INTRODUCTION
• Work related injury and illness is a significant and expensive problem in NSW. In 2006/2007 there were 137 fatal employment injuries and 41,231 reported workplace injuries for which compensation was payable. The gross cost of injuries was $812 million.
• Occupational Health and Safety (“OH&S”) laws attempt to protect the health, safety and welfare of people at work.
• The main OH&S laws in NSW are the Occupational Health and Safety Act 2000 (“Act”) and the Occupational Health and Safety Regulation 2001 (“Regulation”).
• The Act places broad general duties on a range of parties, such as employers and persons in control of workplaces, which are supplemented by the Regulation and codes of practice which provide further detail and guidance.
• These laws requires those who owe OH&S obligations to be proactive in eliminating health and safety risks at places of work, rather than reactive to incidents.
• Compliance with these laws is monitored and enforced predominantly by the WorkCover Authority of NSW. WorkCover is given broad powers to inspect workplaces and take enforcement action ranging from informal measures such as advice and persuasion, to administrative sanctions such as improvement, prohibition and infringement notices, to formal prosecution.
• Workplace safety laws are no longer limited to the building site or factory floor. They now apply to most places of work, including strata schemes. Consequently OH&S laws apply to owners corporations and strata managers.
• This paper will not deal with all OH&S laws. It will deal briefly with those OH&S laws which are most applicable to an owners corporation and strata manager.
HEALTH AND SAFETY
Part 2 of the Act outlines general duties relating to health, safety and welfare at the workplace. Briefly:
• Section 8 provides that employers have a responsibility to ensure, so far as is reasonably practicable, the health, safety and welfare of employees and other persons at the workplace;
• Section 9 provides that a self-employed person must, so far as is reasonably practicable, ensure that people (other than the employees of the person) are not exposed to risks to their health or safety arising from the conduct of the person’s undertaking while they are at the person’s place of work;
• Section 10 provides that a person who has control of work premises, plant or substances has a responsibility for ensuring, so far as is reasonably practicable, the premises, plant or substances are safe and without risks to health;
• Section 20 provides that employees must take reasonable care for the health and safety of others in the workplace and cooperate with employers.
• Section 26 requires officers of a corporation (including a body corporate such as an owners corporation) to exercise due diligence to ensure that the corporation complies with its OH&S duties.
The most important provisions for an owners corporation and strata manager are sections 8 and 10 which concern the general duties of an employer and controller of work premises respectively.
DUTIES OF AN EMPLOYER
An owners corporation can be an employer, for example, when an owners corporation employs a part-time gardener or building manager to assist it exercise its functions. So the OH&S laws applicable to employers can, and often do, apply to an owners corporation.
Where an owners corporation is an employer, it will have a duty under section 8(1) to ensure the health, safety and welfare at work of its employees. This will include duties to:
• Ensure, so far as is reasonably practicable, that any premises controlled by the owners corporation where its employees work (and the means of access to or exit from the premises) are safe and without risks to health;
• Ensure, so far as is reasonably practicable, that any plant or substance provided for use by its employees at work is safe and without risks to health when properly used;
• Ensure, so far as is reasonably practicable, that systems of work and the working environment of the employees are safe and without risks to health;
• So far as is reasonably practicable, provide such information, instruction, training and supervision as may be necessary to ensure the employees’ health and safety at work; and
• So far as is reasonably practicable, provide adequate facilities for the welfare of the employees at work.
An owners corporation that is an employer will also fall under a duty under section 8(2) to ensure, so far as is reasonably practicable, that people (other than its employees) are not exposed to risks to their health and safety whilst they are at the owners corporation’s “place of work” (i.e. the common property) arising from the conduct of the owners corporation’s business (i.e. the business of operating a strata scheme).
An owners corporation that is an employer will also owe a duty to consult with its employees to enable the employees to contribute to the making of decisions affecting their health, safety and welfare at work: section 13.
DUTIES OF A CONTROLLER OF WORK PREMISES
A person in control of premises used by people as a place of work, or plant used by people at work, has a duty to ensure, so far as is reasonably practicable, that the premises, and any such plant, are safe and without risks to health pursuant to section 10 of the Act.
