Policy Consultation and review

This policy is under review and is seeking your consultation.  Please read and review the document and provide comments at the bottom.  Your comments will be acknowledged by the Policy committee and will be taken into review for any further changes.


Policy Number:  2.2.1

Effective From:  DRAFT

1. AIM


FLINTWOOD is committed to ensuring  Participants who exhibit behaviours of concern are supported that ensure a safe environment and recognition of the Participant’s rights and needs.





This policy applies to all employees supporting a Participant who may have behaviours of concern       




Restrictive Practice: is any intervention and/or practice that is used to restrict the rights or freedom of movement of a person with disability.


Seclusion: is the sole confinement of a person with disability in a room or physical space at any hour of the day or night and where voluntary exit is prevented.


The use of this practice as a punishment, for reasons of convenience or in response to resource limitations is strictly prohibited. FLINTWOOD does not practice seclusion under any circumstances.


Seclusion of children or young persons (less than 18 years of age) is a PROHIBITED Practice and not permissible under ANY circumstances.


Psychotropic Medication: Abbreviation meaning “when necessary” (from the Latin “pro re nata”, for an occasion that has arisen, as circumstances require, as needed). In regards to Restrictive Practices, it refers to any medication that affects:


  • Cognition
  • Mood
  • Levels of arousal
  • Behaviour


Chemical restraint: the use of medication or chemical substance for the primary purpose of controlling a Participant’s behaviour. Psychotropic Medication on a PRN basis must not be the primary behaviour support strategy. If used it must form part of a documented support plan that has been developed in conjunction with a consulting Psychiatrist. Consent is always required for the administration of psychotropic medication.


Physical Restraint: the use or action of physical force to prevent, restrict or subdue movement of a person’s body, or part of their body, for the primary purpose of controlling their behaviour. Physical restraint does not include physical assistance or support related to duty of care or in activities of daily living.


Restricted Access: The recommendation to use physical barriers such as locks or padlocks or to impose enforceable limits or boundaries within an environment beyond normally accepted community practices.

(e.g. keeping hazardous chemicals or cleaning products securely stored, keeping a wardrobe or front door locked) The limiting of any Participant’s access to items or experiences, with the intention of manipulating the particular behaviour or managing the risks associated with it.



RESPONSE COST: is withholding positively valued items or activities from a Participant in response to a particular behaviour or set of behaviours. For example, denying access to a computer game or TV program. Withheld items must not include:


  • Money
  • Personal possessions
  • Attendance at Day Placement
  • Access to employment
  • Access to family or a support person
  • Denial of food, shelter, comfort or access to toileting facilities.


A response cost strategy that is excessive or interferes with identified support needs, health or wellbeing of Participants is prohibited by FLINTWOOD.



Prohibited Practices: are those restricted practices that are not authorised. Some practices will never be authorised as they are considered abusive, unlawful or unethical. Some examples might be electric shock, verbal abuse, and physical punishment.


Duty of Care: refers to the circumstance where a risk to the Participant exists due to the Participant’s potential or predictable actions (e.g. a lack of road skills and impulsivity can predictably imply risk when around traffic) as well as unpredictable occurrences. Duty of Care therefore requires a planned response to manage the identified “risk” for a Participant’s potential or predictable actions.


Behaviours of concern(Challenging behaviour) is defined as ‘culturally abnormal behaviour(s) of such intensity, frequency or duration that the physical safety of the Participant or others is placed in serious jeopardy, or behaviour which is likely to seriously limit or deny access to the use of ordinary everyday community facilities.



FLINTWOOD continuously works towards the elimination and reduction of the use of restrictive practices within its services, however, FLINTWOOD recognises that from time to time Participants may be subjected to restrictive practices in response to risk of serious harm to themselves or others due to behaviours of concern. Any restrictive practice used at FLINTWOOD will meet best practice requirements, including:

  • being the least restrictive option
  • used for the least possible time
  • used as a last resort
  • used when necessary to prevent harm to the Participant or others
  • not using it as a punishment of the Participant
  • not used for employee convenience
  • recognising the benefits of the restricted practice must outweigh the possible negative effects of its use.


Restrictive practices will be reviewed regularly, and be part of a positive behaviour support plan that has been developed by an experienced and qualified person with sufficient expertise in the area of behaviour support and in consultation with the Participant, his / her family, an employee and or any other relevant party.    




5.1 A restrictive practice audit will periodically be completed at FLINTWOOD. The audit will aim to identify any restrictive practices used in service delivery.


