Following assessment, a plan to control the risk must be developed. This is generally done at the same time as the risk assessment, by the same people. You need to consider how to control the risks and how this could impact on service delivery.

The risk assessment will have identified the highest risks and these must be dealt with first. However, if a low priority hazard can be easily fixed, it should still be fixed immediately. 

Legislation specifies a “hierarchy of control” which should be considered when planning risk control measures. The higher up the hierarchy, the more effective the control. You should always start at the top and work your way down the hierarchy.  And remember, sometimes the best solution may need more than one control. Administrative controls and personal protective equipment must be used in combination with other controls.

The table below shows the hierarchy of control, a description of the controls and examples of how they may apply in the home care setting.  Example 1 is for showering a client and example 2 is for cleaning a shower.

Risk Control Action	Description	Option/example 1	Option/example 2
1. Eliminate the hazard	No longer carry out the task	not shower client	not clean the shower
If this is not practical then
2a. Substitute for a lesser risk	Substitute the hazard giving rise to the risk with one that presents a lesser risk	bed-bathe or sponge the client	use a safer / less toxic cleaning product
and/or
2b. Isolate the hazard from the person at risk	Separate the hazard in time or space from the person at risk.	shower the client in another  accessible room until the hazard is resolved	leave the bathroom to air after applying the shower cleaner
and/or
2c. Use engineering controls	Physical changes to equipment or the environment e.g. redesign, ventilation	modify the shower for level access, shower the client on a shower commode chair, use a hand shower	Install an exhaust fan to increase ventilation when cleaning the shower
If this is not practical then
3a. Use administrative controls	Changing work methods, organisation of tasks, review work routines, training	write a procedure on how to shower the client safely, train workers in the procedure	provide material safety data sheet, train workers in safe use of chemical
and/or
3b. Use personal protection	Least effective. Use in combination with other controls.	wear gloves, non- slip shoes, apron when showering client	wear gloves and a mask to clean shower

You must come up with a plan such as this for implementing the controls and document your plan.  Include:

• the actions required to get the controls in place 
• who is responsible for the actions 
• time frames to do the actions
• date to review the risk control

Industry example

Hazard: vacuum cleaner not working for cleaning service Quick-fix – use carpet sweeper and restrict cleaning area for current service, client to borrow or purchase another vacuum cleaner for next service  Long-term control – client to purchase new vacuum cleaner

 

One of the key considerations in developing a risk control plan is to continue to provide services to the client while risks to the support workers are controlled. You must not allow support workers to be exposed to unsafe work practices. At the same time you do not want to limit service delivery to the client. A well managed risk control plan will ensure all options to resolve WHS risks are explored before any decisions about limiting service are made.

 

It is preferable that WHS risks are managed without impacting on service delivery. If this is not possible, you should use strategies that will minimise the impact of risk control on service delivery, for example:

• deliver the parts of the service that are safe while waiting for risk controls to be actioned for those that are not e.g. shower and dress the client but do not transfer them into/out of bed until the bed height is raised
• doing tasks in an alternative way as an interim measure e.g. bed bathe until the bathroom is made accessible
• using alternative equipment while existing equipment is replaced or repaired, e.g. carpet sweeping the main living area of the house until a new vacuum cleaner is provided
• providing the service in another part of the house, e.g. there may be a second bathroom or laundry area that is suitable for showering the client whilst home modifications are completed in their preferred bathroom
• providing the service in another location away from the house e.g. personal care at school or day programs

Risk control constraints should also be identified and considered when completing the risk control plan, including:

• time required for managing client/worker understanding and acceptance of changes
• client compliance with controls, or capacity to comply
• access to, trial and purchase of, large items of mobility and personal care equipment
• time frames for environmental modifications
• access to workders for training
• access to specialists/experts for risk assessment and control advice in risk areas such as manual handling, challenging behaviours

Once the final risk control plan has been successfully negotiated, the plan is implemented in the context of ongoing consultation, participation and review with the client, support workers and other key stakeholders. The implementation of risk control strategies commonly includes the introduction of equipment, changes to the work environment, organisation and/or changes to work practices, development of safe work procedures and training of workers. 