This duty will apply to an owners corporation. This is because:
• An owners corporation has control of the common property including plant situated on common property – e.g. the owners corporation has a statutory duty to manage and control the use of the common property for the benefit of the owners under section 61 of the Strata Schemes Management Act 1996 (“Strata Act”);
• The common property in any type of strata scheme is capable of being a place of work – e.g. when contractors engaged by an owners corporation work on the common property or the common property is used by employees and clients of home business owners as a means of ingress to and egress from the place of business; and
• Plant situated on common property is cable of being used by people at work – e.g. a lift.
This means that each and every owners corporation owes a statutory duty to ensure, so far as is reasonably practicable, that common property, and plant situated on common property, are safe and without risks to health.
There is a common misconception that this obligation does not apply to an owners corporation because the Act says that the obligation does not apply to premises occupied as a private dwelling or to plant and substances used in any such premises, and the obligation only applies if premises or plant are controlled in the course of a person’s trade, business or other undertaking. However the common property is not a private dwelling. And the common property is probably controlled by an owners corporation in the course of carrying on the business of managing a strata scheme: see Young & 1 Or v The Owners SP 3529 & 2 Ors [2001] NSWSC 1135
The extent of the obligation owed under section 10 is limited to the extent of control over premises exercised by a party.
Sometimes there is more than one person in control of work premises, meaning numerous people owe concurrent obligations to ensure work premises are safe and without risks to health. For example, where an owners corporation delegates its functions to manage and control, and maintain and repair, common property to a strata manager, the strata manager will have control of the common property and so must also comply with the obligations imposed by section 10.
Unfortunately the Act provides little guidance as to what is expected of the various duty holders to the extent that they have control over the common property. This often leads to confusion or uncertainty on how duty holders should apportion, and make decisions about, OH&S risks and hazards.
NEW NATURE OF THE OH&S DUTIES
Nonetheless, the general duties imposed on employers and controllers of workplaces must be satisfied. These duties were once absolute and unqualified. They were not to take “reasonable care”. They imposed a higher standard: Kirk v Industrial Relations Commission; Kirk Group Holdings Pty Ltd v WorkCover Authority of New South Wales (Inspector Childs) [2010] HCA 1.
However recent reforms to OH&S laws (discussed below) have watered down the absolute nature of these duties by introducing the “so far as is reasonably practicable” standard. So duty holders will need to ensure health and safety only so far as is reasonably practicable. This will require duty holders:
• to eliminate risks to health and safety so far as is reasonably practicable, and
• if it is not reasonably practicable to eliminate risks to health and safety, to minimise those risks so far as is reasonably practicable: see section 7A.
In determining what is reasonably practicable in relation to ensuring health and safety, all relevant matters are to be taken into account and weighed up. These will include:
• the likelihood of the hazard or the risk concerned occurring, and
• the degree of harm that might result from the hazard or the risk, and
• what the person concerned knows, or ought reasonably to know, about:
- the hazard or the risk, and
- ways of eliminating or minimising the risk, and
• the availability and suitability of ways to eliminate or minimise the risk, and
• 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.
RISK MANAGEMENT
Chapters 2 and 4 of the Regulation deal with risk management. This is the process of identifying hazards, assessing the risks associated with the hazards, eliminating the hazards or implementing control measures for those hazards and reviewing the effectiveness of the control measures.
Chapter 2 deals with risk management for employers. Chapter 4 covers risk management for the “controller of premises” used by people as a place of work.
An owners corporation can be an employer, it is the controller of the common property, and the common property can be used as a place of work. This means that, subject to a limited exemption discussed below, an owners corporation will need to comply with the risk management processes in the Regulation.
This will require an owners corporation to, so far as it is reasonably practicable (among other things):
• identify any foreseeable hazard arising from the common property that has the potential to harm the health or safety of any person accessing, using or egressing from the common property;
• assess the risk of harm to the health or safety of any person arising from any hazard identified;
• eliminate any risk, arising from the common property, to the health or safety of any person accessing, using or egressing from the common property, or if it is not reasonably practicable to eliminate the risk, control the risk;
• regularly review its risk assessment; and
• provide information about risk management to certain users of the common property who owe OH&S obligations under the Regulation, such as contractors.
The Regulation also imposes risk management and other obligations on the controllers of work premises regarding: fall prevention, electrical installations and asbestos.
COMPLYING WITH RISK MANAGEMENT OBLIGATIONS
In order to satisfy this part of the legislation, an owners corporation needs to be sure that it has processes to:
• identify hazards;
• assess the risks associated with the hazards;
• eliminate the hazards or implement control measures for those hazards; and
• review the effectiveness of the control measures.
