DRAFT
Business Leaders’ Health and Safety Forum
Submission to the Transport and Industrial
Relations Committee
Health and Safety Reform Bill
11 April 2014
Business Leaders’ Health and Safety Forum
Terrace Business Centre, Level 6, Berl House, 108 The Terrace
PO Box 10.403, Wellington 6143
Phone: 027 248 9545 email: info@zeroharm.org.nz
Julian Hughes, Executive Director
Business Leaders’ Health and Safety Forum
Health and Safety Reform Bill Submission v3 (DRAFT)
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Contents
Introduction .............................................................................................................3
Background...........................................................................................................3
Opening comments ................................................................................................4
The Health and Safety Challenge .............................................................................4
Summary of our submission Health and Safety Reform Bill: ...........................................5
Part 1 – Health and Safety at Work ..........................................................................5
Part 2 Health and Safety Duties ...............................................................................6
Part 3 – Consultation, Representation and Participation ..............................................6
Part 4 - Enforcement and other matters ...................................................................7
Conclusion ...............................................................................................................8
Appendix A ..............................................................................................................9
Business Leaders’ Health and Safety Forum
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Introduction
The Business Leaders’ Health and Safety Forum (the Forum) welcomes the opportunity to
submit on the Health and Safety Reform Bill.
The Forum has 162 corporate members (see Appendix A) who, collectively, are
responsible for the safety of a considerable number of workers, and visitors to places of
work, at worksites throughout New Zealand.
We ask the Committee to note that:
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Many members anticipate making separate submissions, as well as supporting this
submission.
The Forum does not purport to represent on this matter those Departments and
Crown entities who are included in our membership; recognising that to do so
would be inappropriate.
The Forum is still gathering and consolidating comments on the Bill, and will make a
further submission to the Committee. We recognise the need for swift legislative action,
but the time given for submissions on such a substantial Bill that affects every business
and worker in New Zealand is simply too short.
That said, the opportunity to engage with and influence health and safety law that will
impact on all New Zealand workplaces is important. The Royal Commission into the Pike
River Pike Mine tragedy and the findings of the Independent Taskforce of Workplace Health
and Safety clearly signalled that change is needed. New health and safety law is one way
of effecting this change.
The Forum has been actively involved in the steps leading up to this select committee. This
includes our support for and involvement with the Independent Taskforce, the select
committee process for the Health and Safety (Pike River Implementation) Bill and with the
initial response to this Bills exposure draft released for comment in November 2013.
In making these submissions we note that the Bill is essentially a copy of the Australian
Model Law and that the changes to the exposure draft are minor.
While we support the intent, scope and broad policy of the Bill, we do have concerns
about:
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The absence of duties and consequences for health and safety representatives;
The absence of positive duties for workers;
The overly prescriptive nature of Part 3, which has not been adapted to recognise
the New Zealand framework, or the recommendations of the Taskforce;
The inappropriateness of direct adoption of the Australian model law without
consideration for our context and when some Australian States have aksed for
amendments to it.
Background
The Forum is the CEOs and Managing Directors of our members. These leaders are
committed to improving workplace health and safety performance in New Zealand. Our
vision is for “all leaders to be passionately committed to achieving Zero Harm Workplaces”.
The Forum is founded on the belief that business leaders have a direct influence on health
and safety performance by what they do, say and measure. Members believe that by
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showing strong leadership on safety, working together, sharing ideas and using their
influence they can improve New Zealand’s poor workplace health and safety record.
Opening comments
The Forum supports a change to our core health and safety legislation to address gaps
with the existing law and to signal a new start, a new way of thinking and acting on
workplace health and safety. We also see some value in aligning our law with the
Australian model law but only where that will assist streamlining business practice and to
create a larger pool of businesses working within a similar health and safety framework
with common principles. Consistency for consistencies sake is not necessary and should
be considered and applied coherently in a way that is workable for New Zealand.
We have some concerns with the proposed Bill. Some of these have been informed by our
understanding of challenges the Australian Model law is now experiencing and the
differences between Australian and New Zealand workplaces. Others relate to provisions in
the Model law that seem to have no sound basis. We see little point repeating them in our
law. Also, there are some areas where the Bill has not been adjusted to reflect the
recommendations of the Taskforce. It is regrettable that the effort from so many parties,
reflecting extensive consultation, into such a broad ranging and thorough review is not
being carried through to the legislation.
