Safety and numbers in ITD – the risk assessment approach
Queensland Teachers' Journal, Vol 125 No 1, 21 February 2020, page no. 22
The Department of Education acknowledges “that an effective and productive industrial technology and design (ITD) curriculum involves a significant amount of high-risk practical workshop curriculum activity,” and makes it clear that such experiences are valued, providing “opportunities to introduce students to the concept of risk management and safe work practices”.
Aligning class sizes to workspaces (or to the actual activities being undertaken) in workshops can at times be contested. In schools where class size becomes a challenge in ITD and other high-risk curriculum areas, it tends to be because the decision relies on the maximum class size target as the point of reference, as opposed to the attributes that the department advises should be taken into consideration when managing risk (and by extension, student numbers) in a workshop. This is the risk assessment approach that teachers are familiar with and which is mandated through curriculum activity risk assessments (CARAs) and underpinned by the Work Health and Safety Act (2011) Queensland. A clause in the recently certified Department of Education State School Teachers’ Certified Agreement 2019 ensures that it is re-iterated in the industrial instrument (law), as well as in department procedures underpinned by the WHS Act.
“Each workplace will take all reasonable steps to identify, prevent, manage and respond to workplace health, safety and wellbeing matters including the consideration of infrastructure capacity to provide a safe and healthy learning environment for curriculum delivery, particularly for practical subjects. CARAs play a key role in informing health and safety considerations, including class sizes, for the delivery of these subjects.”
The clause reinforces what the department has led through the CARA process and in documents like the ITD handbook. The CARA process is strongly built on the understanding that it is a person or a team of people with deep knowledge of their work who are best placed to undertake the risk assessments. The team approach is the strongest approach (it is already embedded in the sound practices of many schools and of course applies to other areas, such as hospitality and agricultural science).
The ITD handbook states: “Appropriate level of supervision when teaching ITD will depend on the range of equipment utilised, the number of students involved, their maturity and individual needs and the physical nature of the particular workplace.”
Teacher knowledge, training and experience is also a significant consideration in managing risk. The input of supervisors plays a role in informing the CARA. In a letter to the QTU General Secretary (29 October 2014), the then Director-General of Education said: “School principals are to implement a risk management approach regarding the management of class sizes… Those responsible for school curriculum activities have legal obligations and a duty of care to ensure the safety of all those involved.”
The WHS Act 2011 expects consultation as an underpinning requirement of a safe work culture. This is even more important where matters are contested, for example with student numbers in practical arts workspaces such as workshops and kitchens. The act identifies proactive, two-way communication as detailed in the Work Health and Safety Consultation, Cooperation and Co-ordination Code of Practice 2011. This should be a key reference document.
The WHS Act identifies specific matters that trigger the requirement for consultation.
"Section 49: A person conducting a business or undertaking must consult with workers when:
- identifying hazards and assessing risks arising from the work carried out or to be carried out
- making decisions about ways to eliminate or minimise those risks
- making decisions about the adequacy of facilities for the welfare of workers
- proposing changes that may affect the health or safety of your workers
- making decisions about procedures for consulting with workers; resolving health or safety issues; monitoring health of your workers; monitoring the conditions at the workplace and providing information and training for your workers."
The appropriate number of students in an ITD workspace is determined by undertaking CARAs in consultation with others. The ITD handbook provides strong guidance as to the range of factors that should be considered, under the sub-heading “managing safety”.
Where matters become contentious, teachers should:
- conduct the risk assessments and consult with the HOD and others
- keep good notes of interactions and confirm understandings and advice through email where possible, seeking confirmation of shared understandings
- speak with their health and safety rep (HSR) (if they have one)
- request that the matter be listed at health and safety committee meetings
Where consultation does not resolve the matter, the teacher should inform the principal and/or seek the assistance of the health and safety representative (HSR) at the school.
A trained HSR (https://www.qtu.asn.au/bradhsr) can make an assessment and place a provisional improvement notice (PIN) on the activity and/or workspace. The school would then have eight days in which to address the safety concerns/practices. Should the workplace not have an HSR, members should consider electing one. Members can seek to resolve the matter through the dispute resolution provisions either within the WHS Act (2011) Queensland or the certified agreement.
Where the class size identified in the risk assessment does not align with the actual number in the classroom, it is usual practice for teachers to withdraw themselves and the students to a theory classroom until the matter is addressed. It is crucial that matters are resolved in a timely way and with a focus on the safety and wellbeing of the teacher and the students and others.