WHS Management Plan
A WHS Management Plan is a document outlining how an Australian business identifies and manages safety risks to comply with the Work Health and Safety Act 2011.
A practical document that outlines how a business manages workplace health and safety risks to meet legal obligations.
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About this Document
A WHS Management Plan is a structured document that outlines how a business identifies, assesses and controls risks to health and safety in the workplace. It is the central tool for meeting your duties under the Work Health and Safety Act 2011. This plan is not just a form you fill out to keep in a drawer. It is a living document that guides your daily operations and keeps your workers and the public safe. If you run a business in Australia, you have a legal duty to ensure the health and safety of your workers. This duty is known as the primary duty of care. A WHS Management Plan helps you prove you are taking active steps to meet this duty.
In Australia, each state and territory has its own WHS Act. These laws are largely harmonised, meaning they share the same core principles. The federal Work Health and Safety Act 2011 applies in the Commonwealth, states like New South Wales, Queensland, South Australia, Tasmania and the territories. Victoria and Western Australia have their own Acts that mirror the harmonised laws closely. Regardless of where you work, the requirements are similar. You must manage risks. You must consult with workers. You must provide training and supervision. You must maintain a safe workplace. The WHS Management Plan is the framework you use to do all these things.
When do you need a WHS Management Plan? You need one if you are a Person Conducting a Business or Undertaking. This includes sole traders, self employed people, contractors and companies. If you employ people, you definitely need a plan. Even if you do not employ staff, you need to consider your own safety and the safety of others who might be affected by your work. For construction projects, the law is stricter. If you are a principal contractor for a construction project where the cost of work is $250,000 or more, you must prepare a written WHS Management Plan before work starts on site. This is a specific legal requirement in the WHS Regulations.
The first step in creating a WHS Management Plan is to identify the hazards in your workplace. A hazard is anything that could cause harm. This could be physical hazards like noise, heights or electricity. It could be chemical hazards like asbestos or cleaning solvents. It could be biological hazards like bacteria or viruses. It could be psychosocial hazards like stress or bullying. You must look at your workplace and list everything that might cause injury or illness. You should walk around the site, talk to your workers and review previous incident records.
Once you have identified the hazards, you must assess the risks. A risk is the likelihood that a hazard will cause harm and the severity of that harm. You do not need complex calculations for this. You can use a simple risk matrix. Think about how likely it is that something will go wrong. Think about how bad the consequences would be. A fall from a roof is very likely to cause death, so it is a high risk. A papercut is minor and rare, so it is a low risk. This assessment helps you decide where to focus your efforts.
The next step is to control the risks. The WHS Regulations tell you to use the hierarchy of control. This is a list of control measures ranked from most effective to least effective. You must try to eliminate the risk first. If you cannot eliminate it, you must minimise it. The order is substitution, isolation, engineering controls, administrative controls and Personal Protective Equipment. Elimination means removing the hazard completely. Substitution means replacing a hazard with something safer. Isolation means keeping people away from the hazard. Engineering controls use physical changes to the workplace. Administrative controls change the way people work. PPE is equipment worn by people to protect them. You should always aim for the highest level of protection reasonably practicable.
The concept of reasonably practicable is central to Australian WHS law. It means you must do everything that you are reasonably able to do to ensure health and safety. You consider the likelihood of the hazard, the degree of harm, what you know about the risk, and the ways to eliminate or minimise the risk. You also consider the cost of the measures. If a control measure is very expensive compared to the risk, you might not be required to use it. But you cannot use cost as an excuse if the measure is standard industry practice. Courts will look at what a reasonable person in your position would have done.
Your WHS Management Plan must detail how you consult with workers. Consultation is a legal requirement. You must talk to your workers about health and safety matters that affect them. This includes consulting when identifying hazards, making decisions about control measures and proposing changes to the workplace. You can consult directly or through health and safety representatives. You must share relevant information with workers and give them a reasonable opportunity to express their views. You must take their views into account. Consulting is not just telling people what to do. It is listening to them and valuing their input.