5.2 Restrictive Practice use by employees will be reported using the on-line incident report form.


5.3 All identified restrictive practices will be put onto a Restrictive Practice Register that will be maintained by a FLINTWOOD General Manager.


5.4 A Restrictive Practices Panel will be convened, comprising  representatives from the Senior management team of FLINTWOOD together with an independent representative who is external to FLINTWOOD and a practicing Psychologist. This panel will be responsible for the monitoring, agreement or non-agreement for use / non use of restrictive practices, the relevant documentation and for the review of any restrictive practices used within FLINTWOOD.


5.5 The panel will assess the quality of any associated behaviour support plan, and recommend referral to FLINTWOOD when / where required. The focus of the panel will be to reduce or eliminate the use of restrictive practices within FLINTWOOD, and to protect the human rights of FLINTWOOD Participants.


5.6 Restricted practices will only be used as part of a comprehensive positive behaviour support plan developed by the appropriate, responsible


5.7 A Behaviour Support Plan will include the following:


  • a description of the behaviour
  • the identifying of triggers and setting events
  • identifying a replacement behaviour that will be developed in support of the Participant
  • listing the strategies to be used by employees if the Participant engages in behaviours of concern
  • listing the methods for reporting any incidents and for the debriefing of any employee involved in any such incidents
  • data collection strategies to ensure that information regarding behaviour is recorded on an ongoing basis


5.8 It is recognised that from time to time an incident may occur and the use of an unplanned restrictive practice may result (i.e. not detailed in a positive behaviour support plan), in response to any incident involving immediate risk of serious harm either to the Participant or another person action may be taken under the employee’s duty of care to the Participant, for self or another person.


5.9  Any employee who uses a restrictive practice that has not been previously placed on a behaviour support plan is required to report its use within 24 hours using FLINTWOOD’s on-line incident report form. This will include notification to their Service Manager. If the incident involving an unplanned restrictive practice meets the criteria for a critical incident as per the Disability Service Commission then a Critical Incident form must be completed within 24 hours and forwarded to the NSW Ombudsman.


5.10  Service Managers will apply to the Restrictive Practice Panel for agreement to use a restrictive practice on any Participant. The panel will consider the application, along with the appropriate supporting documentation and will decide through consensus if the restrictive practice can be agreed for use on an interim or permanent basis, or if not agreeing with its use.


5.11  Any restrictive practice agreed for use on a permanent or interim basis will be reviewed at least every twelve months by the restrictive practice panel. Any restrictive practice not used for at least twelve months will be automatically considered eliminated from use. This is to guard against practices being on the register where evidence demonstrates that it is not in use.


5.12  The Restrictive Practice Panel has the final authority to agree the use of a restrictive practice at FLINTWOOD (except 5.13). The responsibility for consenting to a restrictive practice lies with the Participant or an authorised alternative decision maker – person responsible, a legally appointed guardian.


5.13  The CEO may overrule the Restrictive Practice Panel or approve a Restrictive Practice at any given time.


5.14  Some practices will be considered prohibited and will never be approved. These include any practice considered to be unlawful, unethical or abusive.





  • All employees must be aware of and comply with this policy.
  • Report any forms of suspected abuse to the Service Manager / General Manager
  • Complete an Incident Report form for any form of restrictive practice
  • Collect data accordingly


Service Manager

  • Must be aware of and comply with this policy.
  • Must comply to all restrictive practices at the site
  • Complete a Submission for Restrictive Practice form as and when needed
  • Review data on restrictive Practices on a regular basis to try and phase out the restrictive practice
  • Report any forms of suspected abuse to the General Manager / CEO
  • Ensure the employee reporting completes an on-line Incident Report Form for any restrictive practice used
  • Ensure an Individual Risk Profile is completed for every Participant inclusive of restrictive practices
  • Will conduct ‘Restrictive Practice’ training with all employees on an annual basis


General Manager

  • Must be aware of and comply with this policy
  • Be aware of all restrictive practices used at all sites he / she is responsible for
  • Report any forms of suspected abuse to the CEO


Human Resources Manager

  • Offer EAP to employees as needed



  • Must be aware of and ensure compliance with this policy.
  • Be aware of the restrictive practices used within FLINTWOOD
  • Be informed as to the approval of any restrictive practice

Changes Required:

  • Date Format: MM slash DD slash YYYY

Flintwood disability services…your disability does not have to define you.