AWHS 032a Name: Centre for Accident Research and Road Safety Queensland University of Technology State/territory: Qld Submission from: Centre for Accident Research and Road Safety – Queensland (CARRS-Q) Bevan Rowland, Research Associate ( b.rowland@qut.edu.au ) Darren Wishart, Research Fellow ( d.wishart@qut.edu.au ) Dr Kirsten McKenzie ( k.mckenzie@qut.edu.au ) Professor Barry Watson, Director CARRS-Q To: Safe Work Australia AustralianStrategy@safeworkaustralia.gov.au Date: 20 May 2012 Draft Australian Work Health and Safety Strategy 2012–2022 The Centre for Accident Research and Road Safety - Queensland are pleased to make this submission to Safe Work Australia on the Draft Australian Work Health and Safety Strategy 2012–2022. Driving a vehicle is the primary mechanism of injury and clearly accounts for the highest proportion of work-related fatalities. Therefore, driving a vehicle for the purpose of work is the most “at risk” activity that staff will perform in their daily work activities. Although the strategy addresses important workplace safety issues, to ensure continuous improvement and further reduction in work-related fatalities and injuries the strategy needs to target work-related road safety. Specifically, the following actions are urgently required to improve work-related road safety: 1. Safe Work Australia should consider including work-related road safety in the Australian Work Health and Safety Strategy 2012-22 and all relevant Model Codes of Practice. 2. Safe Work Australia prepares and develops a specific work-related road safety Code of Practice in consultation and collaboration with relevant industry and academic organisations. 3. Safe Work Australia and government regulatory bodies should increase regulation and enforcement in the area of work-related road safety. 4. To enable increased enforcement of work-related road safety, government statutory authorities should consider recruiting and appointing WH&S inspectors familiar and experienced with work-related road safety. 5. Safe Work Australia should consider resourcing and implementing a competitive grant scheme for identified safety high priority areas. 6. Safe Work Australia and state regulatory authorities should endeavour to improve fatality and injury recording, analysis and reporting to include additional data and not primarily compensated injuries and fatalities. For example, most work-related road fatalities and injuries are not included within compensated fatality and injury statistics. To be totally committed to saving lives, Safe Work Australia, state workplace safety regulators and all Australian governments must lead and promote work-related road safety as a priority issue. Yours sincerely, AWHS 032b Name: Centre for Accident Research and Road Safety Queensland University of Technology Work-Related Road Safety – An issue worthy of further scrutiny and attention Work related crashes are the most common cause of work-related death, injury and reduced productivity in the industrialised world (Wheatley, 1997). In Australia Work-related Traumatic Injury Fatality figures indicate that over the last seven years two thirds of workers killed at work was the result of motor vehicle incidents (Safe Work Australia, 2012). In addition, according to Safe Work Australia (2012) work fatalities involving motor vehicles as the primary mechanism of injury clearly accounts for the highest proportion of fatalities (46%) with the next highest mechanism of injury consisting of being hit by moving objects (12%) and falls from heights (11%). Figure 1 shows that across the seven years these three mechanisms accounted for 46%, 12% and 11% of Worker fatalities respectively. In addition, in 2009–10, 100 workers (46%) died following a Vehicle incident. Of these 100 collisions, 73 occurred on a public road (Traffic incident) and 27 at a worksite (Safe Work Australia, 2012). Figure 1 Worker fatalities: Proportion by mechanism of incident, Australia, 2003–04 to 2009–10 combined Source: Safe Work Australia Work-related Traumatic Injury Fatalities, Australia 2009–10 Furthermore, in 2009–10, 70 workers died while working in or around a truck, 32% of all Worker fatalities. The Safe Work Australia (2012) report detailing work-related traumatic injury fatalities in Australia 2009–10 identified that a traffic incident was the cause of 53 of the deaths with 38 truck drivers and 2 passengers killed in crashes on a public road. In addition, 10 car drivers were killed following a collision with a truck and 1 worker on foot was killed when hit by a truck. Statistics also show that from 2003–04 to 2009–10, 567 workers have been killed in truck-related incidents. Moreover, in 2009–10, 79 workers died while travelling to or from work. Although this is the lowest number recorded in seven years (i.e., 2003/04 – 2009/10), indications are that this lower rate will not continue with the number of deaths notified to work health and safety authorities in the 2010–11 showing a 7% increase on 2009–10. In addition, the low result in 2009-10 may be partially due to inconsistencies in reporting and recording of commuting __________________________________________________________________________ Centre for Accident Research and Road Safety – Queensland (CARRS-Q) AWHS 032b Name: Centre for Accident Research and Road Safety Queensland University of Technology type crashes across Australian States. For example, difficulty in identifying workers who are commuting from other road fatalities, as the purpose of the journey is generally not ascertained by investigating officers. Therefore, the magnitude of the commuting to or from work problem is relatively unknown. Over previous years data shows that the highest number of commuter fatalities, 127, was recorded in 2005–06 followed by 126 in 2008–09 (Safe Work Australia, 2012). However, changes across industry in relation