Internal Review
Purpose
RPD reviews the WHSMS to confirm it is being followed and remains effective. That review runs through WHS system audits, project and SSMP audits, subcontractor audits, site inspections and management review.
Internal audits, findings, corrective actions, root cause records, effectiveness checks and management review evidence are managed in PIMS. Site-level walk inspections sit in Breadcrumb. Where a site inspection finds a systemic issue, it is escalated into PIMS as a formal finding.
Procedure
| Field | Requirement |
|---|---|
| Applies when | All RPD operations, projects, processes and subcontractor work covered by the WHS Manual and the project SSMP. |
| Owner | Director or WHS-appointed person sets the annual audit programme. Project Manager owns project-level audits. Auditor is competent, independent of the work being audited where possible. |
| Before work starts | Confirm the annual audit schedule, scope, criteria, auditor competency and access to the relevant procedures, SSMPs and records. |
| Minimum controls | Audits use the WHS Manual and the SSMP as the criteria. Findings are recorded, classified, given a root cause and assigned a corrective action with a due date. Effectiveness is checked before close-out. Results are reported to Senior Management. |
| Hold point | Where an audit identifies a high-risk non-conformance, the affected work is paused, the control is restored and the matter is recorded in PIMS before work continues. |
| Breadcrumb function | Day-to-day site walks, hazard reports, site inspections and immediate site-level fixes. Systemic issues are escalated from Breadcrumb into PIMS. |
| Stop / escalate | Stop work for high-risk non-conformances. Escalate repeat findings, overdue corrective actions, ineffective controls and trends into Senior Management review through PIMS. |
Audit Types
| Audit type | Criteria | Frequency | Auditor |
|---|---|---|---|
| WHS Manual / system audit | This manual and the WHS Manual procedures | Annual programme per the schedule below | WHS-appointed person, supported by an independent reviewer where required |
| Project / SSMP audit | The project SSMP, contract WHS requirements and the WHS Manual | At project start-up, mid-project and on completion (and as triggered by incidents or client request) | Project Manager or WHS-appointed person, independent of the project where possible |
| Subcontractor audit | The subcontractor's SWMS, licences, insurances and on-site practice against the WHS Manual and SSMP | Sample basis through the project, and triggered by performance issues | Project Manager or Site Supervisor |
| Site walk inspection | Site rules, SWMS in use, permits, controls in place, housekeeping | Per the project SSMP (typically weekly, plus event-triggered) | Site Supervisor; records in Breadcrumb |
| External / client / FSC audit | Client or regulator criteria | As required by the client, contract or regulator | External auditor; results recorded in PIMS |
Internal Audit Programme
Audits are scheduled annually by the Director or WHS-appointed person, weighted by risk to RPD and to the projects in progress. Each audit uses the WHS Manual as the criteria for the management system processes and the project SSMP and contract for the project management processes.
Before each audit, the auditor familiarises themselves with the process being audited, the relevant procedures and the records held in Breadcrumb, PIMS and the project file. Results are recorded on the audit form (held in PIMS) and any non-conformances are handled through the corrective action process.
Annual Internal Audit Schedule
The schedule is mapped to the NSW WHS Management Guidelines for Construction (Edition 6) Checklists 1 to 12 so each element of the WHS system is audited at least annually. WHS Manual sections sit one-to-one against the Checklists. Project audits run on project events rather than calendar months.
| Checklist (NSW Guidelines Edition 6) | WHS Manual section | Audit focus | Frequency | Indicative month |
|---|---|---|---|---|
| Checklist 1 — Senior Management Commitment | 01 Policy and Senior Management Commitment | Policy currency, WHS objectives and targets, responsibility structure, due diligence and resource allocation. | Annual | February |
| Checklist 2 — Communication and Consultation | 02 Consultation and Communication | Toolbox talks, site alerts, pre-starts, worker consultation, issue resolution, internal and external communication. | Annual | March |
| Checklist 3 — Service Provider and Contractor Management | 03 Service Provider and Contractor Management | Pre-qualification, insurances, licences, SWMS approval, induction, on-site monitoring, escalation through PIMS. | Annual | April |
| Checklist 4 — Safety in Design | 04 Safety in Design | Design risk reviews, DBP Act coordination for Class 2 work, temporary works, access design, hold points. | Annual | May |
| Checklist 5 — Risk Management | 05 Risk Management | WHS Risk Register, project risk assessments, SWMS quality, hierarchy of controls, change triggers, hazard reports. | Annual | May |
| Checklist 6 — Training | 06 Training and Competency | Induction, licences, VOCs, plant inductions, fitness for work, training register currency. | Annual | June |
| Checklist 7 — Inspection, Testing and Servicing | 07 Inspection, Testing and Servicing | Inspection schedule, plant pre-starts, test status, calibration, health surveillance and exposure monitoring. | Annual | July |
| Checklist 8 — Incident Management | 08 Incident Management | Incident and investigation records, notifiable incident handling, root cause, corrective action, injury management. | Annual | August |
| Checklist 9 — Purchasing, Handling and Storage | 09 Purchasing, Handling and Storage | Pre-purchase WHS checks, supplier compliance, SDS, hazardous chemicals register, manual handling, labelling. | Annual | August |
| Checklist 10 — Client Reporting and Performance Measurement | 10 Client Reporting and Performance Measurement | WHS objectives, KPIs, LTIFR, client reporting cadence, Senior Management feedback. | Annual | September |
| Checklist 11 — Internal Review | 11 Internal Review | Audit programme delivery, auditor competency, finding classification, corrective action close-out and effectiveness. | Annual | October |
| Checklist 12 — Documentation and Records | 12 Documentation and Records | Document control, version currency, record routing (Breadcrumb / PIMS / HR / project file), retention and archive. | Annual | October |
| Management review | All sections | Senior Management review of WHS performance, audit results, corrective action status, KPIs and LTIFR, incident trends, legal change and resource needs. | Annual (minimum) | November |
| Project / SSMP audit | 03, 05, 06, 07, 08 (applied to a project) | The project SSMP, contract WHS requirements and the WHS Manual applied to a live project. | Per project — start-up, mid-project, completion | Project-driven |
| Subcontractor audit | 03 applied to subcontractor work | SWMS, licences, insurances, on-site practice. | Sample through the project and event-triggered | Project-driven |
| External / client / FSC audit | All sections | Client, regulator or Federal Safety Commissioner audit criteria. | As required | Event-driven |
The schedule may be brought forward or repeated where an incident, client requirement, audit trend, project complexity or notifiable issue justifies it.
