A safe workplace for every worker and every participant — because safer work leads to safer care
This policy sets out how Together Two Limited manages work health and safety across all operations, sites, and service streams. It establishes the WHS management system that protects the physical and psychological health and safety of workers, participants, volunteers, contractors, and visitors.
Together Two employs 144 workers across more than 15 sites, delivering supports in environments that are workplaces under the WHS Act 2011 (NSW) — SIL dwellings, participants' homes, community settings, day program venues, employment placements, vehicles, and the main office at 754 Darling Street Rozelle. Workers provide high-intensity clinical supports, complex behaviour support, personal care, and community access in settings where manual handling, occupational violence, lone working, and psychosocial hazards are inherent features of the work.
Together Two is a Person Conducting a Business or Undertaking (PCBU) under the WHS Act. This policy documents how the organisation meets its primary duty of care under section 19, how officers exercise due diligence under section 27, and how workers meet their duties under section 28.
→ Business and Operational Plan 2025–2028: Section 9 (Legislative and Regulatory Framework); Risk Register (Form 01).
This policy applies to all Together Two workers (employees, contractors, casual workers, labour hire, students on placement), volunteers (including Good in the Hood volunteers), officers (Board directors, CEO), and visitors at any location where work is carried out for Together Two.
A workplace includes any place where a worker goes, or is likely to be, while at work. For Together Two, this includes SIL dwellings, participants' homes (in-home support), community locations during community access, vehicles during transport, ZigZag day program venues, SLES and employment placement sites, the café (once operational), and the Rozelle office.
This policy supports compliance with:
| Legislation or Standard | Key Requirements |
|---|---|
| Work Health and Safety Act 2011 (NSW) | Primary duty of care (s 19), officer due diligence (s 27), worker duties (s 28), consultation (ss 47–49), HSR provisions (ss 50–80), HSC (ss 75–79), notifiable incidents (s 38), right to cease unsafe work (s 84) |
| Work Health and Safety Regulation 2025 (NSW) | Commenced 22 August 2025. Hierarchy of controls for psychosocial risks (s 55C), factors for controlling psychosocial risks (s 55D), hazardous manual tasks, first aid, hazardous chemicals, emergency plans, PPE |
| Section 26A WHS Act (commencing 1 July 2026) | New duty for PCBUs to comply with approved Codes of Practice or demonstrate equivalent or higher standard. Codes of Practice become mandatory benchmarks |
| Managing Psychosocial Hazards at Work Code of Practice (2021) | Approved Code — becomes mandatory benchmark under s 26A. Hazard identification, risk assessment, hierarchy of controls for psychosocial risks |
| Healthcare and Social Assistance Industry Code of Practice | Practical examples relevant to disability support services |
| Workers Compensation Act 1987 (NSW) | Workers compensation insurance, icare 48-hour notification |
| Workplace Injury Management and Workers Compensation Act 1998 (NSW) | Injury management, return to work obligations |
| NDIS Practice Standards, Core Module | Risk Management, Human Resource Management (infection control training, emergency/disaster workforce), Emergency and Disaster Management |
| NDIS (Code of Conduct) Rules 2018 | Worker and provider obligations including safe and competent supports |
→ Business and Operational Plan 2025–2028: Section 9 (Legislative and Regulatory Framework); Compliance Register (Form 17).
Together Two, as a PCBU, must ensure so far as is reasonably practicable:
The provision and maintenance of a work environment without risks to health and safety, including risks to psychological health.
The provision and maintenance of safe plant, structures, and systems of work.
The safe use, handling, and storage of plant, structures, and substances.
The provision of adequate facilities for the welfare of workers, including access to amenities.
The provision of any information, training, instruction, or supervision that is necessary to protect all persons from risks to their health and safety arising from work.
The monitoring of the health of workers and the conditions at the workplace for the purpose of preventing illness or injury.
Together Two also owes a duty of care to persons other than workers — participants, their families, visitors, and members of the public — whose health or safety may be put at risk by work carried out as part of Together Two's operations.
When Together Two workers deliver supports in a participant's home, there may be multiple PCBUs with concurrent duties. Together Two consults, cooperates, and coordinates with participants (or their nominees) to manage WHS risks in the home environment, using the SafeWork NSW Home Safety Checklist and Home Safety Risk Assessment tools where appropriate.