THE EXEMPTION ORDER
WorkCover may, by order published in the Gazette, exempt any class of persons or things from a specified provision of the Regulation in its application to a workplace: see clause 348 of the Regulation.
In 2007, WorkCover issued exemption order no. 014/07. The order applies from 8 November 2007 for a period of five years. It operates to exempt an owners corporation from complying with some of the risk management obligations imposed on the controller of premises in Chapter 4 of the Regulation (clauses 33-44) which are identified above in respect of the common property in a residential strata scheme or the common property leading to or exclusively used by a residential component of a mixed use strata scheme.
This means that an owners corporation to which the order applies does not need to fulfil the obligations under Chapter 4 of the Regulation to identify hazards, assess the risks associated with the hazards, eliminate the hazards or implement control measures for those hazards and review the effectiveness of the control measures.
However this does not mean that an owners corporation can or should completely ignore these obligations, and it is important to realise that the order has an extremely limited scope of operation.
For example, the order has no effect on the obligation of an owners corporation to ensure that the common property and any plant or substances under its control are safe and without risks to health pursuant to section 10 of the Act. Often the risk assessment process exempted by the order needs to be followed to comply with this and other OH&S obligations.
The order does not apply to every owners corporation. The risk management obligations imposed by the Regulation will still apply in relation to common property where the lots in the strata scheme are commercial or mixed commercial and residential, except in relation to common property which is only used to access the residential lots.
Further, the order does not apply to strata managers. So strata managers of residential strata schemes are not exempted from any OH&S requirements as a result of the order.
OTHER HEALTH AND SAFETY OBLIGATIONS
An owners corporation will owe health and safety obligations outside of the OH&S laws.
OCCUPIERS’ DUTY
An owners corporation is the “occupier” of the common property: see Ridis v Strata Plan 10308 [2005] NSWCA 246. It will therefore owe an occupiers’ duty of care under the common law. This is a duty to take reasonable care to protect entrants on the common property from risks of injury which can be foreseen and avoided: see Australian Safeway Stores Pty Limited v Zaluzna (1997) 162 CLR 479. The scope or extent of that duty is judged by what a reasonable person would do by way of response to the foreseeable risk of injury. In determining whether a reasonable person would take precautions against a foreseeable risk of injury, a court will consider: the probability that harm would occur if care were not taken, the likely seriousness of the harm, and the burden of taking precautions to avoid the risk of harm: see section 5B Civil Liability Act 2002; Wyong Shire Council v Shirt (1980) 146 CLR 40).
DUTY TO REPAIR
Section 62 of the Strata Act imposes on an owners corporation a strict duty to properly maintain and keep in a state of good and serviceable repair the common property and renew or replace any fixtures or fittings comprised in the common property.
The duty is not one to use reasonable care to maintain and keep in good repair the common property, nor one to use best endeavours to do so, nor one to take reasonable steps to do so, but a strict duty to maintain and keep in repair.
The duty involves an obligation to keep the common property in proper order by acts of maintenance before it falls out of condition in a state which enables it to serve the purpose for which it exists. This means an owners corporation must take preventative measures to ensure that there is no malfunction or defect in the common property. The duty extends to require remediation of defects in the original construction of the common property. As soon as something in the common property is no longer operating effectively or at all, or has fallen into disrepair, there has been a breach of the statutory duty to repair.
The strict nature of the statutory duty to repair makes whether or not the owners corporation took all reasonable steps irrelevant if ultimately it failed at any time to meet the strict requirements of the duty. Because of the strict nature of the duty it is irrelevant whether the owners corporation fixes defects in the common property with due diligence and expedition.
The duty to repair is owed to each lot owner and occupier and its breach gives rise to a private cause of action under which damages may be awarded to a lot owner or occupier for breach of statutory duty: Seiwa Pty Ltd v Owners Strata Plan 35042 [2006] NSWSC 1157; Trevallyn-Jones v Owners Strata Plan 50358 [2009] NSWSC 694; Nicita v Owners of Strata Plan 64837 [2010] NSWSC 68; see also Wu v Carter [2009] NSWSC 355.