The Health and Safety Challenge
Good health and safety law is a good foundation to set out society’s expectations, provide
minimum standards and outline who is responsible for ensuring workers go home safely
each day. Good law is essential, but on its own it is not enough.
Safe, healthy and productive workplaces do not occur by chance or because the law says it
should happen. They require many things working well together. Creating and maintaining
a safe workplace is one of the toughest leadership challenges. The interactions between
people, their workplaces, their work tasks and their workmates and their leaders are
complex and difficult to control. It is therefore a mistake to think that health and safety
law alone will correct the unacceptable level of workplace injury and harm in New Zealand.
In our submission to the Taskforce in 2013 we identified a set of principles we believe
should underpin the new legislation:
1. All people have the right to work and to be productive without suffering injury or ill
health (rights).
2. The best people to manage risks are the people who create them (commitment).
3. Standards should ensure safe work without negatively impacting on innovation,
creativity and business performance (balanced standards).
4. All people involved in work have a responsibility to ensure their own safety and the
safety of others (personal responsibility).
5. All workplaces must play their part. Failure of one has an impact on others
(collective responsibility).
6. All people harmed by their work should have access to support and rehabilitation
(security).
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The Bill reflects many of these principles, including the concepts of a right to harm-free
work and a commitment that those who create risk should be responsible for managing it.
There are, however, two areas where these principles are not reflected in the draft:
Balance standards: The level of prescription, particularly in Part 3, will severely limit
innovative approaches to gaining worker engagement in health and safety. It is likely that
the prescriptive nature of the Bill will be further exacerbated by new regulations.
Personal responsibility: The Bill's main purpose (clause 3) is "to provide for a balanced
framework" including by "ensuring appropriate scrutiny and review of actions taken by
persons performing functions or exercising powers under the Act" (clause 3(1)(f). This
however is not reflected in the detail of the Bill. All players in the system should have a
duty; this is reflected by the introduction of a positive duty for officers but does not go far
enough. If we want to effect a true change in culture this positive duty should apply to
everyone in the system, including workers and health and safety representatives.
The qualifier in all circumstances should be the same, ie what is reasonably practicable.
This will require an assessment of whether it is reasonable for an Officer, a Worker or a
health and safety representative to have taken action in any given circumstance.
It is tempting to look at that with hindsight, and assess what was done. However, a true
health and safety regime should be focussed on what is (or is not) being done. The
emphasis should be on encouraging safety so incidents do not happen. Of course,
defaulters need to be sanctioned, but the unduly heavy emphasis in the Bill on
criminalisation (fines and offences) is misplaced and is out of keeping with creating a
positive cultural change.
Summary of our submission Health and Safety Reform Bill:
Part 1 – Health and Safety at Work
We broadly support Part 1. However, we have some recommendations:
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The term “risk” is critical and should attract a more formal definition.
Officer is included in the general interpretation section and does not have a
definition under the Key Terms section of the Bill. Is this intended?
The definition of Officer is an important one: the definition should be clearer to
ensure it is easily identifiable who is/is not an officer.
It should be clarified that in almost all circumstances the term “Person Conducting a
Business or Undertaking” (PCBU) refers to an entity and is almost never an
individual – PCBU should be a consistent term used throughout the Bill.
The Bill needs to address sites where there are multiple PCBUs in operation in more
detail than clause 26 currently provides.
A cleared definition of “worker” is needed, especially when considered in
conjunction with an definition of “officer”, it is possible to interpret the current
definitions were a worker could also be an officer. Is this intended?
We see little reason for exempting volunteer associations from the definition of a
PCBU (clause 13(2)) while including volunteers in the definition of a worker (clause
14(a)) who may carry out work in any capacity for another PCBU and have duties
under clause 41: why do the Associations have an exemption from the primary duty
of care (clause 30), particularly where they are responsible for managing the safety
of others (e.g. organising and managing cycle races).