Findings, Corrective Action and Effectiveness
Findings from any audit are classified by severity (e.g., critical / major / minor / observation). For each finding, the auditor records:
- What was checked and what was found
- The clause, procedure or SSMP rule the finding sits against
- Root cause
- Corrective action and the person responsible
- Due date
- Close-out evidence
- Effectiveness check date and outcome
All findings, corrective actions and effectiveness checks are tracked in PIMS through to close-out. Repeat findings, overdue actions and ineffective controls are escalated to Senior Management through management review.
Management Review
Senior Management reviews WHS performance at least annually. Management review is where Senior Management decides whether the WHSMS remains suitable, effective, properly resourced and aligned with RPD's work. The review considers:
- Audit results and trends (WHS Manual audits, project audits, subcontractor audits, external audits)
- Status of corrective and preventive actions
- KPIs and LTIFR
- Incident, near miss and notifiable incident trends
- Hazard report patterns
- Worker, subcontractor and client feedback
- Changes in legal, Code of Practice, contract or client requirements
- Resource needs (training, plant, supervision, systems)
- Effectiveness of the WHS system overall
Outputs of the management review include actions, resource decisions, policy or procedure updates and the next audit programme. Records are held in PIMS.
Auditor Competency
Auditors must be competent in WHS, in audit method and in the area being audited. The Director or WHS-appointed person confirms competency before assigning an audit. Auditors should be independent of the work being audited where possible. External auditors are used where independence, technical depth or client requirement calls for it.
Records and Evidence
| Record | System / location | Evidence required |
|---|---|---|
| Annual internal audit programme | PIMS | Approved schedule, scope, criteria, auditor, dates and status. |
| Audit reports | PIMS | Scope, criteria, evidence sampled, findings, classification and auditor. |
| Non-conformances and corrective actions | PIMS | Finding, root cause, action, responsible person, due date, close-out and effectiveness check. |
| Project / SSMP audits | PIMS + project file | Project audit reports at start-up, mid-project and completion. |
| Subcontractor audits | PIMS + Breadcrumb | Subcontractor performance review, audit findings and corrective actions. |
| Site walk inspections | Breadcrumb | Inspection date, inspector, items checked, defects, immediate actions and escalation where required. |
| External / client / FSC audits | PIMS | External audit reports, findings, responses and close-out. |
| Management review | PIMS | Minutes, attendees, agenda, decisions, actions, resource decisions and outputs. |
| KPI and LTIFR trend data | PIMS | Period data, trend, target and review notes. |
Quick Guide
| Step | What RPD checks |
|---|---|
| 1. Plan the year | Approve the annual audit programme weighted by risk. Confirm scope, criteria, auditor and timing. |
| 2. Use the right criteria | WHS Manual for system audits. SSMP and contract for project audits. SWMS, licences and insurances for subcontractor audits. |
| 3. Prepare the auditor | Confirm competency and independence. Brief on the process, procedures and records to be sampled. |
| 4. Record the finding | Capture what was checked, what was found, the clause, the classification and the evidence sampled. |
| 5. Fix the root cause | Identify the root cause, assign a corrective action, set the due date and the responsible person. |
| 6. Check it worked | Verify effectiveness before close-out. Reopen the finding if the control has not held. |
| 7. Report up | Take audit results, corrective action status and trends to management review. |
| 8. Escalate the pattern | Repeat findings, overdue actions and ineffective controls escalate through PIMS to Senior Management. |
Audit Schedule Note
The annual audit schedule is indicative. The Director or WHS-appointed person may bring forward, repeat or add audits where risk, incidents, client requirements or audit trends justify it. Project audits are run against the project SSMP and the contract WHS requirements, not the WHS Manual alone.