The plan must also cover training and supervision. You must provide workers with the information, training and instruction they need to do their job safely. You must keep records of this training. If a worker is new to the job or using new equipment, you must ensure they are competent. You must also provide adequate supervision. The level of supervision depends on the risks involved and the experience of the workers. High risk work like scaffolding or asbestos removal requires strict supervision.
You must have procedures for reporting and managing incidents. An incident is any unplanned event that results in, or could have resulted in, injury or illness. This includes near misses. Workers need to know how to report an incident and who to report it to. You need a system to investigate incidents to find out why they happened and how to prevent them from happening again. Serious incidents must be reported to the WHS regulator. These are called notifiable incidents. They include deaths, serious injuries or illnesses and dangerous incidents that expose a person to a serious risk. You must report these immediately, usually by phone, and follow up with a written report within 48 hours.
Emergency procedures are another vital part of the plan. You need to plan for what you will do in an emergency. This could be a fire, a medical emergency, a chemical spill or a severe weather event. You must have first aid kits and trained first aiders. You must have evacuation routes and assembly points. You must test your emergency procedures regularly. Drills are a good way to do this.
Keeping records is essential. Safe Work Australia and the WHS regulators require you to keep certain records. You must keep records of risk assessments, control measures, training, consultations and incidents. You must keep inspection reports for plant and equipment. If a worker is injured, you must keep records of the injury and your return to work program. These records prove you are complying with the law. They also help you review your performance and improve your safety systems.
A common mistake is to copy a plan from another business or download a generic template and fill in the blanks without thinking. A generic plan will not address the specific risks of your workplace. It might miss critical hazards. Another mistake is to write the plan and then ignore it. The plan must be put into action. You must communicate it to your workers. You must enforce the rules. You must review and update the plan regularly, especially if something changes in the workplace. A change in equipment, a change in location or a new type of work can create new risks.
Small businesses and tradespeople often think they do not need a formal plan because they are small. This is dangerous. Small businesses often have the highest rates of injury. Lack of time and resources is not a valid defence in court. A simple, practical plan is better than a complex, unused one. You can write a plan for a small trade business on a few pages. The key is to make it relevant and use it every day.
You should also consider the requirements for subcontractors. If you hire subcontractors, you must ensure they are safe. You must exchange information about risks and control measures. You must coordinate your activities so you do not create risks for each other. This is a shared duty under the Act. Your WHS Management Plan should set out how you manage your supply chain and ensure your subcontractors meet your safety standards.
The Fair Work Act 2009 also intersects with WHS. Under this Act, employees have a right to a safe workplace. If an employer takes adverse action against an employee for raising a WHS issue, it is a breach of the Fair Work Act. This includes dismissing an employee, injuring them in their employment or altering their position to their detriment. This means you cannot fire someone because they complained about safety. This reinforces the importance of consultation and a positive safety culture.
The Australian Taxation Office (ATO) and ASIC do not regulate WHS directly, but they have an interest in your business. If you have a serious incident and are prosecuted, the fines can be significant. In some cases, directors can be personally liable. Insolvency can result from large fines and legal costs. This highlights that WHS is not just a safety issue, it is a business risk issue.
Relevant standards also play a role. Standards Australia produces codes and standards. While these are not laws, they can be used as evidence in court to show what is reasonably practicable. For example, AS/NZS 4801 is the standard for occupational health and safety management systems. Following these standards helps you meet your legal duties. Safe Work Australia produces Model Codes of Practice. These provide practical guidance on how to achieve the standards of the WHS laws. Regulators use these codes as evidence in court. You should follow the codes of practice relevant to your industry.
To complete a WHS Management Plan, start with a policy statement. This is a signed commitment from the business owner or director. It states that safety is a priority and sets the goals for the business. Then list the responsibilities. Who is responsible for safety? Everyone is responsible. But you need to name specific people for specific tasks like risk assessments, training and incident reporting. Then describe the risk management process you use. List the hazards, the assessments and the controls. Then detail the consultation arrangements, the training procedures, the incident reporting system and the emergency plan.