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We are concerned that the Minister can delegate approval of codes of practice to
the regulator responsible for drafting the code. That is not the case under the
Australian model, and removes an important check in the process.
Part 2 Health and Safety Duties
In general we support Part 2, but we have some recommendations:
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We agree with the introduction of a positive duty for Officers, but think a positive
duty should also be introduced for “workers” and the duties of “workers” in clause
40 should be defined in a more positive, consistent manner. For example, this
clause should adopt "reasonably practicable" as a measure ((a) and (c)) and
workers should have a duty "to comply" in clause 40(d) not just to co-operate.
We are concerned with how overlapping duties for PBCUs will be treated. The
current approach is very broad and does not set up any legal framework to help
PCBUs understand how they can fulfil their duty.
We support the approach to increased fines from the current level, especially for
serious breaches. We believe placing limits on fines may be counter-productive –
especially for very large businesses.
We are concerned that the introduction of fines for breaches of various sections of
the Bill could drive a strict compliance culture rather than one focused on managing
risk. It could also increase disputes, defended hearings and is likely to be very
difficult to enforce.
We believe a “duty to others” is an important concept, but should be qualified to
avoid unintended consequences. If a “duty to others” remains unqualified there is a
risk the law may become the last port of call for people seeking redress. For
example do medical professional have a duty under the bill towards the patients
they treat, do corrections staff have a duty under the bill to prisoners, do
emergency service personal have a duty under the bill towards people they are
seeking to assist?
Part 3 – Consultation, Representation and Participation
We have significant concerns with Part 3.
In general we support:
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a greater emphasis on worker engagement, participation and involvement in
workplace health and safety.
the ability to engage workers in a range of different ways to ensure they are
involved in workplace safety leadership, in decision making processes, in review
and development of processes and policies and in engaging others.
the role of agreed structures such as committees and defined roles such as
workplace health and safety representatives as a part of this process, but not the
only way to achieve effective engagement.
We do not support:
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the very prescriptive nature of the Bill in this area and the concept that a prescribed
series of committees and elected representatives is the only way to engage workers
in health and safety.
the likelihood that this approach will be ineffective and will limit innovation and
create bureaucracy that will do little to reduce risk.
the proposed role in the Bill for elected representatives to consult with workers –
this is the role of management (with support, if agreed, from elected
representatives).
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the fact health and safety representatives have no duties (clause 83) and that they
have an immunity from liability (clause 84). It is proposed health and safety
representatives will have a number of functions and powers; there should be duties
as well (similar to clause 12, schedule 2 for health and safety representatives in the
mining sector).
the proposed approach could potentially be counter-productive, could create
barriers to innovative approaches to engagement and could add significant costs
without any evidence of the benefits.
the concept of “workgroups”, the functions and powers of health and safety
committees and representatives and the assumption that the model of committees
and representatives is the only way to have meaningful engagement with your
workforce.
the requirements for participation across multiple PCBUs is also unclear and
appears unworkable as currently drafted.
while we support the right to cease unsafe work we remain concerned that without
access to quick, effective remedies to ensure work can be resumed when it is safe
to do so could lead to unnecessarily loss of production, especially if these powers
are used inappropriately, for example when they relate predominantly to wider
employment issues or disputes.
the additional compliance and procedural requirements being imposed under
Subpart 6 and 7 are not consistent with existing procedures under the Employment
Relations Act 2000 or the effective problem solving procedures in place under that
Act, which could be adopted for workers and PCBUs.
We believe that an amendment allowing PCBUs and workers to agree on alternative
arrangements that meet the expectations of Part 3 is required. What is prescribed might
be an option for some situations but should not be imposed on everyone. One size will
never fit all comfortably.
Part 4 - Enforcement and other matters
We have very few concerns with Part 4 apart from:
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The reversal of the burden of proof (eg in clause 118(3)).
The set up and access to independent review and appeal process.
The timeframe for WorkSafe to bring a prosecution (extended to at least 2 years).
We are concerned that extending the limitation periods from 6 months to 2 years
(and possibly longer) may have undesirable effect of delaying remedial action in
case it is seen as an admission of guilt.
