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Prevention and control of leptospirosis – quick guide (PDF 549 KB)

Note to readers

Use of ‘must’ and ‘should’

The words ‘must’ and ‘should’ indicate whether:

• an action is required by law, or
• is a recommended practice or approach.

Must: Legal requirement that you must comply with

Should: Recommended practice or approach

Key terms

The glossary in Appendix 1 of this guidance has a list of the technical words, terms, and abbreviations used in this guidance, and explains what they mean.

Lists

Lists of examples are not intended as complete lists. They may list some but not all possible examples.

Images

Images used in these guidelines are a guide only. Images are not intended to provide technical specifications.

Illustrations

Illustrations are a guide only. They are not intended to provide technical specifications.

1.0 Introduction

What is this guidance about and who is it for?

This guidance provides practical suggestions for managing and preventing leptospirosis, an infectious disease that passes from animals to people and between animals.

This guidance is for those working in close contact with animals and anyone visiting rural/farming areas.

It is also aimed at persons conducting a business or undertaking (PCBUs).

Note: Where the word ‘you’ is used in this guidance it refers to you as a PCBU.

2.0 What is leptospirosis?

Leptospirosis (commonly known as lepto) is an infectious disease transmitted from animals to people and between animals by infected urine or urine contaminated water, soil or environments.

Infection can occur through breaks in the skin or through body openings such as the eyes, nose or mouth.

Infection occurs in almost all mammals, including farm, domestic and feral animals.

Leptospirosis is caused by bacteria that multiply in the kidneys of animals and come out in their urine. The bacteria can survive for weeks or months outside the body.

The disease can be very difficult to eliminate from an animal population, and control measures should focus on animal vaccination and minimising exposure.

It can affect the brain, liver, lungs, heart, or kidneys with symptoms ranging from mild to severe. Although rare, it can cause death.

3.0 How do people catch it?

People usually catch leptospirosis from exposure to the urine of infected animals, and outbreaks often happen after heavy rain and flooding.

It can also be caught through handling or being in contact with the blood or flesh of an infected animal.

Human infections can come from direct or indirect exposure to the bacteria:

• direct contact with an infected animal’s urine, body tissues, blood, birthing fluids or unpasteurised milk
• indirect contact through contaminated water supply, moist/damp soil, mud or vegetation.

The bacteria from infected animals or environmental sources can enter the body in three ways:

• Absorption: Through broken skin such as cuts, abrasions and rashes. Exposure can happen through direct contact with an infected animal or indirect contact with contaminated soil, water, mud or vegetation.
• Ingestion: Through the nose, eyes and mouth, when eating and drinking, licking your lips or smoking with unwashed, contaminated hands.
• Inhalation: Through droplets of urine from infected animals.

Contaminated rivers, waterways and lakes can also spread the disease.

On New Zealand farms, flood water, and water-logged paddocks and waterways, are a particular risk.

Leptospirosis is commonly spread by a variety of animals, including cattle, rodents, possums, pigs, horses, dogs, sheep, deer, and goats.

Many animals can spread the bacteria, including farm animals, pets and wildlife.

Infected animals may show no obvious signs of infection. Food and water contaminated by rodents, especially rats, has occasionally caused infections.

Leptospirosis is not generally spread from person to person.

4.0 Who is at risk?

Leptospirosis is a particular risk to people who work in close contact with animals and are exposed to their urine, body fluids or flesh, especially in wet environments.

There is no human vaccine for leptospirosis, which is still the most common work-related infectious disease in New Zealand. Some of the most high-risk jobs include:

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Text alternative for Figure 1: High-risk jobs

The image shows five types of high-risk jobs:

• Farmers and farm workers, eg sheep, beef, deer, pig and dairy farmers, farm residents, relief milkers, casual labourers.
• Farm service workers, eg stock truck drivers, artificial insemination (AI) technicians, shearers, saleyard workers.
• Abattoir and meat industry, eg abattoir workers, meat inspectors, meat processing workers, industry service workers.
• Veterinary service providers, eg on-farm veterinarians, veterinarians in meat processing plants, veterinary technicians.
• Workers in high-risk environments, eg plumbers, sewer workers, drain layers, miners, forestry workers, fishing industry workers.