→ Support Provision Policy; Support Provision Operational Procedure.
Each officer of Together Two (Board directors and CEO) has a duty under section 27 of the WHS Act to exercise due diligence to ensure the PCBU complies with its duties. Due diligence requires each officer to:
Acquire and keep up-to-date knowledge of WHS matters.
Understand the nature of the operations and the hazards and risks associated with those operations.
Ensure the PCBU has appropriate resources and processes to eliminate or minimise risks.
Ensure the PCBU has appropriate processes for receiving and considering information about incidents, hazards, and risks, and for responding in a timely way.
Ensure the PCBU has and implements processes for complying with its duties and obligations under WHS laws.
Verify the provision and use of the resources and processes referred to above.
The Board receives WHS reports as part of the standing governance agenda, including incident trends, workers compensation data, WHS Committee minutes, and WHS audit findings. The SafeWork NSW 2025–26 Regulatory Statement has confirmed that executive decision-makers will be held accountable for WHS breaches, particularly in psychosocial risk areas.
→ Strategic Planning Policy; Board Skills Matrix.
Every worker must:
Take reasonable care for their own health and safety.
Take reasonable care that their acts or omissions do not adversely affect the health and safety of other persons.
Comply, so far as the worker is reasonably able, with any reasonable instruction given by Together Two to allow compliance with the WHS Act.
Cooperate with any reasonable policy or procedure of Together Two relating to health and safety that has been notified to workers.
Workers must report hazards, incidents, near-misses, and unsafe conditions to their Senior Support Lead (SSL) or the WHS Committee immediately. Workers must not intentionally or recklessly interfere with or misuse anything provided in the interests of health, safety, or welfare.
Together Two maintains a WHS Committee chaired by Marco De Angelis (WHS Officer). The WHS Committee:
Meets quarterly (or more frequently if required by circumstances).
Includes worker representatives from across service streams and management representatives with authority to make decisions.
Facilitates cooperation between Together Two and workers in developing and carrying out measures to ensure workers' health, safety, and welfare.
Assists in developing WHS standards, rules, and procedures.
Reviews WHS incident data, workers compensation trends, hazard reports, and the effectiveness of controls.
Makes recommendations to the CEO and SLT on WHS matters.
Reviews the results of WHS inspections and audits.
Minutes of WHS Committee meetings are maintained and made available to workers.
Together Two consults with workers who carry out work and who are, or are likely to be, directly affected by a WHS matter. Consultation occurs when:
Identifying hazards and assessing risks.
Making decisions about ways to eliminate or minimise risks.
Making decisions about the adequacy of facilities for the welfare of workers.
Proposing changes that may affect the health or safety of workers.
Making decisions about procedures for consulting with workers, resolving WHS issues, monitoring workers' health, or providing information and training.
Consultation is meaningful: workers are given relevant information, a reasonable opportunity to express their views, and their views are considered. Workers are advised of the outcome of the consultation in a timely manner.
If workers request the election of Health and Safety Representatives (HSRs), Together Two will facilitate the formation of work groups and the election of HSRs in accordance with Part 5 of the WHS Act. Elected HSRs are entitled to approved training (5-day initial course, 1-day annual refresher) at Together Two's cost and are supported to exercise their powers and functions without disadvantage.
→ Bullying, Harassment and Discrimination Policy (psychosocial hazards consultation).
Together Two identifies hazards through:
Workplace inspections at all service delivery sites (scheduled and unscheduled).
Worker consultation and hazard reporting.
Incident and near-miss investigation.
Review of workers compensation claims and injury data.
WHS Committee review of hazard reports and trends.
Site-specific risk assessments for all 15+ service delivery locations.
Participant-specific risk assessments (including home environment assessments for in-home support).
Risks are assessed using the 5×5 risk matrix documented in the Risk Management Policy. Controls are implemented using the hierarchy of controls mandated by section 36 of the WHS Regulation 2025:
| Level | Control | Example |
|---|---|---|
| 1 | Elimination | Remove the hazard entirely (e.g. cease a task, remove a substance) |
| 2 | Substitution | Replace with something less hazardous (e.g. non-toxic cleaning products) |
| 3 | Isolation | Separate persons from the hazard (e.g. barriers, locked storage) |
| 4 | Engineering controls | Modify the work environment or equipment (e.g. hoists, anti-fatigue mats, adjustable desks) |
| 5 | Administrative controls | Safe work procedures, training, job rotation, supervision, signage |
| 6 | PPE | Personal protective equipment as last resort (e.g. gloves, masks, eye protection) |
Higher-order controls (levels 1–4) are always preferred. Administrative controls and PPE alone are not sufficient. The WHS Regulation 2025 requires this hierarchy to be applied to psychosocial risks, not just physical hazards.