to the work environment including increases in part-time and casual work, increase in the use of a contractor workforce, variations in work shift times (including shifts greater than 8 hours), and time required for commuting to/for work, have influenced issues surrounding workrelated driving and commuting. For example, these developments influence not only workrelated road risk exposure, but also changes driver behaviour and organisational expectations. Work-Related Road Safety – A responsibility for individuals Research has indicated that individual workers across many industry groups do not rate workrelated driving as a priority issue. This attitude stems primarily from a lack of support and commitment from both the organisation they work for and government response to the workrelated road safety issue. For example, CARRS-Q work-related road safety research has suggested that many individuals place no additional importance on work-related driving other than the task is a daily requirement and only a means to travel to, during and from work (Rowland et al., 2010). Research also indicated that although work-related drivers were unaware of their specific obligations or duty of care related to workplace health and safety legislation, they were aware of the road rules which they sometimes breached for a variety of reasons. For example, speeding to meet personal, organisational and client deadlines (Rowland et al., 2010). Likewise, research identified that a considerable number of workrelated drivers believed it was acceptable to take risks while driving to meet deadlines and save time, thereby increasing work productivity, financial returns and organisational satisfaction. There exists an urgent need for employees of industry organisations to be aware of their duty of care in relation to work-related road safety and driving for work. However, this process also requires to be supported by organisational policy, procedures and practice, as well as, government promotion and enforcement. Work-Related Road Safety – A responsibility for all organisations Work related road safety is an issue often ignored by industry with many organisations risk management practices primarily focusing on workplace processes that the organisation considers central to their core business, while not addressing driving for work processes with similar levels of consideration (Davey et al., 2008a; Wishart et al., 2004; Wishart & Davey, 2004). Traditionally, work related road safety within organisations has been an area often neglected and any vehicle fleet management procedures have primarily focussed on issues of asset management and insurance (Rowland, Davey, Freeman, & Wishart, 2008; Wishart, __________________________________________________________________________ Centre for Accident Research and Road Safety – Queensland (CARRS-Q) AWHS 032b Name: Centre for Accident Research and Road Safety Queensland University of Technology Davey, & Freeman, 2007). For most organisations, driving a vehicle for the purpose of work is the most at risk activity that staff will perform in their daily work activities. The Australasian Fleet Managers Association (2008) state that in Australia approximately 75% of all locally produced passenger vehicles are purchased as fleet vehicles and more than half of all new vehicle registrations annually consist of fleet vehicles. This would indicate that a high proportion of vehicles operating within the Australian road environment are utilised for work purposes. Furthermore, under many jurisdictions, a vehicle when used for the purpose of work is considered a workplace and thus organisations and other stakeholders are obligated by legislation to ensure a safe system of work in the use of the vehicle (Rowland et al., 2006). Previous research has also indicated that road crashes are the most common form of work related fatalities (Haworth et al., 2000; National Institute for Occupational Health and Safety [NIOSH], 2004; Safe Work Australia, 2009; 2012). Work related road crash injuries are also approximately twice as likely to result in death or permanent disability as other workplace injuries (Wheatley, 1997) and the average time lost due to injury is greater than any other workplace claim (Stewart-Bogle, 1999). In relation to workers compensation claims, vehicle accidents are the most likely mechanism of injury, approximately three times higher than the next most common mechanism of injury attributed to injury from chemicals or substance (Australian Safety and Compensation Council, 2006). Despite the legal obligations and trauma associated with motor vehicles used for work purposes, many organisations often lack the necessary risk management frameworks and processes central to minimising work related road safety risk (Rowland et al., 2005; Rowland et al., 2006; Wishart & Davey, 2004). Furthermore, many organisations also fail to actively promote work related road safety. For instance, in many organisations there exists posters and informative material regarding manual handling, office ergonomics, skin cancer and general health issues along with established training programs promoting and educating staff in safe work procedures. In contrast, these same organisations offer very little in the way of similar mechanisms directed toward promoting and improving work-related road safety. Organisations in attempting to address issues associated with work related road safety often adopt an overarching reactive one size fits all approach, often primarily focussing on the driver, without addressing deficiencies in the supporting organisational systems and processes required to support safe vehicle use (Davey et al., 2008). In order to improve their work related road safety organisations need to implement a multidimensional organisational approach of risk management incorporating all processes associated