We agree that fines have to be appropriate and meaningful, and in some cases increases
may be justified. However:
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they must be reasonable. We note that Western Australia has not adopted the
heavy Model Law penalties because they see them as unreasonably punitive; and
the Bill should not depart from ordinary Sentencing Act principles. In particular, the
provision (s169(2)(f)) that suggests a fine should be increased just because a
defendant is wealthy is wrong in principle and an unjustified departure from usual
sentencing rules in the general law.
Review: Given the substantial change the Bill introduces we believe a review should be
built in to legislation to commence a review of progress in 2 years’ time, and have it
completed and reported to Parliament by the Minister within the next year.
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Conclusion
While the Forum supports the objectives of the Bill and believes that it will help to change
our workplace health and safety culture, we have serious concerns about the practicality
and appropriateness of many of the provisions, especially Part 3.
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Appendix A
Members of the Business Leaders’ Health and Safety Forum – as at 31 March 2014
Name
Role
Business
Peter Dudson
Chief Executive Officer
AB Equipment Limited
Alan Clarke
Managing Director
Abano Healthcare Group
Scott Pickering
Chief Executive Officer
Accident Compensation Corporation
Mark Cameron
Managing Director
Action Engineering Ltd
Mike Davies
Managing Director
Adecco NZ
John Bridgman
Managing Director NZ
AECOM
Christopher Luxon
Chief Executive Officer
Air New Zealand
Ed Sims
Chief Executive Officer
Airways New Zealand
Mark Hopwood
Chief Executive
Arrow International Group Ltd
Adrian Littlewood
Chief Executive Officer
Auckland International Airport
Mary-Anne Macleod
Chief Executive
Bay of Plenty Regional Council
David Carter
Executive Director
Beca Group
Mark Hamilton
Chief Executive
Bell Tea and Coffee Company
Craig Cotton
Chief Executive Officer
Better Drinks Company
Matt Elliott
Managing Director
BP New Zealand Holdings
Joanne Denley
Director
Bridgestone New Zealand
Mike Toxopeus
Managing Director
Bridon New Zealand Ltd
David McGregor
Chief Executive Officer
Brightwater Group
Dean Camplin
Chief Executive
C3 Limited
Shige Takatori
Managing Director
Cableprice New Zealand
Roger Sutten
Chief Executive Officer
Canterbury earthquake Recovery Authority
Tony Gorton
Managing Director
Cardinal Logistics
Dr Jon Ryder
Chief Executive
Carter Holt Harvey Pulp, Paper & Packaging
Blair O’Keeffe
Chief Executive Officer
CentrePort Limited
Andre Gargiulo
Country Manager New Zealand
Cerebos Greggs Limited
Mike O'Brien
Country Manager
CHEP New Zealand
Malcolm Johns
Chief Executive
Christchurch International Airport Ltd
Onno Mulder
Chief Executive Officer
City Care
Barry O’Connell
Managing Director
Coca-Cola Amatil (NZ) Ltd
Alister Morison
Chief Executive Officer
Cold Storage Nelson Limited
Glenn Corbett
Managing Director
Compass Group
Jono Brent
Chief Executive
Connettics
Dennis Barnes
Chief Executive Officer
Contact Energy
Grady Cameron
Chief Executive Officer
DELTA
Lou Sanson
Director General
Department of Conservation–Te Papa Atawhai
Shane Dufaur
Chief Executive Officer
Dominion Salt
Cos Bruyn
Chief Executive Officer
Downer EDI Works
Scott Brownlee
Chief Executive Officer
