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Step 4: Maintain and Review Controls

Overview​

Risk management is not a one-time activity. Control measures must be regularly reviewed and maintained to ensure they continue working as intended. Changes in the workplace, new information, or control failures can make previously effective controls inadequate.

[!important] Legal Requirement WHS Regulation 38 requires PCBUs to review control measures and, if necessary, revise them in specific circumstances including when controls are not effective, before changes that may introduce new risks, when new hazards are identified, or when consultation indicates review is necessary.

Why Review and Maintenance Are Essential​

Control Degradation: Even well-designed controls can become less effective over time:

  • Equipment wears out or is damaged
  • Procedures are not followed consistently
  • Workers develop workarounds that bypass safety measures
  • Environmental conditions change

Workplace Changes: Construction sites are dynamic environments where conditions change constantly:

  • New subcontractors commence work
  • Work methods or sequences change
  • Different plant or materials are introduced
  • Site conditions evolve (weather, access, adjacent activities)

New Information: Knowledge about hazards and effective controls improves over time:

  • Industry incidents reveal new risks
  • Regulatory guidance is updated
  • Better control technologies become available
  • Health monitoring identifies previously unrecognized exposures

When to Review Control Measures​

Mandatory Review Triggers (WHS Reg 38)​

1. Control Measure Not Effective:

If a control is not working as intended, immediate review is required.

Indicators:

  • Incidents or near misses occurring despite controls being in place
  • Monitoring reveals exposures exceeding safe levels (noise, silica dust, heat stress)
  • Physical inspection shows controls are not functioning (damaged guards, blocked ventilation, torn safety mesh)
  • Workers report controls are inadequate or difficult to use

Example: Noise monitoring shows workers are still exposed to 90dB despite hearing protection, indicating the control (PPE alone) is not effective. Review required to implement higher-level engineering controls (source noise reduction, isolation).

2. Before Changes That May Introduce New Risks:

Review controls before implementing changes that could affect health and safety.

Construction Examples:

  • New plant or equipment: Hiring a larger excavator, introducing a concrete pump
  • Different materials: Using a new formwork system, changing concrete suppliers
  • Changed work methods: Switching from manual to mechanical demolition
  • Site modifications: Removing temporary access, relocating site facilities
  • Workforce changes: New subcontractors, labor hire workers
  • Time pressure changes: Accelerated program, weather delays requiring catch-up

Process: Assess whether existing controls remain adequate for the changed conditions, or whether new or additional controls are needed.

3. New Hazard or Risk Identified:

If hazard identification reveals previously unrecognized risks, review controls to address them.

Examples:

  • Discovering asbestos during demolition that was not identified in the pre-work survey
  • Underground services located in different positions than indicated on plans
  • Unstable ground conditions encountered during excavation
  • Psychosocial hazards (bullying, excessive pressure) reported by workers

4. Consultation Indicates Review Is Necessary:

Workers or health and safety representatives may request review based on their observations and experience.

Triggers:

  • HSR identifies recurring near misses or unsafe conditions
  • Workers report controls are impractical or not being used
  • Toolbox talk discussions reveal concerns about adequacy of controls
  • WHS committee identifies trends requiring review

5. New Information Becomes Available:

Review when new knowledge suggests current controls may not be most effective.

Examples:

  • Industry safety alert about incidents involving similar equipment or processes
  • Updated Code of Practice or regulatory guidance
  • New technology providing more effective control solutions
  • Research findings about previously unknown health effects

Proactive Scheduled Reviews​

In addition to mandatory triggers, implement regular scheduled reviews:

High-Risk Activities: Review controls for extreme and high-risk activities frequently (monthly or quarterly):

  • Working at heights
  • Confined space entry
  • Excavation near services or structures
  • Hot work in high-fire-risk areas
  • Crane lifts of critical loads

Moderate-Risk Activities: Review controls for moderate-risk activities periodically (quarterly or six-monthly):

  • Manual handling tasks
  • Use of power tools
  • Site traffic management
  • General construction work

Routine Low-Risk Activities: Review controls for low-risk activities annually or when other triggers occur.

How to Review Controls​

1. Consult Workers and HSRs​

Workers performing tasks have the most direct knowledge of whether controls are effective.

Questions to Ask:

About Control Effectiveness:

  • Are controls working as designed?
  • Do controls remain in place and functional throughout the task?
  • Are there situations where controls cannot be used?
  • Have you noticed any problems or near misses?