End of text alternative.

As a PCBU you must take a risk management approach (in consultation with your workers) to identify and eliminate risk of exposure to the disease at work so far as is reasonably practicable.

If risk remains you must minimise it, so far as is reasonably practicable.

5.0 How does it affect people?

People who catch leptospirosis display a wide range of signs and symptoms, from none at all, to mild ‘flu-like’ sickness, to severe conditions that can cause multi-organ failure.

Flu-like symptoms usually start within 2 to 14 days of exposure, but it could be up to 30 days before someone has symptoms.

Severe forms of leptospirosis can come on quickly, and result in long lasting (chronic) illness, however, death from leptospirosis is rare.

Some people have described collapsing, being unable to see or move, and even having memory loss before waking up in hospital.

The disease can affect people differently depending on the health, sex and age of the infected person and usually starts with mild flu-like symptoms.

Figure 2 below shows some of the signs and symptoms of leptospirosis infection.

Signs and symptoms

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Text alternative for Figure 2: Signs and symptoms

Image shows three types of signs and symptoms:

Initial (when someone is first sick):

• Tiredness, severe headaches, fever, chills, muscle aches, stomach pain, nausea/vomiting, diarrhoea, loss of appetite, red eyes, sore throat/cough, light sensitivity, vision problems.
• Secondary (after someone has been sick), eg skin rash, breathing problems, chest pain.
• Severe (if someone becomes very ill), eg jaundice (skin yellowing), kidney failure, haemorrhage (bleeding from a ruptured blood vessel), encephalitis/meningitis (spinal cord/brain membrane inflammation), pneumonitis (lung inflammation), cardiovascular collapse, miscarriage. Although rare, can cause death.

End of text alternative.

Long term impacts

Severe cases can result in permanent complications, most commonly kidney failure but it can cause other severe disease (see Figure 2).

Most people who are severely affected will need to be hospitalised.

Some people suffer long-lasting, recurring symptoms, such as depression or muscle pains, and may have repeat hospital admissions over time.

People who are severely affected may find it difficult to return to work quickly and may find their energy levels take a long time to recover.

6.0 Managing risk

You must use the hierarchy of control measures to work out the most effective control measures to use. See Appendix 6 of this guidance for more information

Leptospirosis is difficult to eliminate so minimisation will usually be the most reasonably practicable option for managing risk.

The hazard of catching or spreading leptospirosis will still exist, but the risk of exposure is minimised through control measures.

Eliminating risk

Elimination is removing a risk from the workplace.

Because elimination is not usually reasonably practicable for leptospirosis (and because animals do not always show obvious signs of infection) minimisation controls must be used so far as is reasonably practicable.

Recognising signs of disease in your animals can help you identify potential infection risk for your workers.

Consult your veterinarian for advice on vaccination of animals and other animal health matters.

Minimising risk

While risks will remain, exposure to the bacteria can be minimised through appropriate control measures. The list below should be considered in minimising risk of exposure to leptospirosis:

• worker knowledge and awareness
• good personal hygiene, including the correct use of personal protective equipment (PPE)
• adopting good farm management practices
• animal vaccination
• pest control.

Understand. Know. Do

Make sure workers know about the causes and signs and symptoms of leptospirosis, as well as ways of reducing risk.

As a PCBU you should implement occupational health programs that include training on recognising leptospirosis symptoms and maintaining proper hygiene and health and safety practices to minimise exposure.

Provide a worker information sheet in a common area (such as a cow shed, stockyard or lunchroom) to remind workers about risks, protection and first aid for exposure.

See our worker information sheet Leptospirosis – a risk for those working with animals

Run an induction programme for new and casual workers, including a leptospirosis briefing.

Make sure people involved in seasonal work (including lambing, drenching, shearing, docking and dagging) know that they may be at risk of infection.

