WHS basics for small builders
You do not need a safety department. You need five documents, used every job: a WHS (Work Health and Safety) policy or plan, SWMS (Safe Work Method Statements) for high risk work, an induction register, an incident report form, and a site inspection checklist. That is the whole system for a crew of one to ten. Everything else is optional.
Why documents at all
The WHS Act 2011 (Qld) puts the primary duty on the PCBU (person conducting a business or undertaking) — that is you, whether you are a sole trader or a Pty Ltd. You must ensure, so far as is reasonably practicable, the health and safety of your workers. Nothing in that sentence says "write it down".
But "reasonably practicable" is judged after the event, by people who were not there. The How to manage work health and safety risks Code of Practice 2021 puts it plainly: records let you show how decisions about controlling risks were made, and demonstrate to regulators that risks are being managed. No record, no proof. The paperwork is not for WHSQ (Workplace Health and Safety Queensland). It is for you.
1. WHS policy and site plan
One or two pages that say who is responsible for what, how you consult with workers, what happens when someone is hurt, and the site rules. Sign it, date it, put your name on it.
If the project costs $250,000 or more, this becomes a legal requirement. Under section 292 of the WHS Regulation 2011 (Qld) that is a "construction project", and the principal contractor must prepare a written WHS management plan before work starts. It has to include names and responsibilities, consultation arrangements, incident arrangements, site-specific rules, and how SWMS are collected and reviewed. Every worker has to be told about it before they start, and it must be kept for the length of the project — two years if there is a notifiable incident.
Below $250,000 a plan is not required. Do a short one anyway. It is the document an inspector asks for first.
2. SWMS for high risk construction work
A SWMS is required before any high risk construction work starts. There are 18 listed activities. For a small builder the usual ones are falls over 2 metres, asbestos, trenches over 1.5 metres, structural demolition, confined spaces, work near live electrical, work near traffic, and powered mobile plant.
A SWMS must identify the high risk work, list the hazards, describe the controls, and describe how those controls are implemented, monitored and reviewed. Prepare it with the workers who will do the work, not in the ute on your own. Keep it on site until the work is done. Review it if anything changes. If there is a notifiable incident, keep it for at least two years.
No dollar threshold. A $4,000 roof repair over 2 metres needs a SWMS.
3. Induction register
Two things go in here. First, that you sighted a general construction induction card (white card) for every person before they did construction work. Anyone who has not done construction work in the previous two years needs a new one. Second, that you gave a site-specific induction — the site rules, the hazards on this job, where the first aid kit and the amenities are, what to do if something goes wrong.
WHSQ's own guidance: keep a record of the people inducted and the date. Name, card number, date, signature. It is the first document an investigator uses to work out who was on site and whether they were told anything.
4. Incident report form
Every injury, near miss and dangerous event gets written up on the day. What happened, who was involved, what you did about it. Not a novel — half a page.
Some incidents are "notifiable": a death, a serious injury or illness (amputation, serious head or eye injury, serious burn, spinal injury, and so on), or a dangerous incident like a structure collapse, an electric shock, or an object falling from height that exposes someone to serious risk. Those must be notified to WHSQ immediately after you become aware of them, the site must not be disturbed (except to help the injured or make it safe), and you must keep a record for at least five years. Penalties apply for both.
The form is what makes "immediately" possible while the ambulance is leaving.
5. Site inspection checklist
A weekly walk-around with a tick sheet. Edge protection, scaffold tags, ladders, electrical leads and RCDs (residual current devices), excavations, housekeeping, PPE (personal protective equipment), first aid kit, amenities. Date it, sign it, fix what you found and write down that you fixed it.
This is the document that proves you were actually looking. Inspectors and lawyers read it the same way: a gap in the checklist dates is a gap in your supervision.
How it fits together
- Policy or plan: sets the rules. Once, updated yearly or per project.
- SWMS: the rules for the dangerous bits. Per job, per activity.
- Induction register: proves people were told the rules. Per person, per site.
- Inspection checklist: proves the rules were followed. Weekly.
- Incident form: proves you responded when the rules failed. As needed.
Five documents in a ring binder or a folder on your phone. If WHSQ turns up, you hand it over and get back to work.
Sources
- WorkSafe Queensland — Work health and safety management plans
- WorkSafe Queensland — Safe work method statements
- WorkSafe Queensland — Notify WHSQ of an incident
- How to manage work health and safety risks Code of Practice 2021 (Qld)
General information only — not legal advice. Your duties depend on the work you do; check the WHSQ website or get advice for your own situation.