About Practical Use:

  • Are controls easy to use correctly?
  • Do controls interfere with completing the work efficiently?
  • Have you seen workers bypassing or disabling controls? Why?
  • What improvements would make controls more effective or easier to use?

About Changing Conditions:

  • Have work methods changed since controls were implemented?
  • Has new equipment or new workers been introduced?
  • Are there new hazards you've observed?

[!tip] Use Multiple Consultation Methods Combine toolbox talks, HSR feedback, incident investigations, and direct observation to gather comprehensive information about control effectiveness.

2. Inspect the Workplace​

Conduct structured inspections to verify controls remain effective:

Physical Condition:

  • Guards and barriers: Intact, securely fastened, not damaged or removed
  • Edge protection: Guardrails, toe boards, and safety mesh properly installed
  • Scaffolding: Tagged, inspected, compliant with design
  • PPE: Available, clean, in good condition, correct type for hazards
  • Ventilation systems: Operating, filters clean, airflow adequate
  • Electrical equipment: RCDs tested and functional, cables protected, no damage
  • Emergency equipment: Fire extinguishers charged, first aid kits stocked, emergency exits clear

Operational Effectiveness:

  • Are controls being used correctly and consistently?
  • Are work procedures being followed?
  • Are workers trained and competent in safe work methods?
  • Is supervision adequate for the risk level?

Housekeeping and Site Conditions:

  • Are walkways clear of trip hazards?
  • Are materials stored safely?
  • Are spills cleaned promptly?
  • Is rubbish removed regularly?

3. Review Records and Data​

Analyze documented information to identify trends and issues:

Incident and Near Miss Reports: Look for patterns:

  • Same hazards causing repeated incidents
  • Particular tasks, times of day, or workers involved in multiple incidents
  • Near misses indicating controls are nearly failing

Health Monitoring Results: Evidence of worker exposure:

  • Hearing tests showing deterioration (noise exposure not adequately controlled)
  • Spirometry showing respiratory effects (silica or other dust exposure)
  • Skin conditions indicating chemical exposure

Maintenance Records:

  • Are controls being maintained as scheduled?
  • Are repairs being completed promptly?
  • Is equipment failing frequently (indicating inadequate specification or maintenance)?

Inspection Reports:

  • Are deficiencies identified in inspections being corrected?
  • Are the same issues appearing repeatedly?

Training Records:

  • Are all workers trained in safe work procedures and use of controls?
  • Is refresher training being provided?
  • Are new workers receiving induction and task-specific training?

Monitoring Results:

  • Noise monitoring, air quality testing, heat stress monitoring
  • Are exposure levels below acceptable limits?
  • Are controls achieving intended reductions in exposure?

4. Check Against Current Standards​

Compare your controls to current best practice:

Regulatory Requirements:

  • Review applicable Codes of Practice for updates
  • Check SafeWork NSW guidance material and safety alerts
  • Ensure compliance with current WHS Regulations

Industry Standards:

  • Consult industry association guidance
  • Review manufacturer recommendations for plant and equipment
  • Benchmark against similar projects or worksites

New Technology:

  • Are more effective control technologies now available?
  • Can higher-level controls be implemented that were not previously feasible?

Example: Ten years ago, battery-powered tools had limited runtime, so petrol-powered tools were used in enclosed areas with ventilation as the control. Modern battery technology now provides adequate runtime, allowing substitution to eliminate carbon monoxide exposure entirely.

Maintaining Control Effectiveness​

Effective controls require ongoing maintenance and support.

1. Assign Accountability​

Clearly allocate responsibility for maintaining controls:

Management Responsibilities:

  • Provide authority, resources, and support for implementing controls
  • Ensure maintenance is scheduled and completed
  • Monitor control effectiveness through inspections and data review

Supervisor Responsibilities:

  • Ensure workers use controls correctly
  • Identify and report control deficiencies
  • Provide on-the-job training and supervision
  • Enforce compliance with procedures

Worker Responsibilities:

  • Use controls as trained and instructed
  • Report damaged or ineffective controls immediately
  • Participate in maintenance (e.g., daily plant pre-start checks)

2. Maintain Plant and Equipment​

Establish scheduled inspection, testing, and maintenance:

Regular Inspection:

  • Daily: Pre-start checks by operators (plant, power tools, PPE)
  • Weekly: Site inspections by supervisors (scaffolding, edge protection, electrical installations)
  • Monthly: Detailed inspections by competent persons (complex plant, lifting equipment)

