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Managing Risk and Compliance

The National Risk Consultants Association (NRCA) is a fledgling
organisation developed by a number of consultants from various
fields of expertise within Australia. They recognised that risk 
management and regulatory compliance were the two
overarching factors that impacted on all groups. The related
areas that were identified include –

Fire safety engineering, Emergency Management, Work Health
and Safety/Occupational Health and Safety, Security
Management, Building Maintenance, Facility Management,
Contractor Management Systems, Training and Workplace
Performance, Enterprise Risk Management and Legal Risk
Management.

Sure, there are reputable associations who represent each field. Organisations such as Australian
Institute of Building Surveyors, Engineers Australia, Fire Protection Association Australasia,
Australian Security Industry Association Ltd, Safety Institute Australia, and Risk Management
Institute Australia. Some require participation by members in continuous professional development
(CPD) to retain accreditation as required under statutory regulations or association rules, whilst
others provide ad hoc training for the information of members.

NRCA has recognised that consultancy in particular fields can have a cross-pollination with other
related occupations. One such example can be found in the documentation of Alternate Solutions for
buildings to satisfy the provisions of the Building Codes of Australia (BCA) or more recently National
Construction Code (NCC). Fire Safety Engineers often require the existence of an Emergency
Management Plan compliant to AS3745 Planning for emergencies in facilities to ensure a timely and
safe evacuation of occupants. At the same time, the Emergency Management Consultant must
understand the fire safety engineered solutions to incorporate within their management strategies
but also determine the risks relevant to the subject building and appropriate emergency evacuation
procedures.

We can go one step further. A safety audit conducted on the same building some years after occupancy
will need to be aware of any Fire Safety Engineering Report and Emergency Management Plan to
ensure that the latter has been reviewed on an annual basis and that any building alterations have not
compromised Essential Fire Safety Measures. Building fit-outs can impact on the accessibility to Fire
Hose Reels and distance of travel to alternate exits.

This brings us to another quandary – the implementation of AS3745 within a residential building to
satisfy the Alternate Solution. At the present time there is no regulatory requirement for an
Emergency Control Organisation and emergency procedures in residential high rise. The Emergency
Management Consultant, tasked with providing a compliant Plan, must ensure the availability of clear
instructions for occupants. This can be achieved in part with the display of Evacuation Diagrams and
an online emergency procedure. There is obviously more information that can be mentioned here but
suffice to say, the final Plan will satisfy the Occupation Certificate requirements but getting residents
to participate in the ongoing management of procedures and an evacuation can be impossible.

If there is a concierge/building manager employed by the Strata Committee the building then
becomes a workplace and subject to WHS/OHS legislation. It is mandatory for the building to have
emergency procedures in place, displayed and maintained, as well as testing of these procedures on a
regular basis. Death or serious injury of any occupant during an emergency and where there is non-
compliance with legislation can result in criminal negligence charges.

Security consultants also have to be aware of any documented Alternate Solution and safety audit
recommendations when offering advice in relation to access and egress. A suggestion to install a
security gate in an open corridor to stop illegal entry may be impacting on an evacuation route for
occupants. The presence of wall and/or window drenchers should alert the consultant that it is an
evacuation route and one that should not be impeded by any obstruction. Access to the Emergency
Plan will ensure that any recommendation for a security gate will include the recommendation for an
emergency release button on the egress side. This would satisfy security concerns as well as
compliance with the evacuation strategy. There would be a need for consultation with a Fire Safety
Engineer to ratify the strategy. Another example of the need for greater awareness of risks associated
with any building.

There is a great raft of documents relating to most buildings that should be available for use by
consultants. They include development approvals and any plan of management, architectural and
hydraulic plans, fire safety engineering reports, emergency management plans and evacuation
diagrams, fire safety schedule and annual fire safety certificates, safety audit reports, asbestos
register, risk register and the list goes on. There is always a risk of any or all documents becoming
lost, misplaced or stolen. Electronic storage is highly recommended so that consultants have ready
access to the unique characteristics and requirements for each building. This is a control measure to
ensure risk mitigation and regulatory compliance. Unfortunately, the handover process from
developer to building management often leaves the ultimate Strata Committee or building owner with
limited access to same.

Maintenance and remediation contractors can be at risk of compromising the integrity of fire safety
engineered solutions and emergency procedures with structural or material alterations to any
building. Access to relevant documentation and knowledge of the content minimises the risk of the
building becoming non-conformant with BCA requirements due to alterations.

Training is often a subject that is neglected or ignored. There is a risk that key WHS/OHS training is
not provided and management fails to comply with the requisite regulation/s. Most organisations
have policies and procedures in place, with staff and contractor inductions to ensure awareness of
requirements. The Act and Regulations now refer to ‘workers’ and the definition includes contractors,
work experience and volunteers, something that is not well communicated.

Training and workplace performance can be provided internally or outsourced to training
organisations. There is also a risk that the organisation is not going to maximise the opportunity,
simply by relying on the content of each course being applicable to the needs of the individual staff
member and the organisation overall. The use of external consultants to work with management and
staff to identify particular training needs and develop an appropriate and relevant program is a win-
win for everyone. So the cross-pollination between training consultants and WHS/OHS providers is
clearly evident.

Safety investigations of workplace accidents/incidents quickly identifies training deficiencies – lack of
instruction for equipment use, no safe work method statement or evidence of communication to the
worker, manual handling procedures, prevention of bullying, emergency procedures, dealing with
aggressive people, working alone, hot work, working at heights, working in confined spaces. If the
worker is going to be, or may be, exposed to any of these hazards it is very important that they are
provided with adequate training and that training is documented. The use of a training and WHS/OHS
consultant will help management to identify possible/probable hazards within the workplace and
maximise training returns for the organisation.

Workplace hazards can take on a physical form as well. The timely reporting and remedial action in
relation to physical hazards that can cause slips, trips and falls, manual handling issues and faulty
equipment is crucial to maintaining a safe working environment. WHS/OHS managers can work with
IT experts to develop the most appropriate reporting and recording system for the organisation. The

interaction between each specialist ensures that risk mitigation and compliance strategies are in
place.

This short article has been drafted to show that there are risk and compliance issues that can be
overlooked by consultants if not fully aware of issues that may impact on their own work. It shows
that we have a need for an Association that caters for consultants in the various fields, with the
emphasis of sharing information. Practitioners will then have a greater awareness of the risk and
compliance issues that may impact on their decisions and recommendations.

In time, the NRCA will become the ‘go to’ page for organisations wanting a consultant with a broader
awareness of the risks and compliance issues that may impact on buildings and business.

For more information contact us at the National Risk Consultants Association.

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