Consultation and Communication Procedure

Nomenclature

Term	Definition
HSE	Health, Safety and Environment.
HSR	Health and Safety Representative — a worker elected by a work group to represent it on work health and safety matters under the WHS Act 2020 (WA).
JSA	Job Safety Analysis.
LTIFR	Lost Time Injury Frequency Rate.
PCBU	Person Conducting a Business or Undertaking.
SWMS	Safe Work Method Statement.
WHS	Work Health and Safety.
WMS	Westlink Management System.
Workforce	Personnel engaged to carry out work on behalf of Westlink — full-time and part-time employees, contractors and consultants.

Purpose

This procedure describes how Westlink consults and communicates with its workforce on work health and safety (WHS) matters. Effective consultation draws on the knowledge and experience of workers, supports informed decisions, and helps Westlink work towards an incident- and injury-free workplace.

Scope

This procedure applies to all Westlink workers — employees, contractors, consultants and site personnel — and to work carried out at both Westlink-controlled sites and client-controlled sites. It covers consultation on hazard identification and risk management, the sharing of WHS information, consultation records, and the resolution of WHS issues.

Consultation with other duty holders who share a WHS duty for the same matter (for example a principal contractor or a client site operator) is within scope. Grievances of a non-WHS employment nature are handled under the relevant human resources process and are out of scope, except where a grievance concerns a WHS issue.

Definitions

Terms and acronyms used in this procedure are defined in the Nomenclature table. Key terms: a PCBU is a person conducting a business or undertaking (Westlink is a PCBU under the WHS Act 2020 (WA)); a worker is any person who carries out work in any capacity for the PCBU; and an HSR is a Health and Safety Representative elected by a work group.

Responsibilities

Role	Responsibility	When
Officers (Company Directors)	Exercise due diligence to ensure Westlink complies with its WHS Act 2020 (WA) duties, including the duty to consult; ensure resources and processes for consultation are available.	Ongoing
Senior Management / Management	Provide reasonable opportunity for workers to take part in consultation on matters that directly affect their health and safety; consider workers’ views before making decisions; ensure consultation outcomes are communicated and actions closed out.	Ongoing / each consultation
Supervisors / Site Supervisors	Lead daily pre-start and toolbox discussions; raise and, where able, resolve WHS issues; escalate unresolved issues; record attendance and topics.	Daily / per shift
Workforce (workers)	Take part in consultation arrangements; raise concerns, ask questions and make WHS recommendations; cooperate with Westlink on WHS matters; be represented by an HSR where the work group has elected one.	Ongoing
Health and Safety Representative (HSR)	Represent the work group on WHS matters; participate in consultation on behalf of the group where elected under s.61 of the WHS Act 2020 (WA).	Where elected

Procedure

When to consult

Consistent with s.49 of the WHS Act 2020 (WA), Westlink consults workers who are (or are likely to be) directly affected when:

• Identifying hazards and assessing risks arising from the work to be carried out;

• Making decisions on 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 workers — including changes to work procedures, the work environment, plant, substances or new products and services;

• Making decisions about procedures for consulting with workers, resolving WHS issues, monitoring workers’ health and workplace conditions, and providing information and training;

• Carrying out incident investigations, where applicable and appropriate.

Where Westlink shares a WHS duty with another duty holder for the same matter, it consults, cooperates and coordinates activities with that duty holder so far as is reasonably practicable (s.46 of the WHS Act 2020 (WA)).

Nature of consultation

Consultation is a two-way process. Westlink shares relevant WHS information with workers, gives them a reasonable opportunity to express their views and contribute to decisions, and takes those views into account before deciding (s.47 and s.48 of the WHS Act 2020 (WA)). In practice this means:

• Talking about WHS matters openly;

• Listening to and responding to the concerns of others;

• Seeking input and sharing views and relevant information; and

• Considering workers’ input when making decisions.

Where a work group is represented by an HSR, consultation involves that HSR.

Sharing information

WHS information is shared across Westlink. This includes:

• WHS policies and procedures;

• Relevant technical information;

• Hazard reports and risk assessments;

• Proposed changes to the workplace, systems of work, plant or substances; and

• Data on work-related incidents, illness or injuries.

Because Westlink teams are often geographically dispersed across project sites, communication uses a mix of face-to-face meetings, phone and video conferencing (for example Microsoft Teams), and site noticeboards.