→ Risk Management Policy; Risk Register (Form 01).
Together Two recognises the following psychosocial hazards as significant risks in disability support work:
Occupational violence and aggression from participants with complex behaviours (SIL, in-home, ZigZag).
High and sustained emotional demands, particularly in SIL and SSRC.
Exposure to traumatic events (incidents involving participants, deaths, critical illness).
Remote or isolated work (lone workers providing in-home support).
Low job control and high job demand during peak periods.
Conflict or poor workplace relationships.
Role ambiguity, particularly for casual and relief workers.
Bullying, harassment, and sexual harassment (addressed in the Bullying, Harassment and Discrimination Policy).
Psychosocial risks are managed using the hierarchy of controls as required by section 55C of the WHS Regulation 2025 and the Managing Psychosocial Hazards at Work Code of Practice (2021). Higher-order controls (work design, staffing levels, rostering practices, supervision structures, environmental modifications) are implemented before relying on administrative controls (training, EAP) or individual-level responses.
The WHS Committee monitors psychosocial hazard reports and workers compensation claims for psychological injury and reports trends to the CEO and Board.
→ Bullying, Harassment and Discrimination Policy; Human Resources Policy; Positive Behaviour Support Policy.
Manual handling is one of the most common causes of injury in the disability sector. Together Two workers regularly assist with transfers, repositioning, personal care, and mobility support. Manual handling risks are managed by:
Participant-specific manual handling assessments documented in support plans.
Provision and maintenance of mechanical aids (hoists, slide sheets, standing frames, shower chairs).
Worker training in safe manual handling techniques, including participant-specific techniques.
Two-worker assists where the participant's support plan requires it.
Environmental modifications (grab rails, non-slip flooring, adjustable beds).
Competency assessment by Wence Buenacosa (RN) for high-intensity manual handling tasks.
Workers delivering supports to participants with complex behaviours face the risk of physical violence, verbal aggression, and threatening behaviour. Together Two manages this risk through:
Positive behaviour support plans (BSPs) developed by approved PBS practitioners (Steven Lowrie, Aisling Scully) that include worker safety strategies.
Client-specific inductions that include de-escalation techniques and individual communication methods.
Staffing ratios (1:1, 2:1, 3:1) that reflect the assessed risk level.
Incident reporting and investigation of all occupational violence events.
Post-incident support for affected workers, including access to the Employee Assistance Program and debriefing.
Risk #13 and Risk #18 in the Risk Register document real events where worker safety was compromised by participant behaviour.
→ Positive Behaviour Support Policy; Incident Management Policy.
Workers providing in-home support often work alone in a participant's home. Lone worker risks are managed through:
Lone worker risk assessments for each participant receiving in-home support.
Check-in protocols at the start and end of each shift.
On-call system available 24/7 for escalation.
Mobile phone access for all lone workers.
GPS-enabled rostering through PayCat (being implemented).
Client-specific risk assessments that identify participants where lone working is not safe (two-worker assists required).
Infection risks are present across all service delivery settings, particularly SIL dwellings, in-home support, and community nursing. Infection prevention and control measures are documented in the Infection Control Policy and include standard precautions, PPE, cleaning protocols, outbreak response, and worker training.
→ Infection Control Policy; Pandemic Management Policy.
Cleaning products and chemicals are used in SIL dwellings and program venues. Together Two maintains Safety Data Sheets (SDS) for all hazardous chemicals, stores chemicals safely, trains workers in safe use and emergency response, and provides appropriate PPE. The Hazardous Chemicals Code of Practice applies.
All electrical equipment at Together Two sites is tested and tagged in accordance with AS/NZS 3760. Hoists, beds, wheelchairs, and other plant are maintained and inspected regularly. Workers report faulty equipment immediately and do not use equipment that appears damaged or unsafe.
