Achieving FSC Accreditation (Part 2)
Interested in becoming a Federal Safety Commission (FSC) accredited company and delivering Commonwealth Funded Construction Projects?
READ ON, this is Part 2 of a 3 part series where we answer all the common questions we receive and get some added insight from our Managing Partner (and long-time Federal Safety Officer), Ralph Willson.
You can read Part 1 here.
Once I become Accredited, What is Involved?
You will be required to implement the FSC accredited system across your organisation (applicable to business operations that hold the ABN/ACN). This includes Australian Government Scheme projects and Non Scheme Projects, including other non- funded projects. That is, the same FSC system and standards need to be applied to all projects. In general, we think that the standard required under the FSC aligns with legislative compliance or otherwise constitutes a reasonably practicable approach.
Once accredited, builders are subject to ongoing audits to assess compliance against the Scheme criteria. These are called Maintenance audits and are usually performed on scheme projects (if you have one) or otherwise non scheme projects. A maintenance audit is typically performed every 12 months, which is often a 1 day audit (sometimes more if outstanding non-conformances exists) and considers a sample of elements under the criteria.
Accredited companies must regularly report WHS performance to the OFSC and must also notify the OFSC in the event of various incident types (if they occur). Poor performance may lead to a show cause process being initiated.
A re-accreditation process applies at the end of the initial accreditation which is typically a 3 year accreditation period.
What criteria is applied during audits?
FSO’s utilise the FSC Audit Criteria. You can find it here www.fsc.gov.au. There is also a published evidence guide that provides additional guidance.
Audits aim to verify that companies are implementing WHS systems and practices in line with their documented systems and processes, and that these continue to meet the requirements of the Scheme.
The Audit Criteria incorporates
· WHS Management Systems Criteria (all are in scope for initial accreditation)
· Focus Point Criteria (all are in scope for initial accreditation)
· Hazard Criteria (2 are chosen for initial accreditation, although FSO discretion can apply subject to work being performed)
There are currently 19 Hazard Criteria which is based on the national high risk construction activity categories. In our experience, the majority of clients do not perform the scope of work where all 19 criteria would be relevant to their business.
What can I expect during an Accreditation Audit?
The first accreditation audit is normally two days in duration and will be performed by an FSO.
Each FSO will approach the audit in slightly differing ways and involve some of their own preferences. However, it will always involve considering all elements of the WHS Management Systems Criteria, all elements of the Focus Point criteria and two (2) selected hazard criteria. The audit is an implementation audit, so site inspection, observation and verification will be performed.
The general intent is to confirm that documented systems and process meet the criteria, the organisation/ project has implemented the processes and that the processes are effective.
The process is rigorous, it usually involves 2 big days and it’s not unusual for audit participants to find the process challenging.
Our WHS Management System is certified (e.g. ISO45001, OHSAS18001, AS/NZS 4801), Is that enough?
This generally depends on quality of your system and rigour of your certification audit/s performed to date. In our experience there is often a significant gap.
You should have a WHS management system to a recognised standard. However, certification alone, will rarely achieve the specific standard required under the FSC criteria. The FSC criteria has some very objective requirements and is very targeted towards improving health and safety in building projects.
What is the process if my company is a new entrant into the Australian Market?
The process is similar to above. The challenge is that companies seeking accreditation need to nominate a project for the accreditation audit. The accreditation audit is an implementation audit performed by an FSO at a project site.
If you don’t have an Australian project, you will need to nominate a suitable project outside Australia. This may require that the project implement a standard of health and safety in excess of the host countries legal requirements and standard practices. This is a challenge, but is also achievable with leadership, sufficient support and effective resourcing.
AusSafe have experience with both sides of the equation, including the support of international clients to obtain accreditation and performing FSO duties for international applicants. Contact us for more information and key considerations.
Look Out for Part 3 over the coming months. Reach out if you just can't wait!