Put on the wall, or display in some way that everyone can see, control and clean-up information procedures for when animal urine splashes occur.

Keep surfaces clean. Wash down affected areas as soon as possible using low pressure water.

Make sure the vaccination status of animals is known and clearly documented.

Keep children away from potential sources of infection.

Hygiene

Maintaining good hygiene provides an extra layer of protection.

Figure 3 shows ways to keep workers and the workplace clean, tidy and hygienic:

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Text alternative for Figure 3: Hygiene

Image shows four ways to keep workers and the workplace clean, tidy, and hygienic:

Personal hygiene:

• Wash your hands regularly, using water, soap, and disinfectant – especially after using the toilet or handling animals, and before eating, drinking, smoking, or taking a break. Wash your face if you have facial hair.
• Use only disposable towels.
• Do not touch your eyes, nose or mouth before washing your hands.
• Scrub hands gently to not break the skin.

Workplace hygiene

• Toilets, showers, kitchens, common areas and hand-washing facilities must be kept clean.
• Keep all food and drink, containers and utensils away from the work area.
• Wash clothes after animal contact.
• Provide clean wipes, sanitiser and tissues.

Eating, drinking and smoking:

• Always wash your hands before eating, drinking, smoking, vaping or taking a break.
• Do not smoke, vape, drink or eat when handling animals, as this can introduce bacteria into the mouth.
• Keep coffee mugs and other food and drink tableware away from work areas and animals.

Cuts, wounds and abrasions:

• Cover cuts, scratches, blisters and skin breaks with waterproof, sterilising coverings, and change coverings regularly.
• Make sure deeper wounds are fully healed before doing close work like shearing or crutching.
• Shower or bathe after work and wash all skin breaks with clean water and soap.

End of text alternative.

Isolating risk

Isolation involves separating the hazard or hazardous work from workers and others. Isolation by itself may be part of a risk management plan, together with rodent/wildlife control and animal vaccination.

You should:

• always ask for a vaccination certificate when buying or trading stock
• have a stock movement control policy to protect animals from infection/spreading disease
• keep people away from animals unless they need to be there
• consider environmental controls, for example, specify safe water sources as part of a grazing contract (reticulated water).

Personal protective equipment (PPE)

The aim of using PPE is to prevent urine, contaminated water and fluids from entering through cuts in the skin or through the eyes, nose or mouth.

Provide and maintain PPE and demonstrate and provide information on how it should be worn, safely removed, and disposed of. For example, not touching the face when taking off PPE.

PPE may include:

• goggles, safety glasses
• face shields that protect the eyes, nose and mouth, particularly during activities that pose a risk of urine splash on the face (such as milking)
• milking sleeves, clean aprons and gumboots (for example, when working in a milking shed)
• plastic aprons and gloves when assisting with animal birth, handling afterbirth, aborted foetuses, and kidneys or bladders (gloves are particularly important when scanning animals for pregnancy using rectal probes, as this requires holding the animal’s tail which is often contaminated with urine)
• appropriate footwear to stop water and other liquids entering wet boots and gloves should be changed before skin softens and allows bacteria in
• PPE should be waterproof and clean. If working in wet conditions extra PPE may be needed (such as overalls; sturdy, closed-toe, waterproof footwear; gloves for urine-soaked wool).

PPE alone cannot be relied on for protection against leptospirosis.

Further control measures

Good overall animal health can reduce the effects of infection or reinfection. While leptospirosis outbreaks can still affect healthy flocks/herds, unhealthy animals will be more severely affected than healthy animals and take longer to recover.

Control rodents and possums, keeping them away from stored food and other crops – do not use rodent-contaminated feed.

Prevent animals having access to open water sources like valley dams, rivers, or ponds – keep animals away from pasture with water-logged areas after heavy rains or floods.

Manage effluent disposal by containing it in properly built ponds or pits.

Avoid putting stock straight onto pasture where effluent from infected animals has been sprayed.

If possible, allow pastures sprayed with effluent to dry before grazing.