Make the document accessible. Put it on your phone or tablet if you work on site. Have a physical copy in the office or site shed. Refer to it in toolbox talks. Use it as a training tool for new workers. Review it at least once a year. Do not wait for an accident to check if your plan is working.
In summary, a WHS Management Plan is a legal necessity and a practical tool for any Australian business. It protects your workers, protects you from prosecution and helps your business run smoothly. By following the steps of identifying hazards, assessing risks, implementing controls, consulting with workers and keeping records, you can build a strong safety culture. Do not view it as red tape. View it as an essential part of doing business in Australia.
Key Facts
- Principal contractors on construction projects over $250,000 must have a written WHS Management Plan.— Work Health and Safety Regulation 2011 (Cth)
- Businesses have a primary duty of care to ensure the health and safety of workers and others.— Work Health and Safety Act 2011 (Cth)
- PCBUs must consult with workers on matters affecting their health and safety.— Work Health and Safety Act 2011 (Cth)
- Notifiable incidents must be reported to the regulator immediately.— Safe Work Australia
- You must manage risks using the hierarchy of control.— Model Code of Practice: How to Manage Work Health and Safety Risks
Sources
Required Sections
WHS Policy Statement
The overarching commitment from management to safety.
Safety Policy Statement
We are committed to providing a safe and healthy workplace for all workers, contractors, visitors, and the public. As a responsible business operating in the Australian trade and construction sectors, we recognise that the safety of our people is paramount to our success. We will not compromise on safety. We believe that all injuries, incidents, and illnesses are preventable.
We will achieve this by complying with all relevant Work Health and Safety (WHS) obligations. This includes strict adherence to the Work Health and Safety Act 2011 (Cth) and the Work Health and Safety Regulations 2011 (Cth). We align our operations with the standards set by Safe Work Australia and relevant Codes of Practice. We take a proactive approach to identify and eliminate risks before work begins. If a risk cannot be eliminated, we will minimise it so far as is reasonably practicable.
Management is accountable for safety. We will provide and maintain a work environment without risks to health and safety. This includes the provision and maintenance of safe plant, structures, and systems of work. We will ensure the safe use, handling, and storage of plant, structures, and substances. We will provide adequate facilities for the welfare at work of all workers. We will provide the necessary information, training, instruction, and supervision to protect everyone from risks to their health and safety arising from work.
We expect all workers to take reasonable care for their own health and safety. We also require workers to ensure their actions or omissions do not adversely affect the health and safety of others. This includes the mandatory use of Personal Protective Equipment (PPE) provided. All workers must comply with any reasonable instruction and policies we give them.
We consult with our workers regularly. We value open communication regarding safety issues. We encourage workers to raise concerns, suggest improvements, and report hazards and near misses immediately without fear of reprisal. We will consult, co-operate, and co-ordinate activities with all other duty holders.
We are committed to the continuous improvement of our WHS performance. We will review this policy regularly to ensure it remains relevant and effective for our changing business needs.
Signed:
[Director Name]
Director
[Date]
Risk Management
The process of identifying, assessing and controlling hazards.
Risk Management Process
Risk management is the backbone of this WHS Management Plan. It is not just paperwork. It is a daily process to identify dangers and keep the crew safe. Under the Work Health and Safety Act 2011 (Cth) and corresponding state legislation, a Person Conducting a Business or Undertaking (PCBU) must eliminate risks so far as is reasonably practicable. If elimination is not possible, you must minimise the risks.
Start by identifying hazards. Walk the site before work starts. Look at the Safe Work Method Statements (SWMS) for high-risk construction work. Consider the environment, the tools, and the materials. Once you find a hazard, assess the risk. Think about how bad an injury could be and how likely it is to happen.
Use the hierarchy of controls to choose your safety measures. This standard ranks controls from most effective to least effective. Do not just rely on Personal Protective Equipment (PPE) straight away. PPE is the last line of defence.