The occupiers’ duty and statutory duty to repair common property do not necessarily mean that an owners corporation needs to fix or upgrade a part of the common property that, although not broken or defective, presents a safety risk or does not comply with current safety standards: Ridis v Strata Plan 10308 [2005] NSWCA 246. In Ridis, the NSW Court of Appeal concluded that the obligation imposed by section 62 and the common law duty of care did not require a glass entrance door which was otherwise in good repair and operating as intended to be replaced even though the glass in it did not accord with that used in contemporary buildings and current safety standards and would shatter on impact.
Nonetheless, the occupiers’ duty and the duty to repair common property impose important, additional health and safety obligations on an owners corporation, outside the OH&S laws, which are often forgotten.
REGISTRATION OF PLANT
Chapter 5 of the Regulation imposes obligations on the controllers of “plant” such as passenger lifts. These obligations will apply to many owners corporations, particularly those whose strata schemes contain a lift.
A person (such as an owner) who has control of an item of plant (such as a lift) may apply to WorkCover to register the plant: clause 113 of the Regulation. The registration of the plant must be annually renewed: clause 118. An employer (which includes an owner of plant affecting public safety such as a lift) cannot allow plant that is not registered to be used: clause 136.
It follows that lifts situated on common property in strata schemes require annual registration.
There are two types of registration: design registration – a one off process covering the design of the lift; and item registration – which applies to every item of plant requiring registration by the Regulation.
A person who applies for registration of a lift must provide a statement that the lift has been inspected by a competent person and is safe to operate: clause 113. A competent person includes a person employed by a lift manufacturer for the purpose of inspecting and maintaining lifts.
In a paper entitled “Information on how to renew your lift registration” dated 29 May 2003, WorkCover indicated that where lifts are installed in the common areas of a residential strata scheme, the owners corporation is usually deemed to be the controller of the lift, but where an owners corporation employs someone on its behalf to initiate and ensure that maintenance of the lift is carried out, such as a strata manager or building manager, that person may be deemed to be the controller of the lift – and therefore be responsible for registering the lift with WorkCover.
CONSTRUCTION WORK
Chapter 8 of the Regulation deals with construction work. It imposes OH&S obligations on a “principal contractor” who is essential a contractor engaged to carry out building work of a certain type.
Construction work includes alterations and additions made to a building, demolition work and asbestos removal. So the requirements of Chapter 8 can apply to any owners corporation intending to add to or alter the common property through building work.
An owner of a place of work at which construction work costing more than $250,000, or high risk construction work, will be undertaken, must appoint a principal contractor for the construction work carried out for the owner: clause 210. A principal contractor must be responsible for the construction work at all times. If an owner does not appoint a principal contractor, it will be taken to be the principal contractor for the construction work: clause 210.
A principal contractor for a construction project must ensure that any person who will carry out construction work on the project has undergone OH&S induction training: clause 213. A principal contractor for construction work costing more than $250,000 must ensure that a site specific occupational health and safety management plan is prepared for each place of work at which the construction work is to be carried out before the work commences, and the plan is maintained and kept up to date during the course of the work: clause 226.
A principal contractor for construction work costing more than $250,000, or high risk construction work, must prepare a written safe work methods statement which includes an assessment of risks associated with the work and ensure the work is carried out in accordance with the statement (if there is no sub-contractor) or ensure that each sub-contractor, before commencing work at a place of work, provides the principal contractor with a written safe work method statement for the work to be carried out by the sub-contractor and is directed to comply with the statement: clause 227.
PENALTIES AND PROSECUTIONS
OH&S laws are primarily enforced by the WorkCover Authority.
Inspectors appointed by WorkCover have the power to enter work premises without notice and to make searches, inspections, examinations and tests, take photographs and make videos: sections 50 – 59 of the Act.
The approach of WorkCover in the event of an accident or injury is to presume that the OH&S laws have been broken and the accused, usually an employer, has to prove that it has complied with the laws.
Enforcement provisions in the Act vary depending on circumstances and the type and severity of the alleged breach.
WorkCover Inspectors may issue different types of notices. Investigation, Improvement and Prohibition Notices are covered by Part 6 of the Regulation.
Penalty Notices are served under section 108 of the Act. More detailed information on Penalty Notices is provided in Part 12.6 and Schedule 2 of the Regulation.
Compliance with Notices is mandatory. When there is a failure to comply with a Notice or where there is a “flagrant and deliberate breach of OH & S responsibilities” prosecutions may be brought under the Act or Regulation.