If you believe a risk to be “uncontrollable”, you should refer it to the next level of management, the WHS representative/s and/or consult WHS personnel.

In cases where there may be an assessed risk which cannot be controlled, any decision to exclude or not offer a service must be based on a comprehensive assessment of the current circumstances of the presenting individual. You must be able to show evidence on how you came to a reasonable conclusion that the person, their environment or the work to be done posed a clear threat to the safety of others, and  that it could not be minimised by other forms of control.

Unfortunately, even when there has been involvement of the client and their family and/or advocates in the risk management process, a small minority of clients may still be reluctant to change their care plans to address the risks identified. This can place you in a difficult situation with legal obligations both to the support worker and to the client. However, your obligations to the client do not outweigh your obligations under WHS legislation. 

If agreement is not granted by the client, you can involve key stakeholders/relevant others, in negotiating risk controls with the client i.e. advocate, external bodies and or mediation. The decision to modify, suspend or cease services due to high risk and/or unwillingness to implement risk controls usually rests with a senior manager.

 

By law, support workers must be involved in and informed of decisions that may affect their health and safety.   As such, their involvement in risk control is important.

 

Ensure all support workers and others going into the client’s home are aware of the risk and the control, and seek their feedback on the effectiveness of the control.

 

The risk control plan is developed as a starting point for discussion with the client, and relevant others. Involvement of the client in the risk assessment process ensures their views and wishes are considered when the risk control action plan is developed. This discussion may include:

• an explanation of proposed control measures in a language they can understand
• their expectations and responsibilities
• options to manage the risks
• alternative or preferred measures
• who will be responsible for controlling the risks
• the time frames for controlling the risks
• any foreseen impacts on service delivery

A useful strategy to assist in negotiating and implementing risk controls can be a case review meeting facilitated by the care coordinator for the client. It involves support workers, any volunteers and other key stakeholders involved in the risk management process. Everyone can discuss and contribute to the risk control options, along with actions required to control the risks (including development of safe work procedures), responsibilities, time frames and the potential impacts on service delivery.  

 

A documented risk control plan must be completed as part of the risk control process. It can also be helpful to keep progress notes related to implementation of the plan. 

 

Documented safe work procedures

Job information can be provided to support workers as Safe Work Procedures (SWP) and are usually linked to clients’ care plans. A SWP is a step-by-step description of the safest way to carry out a particular task. It includes any risks associated with the task and incorporates the appropriate risk controls. They should be developed in consultation with the support workers as part of the risk management process.

A SWP provides evidence that safe systems and procedures have been identified and developed (whether proactively or in response to incidents or changes), and can be used as a tool for training and supervising workers.

Home care organisations have many SWP formats, however, the basic information required includes: 

• date of development
• persons contributing to the SWP
• manager sign-off
• name of the task
• number of workers required for the task
• identified risks for the task
• control measures for the identified risks
• step-by-step instructions for the task including preparation, doing the task and concluding the task
• equipment required to complete the task
• review requirements
• worker sign-off

It is important that the SWP’s are explained to the support workers and that they understand them. You may require support workers to sign that they have read or had the procedures explained to them, as well as understand and agree to follow them. This provides evidence that they have been given WHS information. It also creates some accountability for support workers to follow procedures when working unsupervised.  Some organisations check workers’ competency against SWP and ‘certify’ workers as being competent to do the task.

Standard safe work procedures
Many home care organisations develop standard safe work procedures for tasks that are common across work areas. You must tailor generic SWP for individual work sites and this should be done in consultation with the support workers performing the tasks.

Material Safety Data Sheets
For guidance on how to manage hazardous substances in the workplace see Managing risk of hazardous chemicals Code of Practice and the WorkCover NSW guide – Reading labels and material safety data sheets.