Consult with your workers. They know the site and the risks better than anyone. Record your findings and review them regularly. If the site conditions change or someone gets hurt, revisit the risk assessment immediately.
Hazard and Risk Control Register
| Hazard | Description of Risk | Control Measures (Hierarchy of Control) |
|---|---|---|
| Working at heights (e.g., scaffolding, ladders, roofs) | Workers falling resulting in serious injury, fractures, or death. Objects falling onto workers below. | Elimination: Prefabricate structures on the ground to avoid working at height.<br>Substitution: Use mobile scaffolds or scissor lifts instead of ladders.<br>Engineering: Install edge protection, guard rails, and toe boards on open edges.<br>Administrative: Develop and display a SWMS. Train workers in height safety.<br>PPE: Wear harnesses with secure anchor points where fall prevention is not possible. |
| Hazardous substances (e.g., silica dust, solvents, paints) | Respiratory diseases, skin irritation, chemical burns, or long-term chronic illness. | Elimination: Remove the need for hazardous chemicals by using water-based alternatives.<br>Substitution: Use products with lower toxicity or non-silica based materials.<br>Engineering: Install exhaust ventilation, use dust extraction tools, or wet cutting methods.<br>Administrative: Store chemicals correctly. Provide Safety Data Sheets (SDS). Train workers on handling hazards.<br>PPE: Wear appropriate respirators (P2 or higher), gloves, and safety glasses. |
| Manual handling (e.g., lifting heavy materials, repetitive movements) | Musculoskeletal disorders, back injury, sprains, and strains. | Elimination: Automate the process with conveyor belts or palletisers.<br>Substitution: Replace heavy bags with smaller, lighter containers.<br>Engineering: Use trolleys, forklifts, cranes, or mechanical aids to move loads.<br>Administrative: Rotate tasks to reduce repetitive strain. Train in safe lifting techniques.<br>PPE: Wear back support belts where appropriate and safety boots with non-slip soles. |
| Electrical installations and temporary power | Electric shock, electrocution, or burns from live parts. Faulty equipment causing fires. | Elimination: Use cordless tools where possible.<br>Substitution: Use low voltage (extra low voltage) tools and lighting.<br>Engineering: Install Residual Current Devices (RCDs) or safety switches on switchboards.<br>Administrative: Tag and test all electrical equipment regularly. Keep a clearance zone around overhead powerlines.<br>PPE: Wear rubber insulating gloves and matting for testing. |
| Noise (e.g., cutting, grinding, heavy machinery) | Permanent hearing loss, tinnitus, and communication difficulties leading to other accidents. | Elimination: Remove the noisy process entirely (e.g., pre-cut materials off-site).<br>Substitution: Use quieter equipment or processes (e.g., electric instead of petrol power tools).<br>Engineering: Fit silencers to equipment, build sound barriers, or isolate the noise source.<br>Administrative: Rotate workers to limit time spent in noisy areas. Display hearing protection area signs.<br>PPE: Wear class 5 hearing protection (earmuffs or plugs). |
Consultation Procedures
How the business communicates with workers about safety.
This business is committed to open communication about workplace health and safety. We talk with workers to identify hazards and make sure everyone goes home safe. We follow the Work Health and Safety Act 2011 (Cth) and relevant state or territory regulations, which require us to consult with workers who are likely to be affected by health and safety matters.
We use several practical methods to ensure every worker has a say. These methods include daily pre-start talks, weekly toolbox talks, and monthly management meetings.
Daily Pre-start Talks Before work starts each day, the supervisor leads a short discussion with the crew. This focuses on the specific tasks for that day. Workers must mention any new hazards they see on the site, such as changed ground conditions or weather risks. We also check that everyone has the right personal protective equipment (PPE) for the job. These talks are quick but essential for spotting immediate risks.
Toolbox Talks We hold formal toolbox talks on a weekly basis. These meetings focus on specific safety topics relevant to our trade. Topics might include working at heights, electrical safety, using hazardous chemicals, or operating heavy machinery. We use the Code of Practice: How to Manage Work Health and Safety Risks to guide these topics. A record of these talks is kept, detailing the subject, date, and names of attendees. This helps us track who has received information on critical safety procedures.
