Topic 2.2 WHS Supporting Safe Work Practices

Maintaining workplace health and safety extends beyond identifying hazards and providing personal protective equipment. Occupational Therapists also have an important role in ensuring that clients, colleagues, students, support workers and other stakeholders understand how to work safely with assistance animals.

Supporting safe work practices involves providing education, confirming understanding, monitoring safe behaviours and fostering a culture where health and safety are considered part of everyday practice.

Rather than assuming that people know how to interact safely with an assistance animal, Occupational Therapists should actively:

• assess relevant knowledge and experience;
• identify gaps;
• provide appropriate information or guidance;
• confirm understanding where necessary;
• monitor whether agreed practices remain effective; and
• contribute to improvement where concerns are identified.

The goal is not simply compliance with organisational policies but the development of competence, confidence and practical systems that support safe, ethical and effective assistance animal partnerships.

Safe Work Practices in Assistance Animal Practice

Safe work practices are the procedures, behaviours and systems used to minimise the likelihood of injury, illness or harm.

In assistance animal practice, safe work practices extend beyond traditional workplace safety and include consideration of both human safety and animal welfare.

Examples include:

• using appropriate handling techniques;
• maintaining appropriate control of an assistance animal where relevant to the person’s role;
• recognising signs of animal stress, fatigue, pain or distress;
• following infection-prevention procedures;
• safely using equipment;
• maintaining accessible and safe environments;
• following emergency arrangements;
• reporting hazards promptly;
• reporting incidents and near misses;
• following applicable organisational policies and procedures;
• implementing agreed risk controls;
• working within professional scope;
• seeking assistance where a task is outside the person’s competence; and
• reviewing practices when circumstances change.

Safe work practices should become routine components of work rather than actions undertaken only after an incident has occurred.

Safe Work Practices Should Be Practical

A safe work practice must be capable of being implemented in the environment in which the work actually occurs.

A procedure may appear appropriate on paper but provide little safety benefit if:

• workers cannot access it;
• instructions are unclear;
• required equipment is unavailable;
• responsibilities are uncertain;
• the procedure does not reflect the actual task;
• required controls are incompatible with the environment;
• insufficient time or staffing is available;
• reasonable adjustments have not been considered; or
• people have not received the information or training required to implement it.

WHS systems should therefore consider both:

work as documented

and

work as actually undertaken

Safe work practices should support people to perform activities safely rather than create requirements that are unrealistic, inaccessible or disconnected from practice.

Confirming Competence

Providing information alone does not ensure safe practice.

Where appropriate to the task and level of risk, Occupational Therapists and organisations should consider whether individuals can apply safety principles in real or appropriately simulated situations.

Competence may be demonstrated through:

• practical observation;
• discussion and questioning;
• simulation activities;
• supervised practice;
• demonstration of safe handling techniques;
• demonstration of equipment use;
• case-based discussion;
• successful completion of relevant organisational training;
• review of workplace performance; and
• review of documentation.

The method used should be proportionate to:

• the person’s role;
• complexity of the task;
• level of risk;
• existing knowledge and experience; and
• consequences if the activity is undertaken incorrectly.

The level of supervision required will also vary according to:

• knowledge;
• experience;
• demonstrated competence;
• role;
• task complexity;
• environment; and
• support needs.

Completion of training alone should not automatically be treated as evidence that practical competence has been demonstrated where this is relevant to safe work.

Supporting Different Learners

People learn and communicate in different ways and may require information to be presented using a variety of approaches.

Education may include:

• verbal explanations;
• written resources;
• demonstrations;
• videos;
• visual supports;
• Easy Read information;
• practical coaching;
• supervised practice;
• scenario-based learning;
• repeated practice; and
• other accessible formats.

Occupational Therapists should adapt education and safety information to the individual’s:

• communication preferences;
• literacy;
• health literacy;
• cultural background;
• language;
• disability-related support needs;
• sensory requirements;
• cognitive accessibility needs;
• existing knowledge;
• experience; and
• role.

The need for accessible information or repeated learning should not be interpreted as evidence that the person cannot participate safely.

The relevant question is whether the information and support provided enable the person to understand and implement the required practice.

Client Education

Clients should have access to relevant education to support safe participation with their assistance animal in everyday environments.

