Behaviour-based safety (BBS) is a workplace practice, not a legal term: you watch how a task is really done, give quick feedback on safe and at-risk actions, and use what you learn to fix causes. It can help, but it does not replace removing or controlling the hazard itself.
This guide is for owners, supervisors and leading hands of Queensland businesses who have heard the term and want an honest view: what it is, a simple way to run safety observations, how it goes wrong, and where it sits next to the law.
What is behaviour-based safety?
In everyday use, behaviour-based safety means a few things done together. Someone observes a task, notes what was done safely and what was not, talks to the worker straight away, and keeps a simple record so patterns show up. Some businesses call these safety observations; others call the same idea behavioural safety. The names and the paperwork vary from workplace to workplace, because it is a management practice, not a defined system.
Is behaviour-based safety a legal requirement in Queensland?
No. We searched the Work Health and Safety Act 2011 (Qld), the Work Health and Safety Regulation 2011 (Qld) and the Queensland approved codes of practice in our library. None of them uses the phrase “behaviour-based safety”, and we found nothing in them that requires a business to run an observation program. The word “behaviour” does appear, but in other ways. For example, section 55A of the WHS Regulation says a psychosocial hazard can arise from, or relate to, “workplace interactions or behaviours”, and section 55D(2) lists that as a matter to consider when choosing controls for psychosocial risks. That is about hazards such as bullying, not about observing work habits.
What the law does set out are duties that an observation routine can help you meet, if it is done well:
- Primary duty. Section 19 of the WHS Act requires a person conducting a business or undertaking (PCBU) to ensure, so far as is reasonably practicable, the health and safety of workers and others. That includes safe systems of work and the information, training, instruction or supervision necessary to protect people (section 19(3)(c) and (f)), and monitoring of the conditions at the workplace (section 19(3)(g)).
- Officers. Section 27(5) of the WHS Act says an officer’s due diligence includes taking reasonable steps to understand the hazards and risks of the operations, and to make sure the PCBU has appropriate processes for receiving and considering information about incidents, hazards and risks and responding in a timely way. Watching real work is one practical way to do this.
- Workers. Section 28 requires a worker, while at work, to take reasonable care for their own health and safety, take reasonable care that their acts or omissions do not adversely affect others, comply with reasonable instructions so far as they are reasonably able, and co-operate with reasonable health and safety policies or procedures that have been notified to workers.
- Instruction. Section 39 of the WHS Regulation requires information, training and instruction to be suitable and adequate for the work, the risks and the controls in place, and, so far as is reasonably practicable, readily understandable.
Where behaviour-based safety sits in the hierarchy of controls
This is the most important point. Section 36 of the WHS Regulation sets out the order in which a duty holder must work. If it is not reasonably practicable to eliminate a risk (section 35 asks you to try that first), you must minimise it so far as is reasonably practicable by substitution, isolation or engineering controls (section 36(3)). Only “if a risk then remains” must you minimise the remaining risk by implementing administrative controls (section 36(4)), and then, if a risk still remains, by ensuring the provision and use of suitable personal protective equipment (section 36(5)). Our guide to the hierarchy of controls walks through each level.
Observing and coaching people is, in our reading, closest to the administrative level, alongside procedures, training and supervision. The approved code of practice How to manage work health and safety risks says administrative controls and PPE are the least effective because they do not control the hazard at the source and rely on human behaviour and supervision, and that they should only be used to supplement higher-level controls, as a short-term interim measure, or when no other practical control is available. The same code says cost cannot be used as a reason for adopting controls that rely exclusively on changing people’s behaviour or actions when there are more effective controls available. An approved code is not law in itself, but section 26A of the WHS Act 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).
In plain words: behaviour-based safety supports your controls. It does not stand in for guarding a machine, fitting edge protection or redesigning a job.
A simple safety observation routine for a small business
This is common practice, not a legal requirement; adjust it to your own crew and site.
- Pick one task and tell people why. Choose a task that matters this week, such as loading a truck, using an angle grinder or working near moving plant. Tell the crew the aim is to see how the job really goes and fix what gets in the way, not to catch anyone out.