7.0 Flooding, contaminated water and environments

Outbreaks of leptospirosis may occur after flooding and heavy rain. Leptospirosis is a significant risk to people and animals especially in flood-prone environments, and where stagnant and contaminated water is found. The bacteria can survive in damp conditions, increasing the chance of transmission to people through water and soil.

Infection risks

Floodwaters

During floods, water bodies can become contaminated with leptospirosis bacteria from the urine of infected animals.

This increases the risk of human exposure when people wade in these contaminated floodwaters, which can result in an increase in the number of leptospirosis cases.

Stagnant water

Stagnant water in ponds, puddles, and irrigation channels creates an ideal environment for the bacteria to thrive. People who have contact with or ingest contaminated water are at risk of infection, particularly if they have cuts or abrasions on their skin.

Contaminated water and soil

Agricultural settings, including farms, are high-risk environments because animals can carry and shed the bacteria in their urine.

Contamination of water sources and soil with animal waste increases the likelihood of human exposure, especially among farm workers and those in other related high-risk jobs, including meat workers and veterinarians.

Any fresh or untreated water in rural or urban fringe areas may harbour leptospirosis bacteria (especially after floods or heavy rain) including:

• ponds
• canals/water races
• lakes
• rivers
• creeks
• flood waters.

Leptospirosis bacteria can survive in waterlogged soil for weeks or even months. In agricultural environments where animals graze, the risk of soil contamination increases, especially in areas prone to flooding or where stagnant water pools.

Workers and others who have contact with contaminated soil are at risk of contracting leptospirosis through cuts, abrasions, or mucous membrane exposure.

Managing the risks of flooding, contaminated water and environments

With flooding and contaminated water, you should follow the risk management strategies outlined Section 6.0 Managing the risk including using PPE, practising good hygiene, animal vaccination, increasing worker knowledge and awareness and disease monitoring.

Other risk management strategies you can use to minimise the risk after flooding or when dealing with contaminated water and environments include:

Avoid contact

The most effective way to limit the risk of infection through water is to avoid contact with potentially contaminated water sources. Where reasonably practicable, stay out of floodwaters, stagnant water, and any water that may be contaminated with animal urine.

Environmental cleanup

After flooding or any other water-contaminating event make sure to thoroughly cleanup and disinfect affected areas to reduce the risk of exposure to leptospirosis.

Where reasonably practicable, areas where infected animals have been housed can be treated with disinfectant products then thoroughly dried to kill the bacteria.

Contact with potentially contaminated water

Treat potentially contaminated water before use, especially when being used for drinking, food preparation or cooking.

Seek advice from the water regulator Taumata Arowai(external link) on treatment methods.

Environmental management

Implementing measures to control rodent populations and prevent animal waste from contaminating water sources is essential for reducing the risk of leptospirosis on farms, this includes:

• proper drainage systems
• regular cleaning of water troughs
• reducing effluent runoff
• improving water quality through good waste management practices
• maintaining clean living conditions for animals.

8.0 Breaking the cycle of infection in animals

To break the cycle of infection, a robust vaccination programme is essential.

Animal vaccination

Vaccination is a protection, not a cure. It will reduce the risk of infection to very low levels and may eliminate infection altogether in closed-herd/housed situations.

Many cases of leptospirosis in people come from unvaccinated animals.

Vaccination is an effective strategy for reducing the disease in animal populations and decreasing the risk of transmission to people.

Farmers and animal owners should work with veterinarians to develop robust vaccination programs tailored to their specific animals and farming practices.

How does leptospirosis affect animals?

Animals may show no obvious signs of disease but you and your workers should know about and be aware of the signs of leptospirosis in animals.

Ask your veterinarian how best to spot the signs of infection in your animals.

These signs will depend on the species of animal, its age, sex, overall health, and the strain of bacteria.

9.0 What to do if you think someone is infected

Leptospirosis treatment should begin as soon as exposure to infection is known or suspected.

It is important you display first aid advice in work areas (in ways everyone can view and understand), provide a first aid kit, and follow first aid procedures.

