Method Statement (Non-Construction)

What Is a Method Statement (Non-Construction)?

A Method Statement is a document that outlines how a specific task will be carried out safely. In the context of non-construction industries, this document serves as a practical plan for managing risks and ensuring work is done systematically. While the construction industry often uses this term for high-risk building activities, other sectors such as manufacturing, cleaning, landscaping, and events management rely on it just as heavily.

In Australia, this document is frequently referred to as a Safe Work Procedure (SWP) or Standard Operating Procedure (SOP). Regardless of the name, the purpose remains the same. It details the exact steps a worker needs to take to complete a job without injuring themselves or others. It acts as a blueprint for safety, aligning with the legal duty to provide a safe working environment.

Think of it as a recipe for safety. It lists the ingredients (tools and equipment), the preparation (hazards and controls), and the method (step-by-step instructions). For a business owner, it is evidence that you have thought through the risks and trained your staff to handle them. For a worker, it is a clear guide on what to do and what to avoid.

When to Use This Document

You should use a Method Statement whenever a task involves specific risks that are not covered by general everyday rules. It is not necessary for routine, low-risk office work like filing paperwork or making a coffee. However, it becomes essential when the work environment changes or when complex tasks are introduced.

Common scenarios for non-construction use include:

• Manufacturing and Maintenance: Repairing heavy machinery, servicing electrical panels, or using hazardous chemicals.
• Trades Services: Arborists cutting down trees near powerlines, plumbers working in confined spaces, or electricians installing switchboards.
• Events and Entertainment: Setting up temporary stages, working with pyrotechnics, or managing crowd control barriers.
• Cleaning Services: Using industrial-strength cleaning agents in enclosed areas or working at heights for window cleaning.
• IT and Telecommunications: Installing cabling in ceiling spaces or server rooms with active electrical equipment.

Service industries often provide these documents to clients as part of a tender process. A commercial cleaning company, for example, might need to submit a Method Statement to a property manager to prove they can clean the premises safely and legally. This demonstrates professionalism and confirms that the business has appropriate insurances and safety protocols in place before starting work.

Key Sections and Required Elements

A useful Method Statement does more than just list safety rules. It must be detailed enough to guide a worker through the entire process. To be effective, it needs specific sections that address the scope, the risks, and the response plan.

Section 1: Scope and Description of Work

This section sets the boundaries of the task. It prevents "scope creep" where additional tasks are added without proper planning. You should clearly define the location, the equipment being used, and the exact nature of the service. For example, instead of writing "Fix the air conditioner," you should write "Maintenance of HVAC Unit at Client X, including filter replacement and electrical inspection." SafeWork NSW guidelines require the specific activity to be clearly described to ensure the correct controls are applied.

Section 2: Hazard Identification and Risk Assessment

This is the core of the document. You must identify what could go wrong. This section typically uses a table to list potential hazards such as chemical exposure, manual handling, or electrical shock. You need to assess the risk rating by looking at the likelihood and consequence of the hazard occurring. You record the risk level before applying controls and the reduced risk level after. This process complies with Regulation 39 of the WHS Regulations, which mandates a formal risk assessment for high-risk activities.

Section 3: Control Measures (The "Method")

Here you outline the step-by-step safe execution of the task. You must apply the Hierarchy of Controls. The best control is elimination, followed by substitution, isolation, and engineering controls. Administrative controls and PPE are the last line of defense. For example, if a task involves noise, the first step might be to buy a quieter machine (Substitution). If that is not possible, the next step is to set up a sound barrier (Isolation). You list these specific steps in the order they must be performed.

Section 4: Personal Protective Equipment (PPE)

This section specifies the protective gear workers must wear. It acts as the last line of defense if other controls fail. You must be specific about standards. Instead of just writing "Glasses," write "Safety Glasses AS/NZS 1337.6". Instead of "Boots," write "Steel-capped boots AS/NZS 2210.1". WHS Regulation 44 requires a Person Conducting a Business or Undertaking (PCBU) to provide suitable PPE to workers at no cost.

Section 5: Emergency Procedures

Even with the best planning, things can go wrong. This section ensures immediate action if the method fails or an incident occurs. It must include the location of the First Aid kit, the Emergency Assembly Point, and contact numbers for Site Supervisors and Emergency Services (000). WorkSafe Victoria compliance codes for emergency planning stress that workers must know exactly what to do when an alarm sounds or someone is injured.

How to Write a Method Statement (Non-Construction) (Step by Step)

Writing a Method Statement should be a collaborative process. It is not just a paperwork exercise for management. Follow these steps to create a document that is legally compliant and practically useful on the job.

Step 1: Consult with Your Workers

Before you write a single word, talk to the people who actually do the work. The WHS Act (Section 47-49) mandates consultation. Workers often spot hazards that managers miss. If you create a document without their input, it may be non-compliant and invalid during an audit. Ask them what makes the job difficult, what scares them, and how they think it could be done safer.

Step 2: Analyse the Task

Break the job down into small, manageable steps. Do not look at the job as one big task. Look at it as a sequence of movements. For example, if you are writing a method for packing a shipping container, the steps might include: checking the floor for debris, stacking the first pallet, securing the load, and closing the doors. This detailed analysis helps you identify hazards at every stage.

Step 3: Identify Hazards and Assess Risks

Go through each step and ask "What could go wrong here?" Look for physical hazards like slips and trips, chemical hazards like fumes, and ergonomic hazards like repetitive lifting. Refer to the Code of Practice: How to Manage Work Health and Safety Risks. This code is admissible in court and provides a solid framework for assessing the severity of risks.

