For the WHS+ consultation and audit programme, the competent person conducting the gap analysis (Phase 1), which includes reviewing the MCHP or HCP implementation, may be from the same entity as the competent person developing and implementing the action plan (Phase 2), which includes advising the risk controls and implementation.
However, the auditor engaged to audit the completion (Phase 3) of the first 2 phases, must not be the same person who assisted the company to complete Phase 1 and Phase 2.