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Safety management plan for construction: where to start

What a construction safety management plan (WHS management plan) must cover, who owns it, how to write it and how to keep it current on a project.

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A construction safety management plan is the document that sets out how health and safety will be managed on a building project: the hazards, the controls, who is responsible for what, and how incidents, consultation and changes are handled. In the WHS laws it's called a WHS management plan. On a construction project worth $250,000 or more, the principal contractor must have one (regulation 292 sets the threshold, and regulation 309 sets out what it must include).

This guide explains who owns the plan, what it should contain and how to keep it current.

Who owns the plan

On a construction project, the principal contractor is responsible for the WHS management plan. The principal contractor is the person in control of the site, usually the head builder. Every contractor and subcontractor on the site must work to the plan, and the plan must be understood by everyone who works under it.

The plan doesn't replace the duties of the people doing the work. Each business still has its own duties under the WHS Act. The plan is the shared rulebook that makes those duties work together on one site.

What the plan must cover

Regulation 309 requires the plan to include arrangements for collecting, assessing, monitoring and reviewing the SWMS for the project. Beyond that, a practical plan covers the areas below. Write each one for the project you're running, not as a generic statement.

1. Project and people

Name the principal contractor, the project manager, the site supervisor, the WHS representative and the main subcontractors. Include each person's role and safety responsibilities, and how to contact them. A worker who doesn't know who to report to will report to nobody.

2. Site information

Describe the site, the access points, security, working hours, emergency arrangements and the rules for visitors. Note the known hazards on the site, such as overhead lines, underground services, neighbouring properties and unstable ground.

3. Consultation and coordination

Set out how the project talks about safety. Daily pre-start meetings, weekly toolbox talks and site safety meetings all work well. Record what was discussed and what changed as a result. Our guide to running a toolbox talk that works covers how to make them useful.

4. Hazards, risks and controls

List the high-risk construction work on the project and how each one will be managed. Link each activity to its SWMS. Use the hierarchy of controls to choose controls, and say who checks that each control is in place.

5. Incidents and emergencies

Explain how incidents and near misses are reported, who is notified, how injured people get help, and how the site is made safe afterwards. Include the emergency plan and the rescue arrangements for work at height and in excavations.

6. Safe work procedures and SWMS

Explain how SWMS are prepared, approved, given to the principal contractor, signed by workers and reviewed. The WHS Regulations require the SWMS to be readily accessible and understandable to the workers who use them (regulation 299). The plan should say where the current versions are kept.

7. Training and competency

Set out the induction for the site, the licences and training each activity needs, and how competency is checked. Every construction worker needs a general induction card (commonly called a 'white card').

8. Records and document control

Explain how documents are kept, how versions are controlled, and how long records are retained. The record of who signed which version is the evidence you'll need after an incident.

Other areas to consider: hazardous chemicals and their register, plant and equipment, traffic management, and workplace security. The plan should point to the more detailed document for each one, rather than repeating it.

How to write it

  1. Start with the site walk. Walk the site with the supervisors and the subcontractors who will be on it. Note what you see, not what you expect to see.
  2. List the high-risk work. Identify each activity that is high-risk construction work. Check against the Do I need a SWMS? checker.
  3. Write the controls with the people who do the work. Workers spot gaps that the office misses. Consultation is a legal duty under section 47 of the WHS Act.
  4. Name an owner for every control. Each control needs a person who makes sure it's in place and a way to check it.
  5. Issue the plan to everyone. Give it to each subcontractor before they start, and make sure workers can see the parts that affect them.
  6. Set a review date. Set a date to review it, and review it whenever the scope, the trades or the site changes.

When the plan must change

Review and revise the plan whenever the risks change. Common triggers are:

  • a new trade or subcontractor joins the project;
  • the scope or method changes, such as moving from brick to steel framing;
  • an incident or near miss shows a control isn't working;
  • an inspection finds a gap; or
  • a worker or health and safety representative raises a concern.

Each time the plan changes, tell the people it affects, and make sure everyone is working from the current version. Old copies on site are a common reason for an inspector to ask questions.

Templates to start from

Start from a plan that already covers the structure above, then adapt it to the site. Our construction OHS/WHS project management plan and construction HSEQ site management plan are good places to start. For managing subcontractors, see managing contractors' WHS documents.

How SafetyDocs helps

SafetyDocs has 1,250+ expert-written management plans and SWMS, so the structure is in place before you start adapting it. The job, client and site details fill in automatically. The builder comments on the exact line and approves the plan before it goes out. Subcontractors and workers sign on any phone with no app or account. When the plan changes, everyone who signed is asked to sign the new version, so you have a clear record of which version was in force.

Common questions

What is the difference between a safety management plan and a WHS management plan? Nothing legally. The WHS laws use the term WHS management plan, and the industry often calls the same document a safety management plan.

Who must prepare the plan? On a construction project, the principal contractor. It's needed for projects worth $250,000 or more.

Does a small job need a plan? The WHS management plan requirement applies to construction projects worth $250,000 or more. Smaller jobs still have WHS duties, and a short written plan is a practical way to meet them.

How often should it be reviewed? Review it when the risks change, after any incident, and at regular points during the project.

This is general information, not legal advice. Check the current law with your WHS regulator.

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