A high risk work licence (HRWL) is a licence from the regulator, Workplace Health and Safety Queensland, that a person must hold to carry out a class of high risk work listed in schedule 3 of the Work Health and Safety Regulation 2011 (Qld), such as forklift operation, scaffolding, dogging, rigging and certain crane and platform work.
This guide covers which work needs a licence, what a licence is not, what a business must check before putting someone on licensed work, and how a licence is obtained and renewed. Forklift answers are in their own section below.
Which work needs a high risk work licence in Queensland?
Section 81 of the Work Health and Safety Regulation 2011 (Qld) (the WHS Regulation) says a person must not carry out a class of high risk work unless they hold a high risk work licence for that class, except as section 82 allows. The classes are listed in table 3.1 of schedule 3. In summary, they are:
| Group | Licence classes in schedule 3 |
|---|---|
| Scaffolding | Basic, intermediate and advanced scaffolding (erecting, altering or dismantling structures where a person or object could fall more than 4 m) |
| Dogging and rigging | Dogging; basic, intermediate and advanced rigging |
| Cranes and hoists | Tower, self-erecting tower, derrick, portal boom, bridge and gantry, vehicle loading, non-slewing mobile and slewing mobile cranes (slewing bands up to 20 t, 60 t, 100 t and over 100 t); materials hoist; personnel and materials hoist |
| Platforms and booms | Boom-type elevating work platform (where the boom is 11 m or more); concrete placing boom |
| Reach stacker | Reach stacker |
| Forklifts | Forklift truck; order-picking forklift truck |
| Pressure equipment | Standard boiler operation; advanced boiler operation; steam turbine operation; reciprocating steam engine |
Read the schedule 3 entry for the exact plant and tasks in each class. A higher class can include lower ones; basic rigging, for example, includes dogging work. For elevating work platforms, see our scissor lift and EWP licence guide. For slinging loads, see dogman vs rigger.
What a high risk work licence is not
- It is not a SWMS. A safe work method statement is required before high risk construction work starts (section 299 of the WHS Regulation). That is a different list, set out in section 291. A licence shows a person is licensed for a class of work; a SWMS sets out the hazards and controls for the job.
- It is not the general construction induction (white card). A business must not direct or allow a worker to carry out construction work unless the worker has completed general construction induction training, with a two-year rule if they have been away from construction work (sections 316 and 317 of the WHS Regulation). A licence does not replace that, and a white card does not license anyone for high risk work. Our guide to the white card in Queensland explains the training duty.
- It is not a site induction. Learning your site and its emergency arrangements is separate. A site induction before work starts is good practice, but a licence does not provide one.
High risk work licence vs high risk construction work
The two names sound alike but work differently. A high risk work licence is about a person: they must be licensed for the class of work in schedule 3. High risk construction work is about the task: the list in section 291 (for example work with a risk of falling more than 2 m, or work in or near a trench with an excavated depth greater than 1.5 m) triggers a written SWMS. One job can need both: a crane lift on a building site may need a licensed operator and dogger and also a SWMS. Read more in our high risk construction work guide.
Forklift licence in Queensland
Schedule 3 has two forklift classes: a forklift truck licence and an order-picking forklift truck licence. For these classes the WHS Regulation defines a forklift truck as a powered industrial truck with a mast and an elevating load carriage carrying a pair of fork arms or other arms that can be raised 900 mm or more above the ground. It does not include a pedestrian-operated truck or a pallet truck. An order-picking forklift truck is a forklift truck whose operator controls are built into the lifting media and rise with it.
The licence question turns on what the machine is. If it meets the definition, section 81 applies to anyone who carries out that class of work with it, subject to the exceptions in section 82. A pallet truck is outside those two classes, but the business still has to manage its risks under its general WHS duties. Our forklift injuries guide covers the hazards, and the Safe Operation of Forklift SWMS template (Word) is a starting point to adapt to your own site if the work also falls under the high risk construction list.
The duty not to let an unlicensed person do licensed work
Section 85 of the WHS Regulation puts a duty on the person conducting a business or undertaking (PCBU) at the workplace. Not sure if that is you? See what is a PCBU. In summary:
- You must not direct or allow a worker to carry out high risk work that needs a licence unless you see written evidence from the worker that they hold the relevant licence (section 85(1)).