with work related vehicle use (Davey et al., 2008; Rowland et al., 2005; Rowland et al., 2006; Wishart & Davey, 2004). One of the initial key steps in proactive risk management and thus minimising risk associated with organisational vehicle use is to investigate and assess the current situation associated with the organisations safety management of their vehicle fleet and use (Rowland et al., 2006; Wishart & Davey, 2004). The failure to effectively implement work-related road safety interventions and initiatives often stems from a lack of regulatory acknowledgement and enforcement, management commitment and support, and general under resourcing. Thus there is an immense discrepancy between what organisations plan to do and what is actually undertaken in addressing work related road safety risks and initiatives. However, there are a number of __________________________________________________________________________ Centre for Accident Research and Road Safety – Queensland (CARRS-Q) AWHS 032b Name: Centre for Accident Research and Road Safety Queensland University of Technology additional organisational difficulties and issues that impact upon the successful implementation of fleet-based interventions and initiatives. These include: • • • • • • • • • A lack of knowledge and understanding of the organisation’s duty of care relating to driving for work; Lack of regulatory requirements, detailed obligations and enforcement; A tendency to focus on asset management rather than on employee safety, Fleet safety is rarely considered to be a core business issue, There is often a lack of resources allocated to work-related road safety, OHS and fleet safety are historically viewed as separate and often competing issues, Organisations do not always see an instant monetary return, Fleet safety is often overlooked until a crash happens; and Organisations rely heavily on inconclusive evidence based on insufficient crash data. Work-Related Road Safety – A responsibility for Government While there is a trend toward national standards regarding OHS processes, particularly the harmonisation of health and safety legislation within Australia, the responsibility of risk management policy and procedures related to work-related road safety currently rests with the organisation in many instances. As a result, the quality and extent of policy and procedure related to work-related road safety between organisations is variable and often directed toward asset management and not necessarily safety. While health and safety legislation clearly encompasses driving for the purpose of work, there is no substantial evidence that government regulators practice enforcement in the area of work-related road safety. Along with a lack of sufficient enforcement there is little supporting information relating to the work-related driving hazard. For example, there are numerous Codes of Practice relating to other specific health and safety hazards (e.g., confined spaces, manual tasks, hazardous chemicals, etc), however, no code of practice for workrelated road safety. Although work-related road fatalities account for almost half of all workrelated fatalities, driving for work exhibits the least attention. In addition, although driving for work applies to most industries and indirectly to most types of work, it is not addressed sufficiently within legislative requirements and supporting documentation and information. For example, the draft Australian Work Health and Safety Strategy 2012-22 does not recognise work-related road safety as a major issue or priority, except in the instance of the transport industry. A higher fatality/injury reduction target could be achieved if work-related road safety was given more attention given the proportion of fatalities and injuries related to vehicle incidents. Recommendations In relation to information outlined within the CARRS-Q Australian Work Health and Safety Strategy 2012-22 response document and this additional CARRS-Q submission document, the following recommendations for improving workplace safety are provided: __________________________________________________________________________ Centre for Accident Research and Road Safety – Queensland (CARRS-Q) AWHS 032b Name: Centre for Accident Research and Road Safety Queensland University of Technology 1. Safe Work Australia should consider including work-related road safety in the Australian Work Health and Safety Strategy 2012-22 and all relevant Model Codes of Practice. 2. Safe Work Australia prepares and develops a specific work-related road safety Code of Practice in consultation and collaboration with relevant industry and academic organisations. 3. Safe Work Australia and government regulatory bodies should increase regulation and enforcement in the area of work-related road safety. 4. To enable increased enforcement of work-related road safety, government statutory authorities should consider training or recruiting and appointing WH&S inspectors familiar and experienced with work-related road safety. Currently inspectors have experience and qualifications in electrical, construction, ergonomics, etc but lack dedicated work-related road safety specialists, which potentially explains a lack of consideration in this area. 5. Safe Work Australia should consider resourcing and implementing a competitive grant scheme for identified safety high priority areas. 6. Safe Work Australia and state regulatory authorities should endeavour to improve fatality and injury recording, analysis and reporting to include additional data and not primarily compensated injuries and fatalities. 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Analysis of City Fleet motor vehicle incidents. Unpublished Manuscript. __________________________________________________________________________ Centre for Accident Research and Road Safety – Queensland (CARRS-Q)