In matters covered by Part 2 of the Act, such as the employers’ and controllers’ duties imposed under section 8 and 10, the maximum penalty for a company found guilty of a first offence is 5000 penalty units. For a second offence the penalty is 7500 penalty units. For individuals found guilty of a first offence the maximum penalty is 500 penalty units and 750 units for a second offence or 2 years imprisonment or both.
In the case of work place deaths under Division 2A, sections 32A and 32B, the penalties are much higher. The maximum penalty for a corporation is 15000 penalty units and for an individual a maximum of 5 years imprisonment or 1500 penalty units or both.
It is important to realise that most insurance policies will not provide cover for penalties imposed for a failure to comply with OH&S laws.
Under Part 7 Division 2 (sections 113 – 116) of the Act there are also non-monetary penalties. The Court can make orders for offenders to do any of the following:
• Take steps to remedy or restore any matter caused by the offence;
• Pay WorkCover the costs of the investigation;
• Publicise or notify other persons of the offence; or
• Undertake a project for the general improvement of health and safety.
DEFENCES
Available defences to prosecutions are limited.
There used to be statutory defences to any proceedings against a person for an offence against a provision of the Act or the Regulation if the person proved that: (a) it was not reasonably practicable for the person to comply with the provision, or (b) the commission of the offence was due to causes over which the person had no control and against the happening of which it was impracticable for the person to make provision: section 28.
However these defences have been abolished under the recent OH&S law reforms due to the introduction of the watered down health and safety duties and to abolish the reverse onus of proof (discussed below).
In the past these defences had often proven difficult to establish. This was because the NSW Industrial Relations Commission (now the Industrial Court of NSW) had tended to interpret the defences as requiring an employer, for example, to take “all possible steps” to prevent the hazard or risk in order to make out the statutory defences.
The approach of the Industrial Court has been tempered by the High Court’s recent decision in Kirk which now makes it relatively clear that the duties cast on an employer by section 8 of the Act will only be breached where there has been a failure, on the part of the employer, to take particular measures to prevent an identifiable risk eventuating.
IMPLICATIONS FOR STRATA MANAGERS
The OH&S laws impact on strata managers in a number of ways.
Strata managers who have been delegated the functions of an owners corporation to manage and control, or to maintain and repair, the common property, will be deemed to be the controller of work premises and owe obligations to ensure that the common property, and plant and substances situated on common property, such as a lift, are safe and without risks to health, to the extent that the strata manager has control of the common property and plant.
Strata managers will also owe obligations as an employer to ensure the safety of their own employees when performing work on common property such as attending owners corporation or executive committee meetings or meeting contractors.
Further, strata managers (and executive committee members) can be held liable for certain breaches of the OH&S laws committed by an owners corporation, where the strata manager (or committee member):
• is an office bearer, or a person who makes, or participates in making, decisions that affect the administration and management of the owners corporation, and
• fails to exercise due diligence to ensure the owners corporation complies with its OH&S duties: see section 26.
This is a new duty imposed on “officers” of “corporations” under the recent OH&S law reforms (discussed below). A corporation includes a body corporate, meaning the officers of owners corporations are caught by this new duty: see section 26 of the Act.
Exercising due diligence will require “officers” of an owners corporation to take reasonable steps:
• to acquire and keep up-to-date knowledge of OH&S matters, and
• to gain an understanding of the nature of the operations of the “business” of the owners corporation and generally of the hazards and risks associated with that business, and
• to ensure that the owners corporation has available for use, and uses, appropriate resources and processes to eliminate or minimise risks to health and safety from work carried out as part of the conduct of the business of the owners corporation, and
• to ensure that the owners corporation has appropriate processes for receiving and considering information regarding incidents, hazards and risks and responding in a timely way to that information, and
• to ensure that the owners corporation has, and implements, processes for complying with any duty or obligation of the corporation under the relevant provisions of this Act.
THE NEW NATIONAL OH&S FRAMEWORK
On 4 April 2008, the Federal Government announced a national review into model OH&S laws. A three person expert panel was asked to review OH&S legislation in each State, Territory and Commonwealth jurisdiction to make recommendations on the optimal structure and content of a model OH&S Act.