Testing and Certification:

  • RCD testing: Every three months (or as per manufacturer requirements)
  • Scaffold inspections: Before use, after modifications, after adverse weather
  • Lifting equipment: Annual certification by competent person
  • Pressure vessels and hoists: Statutory inspection intervals

Maintenance and Repair:

  • Promptly repair or replace damaged or worn equipment
  • Tag defective equipment "Out of Service" and remove from use
  • Keep maintenance records showing what was done, when, and by whom

3. Maintain Worker Competency​

Ensure workers remain competent to work safely:

Induction Training:

  • Construction General Induction (White Card) for all construction workers
  • Site-specific induction covering site hazards, emergency procedures, reporting

Task-Specific Training:

  • High-risk work licenses (scaffolding, rigging, dogging, crane operation, forklift)
  • Competency in use of specific controls (working at heights, confined space, respirator fit testing)

Refresher Training:

  • Periodic refresher training to reinforce safe work practices
  • Training when procedures change or new controls are introduced
  • Training when incidents reveal knowledge gaps

New Workers:

  • Provide close supervision for inexperienced workers
  • Buddy systems pairing new workers with experienced mentors
  • Verify competency before allowing independent work

4. Update Information and Procedures​

Keep hazard information and safe work procedures current:

Safety Data Sheets: Check for updated SDS from suppliers and replace outdated versions.

SWMS and Safe Work Procedures: Revise when work methods, equipment, or controls change. Communicate updates to all affected workers.

Manufacturer Information: Obtain updated operating manuals and safety bulletins for plant and equipment.

Site Plans and Documentation: Update site layout plans, traffic management plans, emergency procedures when site conditions change.

Taking Action After Review​

If Controls Are Working Effectively:​

  • Record the review date and findings
  • Schedule the next review
  • Maintain controls through ongoing inspections and maintenance
  • Continue monitoring for changes that might require earlier review

If Controls Are Not Effective:​

Return to the risk management steps:

1. Re-Assess the Risk: Is the risk higher than initially assessed? Have circumstances changed?

2. Identify Why Controls Failed:

  • Design inadequacy (control not suited to the hazard)
  • Implementation failure (control not installed or used correctly)
  • Maintenance failure (control degraded or damaged)
  • Behavioral issues (workers not following procedures)

3. Select Improved Controls: Apply the hierarchy of control to select more effective measures:

  • Can you eliminate the hazard now?
  • Are higher-level controls now reasonably practicable?
  • Do you need multiple controls working together?

4. Implement and Monitor: Put revised controls in place and monitor closely to ensure they work as intended.

[!example] Review Leading to Improved Controls Initial Control: Workers used hearing protection (PPE) when operating jackhammers.

Review Finding: Hearing tests showed workers developing hearing loss despite using earplugs.

Investigation: PPE was inconsistently worn, and protection was inadequate for noise levels.

Improved Controls:

  • Substitution: Replaced pneumatic jackhammers with lower-noise hydraulic breakers (10dB reduction)
  • Isolation: Enclosed noisy work areas with sound barriers
  • Administrative: Limited daily exposure duration
  • PPE: Upgraded to fitted earmuffs with verified attenuation ratings

Follow-up monitoring confirmed exposures now below safe limits.

Record Keeping​

Document all reviews to demonstrate compliance and inform future reviews:

Review Records Should Include:

  • Date of review and who conducted it
  • What was reviewed (specific controls, activities, or site areas)
  • Method of review (inspection, consultation, data analysis)
  • Findings (are controls effective? what issues identified?)
  • Actions required (what will be changed, who is responsible, deadline)
  • Follow-up verification (confirm actions completed and effective)

Retention: Keep review records for the life of the project, and retain for periods specified in WHS Regulations for specific hazards (e.g., asbestos records must be kept for 30 years).

Summary​

Step 4 ensures controls remain effective through:

Regular Reviews triggered by:

  • Control ineffectiveness
  • Workplace changes
  • New hazards or information
  • Consultation
  • Scheduled intervals based on risk level

Consultation with workers to understand practical effectiveness and identify improvements

Workplace inspections verifying controls are physically intact and operationally effective

Data analysis of incidents, health monitoring, and maintenance records to identify trends

Ongoing maintenance of plant, equipment, competency, and information

When reviews identify deficiencies, return to the risk management steps to implement improved controls.

Risk management is a continuous cycle: Identify → Assess → Control → Review → Improve.