GSPO Changes Afoot
04/4-17 at 11.03 by: Jason Somerville-Kimlin
Recently I attended an Australian Leisure Facilities Association Queensland (ALFAQ) seminar primarily focused on two topics; supervision standards for aquatic centres, and investigative processes adopted by the Workplace Health and Safety Queensland (WHSQ) during a death and/or major incident.
Regarding supervision standards for aquatic centres and changes to the Guidelines for Safe Pool Operation (GSPO), aspects of the discussion were pleasing as [RLSSA] organisational administrators realised the need to adopt a risk management methodology rather than a prescriptive one-rule-fits-all approach. This is no different to the WHS Act (2011) and WHS Regulation (2011) methodology of controlling risks and hazards in the workplace and relies heavily on self-assessment type checklists and approach.
As with most informational services nowadays, the RLSSA shall provide information via a SaaS (software as a service) model inclusive of all the standard functions we’ve come to expect from providers of Standards, Guidelines, Codes of Practice and the like. Automated version control, search function, push notifications, a generic renewal date and access to ancillary information, shall be available within the next iteration of the GSPO. One feature I'm particularly fond of is, all guidelines will now publish an effective as of date. This bodes well for PCBU’s who manage a safety management system, allowing PCBU’s time to disseminate the amendment and/or train staff or others prior to the implementation of the new iteration.
The digitised format of the GSPO will also provide an opportunity to revise and amend guidelines on a regular basis, however, and alarmingly, administrators have already proposed to push the revision window out to 18 months, a move in my opinion that is counter-productive in terms of maintaining relevance and validity. Research efforts into the supervision and scanning of swimmer modalities must continue (e.g. weak swimmers versus non-swimmers) and as with all tragic aquatic environment outcomes, conclusions via any coronial inquest must be integrated into future versions of the new guidelines.
We could/should see the implementation of a lifeguard-to-swimmer-supervision (LTSS) table suggesting a LTSS ratio based on a risk management approach as already done in the UK. Note, LTSS is the term I used to describe the method so the RLSSA may choose to coin their own acronym, this aside, I have no objections if the RLSSA wish to adopt same.
Our second point of discussion, led by Vicki Bennett, a senior inspector from Workplace Health and Safety Queensland (WHSQ), offered insight into the key investigative processes followed by her office and counterparts within the State Government. Sadly, Vicki primarily visits aquatic centres as part of an investigation whereby a category 1 or 2 offence (drowning, immersion, serious injury) is alleged or repudiated.
The key processes scrutinised by WHSQ are:
- Qualifications and competencies (has the person or persons gone outside the scope of their qualification/s?);
- Asset maintenance;
- Systems of work (SOP’s, RA’s, planning documents);
- Testing and tagging of electrical appliances;
- Witness statements; and
- Site inspections (scenes of crime, collation of photographic and datum evidence).
Noting, coronial involvement shall occur unless death by natural causes.
Vicki also suggested PCBU’s focus attention on the following four areas, responsible for most of the non-compliances accrued during a non-compliance and/or technical audit:
- Personal protective equipment (PPE);
- Safety Data Sheets (SDSs);
- Registers (hazardous chemical registers, SDS registers, PPE registers, electrical equipment registers etc.); and
- Operational Manuals (SOP’s, policies, procedures etc.).
PCBU’s on top of the game all use a safety management system (SMS) to manage risks, hazards and documentation necessary to gain compliance—they’re also mindful of the high financial penalties applied against non-conforming actions (or in-actions). More than ever, PCBU’s need reliable, relevant and site specific datum, systems and processes—use this article, particularly Vicki’s comments, to review those key processes.