DTL New Zealand
Stephanie Grieve
Partner
Duncan Cotterill
Heather Stewart
GM Organisation Development
Earthquake Commission
Matt Todd
Group Chief Executive
Eastland Group
Grant Mirfin
Managing Director
ECL Group
Judi Burgess
Chief Executive Officer
EcoCentral Limited
Dean Addie
CEO
EIS
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Name
Role
Business
Gavan Jackson
Managing Director
Electrix Ltd
Steve Fuller
Chief Executive Officer
Enable Services
Gary Saunders
Managing Director
Envirowaste
Thomas Song
Managing Director
Ernslaw One
Tom Barratt
Managing Director
Evonik-Degussa Peroxide Ltd
Daniel Flinn
HR Director
Express Couriers
Richard Ellis
Managing Director
Fitzroy Engineering Group Ltd
Graham Darlow
Fletcher Building
Nicole Rosie
Chief Executive Construction
Group
Director Health and Safety
Steve Anderson
Chief Executive
Foodstuffs (New Zealand) Ltd
Barry Raymond
Chief Executive
Freightlines LTD
Nick Miller
Managing Director
Fulton Hogan
Chris Birkett
Managing Director, Oceania
Region
Chief Executive
General Cable
Gilbarco (NZ)
Mike McWilliams
Director Sales & Marketing
ANZ/General Manager NZ
Chief Executive
Karl Smith
Group Chief Executive Officer
Gough Group
Scott O’Donnell
Managing Director
H W Richardson Group Limited
Alan Pearson
Chief Executive
Halls Group
Barry Harris
Chief Executive Officer
Hamilton City Council
Bill McCallum
General Manager
Hancock Forest Management Ltd
Glen Cornelius
Managing Director
Harrison Grierson
Paul Ainsworth
General Manager
Hikurangi Forest Farms Ltd
Mike Foureur
Managing Director
Hirepool
Jeremy Smith
Managing Director
Holcim New Zealand
Onur Yilmaz
General Manager
Huhtamaki Henderson Limited
Adrian Hynds
Managing Director
Hynds Pipe Systems Ltd
Paul Kennedy
Chief Executive Officer
Impac Services Ltd
Don Stock
Independent member of
Steering Group
Director, Bell Tea and Coffee
Company
Independent Director
Independent member
Inghams Enterprises (NZ) Pty Limited
Mahendra de Alwis
Group Executive - General
Manager NZ
Managing Director
Greg Dickson
Managing Director
ISO Limited
Jim Quinn
Chief Executive
Kiwi Rail
Andrew Chalmers
Executive Director
KiwiForestry
Steven Carden
Chief Executive
LandCorp
Anthony Leighs
Managing Director
Leighs Construction Limited
Andrew Stevens
General Manager
Leightons Contractors New Zealand
Albert de Geest
Chief Executive Officer
Liquigas Ltd
Peter Davie
Chief Executive
Lyttelton Port of Christchurch
Gerry Lynch
General Manager
Mars
Marcel Manders
Chief Executive
MB Century
Roger McRae
Managing Director
McConnell Dowell Constructors Ltd
Mark Binns
Chief Executive
Meridian Energy
Albert Brantley
Harry Stilin
George Adams
Chris Ellis
Adrian Revell
Business Leaders’ Health and Safety Forum
Health and Safety Reform Bill Submission v3 (DRAFT)
Fonterra Co-operative Group
Genesis Energy
GNS Science
Independent Member
Intertek - NZ and Pacific
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Name
Role
Business
Vanessa James
Methanex New Zealand
David Smol
Senior VP, Global Marketing and
Logistics & New Zealand
Chief Executive
Andrew Caseley
Managing Director
MWH NZ Ltd
Rick Herd
Managing Director
Naylor Love
Lee Babe
Chief Executive
Nelmac
Lees Seymour
Managing Director
Nelson Forests Ltd
Veronique Cremades
Chief Executive Officer
Nestlé New Zealand Ltd
Murray Willocks
Chief Executive Officer
New Zealand Agriseeds Ltd
Deane Manley
Managing Director
New Zealand Crane Group Limited
Lieutenant General T.J.