A readily available supply of clean water is important when exposure is known or suspected.

Look after your health. As soon as there is exposure to urine or infection is suspected:

1. Dry off immediately
   Pat dry urine splashes as the bacteria dry out easily.
2. Wash affected area
   Clean cuts or grazes with water and disinfectant, then dry thoroughly.
3. Flush exposed areas
   Rinse mouth, eyes, and any exposed skin with plenty of running water.
4. Wash hands and face
   Use soap and water, paying close attention to facial hair. Dry thoroughly.
5. Record the incident
   Document the exposure in the incident register.
6. Inform a supervisor
   Report the incident to your supervisor for further guidance and assessment.

Anyone who experiences symptoms or suspects they have been exposed should contact their doctor or healthcare provider as soon as possible, and let them know what their job is and that leptospirosis may be the cause.

Call Healthline on 0800 611 116 anytime 24/7 for free health advice and information about what to do next. In an emergency call 111.

10.0 Reporting and notification

Leptospirosis is a notifiable illness under the Health and Safety at Work Act (HSWA) 2015. WorkSafe must be notified of leptospirosis cases.

Duties under HSWA

You must notify WorkSafe as soon as possible after becoming aware of a case of leptospirosis in a worker.

There is more detail on what a notifiable illness is, with examples, and how to notify us at What events need to be notified?

Notification can be made on the WorkSafe website.

You may also have overlapping duties with another PCBU under HSWA. If multiple PCBUs are involved in the work, one PCBU should be nominated to notify the regulator. However, all PCBUs are responsible for ensuring a notification is made. For example, if a contractor was infected with leptospirosis while carrying out work for a farmer, both the farmer and contractor have a duty to notify WorkSafe. However, the farmer and contractor may agree that only the farmer would notify WorkSafe, which would fulfil the duty.

You should also record details of potential leptospirosis exposure events or actual infections for future reference.

Appendices

Appendix 1: Glossary

Control measures

A control measure is a way to eliminate or minimise (reduce) a risk to health and safety.

For more information, see our guidance How to manage work risks

Closed-herd

Means no animals coming onto the farm (not bringing in potentially infected animals from other sources).

You don’t have a closed-herd if you:

• buy in or borrow animals
• exhibit at shows
• share animal handling facilities for testing
• accept unsold animals back onto your farm
• have poor boundary fences
• use common grazing or housing
• animals are transported by someone else or in someone else’s vehicle.

Eliminate

To eliminate a risk means removing the hazard (the source of harm).

For more information, see our guidance How to manage work risks

Minimise

To take steps that protect the health and safety of people by reducing the likelihood of an event occurring, reducing the level of harm to people if it does occur, or both.

For more information, see our guidance How to manage work risks

Notifiable illness or injury

An illness or injury that requires the person to have immediate treatment (other than first aid).

For example, a serious head injury, a serious burn, an injury or illness that requires, or would usually require, the person to be admitted to a hospital for immediate treatment or to have medical treatment within 48 hours of exposure to a substance.

See our guidance on What is a notifiable event

Occupational

Relating to, or caused by, employment in a place or field of work.

Overlapping duties

When a PCBU shares duties with other PCBUs. When two or more PCBUs are working together at the same location or through a contracting chain, they must work together to fulfil their duties of care and manage risks. Where those duties overlap, the PCBUs must consult, cooperate and coordinate with each other to meet their health and safety responsibilities to workers and others. For more information, see Appendix 4

Person conducting a business or undertaking (PCBU)

‘Person conducting a business or undertaking’ (PCBU) is a term used to cover all types of working arrangements.

PCBUs can range from businesses (large corporates, small-medium companies, partnerships, sole traders) to non-commercial organisations such as not-for-profit groups.

PCBUs have many health and safety duties.

Certain people/organisations are not PCBUs – including certain types of volunteer organisations.

For more information, see our guidance What is a PCBU?

