A work health and safety (WHS) policy is a short written statement of how your business looks after health and safety: who is responsible for what, how people raise problems and how you manage risks. Queensland’s WHS laws don’t require an ordinary business to have a document with that name, but writing one down is a simple way to record what you have decided to do. You can start from our free work health and safety policy template.
Does Queensland law require a WHS policy?
Neither the Work Health and Safety Act 2011 (Qld) nor the Work Health and Safety Regulation 2011 (Qld) says an ordinary business must have a document called a WHS policy. The Regulation does require a safety policy as part of the safety management system of a determined major hazard facility (section 558 and schedule 17 of the Regulation), but that is a specialised regime most small businesses will never be part of.
What the law does require is that the business actually looks after health and safety. A person conducting a business or undertaking (a PCBU) must ensure, so far as is reasonably practicable, the health and safety of its workers and of other people put at risk by the work (section 19 of the WHS Act). Section 19(3) spells out what that includes:
- a work environment without risks to health and safety
- safe plant and structures
- safe systems of work
- the safe use, handling and storage of plant, structures and substances
- adequate welfare facilities for workers
- the information, training, instruction and supervision people need
- monitoring the health of workers and the conditions at the workplace
A policy is where you write down how your business does those things. It helps in three practical ways:
- Workers have something to follow. Workers must co-operate with any reasonable policy or procedure of the PCBU relating to health or safety that has been notified to workers (section 28(d) of the WHS Act). The words “notified to workers” matter: a policy in a drawer doesn’t do the job.
- Officers can show what is in place. The officers of a business must exercise due diligence, and the Act says that includes taking reasonable steps to make sure the business has processes for receiving and considering information about incidents, hazards and risks, and for complying with its duties (section 27(5) of the WHS Act). A policy that names those processes is a good starting record. Company directors are the usual example of officers (the Act’s definition excludes a partner in a partnership), but the Act’s dictionary links the word to the Corporations Act 2001 (Cth), so ask your adviser if you are unsure whether you count.
- New people see your standards on day one. It gives you something to explain at induction. Our safety induction checklist for new workers shows where it fits.
Documents the law does require, whatever your policy says
A policy doesn’t replace the specific documents and plans the Regulation asks for. Three examples:
- A safe work method statement (SWMS) must be prepared before high risk construction work starts (section 299 of the WHS Regulation). See our guide to high risk construction work.
- An emergency plan must be prepared for the workplace (section 43 of the WHS Regulation). See emergency plan requirements.
- If you identify a risk of sexual harassment or sex or gender-based harassment at work, the Regulation requires a written prevention plan to manage it (section 55H, with the duty to manage psychosocial risks in section 55C). A line in a policy is not a prevention plan.
Policy, procedure and SWMS: what each one is for
| Document | What it answers | Typical length |
|---|---|---|
| Policy | What does the business commit to, and who is responsible? | One or two pages |
| Procedure | How do we do a regular process, such as reporting an incident or running a toolbox meeting? | One to three pages each |
| SWMS, JSA or risk assessment | How do we do this particular task safely? | Per task or job |
If you want the bigger picture, see our guides to the WHS management system, safe work procedures and SWMS and the job safety analysis (JSA).
What to put in a small business WHS policy
- A commitment statement. One short paragraph, signed and dated by the owner or most senior person. Use the law’s own standard: you will provide a safe and healthy workplace so far as is reasonably practicable (sections 18 and 19 of the WHS Act).
- Who is responsible for what. The owner or PCBU (section 19), officers (section 27), workers, including contractors and subcontractors (section 28, with the meaning of worker in section 7), and other people at the workplace such as visitors (section 29). Name the person who handles safety day to day, and what managers and supervisors are expected to do.
- How you consult your workers. The Act requires you to consult workers, so far as is reasonably practicable, on matters that directly affect them (section 47), and lists when consultation is required, including when identifying hazards, assessing risks, deciding on controls and proposing changes that may affect health or safety (section 49). Say how it happens in your business: toolbox meetings, a safety noticeboard, a safety representative. Our guide to health and safety representatives, committees and consultation covers the detail.
- How you manage hazards and risks. Identify reasonably foreseeable hazards, eliminate the risk so far as is reasonably practicable and, if you can’t, minimise it using the hierarchy of control (sections 34 to 36 of the WHS Regulation), then review the controls (section 38). Point to your risk assessment method. See hazard vs risk and how to identify hazards.
- How people report hazards, near misses and injuries. Say who to tell and how, and that you want people to speak up. Mention that notifiable incidents must be reported to the regulator straight away (section 38 of the WHS Act). See notifiable incidents in Queensland and our free hazard report form.
- Training, induction and supervision. What each worker gets before they start and when it is refreshed (section 19(3) of the WHS Act).
- Emergencies and first aid. A line saying the business provides first aid and has an emergency plan, with the detail kept in those documents (sections 42 and 43 of the WHS Regulation). See first aid requirements.
- The risks that matter most in your business. A short list, such as working at heights, plant, hazardous chemicals, manual tasks, fatigue or psychosocial risks like bullying and harassment. Each one can point to its own procedure.
- A review date. The law doesn’t set a review period for a policy. It does require you to review control measures when, for example, they don’t control the risk, before a change that could create a new risk, or when a new hazard is identified (section 38 of the WHS Regulation), so it makes sense to review the policy when those things happen.
Example wording for the commitment statement
Adapt this to your business and your own words:
“[Business name] is committed to providing a safe and healthy workplace for our workers, contractors and visitors, so far as is reasonably practicable. We will identify hazards and eliminate or minimise the risks, consult with our workers on health and safety matters, provide the training and supervision people need, and review how we are going. Everyone at our workplaces is expected to take reasonable care for their own safety and the safety of others, follow our safe work procedures, and report hazards, near misses and injuries. Signed: ________ Date: ________”
Making the policy work in five steps
- Keep it short. One to two pages. Put the detail in procedures and SWMS.
- Talk to your workers first. Consulting them on how health and safety is managed is part of your duty to consult (sections 47 and 49 of the WHS Act), and it usually makes the policy more realistic.
- Sign and date it. The owner or most senior person should sign it, and mean it.
- Tell everyone. Cover it at induction, display it where people will see it, and give a copy to contractors who work under your control.
- Check it against Queensland law. A policy copied from another state, another country or a generic template may quote the wrong Act or leave out Queensland requirements.
Templates to build your policy
Start with the free work health and safety policy template, then add the policies your work needs. These cover the topics above:
- Hazard management policy template
- Incident management policy and procedure template
- Consultation, communication and training policy template
- Risk management policy and procedure
Need the full set? Browse all policies and procedures, or the policies and procedures bundle. For a complete system, see the WHS manual template.
This guide is general information, not legal advice. Check the current law or talk to Workplace Health and Safety Queensland for your situation.
Templates for this job
Ready-to-edit Word and Excel templates for Queensland workplaces.
