Safety culture is the set of shared attitudes and everyday habits that decide how safety is really handled in your business, especially when nobody is watching. It is not a legal term, but the Work Health and Safety Act 2011 (Qld) gives you duties, such as consulting workers and training them, that a good culture helps you meet.
This guide is for owners, supervisors and leading hands of small Queensland businesses. It explains what safety culture means in plain words, the signs of a good and a poor one, eight practical things you can do, where behaviour-based safety fits, and how to tell whether it is working.
Is safety culture a legal requirement?
No, not as a phrase. The Work Health and Safety Act 2011 (Qld), the Work Health and Safety Regulation 2011 (Qld) and the approved codes of practice we checked do not define “safety culture” or set a separate duty to have one. What the law does set out are duties that, in practice, a healthy culture makes much easier to meet:
- Primary duty of care. 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 any information, training, instruction or supervision necessary to protect people (section 19(3)(c) and (f)).
- Officers’ due diligence. Section 27 of the WHS Act requires an officer of a PCBU to exercise due diligence to ensure the PCBU complies with its duties. The Act defines who is an officer, so check whether it covers you.
- Consultation. Sections 47 to 49 of the WHS Act require the PCBU to consult workers, so far as is reasonably practicable, on matters such as identifying hazards, assessing risks and deciding how to control them.
- Worker duties. Section 28 requires workers to take reasonable care for their own health and safety and that their acts or omissions do not adversely affect the health and safety of others, to comply with reasonable instructions so far as they are reasonably able, and co-operate with reasonable policies and procedures notified to them.
- Information, training and instruction. Section 39 of the Work Health and Safety Regulation 2011 (Qld) requires it to be suitable and adequate for the work, the risks and the controls in place, and provided so far as is reasonably practicable in a way people can readily understand.
Think of the law as the list of jobs that must be done, and culture as how willingly and reliably they get done.
What does a good safety culture look like?
These signs are practical observations, not legal tests.
| Sign | Good culture | Poor culture |
|---|---|---|
| Reporting | People report hazards and near misses early, because it is easy and nothing bad happens to them | Problems are hidden, or only come out after someone is hurt |
| Leaders | The boss wears the gear, follows the rules and stops work when something is wrong | Rules apply to the crew but not the boss |
| Speed versus safety | Taking time to do the job safely is accepted and backed up | Shortcuts are quietly rewarded when the job is behind |
| New starters | They are shown the site, the hazards and who to ask | They are thrown in and told to watch someone |
| After an incident | The question is “what let this happen?” | The question is “who stuffed up?” |
| Fixes | Reported hazards get a response and the person hears back | Reports disappear into a folder |
Eight things a small business can do
1. Leaders go first
Workers copy what the owner and supervisors do, not what the policy says. Wear the PPE, use the harness, follow the same site rules. For officers, section 27(5) of the WHS Act lists steps that due diligence includes, such as keeping up to date with work health and safety matters, understanding the hazards and risks of your operations, making sure appropriate resources and processes are available and used, and verifying that this is happening. Walking the site and asking questions is one practical way to do that last step.
2. Make reporting easy
If reporting takes a long form and an awkward conversation, people will not do it. Offer a simple route, such as the free hazard report form in the ute or site shed, or a quick word to the supervisor. Section 27(5)(d) of the WHS Act refers to processes for receiving and considering information about incidents, hazards and risks and responding in a timely way. Our guide on reporting injuries, incidents and near misses goes into more detail.
3. Close the loop on every report
Tell the person what was done, even if the answer is “we can’t fix that this week, so here is the interim control”. Nothing kills reporting faster than silence. This is practice, but it lines up with section 48(1)(d) of the WHS Act, which says consultation includes advising the workers consulted of the outcome in a timely way.
