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Managing subcontractors on site

CClaus, Director — Hampton Homes · 35 years on site
Running the site · Updated 7 September 2026 · 4 min read

Here's the bit most head contractors get wrong: signing a subbie up doesn't hand them your safety duty. Under the Work Health and Safety Act 2011 (Qld) you cannot contract out of your duty as a PCBU (Person Conducting a Business or Undertaking). The subbie has their own duty for their own work. You still have yours for the site. When a subbie's apprentice falls off the roof, both of you get a visit from the inspector. So manage them properly: check them before they start, induct them on day one, read their SWMS (Safe Work Method Statement) before they lift a tool, and keep the records.

Shared duties, shared liability

The WHS Act works on the idea that more than one business can owe a duty for the same work at the same time. Your plumber is a PCBU. Your sparky is a PCBU. You're a PCBU. Each of you has the primary duty under section 19 to ensure, so far as is reasonably practicable, the health and safety of workers and other people affected by the work.

Safe Work Australia puts it plainly: a PCBU cannot "contract out" of their responsibility, and a duty cannot be transferred to another person. A clause in the subcontract saying "the subcontractor is solely responsible for safety" is worth nothing in court. It might help you recover money afterwards. It won't keep you out of the dock.

The 2024 amendments made this sharper. Industrial manslaughter in Queensland now lets multiple parties in a contracting chain be charged over the same death. Head contractor and subcontractor, together. The maximum is 20 years' jail for an individual and $10 million for a company.

Pre-qualification: before they get a start

Do this once per subbie, then update it yearly. It takes an afternoon and it's the best money you'll never spend.

Site induction: day one, every one

A white card is generic. It says the worker understands construction hazards in general. Your site induction is specific: where the power is, where the trench is, where the first aid kit is, who the supervisor is, what the site rules are, and what happens if there's an incident.

If you're the principal contractor on a construction project (work worth $250,000 or more), the WHS management plan must contain site-specific rules and how workers will be told about them. The induction is how you do that. Keep a signed register with name, company, date, and who inducted them. New worker turns up on Thursday with the tiler? Induct them Thursday. Don't wait for Monday.

Checking their SWMS

On a construction project, the principal contractor must obtain each contractor's SWMS before their high-risk construction work starts. Obtain doesn't just mean collect. WorkSafe Queensland expects your management plan to say how SWMS are collected, assessed, monitored and reviewed. Here's what I look for in five minutes:

Then walk out and watch. If the SWMS says edge rails and there aren't any, the SWMS is a lie and you're now the one who knew about it. Stop the work, fix it, note it.

Keep the records

Pre-qualification file, induction register, SWMS register, toolbox talk notes, and a diary of what you saw and what you did about it. SWMS have to be kept until the high-risk work is finished, and for at least two years if there's a notifiable incident. Same for the WHS management plan.

None of this is hard. It's an hour a week on a busy site. The builders who get into trouble aren't usually the ones who did nothing. They're the ones who did most of it, kept none of it, and couldn't prove a thing when it mattered.

Get the documents — from $97

Sources

General information only — not legal advice. Laws and penalties change; check the current legislation or get advice for your own situation.

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