WHS Management Plan Queensland: do you need one?
If the construction work is worth $250,000 or more, it's a "construction project" under the Work Health and Safety Regulation 2011 (Qld), and the principal contractor must have a written WHS (Work Health and Safety) management plan in place before work starts. Under $250,000 the plan isn't compulsory, but you still carry all your normal duties, and a plan is the easiest way to prove you're meeting them.
The $250,000 line
Regulation 292 defines a construction project as construction work with a value of $250,000 or more. WorkSafe Queensland says that figure includes project management costs, fittings, furnishings and any applicable taxes and levies, but excludes GST. So don't kid yourself that a $240,000 contract plus the client's own kitchen supply keeps you under.
On the Gold Coast that line gets crossed fast. A decent extension, a second storey, a new build of any size, a small commercial fit-out. If you're a builder doing anything more than bathrooms and decks, assume you're doing construction projects.
Who is the principal contractor
Every construction project has exactly one principal contractor at any time. Regulation 293 doesn't allow two. The principal contractor is the PCBU (Person Conducting a Business or Undertaking) that:
- commissions the construction work (usually the client), or
- is engaged by the client to have management or control of the workplace (usually the head builder).
In practice, on residential work, the client engages you and you become the principal contractor. That's not something you can shrug off onto the owner. It comes with the role.
What the principal contractor has to do
The plan is one duty on a longer list. WorkSafe Queensland's guidance sets out that the principal contractor must:
- put up signage that identifies the principal contractor and shows how to contact them
- prepare a WHS management plan before work starts and keep it up to date
- make sure everyone on the project knows about the plan before they start
- obtain a SWMS (Safe Work Method Statement) from each contractor before their high-risk construction work begins
- manage risks from construction materials and waste, plant, traffic and essential services
- make sure site facilities and amenities meet the required standard.
Miss the signage and you're an easy target for an inspector driving past. It's the cheapest duty on the list.
What goes in the plan
The Regulation doesn't want a novel. It wants a plan that a subbie can read in ten minutes and understand. At a minimum it must state:
- the names, positions and health and safety responsibilities of everyone on the project with a specific WHS role: site supervisor, first aider, the person who signs off SWMS
- how consultation, cooperation and coordination will happen between all the businesses working on the site
- how incidents will be managed, including who gets called and how notifiable incidents get reported
- the site-specific safety rules, and how workers will be told about them
- how SWMS will be collected, assessed, monitored and reviewed.
That last point is the one most builders skip. It's not enough to have a folder of subbie SWMS. You need to say who reads them, what they check, and what happens when a SWMS is rubbish. Because some of them will be.
The plan has to be written so it's easy to understand, and signed and dated by the principal contractor. A generic 80-page manual with the company name find-and-replaced is not a site-specific plan and inspectors know it on sight.
Keeping it on site
The plan has to be available for the length of the project. You can't let work start until the plan has been given to, or discussed with, everyone who needs it, and it must be available or readily available for inspection. A copy in the site shed or on the supervisor's tablet does the job. A copy on the office server in Southport does not.
Review it and revise it if anything changes in how risks will be managed. New scaffold contractor, a crane coming in, a change of supervisor. When you revise it, tell the people affected.
If there's a notifiable incident, keep the plan for at least two years after the incident.
Under $250,000: should you bother?
Legally the plan is only mandatory on a construction project. But the duties don't switch off below the threshold. You still have to consult, coordinate, manage incidents and deal with subbie SWMS on a $150,000 reno. The only difference is nobody's forcing you to write it down.
My advice after 35 years: write it down anyway. A short plan on a small job costs you an hour. Standing in front of an inspector after a fall with nothing on paper costs you a great deal more. Category 2 offences under the WHS Act 2011 (Qld) run to $1.5 million for a company and $300,000 for an individual PCBU or officer. The plan is your evidence that you had a system.
Sources
- WorkSafe Queensland – Work health and safety management plans
- WorkSafe Queensland – Principal contractors
- Safe Work Australia – Cross-jurisdictional table of maximum penalties (Aug 2025)
General information only — not legal advice. Laws and penalties change; check the current legislation or get advice for your own situation.