Environmental hazards (wet floors, uneven surfaces, poor lighting, cluttered walkways) are identified through workplace inspections and site-specific risk assessments. Controls include housekeeping standards, adequate lighting, non-slip surfaces, signage, and immediate clean-up of spills.
Together Two must notify SafeWork NSW immediately (by phone on 13 10 50) of any notifiable incident:
The death of a person.
A serious injury or illness of a person (including injuries requiring immediate treatment as an in-patient in hospital, immediate treatment for amputation, serious head injury, serious eye injury, serious burn, spinal injury, loss of bodily function, or serious lacerations).
A dangerous incident (including an uncontrolled escape, spill, or leak of a substance, an uncontrolled implosion, explosion or fire, an uncontrolled escape of gas or steam, or electric shock).
| Step | Action | Responsible | Timeframe |
|---|---|---|---|
| 1 | Provide first aid; make the area safe | Worker on scene | Immediately |
| 2 | Notify SSL and on-call manager | Worker | Immediately |
| 3 | Notify SafeWork NSW (13 10 50) | CEO or Marco De Angelis (WHS Officer) | Immediately on becoming aware |
| 4 | Preserve the incident site | SSL / Manager | Until released by SafeWork NSW inspector |
| 5 | Notify insurer (icare) | Ayrat Akhmetshin | Within 48 hours |
| 6 | Complete NDIS Commission notification if also a reportable incident | Steven Lowrie (CEO) | Within 24 hours (initial) / 5 business days (final) |
| 7 | Investigate the incident | As per Incident Management Policy | Within timeframes specified |
The incident site must not be disturbed until an inspector arrives or directs otherwise, except to protect the health and safety of a person, to provide first aid, or to make the site safe. Failure to notify SafeWork NSW of a notifiable incident attracts a penalty of up to $50,000 for a body corporate and $12,500 for an individual (WHS Regulation 2025 increased penalties).
→ Incident Management Policy; Business Insurance Policy.
Together Two is committed to supporting injured workers to return to work safely and as soon as medically appropriate. The injury management process includes:
Immediate first aid and medical treatment.
Workers compensation claim lodgement through icare (within 48 hours of becoming aware of the injury).
Development of a return-to-work plan in consultation with the worker, their treating medical practitioner, and the insurer.
Provision of suitable duties where the worker is certified for modified work.
Ongoing monitoring and review of the return-to-work plan.
CI-012 in the Continuous Improvement Register documents a real return-to-work event (worker fell off toilet while assisting a participant; returned to work after several weeks on suitable duties).
→ Business Insurance Policy; Human Resources Policy.
All workers receive WHS training as part of organisational induction, covering:
WHS rights and responsibilities (PCBU, worker, officer duties).
Hazard identification and reporting.
Incident and near-miss reporting.
Emergency procedures (evacuation, fire, first aid).
Manual handling (generic and participant-specific).
Infection prevention and control.
Psychosocial hazard awareness (occupational violence, de-escalation, lone worker safety).
PPE selection and use.
Specialist WHS training is provided for workers in specific roles:
| Training | Who | Frequency |
|---|---|---|
| First Aid (HLTAID011) | Minimum one first aider per site/shift | Every 3 years |
| CPR (HLTAID009) | All SIL workers, all SSLs | Annually |
| Manual handling — participant specific | All workers providing personal care or transfers | At induction + when support plan changes |
| Fire Warden | Designated wardens per site | Every 2 years |
| Working at heights (if applicable) | Maintenance workers | As required |
| Infection control | All workers | At induction + annual refresher |
| Psychosocial hazard awareness | All workers | At induction + annual refresher |
| WHS for Officers | Board directors, CEO | At appointment + annually |
Training is recorded in the Skill and Competency Matrix and audited through the Internal Audit Program (IA-003).
→ Human Resources Policy; Skill and Competency Matrix; Internal Audit Schedule and CI Register.