Reasonably practicable

What is or was reasonably able to be done to ensure health and safety, accounting for and weighing up relevant matters including:

• the likelihood of the risk concerned occurring or workers being exposed to the hazard
• the degree of harm that might result
• what the person concerned knows, or ought reasonably to know, about:
• the hazard or risk
• ways of eliminating or minimising the risk
• the availability and suitability of ways to eliminate or minimise the risk
• after assessing the extent of the risk and the available ways of eliminating or minimising the risk, the cost associated with available ways of eliminating or minimising the risk, including whether the cost is grossly disproportionate to the risk.

For more information see our fact sheet Reasonably practicable [PDF, 44 KB]

Symptoms

A change in a person’s body that may be linked to a disease.

Appendix 2: Health and Safety at Work Act duties

The Health and Safety at Work Act 2015(external link) (HSWA) is New Zealand’s key work health and safety law.

All work and workplaces are covered by HSWA unless they have been specifically excluded. For example, HSWA does not apply to the armed forces in certain situations.

HSWA sets out the work health and safety duties that duty holders must comply with.

There are four types of duty holder under HSWA:

• a person conducting a business or understanding (PCBU)
• an officer
• a worker
• an ‘other person’ at the workplace.

Most duties under HSWA relate to how work is carried out. However some duties are linked to where work is carried out: the workplace.

Duty holder: Person Conducting a Business or Undertaking (PCBU)

Who they are?

A person conducting a business or undertaking (PCBU) may be an individual person or an organisation.

The following are not PCBUs:

• officers
• workers
• other persons at a workplace
• volunteer associations that do not have employees
• home occupiers (such as home owners or tenants) who pay someone to do work around the home
  section 17 of HSWA(external link)

Examples

• a business
• a self-employed person
• partners in a partnership
• a government agency
• a local council
• a school or university.

What are their duties?

A PCBU has many duties. Key duties are summarised below.

Primary duty of care – section 36 of HSWA(external link)

A PCBU must ensure, so far as is reasonably practicable, the health and safety of workers, and that other persons are not put at risk by its work.

For more information see:

• Introduction to the Health and Safety at Work Act 2015
• Appendix 1 of this guidance for an explanation of ‘so far as is reasonably practicable’

Managing risks – section 30 of HSWA(external link)

Risks to health and safety arise from people being exposed to hazards (anything that can cause harm). A PCBU must manage work health and safety risks.

• A PCBU must first try to eliminate a risk so far as is reasonably practicable. This can be done by removing the source of harm
  • for example, removing faulty equipment or a trip hazard.
• If it is not reasonably practicable to eliminate the risk, it must be minimised so far as is reasonably practicable.

For more information see:

• Identifying, assessing and managing work risks [PDF, 404 KB]
• Section 6 of this guidance or Appendix 6 of this guidance.

Overlapping duties: working with other PCBUs – section 34 of HSWA(external link)

A PCBU with overlapping duties must, so far as is reasonably practicable, consult, cooperate and coordinate activities with other PCBUs they share duties with.

For more information see Appendix 1 of this guidance

Involving workers: worker engagement, participation and representation – Part 3 of HSWA(external link)

A PCBU must, so far as is reasonably practicable, engage with their workers (or their workers’ representatives) about health and safety matters that will directly affect the workers.

A PCBU must have worker participation practices that give their workers reasonable opportunities to participate in improving health and safety on an ongoing basis.

For more information see Good practice for worker engagement, participation and engagement

Duty holder: Upstream PCBU

Who they are?

A PCBU in the supply chain.

Examples

• a designer
• a manufacturer
• a supplier
• an importer
• an installer, constructor, or commissioner.

What are their duties?

Upstream PCBU – sections 39–43 of HSWA(external link)

An upstream PCBU must ensure, so far as is reasonably practicable, that the work they do or the things they provide to other workplaces do not create health and safety risks.

For more information see Introduction to the Health and Safety at Work Act 2015

Duty holder: Officer

Who they are?

A specified person or a person who exercises significant influence over the management of the business or undertaking – section 18 of HSWA(external link)

Examples

• a company director
• a partner or general partner
• a chief executive.

What are their duties?