Consultation at Westlink-controlled sites

At sites Westlink controls, consultation gives all relevant personnel the opportunity to jointly examine WHS issues and seek acceptable solutions. Expectations of the WMS are communicated through documented policies and procedures, monitoring and posting of HSE performance, HSE meetings, HSE and Quality alerts, and targeted campaigns arising from audits, statistics or external lessons. The forums below are used.

HSE meetings

Monthly HSE meetings are held with personnel (including contractors where possible) and Senior Management. They share information on relevant incidents and dangerous occurrences, consult on workplace changes affecting WHS, and let Management consider workers’ views before deciding further action. The agenda includes actions from previous meetings, shared HSE topics from current and other project sites, new WMS procedures, training requirements and renewals, and an open forum.

Pre-start meetings (projects)

Pre-start meetings are held daily on projects. Workers attend a planning session before each shift to discuss the day’s task, any related incidents, and feedback from the previous 24 hours. Information may include:

• Review of the work activities and the associated SWMS and JSA for safe completion of work;

• Any applicable changes to JSAs;

• Applicable HSE issues and problems experienced on the previous shift;

• Site coordination information;

• Individual concerns and the reporting of hazards and equipment defects;

• Known hazards and items of significance to follow up.

Toolbox meetings

Toolbox meetings are held monthly as a minimum and provide two-way communication between workers and management. They introduce new or revised HSE procedures and encourage worker involvement. Topics include items needing reinforcement, changes to systems and processes, review of work activities and facilities, emergency planning, housekeeping and inspection results, training requirements, known and reported hazards, and equipment defects. A formal record of attendance and content is kept.

HSE performance reporting

HSE performance is reported monthly and includes injuries by severity, part-of-body injury occurrence, Westlink frequency rates, and Lost Time Injury Frequency Rate (LTIFR).

Consultation at client-controlled sites

Personnel based on client sites work within the client’s management system. Before starting on site they complete the client’s site induction and provide evidence that relevant training, qualifications and licences are current. They then participate in all relevant site activities. The client’s system takes primacy on cadence and format:

• Daily pre-start meetings are typically run by Site Supervisors for all personnel involved in the day’s work, covering the work plan, safety hazards, environmental impacts, and incidents or issues from the previous day;

• Toolbox meetings may be held daily, weekly or monthly to address specific issues, with timing set by the client or site management.

Where a client site is a mine, the client operates under the WHS (Mines) Regulations 2022 (WA); Westlink personnel comply with the client’s WHS arrangements made under those regulations.

Issue and dispute resolution

Westlink prefers to resolve WHS issues consultatively. The following ladder is consistent with s.81 of the WHS Act 2020 (WA). A worker may take any steps that are reasonably necessary to report an issue, including leaving their part of the workplace where it is unsafe to remain.

• Where it is safe to do so, the worker first attempts to resolve the issue.

• If unresolved, the worker reports the matter to their Supervisor, who tries to resolve it in consultation with the worker.

• If still unresolved, the parties (which may include the HSR) arrange further discussions involving more senior management and representatives as appropriate.

• If the matter remains unresolved, either party may ask the regulator, or an agreed independent person, to assist in resolving it through conciliation or arbitration.

In resolving an issue the Supervisor considers relevant factors, including whether the hazard or risk can be eliminated, the control measures needed, the number and location of people affected, recommendations from the workforce, whether temporary measures are possible, whether additional monitoring is desirable, the time before a permanent correction, and who is responsible for overseeing removal of the hazard or risk. The details of the issue and its resolution are recorded in writing and communicated to all parties.

Not all consultation must be documented. As a minimum, the records listed in the Records section are maintained. Each record captures who participated, the WHS topic, the decisions made and actions assigned (to whom and by when), and when actions were completed.

Applicable Standards and Legislation

• Work Health and Safety Act 2020 (WA) — s.27 (duty of officers); Part 5 (Consultation, representation and participation): s.46 (duty to consult other duty holders), s.47 (duty to consult workers), s.48 (nature of consultation), s.49 (when consultation is required), s.61 (election of health and safety representatives), s.81 (resolution of health and safety issues).

• Work Health and Safety (General) Regulations 2022 (WA).

• Work Health and Safety (Mines) Regulations 2022 (WA) — applicable to client mine operators; relevant to Westlink as client-site context.

• ISO 45001:2018 Occupational health and safety management systems — cl. 5.4 (Consultation and participation of workers).

• Code of Practice: Work health and safety consultation, cooperation and coordination.