A WHS management system is the set of policies, procedures, records and routines a business uses to plan, carry out, check and improve its work health and safety. In Queensland, most small businesses are not required by law to have a formal or certified system. What the law requires is that you meet your duties under the Work Health and Safety Act 2011 (Qld) and the Work Health and Safety Regulation 2011 (Qld), and a documented system is the practical way to meet them and to show that you have.
What is a WHS management system?
It is not one document. It is how your business handles safety day to day: who is responsible, how hazards are found and controlled, how people are trained and consulted, how incidents are reported, and how the whole arrangement is checked and improved. People also call it an OHS management system, a safety management system or a safety management plan, and they use the terms loosely.
The system covers the whole business, whatever job is on. It helps to separate it from the documents that sit inside or alongside it:
- A WHS management plan is project-specific. A principal contractor on a construction project costing $250,000 or more must prepare a written one before work starts (regulations 292 and 309).
- A safe work method statement (SWMS) is prepared for high risk construction work (regulation 299).
- A job safety analysis (JSA) plans one task. See our guide to what a JSA is.
Does Queensland law require one?
Not in general. The Act and the Regulation do not say that every business must hold a management system, and they do not require certification. The Regulation does require a safety management system in a few specific, narrow situations:
- The operator of a determined major hazard facility must establish and implement a safety management system (regulation 558).
- The operator of a major amusement park must establish a safety management system for all the amusement devices at the park (regulation 608O).
- For a class A asbestos removal licence, the regulator must be satisfied that the applicant has a “certified safety management system” in place (regulation 498). The Regulation defines that as a system that complies with AS 4801:2001 or an equivalent system determined by the regulator (schedule 19 and regulation 6).
For everyone else, the law is about duties. A system is not a defence by itself: the duties apply to what actually happens at your workplace, not to what is in a folder.
The duties a WHS management system helps you meet
If you are a person conducting a business or undertaking (a PCBU), a management system gives you a place to build in each of these:
| Duty | Where it comes from | What a system provides |
|---|---|---|
| Primary duty of care, including safe systems of work, information, training, instruction, supervision and monitoring | Section 19 of the Act | Policy, procedures, training and inspection routines |
| Identify hazards, eliminate or minimise risks, use the hierarchy of control, maintain and review controls | Regulations 34 to 38 | Risk register, procedures, review schedule |
| Consult workers when identifying hazards, deciding on controls and proposing changes | Sections 47 to 49 | Consultation arrangements and records |
| Consult, cooperate and coordinate with other duty holders | Section 46 | Contractor and site coordination process |
| Officers exercise due diligence, including making sure the business has and uses resources and processes and verifying them | Section 27 | Reporting to owners and directors, resourcing, checks |
| Provide suitable and adequate information, training and instruction | Regulation 39 | Induction and training records |
| Provide first aid and prepare an emergency plan | Regulations 42 and 43 | First aid and emergency procedures, with testing |
| Notify the regulator of notifiable incidents and keep a record for at least 5 years | Section 38 | Incident procedure and register |
| Keep a hazardous chemicals register with current safety data sheets | Regulations 344 and 346 | Chemical register |
| Prepare a SWMS before high risk construction work, and keep and review it | Regulations 299 to 303 | SWMS library and review process |
The section 27 duty is the one owners and directors should read closely. It asks officers to take reasonable steps to know about work health and safety, understand the business’s hazards, make sure the right resources and processes exist, make sure information about incidents and hazards is received and acted on, and verify all of it. A management system is the obvious way to show those steps were taken.
What goes in a WHS management system
- Policy and commitment. A short, signed statement of what the business will do about safety and who is responsible.
- Roles and responsibilities. What owners and officers, supervisors and workers must do (sections 27 and 28).
- Consultation. How you consult workers and the other businesses you work with.
- Hazard identification and a risk register. The hazards, how serious they are, and the controls you chose.
- Safe work procedures, JSAs and SWMS. Written methods for the common and high risk tasks.
- Induction, training and competency. Inductions, licences and tickets, and a training register.
- Inspections, maintenance and audits. Workplace inspections, plant and equipment checks. See our guide to workplace inspections and audits.
- Incident reporting and investigation. Including near misses and notifying the regulator when required.
- Emergency and first aid arrangements.
- Contractor and visitor management.
- Document and record control. Who approves documents, which version is current, where records are kept. Our guide to safety-related paperwork covers the basics.
- Review and improvement. Regular reviews, plus a review after incidents and when the work changes (regulation 38).
Keep it proportionate for a small business
The How to Manage Work Health and Safety Risks Code of Practice 2021 is an approved code of practice. It says the detail and extent of recording depend on the size of the workplace and the potential for major work health and safety problems. A five-person trade business does not need a 300-page manual. It needs a short policy, a risk register for its main tasks, procedures and SWMS for the work it actually does, training and incident records, and a regular check that they are being used.
A common failure is a system so big or generic that nobody on site uses it. Start small, make it match how you really work, and grow it as the business does.
AS/NZS ISO 45001:2018: a voluntary standard
AS/NZS ISO 45001:2018 is the Australian and New Zealand version of the international standard for occupational health and safety management systems. It is built on a plan, do, check, act cycle. It is a voluntary standard, not law. Australian Standards only become mandatory where a law or a contract calls them up, and the Queensland Regulation does not require ISO 45001. The only management system standard the Regulation names is AS 4801:2001, in the asbestos licensing definition above.
Some clients and tender processes ask suppliers for ISO 45001 certification, which means an independent audit of the system. If a tender asks for it, you will need to follow the standard and pass the audit. If nobody asks, you can still borrow its structure: policy, planning, consultation, operation, checking and review.
How to build your system: 6 steps
- Write a short policy and have the owner or senior officer sign it.
- Walk the work with your crew and record the hazards and controls in a risk register. The Code of Practice includes a sample risk register layout.
- Write procedures for your common tasks and keep a SWMS for each type of high risk construction work you do.
- Set up your records: training, inspections, plant maintenance, incidents and consultation.
- Agree your routines: toolbox meetings, monthly checks and a set review date.
- Check that it works. Ask whether the controls are working, fix gaps, and tell the people affected.
Templates to build your WHS management system
If you would rather not start from a blank page, the WHS manual template gives you a ready-made manual structure to adapt to your business, and the policies and procedures bundle covers individual policies and procedures you can add as you grow. Principal contractors can also look at the site safety management plan, which is for a specific site rather than the whole business. Check whatever plan you use against regulation 309(2), which lists what a WHS management plan must include. You can browse the full safety management systems range too.
To start with free documents, try the free work health and safety policy template, the free employee training register and the free risk assessment template.
This guide is general information, not legal advice. Check the current law or talk to WorkSafe Queensland for your situation.
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