Education may include:

• recognising signs of fatigue or stress in the animal;
• recognising changes in health or behaviour;
• maintaining appropriate hygiene;
• safe use and handling of equipment;
• responding to emergencies;
• understanding contingency arrangements;
• maintaining relevant public-access standards;
• balancing task performance with animal welfare;
• understanding agreed risk controls;
• identifying when an activity may need to be modified;
• reporting concerns; and
• knowing when to seek assistance.

Education should be:

• individualised;
• accessible;
• relevant to the person’s goals;
• proportionate to actual risk; and
• reviewed when circumstances change.

Education should support independence rather than create unnecessary dependence on professionals or support people.

Family and Carer Education

Family members, carers and support people may provide practical support to assistance animal partnerships.

Where relevant and with appropriate regard to consent and privacy, education may include:

• safe interaction with the assistance animal;
• respecting the animal’s working role;
• recognising animal welfare concerns;
• infection prevention;
• supporting consistency;
• emergency procedures;
• temporary animal care;
• understanding relevant equipment;
• reporting concerns; and
• understanding the role of the assistance animal.

Providing clear and consistent information can reduce misunderstandings and support safer practice across environments.

However, family members and carers should not automatically be given responsibilities that belong to:

• the client;
• practitioner;
• employer;
• organisation; or
• another duty holder.

Role expectations should be clear.

Educating Workplaces and Community Organisations

Occupational Therapists frequently work with:

• employers;
• schools;
• universities;
• health services;
• aged-care services;
• disability providers; and
• community organisations.

Education may address:

• assistance animal access;
• workplace adjustments;
• reasonable adjustments;
• emergency planning;
• appropriate interactions with working animals;
• allergy management;
• infection prevention;
• environmental safety;
• responsibilities under disability discrimination legislation;
• incident reporting;
• animal welfare; and
• relevant WHS responsibilities.

Effective education can reduce unnecessary barriers to participation while promoting workplace safety.

Safety education should not be used to justify exclusion where a risk can be managed through a reasonable and effective control.

Supporting Support Workers and Other Professionals

Support workers, educators and other professionals may also require education regarding safe assistance animal practice.

Topics may include:

• maintaining agreed task consistency;
• recognising behavioural changes;
• recognising stress or fatigue;
• reporting concerns;
• avoiding distraction of the assistance animal;
• supporting client independence;
• implementing agreed controls;
• responding to incidents;
• emergency procedures;
• equipment use;
• infection-prevention requirements; and
• understanding professional or role boundaries.

Clear role definition helps ensure that people understand:

• what they are responsible for;
• what they are not responsible for;
• when to seek assistance; and
• when to escalate a concern.

Monitoring Safe Work Practices

Safe practice should be reviewed regularly rather than assumed to remain effective over time.

Occupational Therapists and organisations should consider whether:

• safe procedures continue to be followed;
• required controls are being implemented;
• environmental risks have changed;
• the person’s functional needs or circumstances have changed;
• the assistance animal remains suitable for the particular activity;
• the assistance animal’s health or behaviour has changed;
• equipment remains appropriate;
• additional education is required;
• workers understand their responsibilities;
• organisational procedures remain effective; and
• restrictions remain necessary and proportionate.

Monitoring should be collaborative and supportive rather than punitive.

The purpose is to identify whether systems remain effective and where improvement is required.

Monitoring the Implementation of Procedures

Developing a WHS policy, procedure, Safe Work Procedure or other safety document does not automatically mean that it will be understood, followed or effective.

Monitoring should therefore consider whether relevant people:

• can locate the applicable document;
• understand its purpose;
• understand what is required;
• have received appropriate information, instruction or training;
• have the competence required for the task;
• have access to required equipment and resources;
• understand the identified hazards;
• understand required controls;
• can implement those controls in the actual work environment;
• complete required documentation;
• understand reporting and escalation pathways; and
• can raise concerns where the procedure does not work as intended.

A procedure that is technically correct but impractical to implement may provide little genuine safety benefit.

Likewise, repeated non-compliance may indicate a problem with the system, not simply the person.

Procedural Deviations

A procedural deviation occurs when actual practice differs from an established:

• policy;
• procedure;
• Safe Work Procedure;
• Safe Operating Procedure;
• work instruction;
• agreed risk control;
• workplace requirement; or
• other documented safety arrangement.

Examples may include:

• required equipment not being used;
• a risk-control step being omitted;
• required documentation not being completed;
• a worker using a different process from the documented procedure;
• required supervision not occurring;
• an agreed communication process not being followed; or
• an activity proceeding outside stated conditions.