Keating, MNZM
Paul Baxter
Chief of Defence Force
New Zealand Defence Force
New Zealand Fire Service
Currently vacant
Chief Executive / National
Commander
Chief Executive
John Morgan
Chief Executive Officer
NIWA
Peter McCarty
General Manager
Norske Skog Tasman
Mark Gatland
Chief Executive
Northpower
Jim Magee
Chief Executive
Nurse Maude
Zane Fulljames
Chief Executive Officer
NZ Bus
Terry Stack
General Manager
NZ Oil Services Limited
Tim Searle
National Manager
NZ Safety
Chris Bush
NZ Country Manager
NZEC Management Ltd
Tony Cummins
Chief Executive Officer
NZL Group Ltd
Geoff Dangerfield
Chief executive
NZTA
James Fletcher
Managing Director
OCS Ltd
Jonathan Marshall
General Manager
O-I New Zealand
Peter Zeilinger
Managing Director
OMV New Zealand
David Prentice
Chief Executive
Opus International Consultants
Matt Cawte
General Manager (acting)
Orica NZ Ltd
Max Murray
Manager Production Upstream
Origin Energy New Zealand
William McCook
Chief Executive
OSPRI New Zealand
Philip Orchard
Chief Executive
PAE (New Zealand) Limited
Peter Clark
Chief Executive Officer
PF Olsen
Mark Dewdney
Chief Executive Officer
PGG Wrightson
Peter Landon-Lane
Chief Executive
Plant and Food Research
Martin Byrne
Chief Executive
Port Nelson
Garth Cowie
Chief Executive
Port of Napier
Geoff Plunket
Chief Executive
Port Otago
Roy Weaver
Chief Executive
Port Taranaki Limited
Tony Gibson
Chief Executive Officer
Ports of Auckland
Nigel Barbour
Chief Executive Officer
Powerco Limited
Dave Chambers
Managing Director
Progressive Enterprises
Greg Campbell
Chief Executive Officer
Ravensdown Fertiliser Co-op
Paul Nicholls
Managing Director
Rayonier New Zealand Ltd
John Gilbert
Managing Director
Rebain International (NZ)
Paul McNoe
Chief Executive Officer
Red Bus Ltd
Sjoerd Post
Chief Executive Officer
Refining NZ
Bryan Mould
General Manager
Rendertech Limited
Russel Creedy
Chief Executive Officer
Restaurant Brands New Zealand
Business Leaders’ Health and Safety Forum
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Ministry, Business, Innovation and Employment
Ngai Tahu Tourism Limited
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Name
Role
Business
Peter Hart
Managing Director
SGS New Zealand Ltd
Rob Jager
Chairman
Shell Companies in New Zealand
Paul Ravlich
Chief Executive Officer
Siemens New Zealand
Keith Cooper
Chief Executive Officer
Silver Fern Farms
Peter Rose
Chief Executitve
Southern Response
Mark O'Connor
Chief Executive
SouthPort
Mark Franklin
Chief Executive Officer
Stevenson Group Limited
Julian Cook
Chief Executive Officer
Summerset Group Holdings Limited
Graeme Martin
General Manager
Super Air
Bryce Howard
Chief Executive Officer
Tasti Products Ltd
Charlie Taylor
Chief Executive Officer
Taylors Contracting Co Ltd
Paul Auret
General Manager
Technip Oceania Pty Ltd
Craig Smith
Chief Executive
TELARC
Jacob Bonisch
Executive General Manager
Tenix
Mark Taylor
Vice President NZ Operations
Tenon Manufacturing Ltd
Chris Hilson
CEO
The NZDDA Ltd
Mark Powell
Chief Executive
The Warehouse Limited
Haydn Davies
Country Manager
Thomson Reuters
Jon Young
Chief Executive
Todd Corporation Limited
John Brockies
Transfield Services
Alastair Hulbert
Executive Director - New
Zealand
Chief Executive
Ken Sutherland
Group Chief Executive
Unison Networks
Rick Ede
Chief Executive
Unitec Institute of Technology
Simon MacKenzie
Chief Executive Officer
Vector
Ian Cathcart
General Manager
Veolia Water
Mark Ford
Chief Executive
Watercare Services Limited
Dr Julian Elder
Chief Executive
WEL Networks Ltd
Kevin Lavery
Chief Executive
Wellington City Council
Graham Wells
Managing Director
Wells Group Limited
Chris Whitaker
Managing Director
Whitaker Civil Engineering Ltd
Ian J. Cummings
General Manager
Wiri Oil Services Limited (WOSL)
Gordon McDonald
Chief Executive
WorkSafe NZ
Pat Hills
Chief Executive Officer
Worley Parsons
Mike Bennetts
Chief Executive Officer
Z Energy
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Turners and Growers
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