Regular workplace inspections are conducted at all service delivery sites:
| Site Type | Frequency | Conducted By |
|---|---|---|
| SIL dwellings | Monthly | SSL (Rodney Martin, Stella Bateman) |
| ZigZag day program | Monthly | SSL (Marvin Hazim) |
| Main office (754 Darling St) | Quarterly | Ayrat Akhmetshin |
| SLES / employment sites | Prior to placement + quarterly | SSL (Sian Cavanagh) |
| In-home support locations | At commencement + annually | Relevant SSL |
| Audit sample sites (Rodd Point, Tempe, Hurlstone Park) | Current risk assessments maintained | Relevant SSL |
Inspection findings are recorded, actioned, and reviewed by the WHS Committee.
WHS compliance is included in the Internal Audit Program. Internal audits assess the effectiveness of the WHS management system, compliance with legislation and Codes of Practice, and the implementation of controls documented in the Risk Register.
→ Continuous Improvement Policy; Internal Audit Schedule and CI Register; Maintenance, Records and Audit Policy.
Together Two maintains the following WHS records:
Injury register (all workplace injuries and illnesses).
Hazard reports.
Incident investigation reports.
Workers compensation claims records.
WHS inspection reports.
WHS Committee meeting minutes.
Training records (in Skill and Competency Matrix).
Site-specific risk assessments.
Safety Data Sheets (hazardous chemicals register).
Equipment maintenance and testing records.
First aid kit inspection records.
WHS records relating to injuries and illness are retained for 30 years in accordance with the WHS Regulation 2025.
→ Staff Records Policy; Maintenance, Records and Audit Policy.
SafeWork NSW has identified the health care and social assistance sector (including disability services) as a priority sector for 2025–26. Key enforcement focus areas include:
Psychosocial hazards, including sexual harassment and workplace violence.
Consultation with workers, particularly frontline staff and HSRs.
Officer due diligence, with executive decision-makers held accountable for WHS breaches.
Manual handling and musculoskeletal disorders (the most common cause of workers compensation claims in the sector).
Together Two addresses these priorities through the WHS Committee, psychosocial hazard controls documented in this policy and the Bullying, Harassment and Discrimination Policy, manual handling training and equipment, and Board-level WHS reporting.
Information sharing between SafeWork NSW and the NDIS Quality and Safeguards Commission has been facilitated by an amendment to the WHS Regulation 2025 (clause 702), which now includes the NDIS Act 2013. This means SafeWork NSW and the NDIS Commission can share investigation and compliance information about Together Two's operations.
| Quality Indicator | How Together Two Demonstrates This | Evidence |
|---|---|---|
| Workers competent and supported to provide person-centred support in a safe environment | WHS management system; hazard identification and control; training; supervision; WHS Committee; psychosocial hazard management | This policy; WHS Committee minutes; training records; inspection reports; Risk Register |
| Workers with emergency/disaster response capabilities identified | Emergency response workers identified in Skill and Competency Matrix; first aiders and fire wardens per site | Skill and Competency Matrix; Emergency and Disaster Management Policy |
| Infection prevention and control training undertaken by all workers | All workers receive infection control training at induction and annual refresher | Training records; Infection Control Policy |
| Worker contact details and secondary employment recorded | Contact details and secondary employment maintained in PayCat and personnel files | Staff Records Policy; Human Resources Policy (secondary employment disclosure) |
Owns this policy. Chairs the WHS Committee. Leads site safety response and workplace inspections. Coordinates with SafeWork NSW for notifiable incidents and inspector visits. Manages WHS risk across community programs, SLES, and Good in the Hood. Monitors psychosocial hazards through workplace culture assessments, worker feedback, and WHS inspections. Reports WHS performance to the CEO and Board.
Designs, reviews, and maintains the WHS management system framework. Ensures this policy reflects current legislation (WHS Act, WHS Regulation 2025, Codes of Practice). Advises on WHS-related employment matters including workers compensation, return to work, and disciplinary processes involving WHS breaches. Ensures WHS training requirements are reflected in the Skill and Competency Matrix.
Maintains the injury register and WHS records. Lodges icare workers compensation notifications within 48 hours. Coordinates equipment testing and tagging, first aid kit inspections, and SDS registers. Produces WHS data reports for the CEO, WHS Committee, and Board.
Aisling Scully (Head of NDIS Services): Ensures WHS compliance across SIL, in-home, ZigZag, and support coordination. Ensures BSPs include worker safety strategies. Oversees client-specific risk assessments and manual handling assessments.