A deviation should not automatically be interpreted as:

• carelessness;
• misconduct;
• lack of motivation; or
• individual failure.

Instead, the organisation should determine why the deviation occurred.

Why Procedural Deviations Occur

Possible contributing factors may include:

• unclear procedures;
• overly complex procedures;
• inaccessible information;
• poor document design;
• inadequate training;
• insufficient supervision;
• unavailable equipment;
• lack of resources;
• inadequate staffing;
• excessive workload;
• time pressure;
• conflicting priorities;
• unrealistic work design;
• unclear responsibilities;
• poor communication;
• changed environmental circumstances;
• changed client circumstances;
• changes in animal health or behaviour;
• a control that is not practicable;
• a procedure that no longer reflects actual work;
• human factors;
• organisational culture;
• fear of reporting problems; or
• deliberate failure to follow a reasonable safety requirement.

Understanding the underlying cause is important because different causes require different responses.

For example, repeatedly instructing workers to follow a procedure will not resolve the problem if the procedure requires equipment that the organisation has not supplied.

Similarly, retraining may be ineffective where the actual problem is:

• unrealistic workload;
• unclear role allocation;
• lack of staffing;
• poor equipment;
• inaccessible information; or
• an ineffective procedure.

Work as Imagined and Work as Done

WHS documentation commonly describes how an activity should occur.

Actual practice may be influenced by:

• environmental conditions;
• time;
• workload;
• equipment;
• staffing;
• competing demands;
• individual needs;
• animal behaviour;
• unexpected events; and
• other contextual factors.

This creates an important distinction between:

work as imagined

and

work as done

A gap between the two does not necessarily mean that the worker is acting irresponsibly.

It may indicate that:

• the documented procedure requires revision;
• additional resources are required;
• controls are unrealistic;
• roles are unclear;
• work design is contributing to risk; or
• the workplace has changed.

Effective WHS systems use deviations as information about how work actually occurs.

Responding to Procedural Deviations

The response should be proportionate to:

• seriousness of the deviation;
• level of risk created;
• whether harm occurred;
• potential for future harm;
• frequency;
• cause;
• legal or organisational requirements; and
• whether the issue indicates a broader systems problem.

Possible responses may include:

• immediate correction of an unsafe condition;
• stopping or modifying a hazardous activity;
• implementing temporary controls;
• clarifying instructions;
• consulting affected people;
• providing additional information;
• education or retraining;
• increased supervision;
• providing required equipment;
• improving access to resources;
• modifying the environment;
• redesigning the task;
• reviewing workload;
• revising responsibilities;
• changing the procedure;
• updating a risk assessment;
• initiating corrective or preventive action;
• conducting further investigation;
• escalating the matter; or
• seeking specialist advice.

The response should address the cause, not merely the visible behaviour.

When Immediate Action Is Required

Some deviations create little immediate risk and can be addressed through routine improvement processes.

Others may create an immediate or serious risk.

Where there is an immediate risk to:

• a person;
• worker;
• assistance animal;
• member of the public; or
• another person,

appropriate interim action should be taken within the practitioner’s or organisation’s authority.

This may include:

• pausing an activity;
• removing defective equipment;
• changing the environment;
• implementing additional controls;
• seeking assistance;
• escalating the issue; or
• postponing work until an effective control is available.

Immediate risk management should be followed by consideration of why the problem occurred so that recurrence can be reduced.

Example – Assistance Animal Heat Procedure

An organisation has a Safe Work Procedure requiring assistance animal assessments undertaken during hot weather to include:

• temperature consideration;
• access to water;
• appropriate rest periods; and
• modification or postponement where heat risk becomes unacceptable.

Monitoring identifies that regular rest periods are frequently not occurring.

A superficial response might be:

“Staff need to follow the procedure.”

A more effective review considers:

• whether appointment schedules allow sufficient rest time;
• whether suitable rest locations are available;
• whether water is readily accessible;
• whether staff recognise signs of heat stress;
• whether travel requirements are excessive;
• whether appointments are being scheduled during inappropriate temperatures;
• whether staff feel authorised to modify or postpone work;
• whether productivity expectations conflict with the procedure; and
• whether the written procedure is practical.

The resulting controls might include:

• changing appointment scheduling;
• providing additional resources;
• clarifying decision-making authority;
• revising the procedure;
• targeted education;
• additional monitoring; or
• modifying organisational expectations.

This approach treats procedural deviation as information about the broader WHS system rather than automatically assigning blame.