Step 4: Select Control Measures

Using the Hierarchy of Controls, decide how you will eliminate or minimise the risks. Do not just rely on telling workers to "be careful." You need concrete changes. If a hazard involves working at height, can you do the work from the ground using a pole (Elimination)? If not, can you use a mobile scaffold (Engineering) instead of a ladder (Administrative)? Document these decisions clearly.

Step 5: Draft the Document

Write the document in plain English. Avoid complex jargon that might confuse a worker. Use bullet points and numbered lists for clarity. Start with the scope, then the PPE requirements, then the step-by-step method. Ensure the formatting is clean and easy to read. Many Australian businesses are now transitioning to digital platforms for this step to allow for photographic evidence of hazards and instant distribution to mobile devices.

Step 6: Review and Sign Off

Once drafted, take it back to the workers. Ask them to review it again to ensure it matches reality. A common practice in Australian industry is to have the employee sign the document to confirm they have read and understood it. This serves as a record of training. Ensure the date and version number are recorded so you can track updates.

Step 7: Implement and Monitor

Put the document into action. Watch the work being performed to see if the method is being followed. Sometimes a method looks good on paper but does not work in the real world. If this happens, revise the document. Australian Standards (AS/NZS 45001:2018) require that you review documented procedures whenever there are changes to the workplace or if the procedures are not effective.

Common Mistakes to Avoid

Many businesses make mistakes when creating these documents. These errors can lead to poor safety outcomes and legal trouble.

Using Generic or Copy-Paste Documents

One of the biggest mistakes is downloading a generic template from the internet and filling in the blanks without much thought. A generic document often fails to identify site-specific hazards. If you use a document that says "Wear safety glasses" but does not mention the specific chemical spill risks in your factory, it is not compliant. The document must reflect the actual work being done.

Failing to Consult with Workers

Management often writes these documents in an office without input from the floor. This is a violation of WHS laws regarding consultation. A Method Statement created without worker input is often unrealistic and ignored by staff. It also leaves you vulnerable during an audit or court case, as inspectors will ask workers if they were involved in the process.

Relying Solely on PPE

Some documents treat PPE as the first and only solution. This is lazy and unsafe. PPE is the lowest level of control. If your Method Statement simply says "Wear a harness" for working at heights, without considering how to prevent the fall in the first place, it is inadequate. You must show that you have tried to eliminate the risk before resorting to PPE.

Not Updating the Document

A Method Statement is a living document. It should be reviewed regularly or whenever the task changes. If you buy new machinery or change the layout of your warehouse, the old document may be dangerous. Keeping an outdated document on file is worse than having no document at all because it gives a false sense of security.

Ignoring Privacy Laws

If your document includes sign-off sheets with worker names or signatures, you must handle this information carefully. The Privacy Act 1988 requires businesses to protect personal information. Do not leave these sheets lying around on a site office table where unauthorised people can see them. Store them securely and follow Australian Privacy Principles regarding data retention.

Legal Considerations (AU)

Complying with Work Health and Safety (WHS) laws is not optional. As a business owner or operator, you have strict legal obligations. A Method Statement is your primary evidence that you are meeting these obligations.

The Primary Duty of Care

Under Section 19 of the WHS Act 2011 (Cth) and state equivalents, a PCBU must ensure, so far as is reasonably practicable, the health and safety of workers. This means you must do everything that is reasonably possible to manage risks. For non-construction tasks, a Method Statement is the proof that you have identified risks and implemented controls. Without it, regulators may assume you have not considered the risks at all.

Risk Management Regulations

WHS Regulation 2011 (Cth) and state equivalents (Regulation 39-51) require a PCBU to implement risk management measures. You must identify hazards, eliminate risks, and if elimination is not possible, minimise them. A Method Statement formally documents this process. It shows that you have followed the regulatory steps for complex tasks like manufacturing maintenance or laboratory work.

Disclaimers and Liability

You cannot use a disclaimer to escape your duty of care. A statement saying "This document does not cover all possible scenarios" is not a legal shield. If you fail to identify an obvious hazard, you are still liable. Disclaimers should frame the document as a "minimum standard" that adapts to site conditions, not a waiver of responsibility. Safe Work Australia explicitly states that a PCBU cannot contract out of its duty of care.

Victorian Differences

If you operate in Victoria, the law is slightly different. Victoria uses the Occupational Health and Safety Act 2004 and OHS Regulations 2017. They do not use the term "PCBU" but rather "Employer." However, the duty to provide and maintain a safe system of work (Section 21) is very similar. The requirement to have written procedures like Method Statements is triggered by the need for a safe system of work, just like in other states.

Australian Standards

While not always law, Australian Standards are often referenced in court to determine what constitutes "reasonably practicable." AS/NZS 45001:2018 covers Occupational Health and Safety Management Systems. Clause 8.1 requires documented procedures for situations where the absence of such procedures could lead to deviations from policy. Using this standard helps ensure your Method Statement meets industry benchmarks.

Frequently Asked Questions (preview)

Is a Method Statement legally required for all jobs?

No, it is not required for every single job. It is required for high-risk work or tasks where there are specific hazards that need to be managed. However, even for lower-risk tasks, having a written procedure is best practice and helps with training and consistency.

Can I use the same Method Statement for different clients?

You can use a template, but you must customise it for each site and task. Different sites have different hazards. A cleaning method for a small office will not work for a hospital or a factory. You need to adjust the scope and hazard identification to reflect the actual work environment.

How often should I update my Method Statements?

You should review them at least annually, or sooner if something changes. Changes include new equipment, new chemicals, an incident occurring, or if a worker points out a flaw in the current method. Regular reviews ensure the document remains accurate and useful.