Restructure of Workplace Standards and Workcover Tasmania CPSU Response to Proposed Structure The following feedback is provided on behalf of CPSU members to the proposed restructure of Workplace Standards and Workcover Tasmania Consultation Process The CPSU has significant concern about the consultation that has been undertaken in regard to this restructure. It is a major change and has the potential to impact on the roles and function of a large number of workers. In these circumstances it is essential that the aims and objectives of the restructure are clearly stated, that staff are provided with accurate and timely information on which to provide their input and that practical information about how positions in the new structure will be filled and the possibility of voluntary redundancies is also made available. Aims and Objectives The only information that has been provided in regard to the aims and objectives of the restructure are the terms of reference document authored by the Department Secretary Simon Overland on 20 March. Rather than identify what the issues are that the restructure is designed to address, the terms of reference just lists the matters that must be considered in developing a ‘new unified structure’. It seems achieving a unified structure is the only objective. Surely a unified structure is an outcome and not an objective. By failing to state what the objectives of the process are at the start it is impossible to assess whether each proposed change contributes to those objectives. This makes it very difficult for staff to provide feedback on the draft structure. Provision of Accurate and Timely Information There is a large amount of confusion amongst staff regarding the changes. This confusion has arisen because there are two contradictory published structures that have been provided to staff. The first structure is for the ‘Office of Regulation’ which separates existing WPS and WC functions into three Directorates. Unfortunately this structure leaves 15 positions in an unallocated pink box. The second structure involves changes to DoJ Head Office and seems to allocate the pink box positions into central Agency structures. Unfortunately this structure is inconsistent with the first structure in some key ways such as: In one structure there is a General Manager Regulation with three Directors reporting through this role. In the other structure there is a Director for Worksafe Tasmania with two deputy Directors reporting through that role and a separate Director of Building and Licencing; In one structure Gas and Electrical standards report to the Director of Building, Electrical & Gas but in the other structure Gas and Electrical standards is outside the Building and Licencing structure This confusion has been exacerbated by inconsistent verbal messages with some staff getting different answers to the same question depending on the manager they have asked the question of. This has been particularly the case for the pink box people with WST making it clear they expect the roles will remain at Rosny reporting directly into the WST/WC structure but some of the policy/communications managers in Head Office making it clear they understand the roles will relocate to the city and the roles and function will be absorbed into the Head Office unit. There is also a lack of clarity around some of the roles with feedback being based solely on the title in the draft structure rather than being based on a description of the function and deliverables of the position. One example is ‘Investigation and Enforcement Services’. Reading the title you would expect this team would be providing specialist support to the Inspectorate and other areas on investigation and be the primary focus for enforcement. Despite this staff have been told that the main role of this team will be around addressing issues of bullying and harassment and that they would have little involvement in other general inspectorate investigations. It is hard to provide feedback with so little detail available. HR Issues There has been little information provided to staff about how the structure will be filled and whether or not the new structure accommodates all existing staff. Staff have been told by senior management that the structure has not been costed which has added to their concerns because staff can see new positions created in management levels and as they have been told that there are to be no ‘new faces’ they are not confident it will be fully implemented. To fill the new positions they are concerned that Inspector/Senior Inspector positions will be reduced to pay for them thus reducing the ability of WST to provide the necessary service and meet legislative requirements. There are a number of staff who have indicated they are considering retirement in the near future and others who would consider voluntary redundancy. Staff feel this should have been assessed and taken into consideration before the structure was developed as it seems consultation is occurring on a structure which will subsequently be changed again when positions are removed to accommodate redundancies. One longstanding issue that has been ignored through this restructure is that a significant number of senior inspectors have outstanding translation appeals. These appeals are likely to be resolved in coming months and if successful has the potential to create a number of structural anomalies. Feedback on Draft Structure The following are issues that have been raised by CPSU members: 1. Proximity It was generally felt that separating functions such as communications, web and information technology from the operational areas reduced the ability of these groups to provide timely and integrated services. While some roles may look to be generic (ie systems manager) in fact the work being undertaken is very specific to the Workplace Standards business units. Feedback was received on how important it is to be able to have systems and websites updated with accurate information quickly in response to urgent incidents. The recent bushfires and rain water tank issues are good examples of this. There is a lack of confidence with this continue with greater separation between the operation units and the support services. It is worth noting that some of these roles and functions were moved to Head Office in 2008 only to be moved back in 2010 because it was acknowledged that the services were not able to be provided to WST at the level required from Head Office. 2. Policy The proposed structure shifts a significant number of policy positions from within operational teams and into Head Office. It was noted that most of these roles are actually involved in operational policy rather than strategic policy and while it was generally agreed Head Office needs a greater capacity for strategic policy this should not be achieved by reducing the capacity for operational policy from those operational units. 3. Key Person Dependency One of the long standing issues in WPS/WC has been the high degree of key person dependency. This coupled with an aging workforce and an absence of succession planning creates significant risk. The proposed structure does little to reduce key person dependency in fact it is even more ‘siloed’ than the current structure and with a significant inconsistency of classifications across similar management levels it is likely to reduce opportunities for staff to move horizontally – thereby expanding their knowledge base. 4. Administrative Staff In general administrative staff, particularly those in the regions, felt the proposed structure provided them with an improved management structure and clearer reporting lines although in some cases e.g. GSS, it was felt the admin role was specialist and therefore fits better within the GSS structure. Conclusion 2013 is a critical year for workplace safety in Tasmania. The introduction of the new Workplace Health and Safety Act is creating many challenges and these will only increase over the next few years. While the CPSU acknowledges the need to ensure WST/WC have the best structure possible to respond to these changes we are not convinced the proposal currently put forward achieves that outcome. We propose a full review of the functions, roles and responsibilities of WPS and WC be undertaken and that from this review a new structure be developed. This review should include input from all stakeholders - Workcover Board, Industry, unions and the workforce. The aim should be to complete such a review by the end of 2013 with implementation of the new structure in 2014. This would provide the opportunity to do the following: Identify what the key functions of WST/WC are to enable form to follow function; Identify the issues currently affecting WST/WC which need addressing; Address issues of corporate risk and key person dependency; Develop a structure that provides for succession planning and future proofing of WST/WC; Review the operational structure of the Department of Justice Head Office to ensure it supports and integrates with a new WST/WC model.