Example – Equipment Procedure Not Followed

A service requires a particular item of animal equipment to be inspected before each use.

An audit finds that practitioners often do not record the inspection.

Possible explanations may include:

• the inspection is occurring but documentation is overly burdensome;
• workers do not understand the documentation requirement;
• the form is inaccessible during community work;
• responsibility is unclear;
• the procedure contains unnecessary duplication; or
• inspections are genuinely not occurring.

Each explanation requires a different response.

The organisation should determine the actual cause before deciding whether the solution is:

• education;
• procedure redesign;
• improved documentation;
• clearer responsibility;
• supervision; or
• another corrective action.

Addressing Unsafe Practice

Unsafe practices should be addressed promptly where they create or may create harm.

Possible actions may include:

• providing additional education;
• reviewing procedures;
• increasing supervision;
• modifying the environment;
• reviewing equipment;
• implementing additional risk controls;
• clarifying responsibilities;
• reviewing workload;
• consulting relevant stakeholders;
• seeking specialist advice; or
• escalating concerns where necessary.

Where concerns cannot be resolved within the Occupational Therapist’s professional scope, referral or consultation with an appropriately qualified professional should occur.

Unsafe practice should not be ignored in the name of maintaining participation.

Equally, identifying a safety concern should not automatically result in unnecessarily restrictive action.

The aim is to identify the actual hazard and apply effective and proportionate controls.

Supporting Dignity of Risk and Occupational Participation

Safe work systems should support meaningful occupational participation wherever reasonably possible.

Risk management should not automatically seek to eliminate:

• the person;
• assistance animal;
• occupation;
• community activity; or
• workplace participation

simply because some risk exists.

When a safety issue is identified, practitioners should consider:

• the actual hazard;
• likelihood and consequence of harm;
• available controls;
• reasonable adjustments;
• person’s goals;
• dignity of risk;
• positive risk-taking;
• animal welfare;
• worker safety;
• public safety; and
• consequences of restricting participation.

The preferred control should be the least restrictive effective option that appropriately manages the identified risk.

Promoting a Positive Safety Culture

A positive safety culture encourages people to recognise hazards, report concerns and contribute to improvement.

Characteristics may include:

• open communication;
• shared responsibility;
• respect for human and animal welfare;
• psychological safety;
• continuous learning;
• evidence-informed practice;
• willingness to report hazards;
• willingness to report incidents and near misses;
• willingness to identify procedural problems;
• constructive responses to mistakes;
• consultation;
• transparency; and
• learning rather than inappropriate blame.

Occupational Therapists can contribute to positive safety culture by:

• modelling safe behaviour;
• encouraging questions;
• responding constructively to concerns;
• reporting their own mistakes where appropriate;
• supporting accessible communication;
• acknowledging uncertainty;
• identifying system problems;
• participating in review; and
• reinforcing that reporting is an opportunity to improve safety.

A blame-focused culture may discourage people from reporting:

• hazards;
• near misses;
• procedural difficulties;
• equipment problems;
• mistakes; or
• emerging risks.

This reduces the organisation’s opportunity to prevent future harm.

Learning from Safe Work Practices

Monitoring should also identify what is working well.

Organisations can learn from:

• effective risk controls;
• successful reasonable adjustments;
• examples of safe adaptation;
• effective communication;
• successful emergency responses;
• good animal-welfare practices;
• effective worker problem-solving; and
• practices that enable participation without unnecessary restriction.

Continuous improvement should therefore involve more than identifying failures.

Understanding why a safe outcome was achieved can help organisations strengthen systems across other areas of practice.

Key Practice Principle

Supporting safe work practices involves more than providing information or enforcing policies.

Occupational Therapists contribute by helping ensure that:

• relevant people understand what is required;
• work practices are accessible and realistic;
• competence is developed where necessary;
• safe practice is monitored;
• deviations are investigated constructively;
• underlying system causes are identified;
• risk controls remain effective;
• unsafe conditions are addressed;
• unnecessary restrictions are avoided; and
• learning informs future practice.

Monitoring should ask not only:

Do we have a procedure?

but also:

Is the procedure understood, practicable, followed and effective?

A difference between documented practice and actual practice should trigger professional curiosity rather than automatic blame.

Effective WHS management therefore requires:

education + competence + monitoring + consultation + system learning + proportionate corrective action

Through these processes, Occupational Therapists can help create environments that protect people and assistance animals while supporting safe, meaningful and inclusive occupational participation.