- You must not direct or allow a worker to supervise a trainee doing high risk work unless you see written evidence that the supervisor holds the relevant licence (section 85(3)).
- You must keep a record of the written evidence for at least 1 year after the high risk work is carried out, or after the last time the worker supervises (section 85(4)).
In practice, check the class, name and expiry date on the licence document, take a copy and record it. The free Employee Training Register is one place to record those details and their expiry dates. Our guide to a training matrix shows how to lay one out. The Queensland approved Managing risks of plant in the workplace Code of Practice 2021 repeats this duty. An approved code is guidance rather than law in itself, but section 26A of the Work Health and Safety Act 2011 (Qld) requires a PCBU to comply with it or manage the risk in a way that gives an equivalent or higher standard of health and safety, and a court can rely on it when deciding what is reasonably practicable (section 275).
Learners and other exceptions
Section 82 of the WHS Regulation lists limited exceptions, including:
- A person doing the work while training towards a certification for the licence, under the supervision of a licensed person. Section 84 requires the business to make sure the supervisor provides direct supervision, except where the task makes that impracticable or unnecessary and the reduced level will not put anyone at risk.
- A person who holds the relevant certification for 60 days from the day it is issued, and who applies for the licence within that 60 days, until the licence is granted or 28 days after written notice under section 91(2)(c) (section 82(1A)).
- Work done while an accredited assessor is assessing the person’s competency (section 82(1B)).
The business must still see written evidence that the worker is in training, holds the certification or has applied (section 85(2)). These are not a general permission to start licensed work without a licence. Read section 82 in full for the conditions and other exceptions.
How to get a high risk work licence in Queensland
- Complete the training and assessment. Only a person who holds a qualification listed in schedule 4 may apply (section 86). Schedule 4 sets the VET course for each class, for example the licence to operate a forklift truck for the forklift class. Competency assessments must be done by an accredited assessor acting for or on behalf of a registered training organisation, unless the regulator is the assessor (sections 113 and 114).
- Apply to the regulator within 60 days of your certification. The application is made in the way and form the regulator approves, with the relevant fee. Under section 87 it must include evidence of identity and age, a photograph, the class sought, a copy of the certification for the specified VET course issued not more than 60 days earlier, and the declarations listed (including about any WHS conviction).
- The regulator decides. Under section 89 the regulator must grant the licence if satisfied about the listed matters, including that the applicant is at least 18, lives in Queensland (or circumstances justify granting it otherwise) and can carry out the work safely and competently. The regulator may ask for more information (section 88) and may impose conditions (section 91A). If it has not decided within 120 days, the application is taken to be refused (section 89(5)); a refusal is a reviewable decision.
- Keep the licence document available. The licence document must be kept available for inspection under the Act (section 94). Notify the regulator of a change of residential address within 14 days (section 96), and as soon as practicable if the document is lost, stolen or destroyed (section 98).
Check current course and fee details with the training provider and Workplace Health and Safety Queensland before you book.
How long does a licence last, and how is it renewed?
A licence takes effect on the day it is granted and, unless cancelled earlier, expires 5 years after that day (section 92). To renew, apply before the licence expires, with a declaration that you have maintained your competency (section 101). If you apply in time, the licence continues in force until you are given notice of the decision (section 102). If it has already expired, you can apply to renew within 12 months, but you cannot carry out the licensed work until it is renewed (section 103). The regulator can also direct a licence holder to obtain a reassessment of competency if it reasonably believes they may not be competent (section 95).
A licence granted under a corresponding WHS law in another jurisdiction is recognised as a high risk work licence if it is an equivalent licence, is used in line with its terms and conditions, and has not expired or been suspended or cancelled (section 83).
Licence checklist for a small business
- Check every machine and task in your business against schedule 3, including the capacity band or boom length.
- Ask each worker for written evidence of the relevant licence class before they start.
- Record the licence number, class and expiry date, and keep the evidence for at least 1 year after the work.
- Prepare a SWMS where the job is also high risk construction work. The Scaffolding SWMS and Rigging & Dogging SWMS templates (Word) are starting points to adapt to your own site.
For crane operators, see also our post on tower crane refresher training.
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.