Officer – section 44 of HSWA(external link)

An officer must exercise due diligence that includes taking reasonable steps to ensure that the PCBU meets their health and safety duties.

For more information see Introduction to the Health and Safety at Work Act 2015

Duty holder: Worker

Who they are?

An individual who carries out work for a PCBU
section 19 of HSWA(external link)

Examples

• an employee
• a contractor or sub-contractor
• an employee of a contractor or sub-contractor
• an employee of a labour hire company
• an outworker (including homeworker)
• an apprentice or trainee
• a person gaining work experience or on work trials
• a volunteer worker.

What are their duties?

Worker – section 45 of HSWA(external link)

A worker must take reasonable care of their own health and safety, and take reasonable care that they do not harm others at work.

A worker must cooperate with reasonable policies and procedures the PCBU has in place that the worker has been told about.

A worker must comply, as far as they are reasonably able, with any reasonable instruction given by the PCBU so the PCBU can meet their legal duties.

For more information see Introduction to the Health and Safety at Work Act 2015

Duty holder: Other person at the workplace

Who they are?

An individual present at a workplace (not a worker).

Examples

• a workplace visitor
• a casual volunteer (not a volunteer worker)
• a customer.

What are their duties?

Other person at the workplace – section 46 of HSWA(external link)

An ‘other person’ has a duty to take reasonable care of their own health and safety, and not adversely affect the health and safety of anyone else.

They must comply with reasonable instructions relating to health and safety at the workplace.

For more information see:

• Introduction to the Health and Safety at Work Act 2015

Appendix 3: So far as is reasonably practicable

section 22 of HSWA(external link)

Certain PCBU duties (the section 36–43(external link) duties including the primary duty of care) must be carried out ‘so far as is reasonably practicable’.

What to consider when deciding what is ‘reasonably practicable’

Just because something is possible to do, does not mean it is reasonably practicable in the circumstances.

Consider:

• What possible actions can be taken to ensure health and safety?
• Of these possible actions, at a particular time, what is reasonable to do?

Think about the following questions.

What is known about the risk?

• How likely is the risk to occur?
• How severe is the illness or injury that might occur if something goes wrong?
• What is known, or should reasonably be known, about the risk?

What is known about possible control measures?

• What is known, or should reasonably be known, about the ways (control measures) to eliminate or minimise the risk?
• What control measures are available?
• How appropriate (suitable) are the control measures to manage the risk?
• What are the costs of these control measures?
• Are the costs grossly disproportionate to the risk? Cost must only be used as a reason to not do something when that cost is grossly out of proportion to the risk.

For more information, see our guidance Reasonably practicable [PDF, 44 KB]

Appendix 4: Working with other PCBUs – overlapping duties

section 34 of HSWA(external link)

More than one PCBU can have a duty in relation to the same matter. These PCBUs have overlapping duties – this means that the duties are shared between them.

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Duties regularly overlap:

• in a shared workplace (for example, a building site or a port) where more than one business has control and influence over the work on site.
• in a contracting chain, where contractors and subcontractors provide services to a head contractor or client and do not necessarily share the same workplace.

A PCBU must, so far as is reasonably practicable, consult, cooperate and coordinate activities with all other PCBUs they share duties with so that all PCBUs can meet their joint responsibilities.

A PCBU cannot transfer or contract out of their duties, or pass liability to another person.

However a PCBU can make an agreement with another PCBU to fulfil specific duties. Even if this occurs, all PCBUs are still responsible for meeting their legal duties.

Appendix 5: Worker engagement, participation and representation

Part 3 of HSWA(external link)

Engage with workers and enable their participation

A PCBU has two main duties related to worker engagement and participation:

• to engage with workers on health and safety matters that affect or are likely to affect workers, so far as is reasonably practicable, and
• to have practices that give workers reasonable opportunities to participate effectively in the ongoing improvement of work health and safety.