4. Consult your workers properly
Section 48 of the WHS Act says consultation means sharing relevant information, giving workers a reasonable opportunity to express views, raise issues and contribute to the decision, taking their views into account, and advising them of the outcome. Section 49 lists when consultation is required, including when identifying hazards, assessing risks, deciding how to control them and proposing changes that may affect health or safety. The people doing the job often know the real hazard before you do. If you have a committee, see the role of committee members; there is also a paid Safety Committee Meeting Form Template.
5. Run short, useful toolbox talks
Pick one real job or hazard from this week, keep it to a few minutes, ask for input and write down who attended and what was raised. The free toolbox meeting template is a starting point you can adapt to your own site. Toolbox talks are common practice and a good way to consult; the Act does not say a business must hold them.
6. Induct and supervise new starters
New and young workers are often the least sure about speaking up. Show them the hazards, the emergency arrangements and who to ask. Section 19(3)(f) of the WHS Act includes supervision where it is necessary, and section 39 of the WHS Regulation requires training and instruction that is suitable and adequate for the work and, so far as is reasonably practicable, readily understandable. Checking understanding by asking them to explain the job back to you is good practice.
7. Review incidents without blame
Find out what happened and what in the system let it happen: the job design, time pressure, missing equipment, unclear instructions. Blame teaches people to hide things. Looking at the controls is also what section 38 of the WHS Regulation expects when, for example, a control measure does not control the risk, a notifiable incident occurs because of the risk, or consultation indicates a review is necessary.
8. Check that the controls are actually used
A written procedure nobody follows is not a control. Watch the work as it is really done, ask why a guard is off or a step is skipped, and fix the cause: the wrong tool, not enough time, no place to put things. Section 38 of the WHS Regulation requires a duty holder to review and, as necessary, revise control measures so that they keep the work environment, so far as is reasonably practicable, without risks to health or safety.
A free work health and safety policy template is a starting point you can adapt to your business, but a policy only helps if people see leaders acting on it. For the bigger picture, see our guide to a WHS management system and our list of work health and safety habits.
Where does behaviour-based safety fit?
Behaviour-based safety usually means observing what people do on the job, noting safe and at-risk behaviours, and giving prompt, respectful feedback. In our opinion it can be useful when it starts conversations and surfaces practical problems. It works best alongside fixing the hazard itself. If the same at-risk behaviour keeps happening, ask why: poor layout, missing equipment or pressure to rush are often the cause, and the better control is usually to change the job, not just coach the person. Section 35 of the WHS Regulation requires a duty holder to eliminate risks so far as is reasonably practicable and, if that is not reasonably practicable, to minimise them so far as is reasonably practicable. Behaviour-based observation is not a substitute for that, and the Act and Regulation we checked do not require it.
A made-up example
This example is invented to show the idea. A small concreting crew keeps losing time because the pump hose is dragged through a walkway. Workers have stopped mentioning it because nothing ever changed. The owner starts a five-minute toolbox talk on Monday, asks what slows the crew down and hears about the hose straight away. By Wednesday the owner has re-planned the hose route, tells the crew at the next talk and thanks the worker who raised it. Two weeks later a different worker flags a loose guard without being asked. Nothing in the written policy changed; what changed was that speaking up led to a fix.
How do you tell whether it is working?
You do not need statistics. Practical signs include:
- You hear about hazards and near misses from the crew before they turn into injuries.
- Workers raise issues without being asked and expect something to happen.
- Toolbox talk records show real topics and real input, not the same page every week.
- New starters can tell you where the first aid kit is, who their supervisor is and how to report a hazard.
- Reported hazards have a recorded outcome and a date.
- Supervisors stop work when something is wrong, and are backed when they do.
Ask your crew, in person or anonymously, what would make it easier to speak up, and act on the answers.
Respect and psychosocial risk
How people treat each other is part of culture too. Section 55C of the WHS Regulation requires a PCBU to manage psychosocial risks under part 3.1 of the Regulation, and section 55A describes a psychosocial hazard as one that may cause psychological harm and arises from, among other things, workplace interactions or behaviours.
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.
