Australian WHS Principles for Warehousing and Transport
Model WHS laws and the Victorian difference, duties of businesses and workers, labour-hire arrangements, consultation, the Hazardous Manual Tasks Code of Practice and Chain of Responsibility.
Last reviewed September 2026 · Part of Manual Handling Training for Warehouse and Logistics Workers
Key learning points
- Describe how Australian WHS laws are structured, including the Victorian difference
- State the general duties of a business (PCBU) and of a worker
- Explain what labour-hire and casual workers are owed and by whom
- Describe the role of the Hazardous Manual Tasks Code of Practice and of consultation
- Recognise how Chain of Responsibility applies to loading and load restraint
One framework, several laws
Most Australian jurisdictions have adopted the model Work Health and Safety Act and Regulations developed by Safe Work Australia — New South Wales, Queensland, South Australia, Tasmania, the ACT, the Northern Territory, Western Australia (with local modifications) and the Commonwealth. Victoria has not adopted the model laws. It operates under its own Occupational Health and Safety Act 2004 and regulations, which use the term employer rather than PCBU and hazardous manual handling rather than hazardous manual tasks. The wording differs; the practical duties are much the same.
The organisation running the business — the person conducting a business or undertaking, or PCBU — holds the primary duty of care. It must ensure the health and safety of workers so far as is reasonably practicable. Workers hold duties too. In a distribution centre there may be several PCBUs on one floor at once: the site operator, a 3PL, a labour-hire agency, a transport company and their contractors. Each owes duties to the workers it influences.
What a business (PCBU) is generally expected to do
- Provide and maintain a safe working environment, safe systems of work and safe plant, so far as is reasonably practicable
- Identify hazardous manual tasks and control the risk, following the risk management process in the Code of Practice
- Provide suitable equipment — pallet jacks, lift tables, conveyors, trolleys, tail lifts — and keep it maintained
- Design work, slotting, pick rates and rosters so they do not create hazardous manual tasks
- Provide information, training, instruction and supervision, including site induction for every new and labour-hire worker
- Consult workers and their health and safety representatives about matters that affect them
- Have working systems for reporting hazards, incidents, near misses, injuries and equipment faults
What a worker is generally expected to do
- Take reasonable care for your own health and safety
- Take reasonable care that what you do, or fail to do, does not harm colleagues, drivers, customers or the public
- Comply with reasonable instructions given by the business
- Co-operate with reasonable policies and procedures — team-lift rules, pallet build heights, equipment pre-use checks
- Use equipment correctly and only when trained and, where required, licensed and authorised
- Report hazards, incidents, near misses, early symptoms and faulty equipment
Labour-hire and casual workers are owed the same duties
If you are placed by a labour-hire agency, both the agency and the host site are PCBUs and both owe you the primary duty of care. The host cannot hand its responsibility to the agency, and the agency cannot assume the host has it covered. You are entitled to the same induction, equipment, procedures and right to speak up as a permanent employee, from your first hour on site. Your own duties as a worker are the same regardless of how you are employed.
The Hazardous Manual Tasks Code of Practice
Safe Work Australia publishes the model Code of Practice: Hazardous Manual Tasks. It has been approved as a code in most jurisdictions, and Victoria has an equivalent Hazardous Manual Handling Compliance Code. A code is not law in itself, but it is admissible in proceedings as evidence of what is known about a hazard and what is reasonably practicable to control it. It sets out the risk factors, how to assess a task and the hierarchy of controls — the same structure this course follows. If your workplace has adopted it, your procedures should reflect it.
Consultation is the other half of the Code. A business must consult workers, so far as is reasonably practicable, when identifying hazards, deciding how to control risks, and making changes that may affect health and safety — a new racking layout, a re-slot, a new pick rate, a change to how containers are unloaded. Consultation happens through health and safety representatives, safety committees, toolbox talks and pre-start meetings, and through you saying plainly that a task is heavy, awkward or too fast. The people picking the orders see the problems first.
Chain of Responsibility
Where heavy vehicles are involved, the Heavy Vehicle National Law adds a Chain of Responsibility. Every party in the chain — consignors, packers, loaders, loading managers, schedulers, operators and drivers — has a primary duty to ensure the safety of transport activities so far as is reasonably practicable, covering mass, dimension, load restraint and driver fatigue. How a pallet is built, wrapped and restrained on the dock is part of that chain. The HVNL applies in New South Wales, Victoria, Queensland, South Australia, Tasmania and the ACT. Western Australia and the Northern Territory are outside the HVNL and run their own road transport laws with similar concepts.
Who is who
- Safe Work Australia
- Develops the model WHS laws and the model Codes of Practice; it does not enforce them
- State and territory regulators
- SafeWork NSW, WorkSafe Victoria, Workplace Health and Safety Queensland, WorkSafe WA, SafeWork SA, WorkSafe Tasmania, WorkSafe ACT and NT WorkSafe inspect, advise and enforce
- National Heavy Vehicle Regulator
- Administers the HVNL and Chain of Responsibility outside WA and the NT
- Health and safety representative (HSR)
- Elected by a work group to represent workers on safety matters; can raise issues, inspect and, if trained, direct unsafe work to cease
- Your supervisor or team leader
- The first place to raise a hazard, a faulty aid or an unrealistic rate
- You
- Follow procedures, use aids, speak up, report — and stop if a task is unsafe
Requirements differ
Work health and safety laws, regulators and codes differ between Australian states and territories, and procedures differ between employers and individual sites. This course provides general education only and is not legal advice. Where this course and your workplace procedure differ, follow your workplace procedure and raise the difference with your supervisor.
Practical scenario
Scenario: the truck leaves in twenty minutes
You are a labour-hire picker. The site procedure says 2.4 m flat-pack cartons are a two-person lift. The host supervisor tells you the truck leaves in twenty minutes and to load them yourself because everyone else is busy.
Whose duties apply, and what should you do?
Reveal the explanation
The host owes you a safe system of work and cannot switch off its own procedure because a truck is waiting. You still have a duty to follow the procedure and to take reasonable care of yourself. Say that the procedure requires two people and ask for a second person or a suitable aid such as a trolley. If the instruction stands, do not perform the lift alone; report it to the host supervisor's manager or the HSR, and tell your labour-hire agency. A missed dispatch is recoverable. A disc injury on a casual contract often is not.
Knowledge check
These questions are for your own learning. They are not part of the final assessment.
1. Which of the following is a worker's duty under Australian WHS principles?
Workers must take reasonable care for themselves and others and co-operate with reasonable procedures and instructions. Providing equipment and procedures is the business's duty.
2. A labour-hire worker is injured at a host distribution centre. Who owed them the primary duty of care?
Both businesses hold the primary duty and must consult and co-operate with each other. Neither can transfer its duty to the other.
3. What is the status of the Hazardous Manual Tasks Code of Practice?
Codes of practice describe how to meet WHS duties. They set no weight limit; they set out a risk management process.
4. Chain of Responsibility under the Heavy Vehicle National Law means:
CoR spreads responsibility for safe transport activities along the chain. WA and the NT are outside the HVNL and have their own road transport laws.
Sources and further reading
The framework this module summarises, from the regulators themselves. Your workplace procedures always take precedence.
- Safe Work Australia — Model Code of Practice: Hazardous manual tasks — The national code the state and territory regulators adopt or mirror.
- Safe Work Australia — Lifting, pushing and pulling (manual tasks)
- Safe Work Australia — Model WHS laws
- National Heavy Vehicle Regulator — Chain of Responsibility — Loading and load restraint duties (not applicable in WA and the NT).