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A PCBU can engage with workers by:

sharing information about health and safety matters so that workers are well-informed, know what is going on and can contribute to decision-making

giving workers reasonable opportunities to have a say about health and safety matters

listening to and considering what workers have to say at each step of the risk management process

considering workers’ views when health and safety decisions are being made

updating workers about what decisions have been made.

A PCBU must engage with workers during specified times, including when identifying hazards and assessing risks.

A PCBU must have clear, effective, and ongoing ways for workers to suggest improvements or raise concerns.

Worker representation

Workers can be represented by a Health and Safety Representative (HSR), a union representing workers, or a person that workers authorise to represent them (for example, a community or church leader, or another trusted member of the community).

HSRs and Health and Safety Committees (HSCs) are two well-established methods of participation and representation. If workers are represented by an HSR, worker engagement must also involve that representative.

For more information

WorkSafe guidance

Good practice guidelines

Worker engagement, participation and representation

Interpretive guidelines

Worker representation through Health and Safety Representatives and Health and Safety Committees

Pamphlets

Worker representation

Health and Safety Committees

Health and Safety Representatives

Appendix 6: Managing risk

section 30 of HSWA(external link)

Risks to health and safety arise from people being exposed to a hazard (a source or cause of harm).

A PCBU must first try to eliminate a risk if this is reasonably practicable. If it is not reasonably practicable to eliminate the risk, it must be minimised so far as is reasonably practicable.

Follow the steps below to identify, assess and manage work health and safety risks.

Step 1: Identify hazards that could give rise to work risks

With your workers, identify what could harm the health or endanger the safety of one or more workers or others (such as visitors, or bystanders).

Step 2: Assess work risks

With your workers, identify and assess the risks arising from each work hazard. Ask:

• Who might be exposed to the hazard?
• What could happen?
  • How severe could the resulting injuries be?
  • How could people’s health be affected?
  • How likely are these consequences?

Decide which risks to deal with immediately. For example, risks with potentially significant consequences such as serious injury or death, chronic ill-health, or those with a high likelihood of occurring.

Step 3: Decide how to manage each risk

With your workers, decide how to manage work risks.

Multiple control measures may be needed to deal with a given risk. Give preference to control measures that protect many workers at the same time (for example, safety barriers, safety nets).

A PCBU can use the following hierarchy of control measures to work out the most effective control measures to use.

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First try to eliminate

First try to eliminate the risk, if this is reasonably practicable. This can be done by removing the source or cause of harm (such as faulty equipment, a noisy machine or a trip hazard).

Then try to minimise

If it is not reasonably practicable to eliminate the risk, the risk must be minimised so far as is reasonably practicable.

Minimise the risk using one or more of the following actions:

• substitute/swap with something that has a lower risk
• isolate the hazard by separating people from the source of harm
• apply engineering control measures (where physical components of the plant, structure or work area are changed to reduce or eliminate exposure to hazards).

If the risk still remains after taking one or more of the actions above, try to minimise the risk with administrative control measures (safe methods of work, procedures or processes).

If there is still risk, use personal protective equipment (PPE) to minimise the risk. PPE is the least effective control measure, and should only be used when other control measures alone cannot adequately manage the risk.

Step 4: Put control measures in place

As soon as possible after a decision is made about the control measures, a PCBU should:

• put the control measures in place
• instruct and train workers (including new workers) about the control measures, including why it is important to use them and how to apply them.

Step 5: Review and improve control measures

Control measures should remain effective, be fit-for-purpose, be suitable for the nature and duration of the work, and be used correctly.

With your workers, regularly monitor control measures to confirm that the measures are effective.

You should review control measures:

• when a new risk is identified
• when there is a change at the workplace or to the work
• when workers or their health and safety representative ask for a review
• when there is evidence that control measures may not be working effectively to manage the risk (for example, when you receive monitoring results or a report following an incident investigation).

Use guidance from WorkSafe or others (for example, industry associations) to help to identify, assess, and manage risks, and review control measures. If you need help, WorkSafe recommends getting advice from a suitably qualified and experienced health and safety professional.

For more information, see our guidance: Identifying, assessing and managing work risks [PDF, 404 KB]