Direct and Ongoing Consultation Workers are encouraged to raise safety issues at any time, not just during meetings. You can approach a supervisor directly to report a hazard or suggest a safer way of doing things. If you see something unsafe, stop work and tell someone. We treat all reports seriously. If a worker requests a health and safety representative (HSR), we support this process as required by the WHS Act.
Issue Resolution If a worker believes a safety issue is not resolved, we follow a standard issue resolution procedure. We discuss the problem promptly to find a solution. If we cannot agree, we may use an inspector from Safe Work Australia or the state regulator to provide advice.
By keeping these lines of communication open, we ensure that safety is a shared responsibility. Every worker plays a vital part in keeping our workplace safe.
Emergency Procedures
Instructions for what to do in an emergency.
Evacuation Procedures
Upon hearing the emergency alarm or receiving a notification from the Warden, stop all work immediately. Shut down machinery and processes if it is safe to do so, but do not delay your exit to lock computers or secure equipment. Leave personal belongings behind. Proceed to the designated assembly area via the nearest safe exit. Do not use the lifts under any circumstances.
If you are the last person to leave a room or workshop, close the doors behind you to slow the spread of fire. Walk briskly and do not run. Move away from the building and stay clear of access roads for emergency services. Once at the assembly area, do not re-enter the building until the Warden or a fire officer gives the all clear.
Medical Emergencies
In the event of a serious injury or illness, call 000 immediately. Request Ambulance service and clearly state the nature of the emergency and your location. If you are trained, apply First Aid. Do not move the patient unless there is an immediate danger to their life, such as a chemical spill or risk of collapse. Locate the nearest First Aid Kit and the First Aid Officer listed on the safety notice board.
Under the Work Health and Safety Act 2011 (Cth) and corresponding state legislation, Persons Conducting a Business or Undertaking (PCBU) must ensure the provision of first aid equipment. Familiarise yourself with the location of these kits in your workshop or vehicle. For minor injuries, treat the wound and record the incident in the register. For notifiable incidents involving serious injury or illness, you must notify Safe Work Australia or your state WHS regulator immediately.
Fire Procedures
If you discover a fire, raise the alarm immediately by breaking the glass on the Manual Call Point or shouting "Fire". If the fire is small and contained, and you have been trained to use the equipment, attempt to extinguish it using the appropriate extinguisher. Remember the PASS technique for handheld extinguishers: Pull the pin, Aim at the base of the fire, Squeeze the handle, Sweep side to side. Use water for paper and wood, CO2 for electrical fires, and dry chemical powder for flammable liquids.
If the fire is too large to control or you feel unsafe, evacuate immediately. Help any person in immediate danger if you can do so without risking your own safety. Follow the evacuation steps above. Compliance with AS 3745-2010 (Planning for emergencies in facilities) is required to ensure all workers know their specific roles during a fire.
Emergency Contact Numbers
- Fire / Police / Ambulance: 000
- Health Direct (24hr Health Advice): 1800 022 222
- Poisons Information Centre: 13 11 26
- State WHS Regulator (Example NSW): 13 10 50
- Workplace First Aid Officer: [Insert Name and Number]
- Site Emergency Warden: [Insert Name and Number]
Training and Induction
Ensuring workers are skilled and aware of risks.
Induction Process
All new workers, including employees, contractors, labour hire staff, and apprentices, must complete a site-specific induction before they start work. This process ensures everyone understands the risks at the workplace and how to work safely. A generic safety induction does not meet this requirement unless it is directly relevant to the site.
The induction must cover the specific hazards of the job and the workplace. Under the Work Health and Safety Act 2011 (WHS Act), a Person Conducting a Business or Undertaking (PCBU) must ensure, so far as is reasonably practicable, the provision of any information, training, or instruction necessary to protect workers from health and safety risks. This induction is the first step in meeting that duty.
