across jurisdictions); a broadstakeholder survey related to perceptions of compliance with duties under the WHS Actand regulations; and a smaller annual activity survey for jurisdictions to gather data onefficiencies.

In most cases the evaluation will use existing information, minimising costs for the evaluationand additional demand on jurisdictions. The new surveys proposed will impose additionaldemand and cost on Safe Work Australia.

The next section of the paper provides a summary of the evaluation design for each of thefour key questions. A diagram representing the 'program logic' for each objective (that is,how actions might generate particular outcomes) is provided first. These models should beread from left to right and top to bottom (following the arrows). The key outcomes for eachmodel are highlighted in cream. Yellow 'ruler' symbols on the diagram demonstrate theaspects about which data will be collected for that Objective: the numbers in these indicatorsymbols relate to the numbering system used in the tables which follow.

Two things should be noted here. First, it is not possible to collect data about every item in alogic diagram. The indicator symbols demonstrate the key aspects about which data will becollected. Second, there is some necessary overlap in the logic models, with aspects thatare shown in more detail in one diagram summarised in briefer form on other diagrams. Forexample, the logic model for Objective 3 'teases out' the processes by which efficiencies forGovernments may be generated; but these processes are summarised in two boxes in thediagram for Objective 4. In the interests of clarity, the indicator symbols used in the diagramfor Objective 3 are not repeated in the diagram for Objective 4.

Each program logic diagram is followed by a table. These tables outline the indicators, maindata collection methods and/or items, and timelines for collection of each data set, with briefcomments about particular items or analyses where required.

Implementation of the full evaluation is subject to availability of resources. Some evaluationresources are available within Safe Work Australia. Some data will be required fromjurisdictions and this is subject to resource capacity in jurisdictions. Some data collectionstrategies identified above are subject to external funding submissions.

Next steps

The program logic diagrams and tables detailed below will be used to design evaluationinstruments, questions and analyses. Safe Work Australia will continue to seek the adviceand expertise of RED Advisory Group members in undertaking these tasks.

It is important to note that data will be collected over a five year period. Resources do notallow all data to be collected and analysed annually and time is needed for some of theanticipated changes to become apparent.

safe work sustmH|a ATTACHMENT B

A timeline on page 17 details what data collection will be undertaken and in which year fromthe present until 2016. Interim reports will be produced on an annual basis. At the end of thefive year period a final report will be produced on the evaluation of work health and safetyreform and the impact of harmonisation on work health and safety practices and outcomes inAustralia.

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