- Observe for a short time with a simple checklist. Five to ten minutes is plenty. List the key steps of the task beforehand and tick what you see done as planned. Note anything that looks like a workaround.
- Talk straight after, in private. Start with what was done well. Then describe what you saw without judgement (“I noticed the guard was off during the cut”).
- Ask why. The most useful question is “what made that the easier way to do it?” The answer is often a missing tool, poor layout, time pressure or a procedure that does not fit the job.
- Fix the system cause. Change the job, the equipment or the plan, and tell the worker what you did. If you cannot fix it straight away, put an interim control in place and say so.
- Share it in the toolbox talk. Raise the lesson (not the name) at the next meeting, and ask the crew what else gets in the way. A free toolbox meeting template is a starting point for running the meeting.
Record each observation with a date, the task, what was seen and what was changed. A free hazard report form can be used to report the hazards that observations turn up. These are starting points: adapt them to your own site.
How it fits with toolbox talks, hazard reports and inspections
- Toolbox talks are where observations are shared back with the crew. Our guide to the Take 5 safety checklist covers a quick pre-task habit that pairs well with observing the task afterwards.
- Hazard and near-miss reports are what workers tell you; observations are what you see. Both feed the same fix list.
- Inspections and audits check the workplace and its controls. The paid Site Safety Audit Checklist and Monitoring & Review Policy Template are starting points if you want a written way to check and review your controls. Section 38 of the WHS Regulation requires a duty holder to review and, as necessary, revise control measures, including when a control does not control the risk it was meant to, or when the results of consultation indicate a review is necessary.
- Culture. Observation works only where people trust that speaking up is safe. Our guide to safety culture in the workplace covers that side in detail.
How behaviour-based safety goes wrong
| What goes wrong | Why it is a problem | A better approach |
|---|---|---|
| Blame: “the worker was careless” | People hide mistakes and workarounds, so you stop seeing real work. | Ask what made the unsafe way the easy way, then fix that. |
| Used instead of fixing the hazard | You lean on the lower levels of the hierarchy while a guard, barrier or better tool would do the job more reliably. | Work through section 36 of the WHS Regulation first. Use observation to check that the controls work in practice. |
| Tick-box numbers | Targets for “observations completed” produce quick, shallow ticks. | Count the fixes made, not the forms filled in. |
| Workers not consulted | The routine feels like surveillance and is resented. | Talk it through with the crew first. Section 49 of the WHS Act requires consultation on matters including identifying hazards, assessing risks and deciding how to control them. |
| Only the crew is observed | Workers see that the rules apply to them but not to the boss. | Supervisors and owners are observed and coached too. |
Under section 47 of the WHS Act a PCBU must consult workers, so far as is reasonably practicable. Section 48 says that means sharing relevant information, giving workers a reasonable opportunity to express views and contribute to the decision, taking their views into account, and telling them the outcome in a timely way.
A made-up example
This example is invented to show the idea. A small fabrication workshop owner watches a worker cut flat bar for ten minutes. The worker takes the guard off the saw for the last few cuts. After the job, the owner thanks the worker for the clean cuts, then asks why the guard came off. The answer: the guard fouls when the offcut is short, and the job was behind. A message reminding everyone to use the guard would have changed nothing. Instead the owner buys a clamp that holds short offcuts with the guard in place, shows the crew at the next toolbox talk, and checks the same cut a fortnight later. The fix came from the question, and the control that worked was a better piece of equipment, not a better attitude.
How to tell it is working
You do not need statistics. Look for practical signs:
- Workers talk freely about workarounds and tell you when something is not working.
- Observations lead to visible changes, and people hear what was done.
- The same at-risk action is not coming up again and again for the same unfixed reason.
- Hazard reports are a mix of near misses and ideas, not silence.
If the same behaviour keeps happening, treat that as a sign the system needs changing. Our guide to workplace incident investigation shows how to look for the causes behind what happened.
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.