In July 2008, the Council of Australia Governments formally committed to the harmonisation of work health and safety laws by signing an Intergovernmental Agreement for Regulatory and Operational Reform in OHS. All states and territories and the Commonwealth have committed to work together to develop and implement model occupational health and safety laws by 1 January 2012.
In NSW, the newly installed O’Farrell Government has quickly moved to fast track the implementation of some of the national OH&S law reforms. On 5 May 2011, the Occupational Health and Safety Amendment Bill 2011 and the Work Health and Safety Bill 2011 were introduced into the NSW Parliament. The Bills were assented to on 7 June 2011.
The main objects of the Occupational Health and Safety Amendment Bill 2011 are to amend the Act so that, in line with the proposed national work health and safety reforms:
• the general duties under the Act to ensure health, safety and welfare (and the duties under the Regulation) are qualified by the inclusion of the “so far as is reasonably practicable” standard – this waters downs, to some extent, the absolute nature of these duties to require duty holders to eliminate, or if elimination is not possible to minimise, risks to health and safety “so far as is reasonably practicable”,
• the reverse onus of proof in OH&S prosecutions that once existed, under which the accused had to prove that it did not breach OH&S laws, is abolished thereby requiring the prosecution to now prove what was reasonably practicable to comply with the OH&S laws, and
• officers of a corporation fall under a duty to exercise due diligence to ensure that the corporation complies with health, safety and welfare duties, and this duty has replaced the provision that deemed directors and managers of a corporation to be guilty of offences committed by the corporation.
The amendments contained in the Occupational Health and Safety Amendment Bill 2011 came into force on 7 June 2011 and are now law.
The Work Health and Safety Bill 2011 willenact the nationally agreed Model Work Health and Safety Act in NSW. It will commence on 1 January 2012 and be supplemented by Model Work Health and Safety Regulations and Codes of Practice. It will generally retain the OH&S reforms included in the Occupational Health and Safety Amendment Bill 2011. Importantly, it will take much of the jurisdiction for OH&S prosecutions away from the Industrial Court and give the Local Court and the District Court power to hear OH&S prosecutions. It will also restrict the right of union officials to commence OH&S prosecutions.
TIPS –
RISK MANAGEMENT
The key questions for an owners corporation or strata manager to answer to assist in proving they have complied with some of their OH&S responsibilities are:
• What processes do I have to manage health and safety risks?
• How effective are they?
• How do I prove I am meeting my obligations?
OH&S AUDIT REPORTS
Often the best way for an owners corporation to meet some of the most important OH&S obligations is to engage a professional chartered building consultant to provide a detailed audit report outlining the health and safety risks of common property. This practice is recommended by WorkCover and, although not essential for complying with the OH&S laws, is certainly advisable.
RECORD KEEPING
It is in every owners corporation’s interests to maintain records such as hazard identification, risk assessment and control, training and education, plant assessment, and so on.
Records will assist to determine the extent to which an owners corporation has observed the requirements of the Act and Regulation. As a minimum, it is prudent to maintain records such as:
• Management decisions concerning OH&S;
• Processes and results of hazard identification;
• Processes and results of risk assessments;
• Evidence of OH&S training activities;
• Copies of all incident records, and particularly those reported to Workcover; and
• Copies of all records concerning dealings between the owners corporation and its insurer or broker.
THE BASICS
An owners corporation and strata manager should at the very least:
• acquaint themselves with their basic OH&S obligations and other health and safety laws;
• regularly carry out a risk management process including:
- identifying hazards,
- assessing the risks associated with the hazards,
- eliminating the hazards or implementing control measures for those hazards, and reviewing the effectiveness of the control measures;
• obtain an annual OH&S audit report in relation to the common property; and
• keep detailed records concerning risk management, OH&S decisions, incidents and other matters relevant to OH&S.
CONCLUSION
Owners corporations and strata managers fall under serious OH&S obligations. These obligations need to be understood and complied with and a proactive, rather than reactive approach, is required.
Times have changed. OH&S laws can no longer be ignored by the strata industry. There are now many consultants offering OH&S audit reports and advice to the strata sector at a reasonable cost. This should make it easier for owners corporations and strata managers to understand and meet their OH&S obligations.
Ultimately, compliance with OH&S laws promotes a safer and better workplace, in turn, leading to less workplace accidents and illness and safer strata schemes. This is an admirable pursuit and one which should be supported by stakeholders in the strata industry.