Nov 2022 - A submission made on behalf of NZISM by Mike Cosman, Chair of the NZISM Governance Board
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New Zealand Institute of Safety Management Post:PO Box 128 532, Remuera, Auckland 1541 Ph:021 479 674 Email:chair@nzism.org Web:www.nzism.co.nz The Manager, Accident Compensation Policy Ministry of Business, Innovation and Employment PO Box 1473 Wellington 6140 New Zealand By email:ACregs@mbie.govt.nz7thNovember 2022 Consultation on Proposed Changes to the Accredited EmployersProgramme(AEP) On behalf of NZISM and a group of Safe+ Assessors, we wish to make the following comments on the proposed consultation. We support change to the AEP audit as the old WSMP approach is based on an outdated Standard (AS/ NZ801) that has been shown to have limited relationship to claims reductions. The current global Standard ISO 45001 is sound but has had limited traction in New Zealand in terms of formalcertification, although anumber of organisations have used its structure in the design of their health and safety management systems. ISO 45001 is already mandated in certain sectors such as Class A Asbestos Licence Holders, although we are unaware as to how many of these are in the AEP. For organisations wishing to start down the ISO 45001 route it can take up to 2 years to gain full accreditation given the amount of work required. This should be factored into any transitional arrangements, as should thetime taken to ensure there are sufficient trained and accredited auditors to meet the expected demand. The Safe+ scheme was established as a voluntary health and safety performance improvement tool to be used by business either directly (through the online version) oron-sitewith assistance from an accredited assessor. Theon-sitetool and process are scalable so that the client can control which parts of their business are assessed and which critical risks are subject to a deep dive. This makes the results partial and not necessarily representative of all risks or activities.If Safe+ were to form part of the AEP accreditation process ACC would need to specify that the assessment covers all parts of the organisation and that samples sizes of locations visited, and people (including worker representatives) interviewed are proportionate. As the client is paying for the assessment (not ACC) it will be important to put in checks and balances to ensure there is no attempt to reduce size and hence cost. Recentinformationon the online toolobtainedvia anOIA request shows a veryhigh percentage of firms areachievingPerforming orabove.This contrasts with the very small percentagewe understand to haveachievedthis using the on-site assessment.Anecdotal feedback suggests many currently AccreditedEmployersare not at Performing.It would perhaps we worth ACC canvassing those current AEP employers to see how many have already completed a Safe+ assessment and reached the suggested level.