A standard induction process includes four steps. First, the worker completes a general registration form to provide their contact details and emergency contacts. Second, the PCBU or supervisor walks the worker through the physical site. This walk through must identify emergency exits, first aid kits, fire extinguishers, and hazard reporting mechanisms. Third, the worker receives a copy of the company’s Safe Work Method Statements (SWMS) relevant to their tasks. Fourth, the supervisor explains the specific rules for the site, such as Personal Protective Equipment (PPE) requirements, restricted zones, and site security.
The induction finishes when the worker signs a declaration stating they understand the safety rules and the nature of the risks.
Training and Record Keeping
Specific training often goes beyond the initial induction. Workers must hold the correct licences and tickets for high-risk work. For example, workers operating forklifts, boom lifts, or scaffolding must hold a High Risk Work Licence (HRWL) issued by the relevant SafeWork state or territory regulator. If the work involves asbestos removal, specific training units like CPCCDE3014A are mandatory.
Records of all inductions and training must be kept current and accessible. Regulation 397 of the Work Health and Safety Regulations 2011 (WHS Regulations) requires a PCBU to keep a register of training completed by workers. This register helps demonstrate compliance during an inspection or incident investigation.
The training register must include the worker's full name and the date of the induction or training. For accredited courses, keep a copy of the statement of attainment or licence card. For site-specific inductions, keep the signed declaration form. Store these records in a secure location. Records for general induction training must be kept for the duration of the worker's employment. Records for specific high-risk work training must be kept while the worker is carrying out that work. You must update the register whenever a worker completes new training or if their qualification is about to expire.
Incident Reporting
The process for reporting and investigating workplace incidents.
Incident Notification Procedure
All workers must report injuries, near misses, and dangerous incidents immediately. You must not ignore minor issues. Reporting near misses helps us fix problems before someone gets hurt. If you are injured, seek first aid or medical attention first. Then tell your supervisor.
Follow these steps for reporting:
- Notify your supervisor immediately. Report all physical injuries, psychological injuries, and close calls. Do not wait until the end of the shift.
- Complete an Incident Report Form. Provide details about what happened, where it happened, and any witnesses. Be honest and accurate.
- Secure the site. If an incident causes damage or creates a risk, cordon off the area. Do not disturb the site unless you need to save a life or make the area safe. This preserves evidence for investigation.
Notifiable Incidents
Certain serious incidents must be reported to the WHS regulator. Under the WHS Act, a notifiable incident includes the death of a person, a serious injury or illness, or a dangerous incident.
Serious injury or illness means the person needs immediate treatment as an inpatient in a hospital, or immediate medical treatment for things like amputations, serious head injuries, serious burns, or loss of consciousness.
Dangerous incidents are events that expose a worker or anyone else to a serious risk to health or safety. This includes structural collapses, explosions, uncontrolled escapes of chemicals, or the fall of a plant from a height.
Regulator Notification Steps
If a notifiable incident occurs, the Person Conducting a Business or Undertaking (PCBU) must contact the regulator immediately. You can do this by phone or via the online notification form.
You must notify the regulator immediately after becoming aware of the incident.
If the incident is notifiable, you must preserve the incident site. The WHS Regulations require that the site not be disturbed until an inspector arrives or gives permission. You may move things if you need to help an injured person or remove an immediate risk. You must only disturb the site as much as necessary to reduce the risk.
- Phone Contact: Call the SafeWork Australia or state-based regulator line.
- Written Notification: If you notify the regulator by phone, you must follow up with a written report within 48 hours.
Keep records of all incidents and reports on site for at least five years. These records are essential for insurance purposes and legal compliance under the WHS Act. Failure to report a notifiable incident is a serious offence and can result in heavy fines.
Frequently Asked Questions
What is a WHS Management Plan?
When do I need a WHS Management Plan?
Is a WHS Management Plan legally required in Australia?
Who is responsible for the WHS Management Plan?
How often should I update my WHS Management Plan?
Do I need a WHS Management Plan for a small business?
What is the difference between a WHS Plan and a SWMS?
What happens if I do not have a WHS Management Plan?
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