Rei Guzman (Head of Aged Care and Clinical Services): Ensures clinical WHS compliance including sharps safety, infection control, and manual handling for high intensity supports. Wence Buenacosa (RN) conducts manual handling competency assessments for workers delivering high intensity supports.
Marco De Angelis (Head of Community and Enterprise): In addition to the Policy Owner responsibilities above, ensures WHS for SLES placements, community access, Good in the Hood volunteer activities, and transport.
SSLs are the front line of WHS. They conduct workplace inspections, investigate incidents and hazards in their stream, ensure workers have and use appropriate equipment and PPE, and escalate unresolved WHS issues to their Head of Department or the WHS Committee.
Approves this policy. Holds ultimate accountability for WHS compliance. Exercises officer due diligence. Notifies SafeWork NSW of notifiable incidents (or delegates to Marco De Angelis). Reports WHS performance to the Board. Ensures the WHS management system is resourced.
Receives WHS reports as part of the standing governance agenda. Exercises officer due diligence. Ensures the WHS management system is proportionate to the size, scale, scope, and complexity of Together Two's operations. Monitors the effectiveness of WHS controls and the organisation's response to regulatory changes.
Failure by a worker to comply with this policy, WHS legislation, or reasonable WHS instructions may result in disciplinary action up to and including termination of employment. Serious breaches may also be reported to SafeWork NSW and the NDIS Commission.
Failure by Together Two to comply with WHS obligations may result in enforcement action by SafeWork NSW, including improvement notices, prohibition notices, infringement notices, enforceable undertakings, and prosecution. Maximum penalties under the WHS Act include $3,463,500 for a body corporate (Category 1 offence) and $693,750 for an individual officer (Category 1 offence).
| Together Two Document | Relevance |
|---|---|
| Risk Management Policy | Risk framework; WHS risks in Risk Register |
| Risk Register (Form 01) | WHS risk domain; occupational violence, manual handling, psychosocial risks |
| Incident Management Policy | WHS incident reporting; SafeWork NSW notifiable incidents |
| Bullying, Harassment and Discrimination Policy | Psychosocial hazards; WHS Committee role |
| Business Continuity Policy | WHS during emergencies; SafeWork NSW communication |
| Emergency and Disaster Management Policy | Emergency response; evacuation; fire safety |
| Infection Control Policy | Infection prevention and control measures |
| Pandemic Management Policy | Pandemic-specific WHS measures |
| Human Resources Policy | WHS induction; training; secondary employment; fatigue management |
| Worker Screening Policy | WHS-related screening requirements |
| Staff Records Policy | WHS record retention (30 years) |
| Business Insurance Policy | Workers compensation; public liability |
| Waste Management Policy | Clinical and hazardous waste disposal |
| Transport Policy | Vehicle safety; driver requirements |
| Skill and Competency Matrix | WHS training records; competency tracking |
| Internal Audit Schedule and CI Register | WHS audit program; corrective actions |
| Delegation of Authority (Form 28) | WHS escalation authorities |
| Business and Operational Plan 2025–2028 | WHS strategic context |
| Version | Date | Author | Change Description |
|---|---|---|---|
| 1.0 | May 2023 | Emma Pollard (Centro Assist) | Initial version. Generic WHS risk management section within Risk Management Policy. No standalone WHS policy. No psychosocial hazards. No NDIS-specific content. No named responsibilities. |
| 2.0 | March 2026 | Marco De Angelis, WHS Officer (approved by Steven Lowrie, CEO) | Complete standalone WHS policy. Comprehensive coverage of WHS Act 2011 (NSW) and WHS Regulation 2025 including new psychosocial hazard controls (ss 55C, 55D), hierarchy of controls, and section 26A Code of Practice compliance duty. PCBU duties, officer due diligence, and worker duties documented. WHS Committee structure with Marco De Angelis as Chair. Consultation framework including HSR provisions. Nine key hazard categories specific to Together Two operations (psychosocial, manual handling, occupational violence, lone worker, infection, chemicals, electrical, slips/trips/falls). Notifiable incident process with updated penalties ($12,500 individual, $50,000 body corporate). Injury management and return to work framework referencing real event (CI-012). WHS inspection schedule by site type with named SSLs. SafeWork NSW 2025–26 regulatory priorities addressed. NDIS Quality Indicators mapped. Named SLT and SSL responsibilities. Cross-referenced to all companion governance documents. |