Who is responsible for manual handling training for labour-hire and casual workers?
Both the host business and the labour-hire agency are responsible, and neither can hand the duty to the other. Under Australian WHS law each is a person conducting a business or undertaking with duties to the same worker, and they are required to consult, cooperate and coordinate. In practice the host controls the site, the tasks and the equipment, so site induction and task-specific training fall to it; the agency must make sure the worker has the general knowledge to start safely and that the host's induction actually happens. Directly employed casuals are simply employees, owed the same training as permanent staff. This guide sets out who does what, and what a certificate does and does not prove.
Last reviewed September 2026 · Applies to the Manual Handling Training for Warehouse and Logistics Workers course.
Who holds the duty
The model Work Health and Safety Act, in force everywhere except Victoria, defines a worker to include labour-hire workers and casuals, and it places the primary duty of care on every business that directs or influences their work. A labour-hire worker on a distribution centre floor is owed a duty by the host, who controls the workplace, and by the agency, who placed them there. Where duties overlap, each business must discharge its own duty to the extent it can influence the matter, and the Act requires them to consult, cooperate and coordinate with each other.
Victoria reaches the same place by a different route. Under the Occupational Health and Safety Act 2004, a labour-hire worker is treated as an employee of the host for the purposes of the host's duties, while the agency keeps its own duties as the worker's employer. Victoria, Queensland, South Australia and the ACT also run labour-hire licensing schemes that require agencies to hold a licence and to meet their workplace safety obligations.
The worker's duty is the same as anyone else's: take reasonable care for your own safety and others', follow reasonable instructions and cooperate with site policies. That duty is easier to meet when someone has actually told you what the site's policies are.
What the host site must do at induction
The host is the only party that knows its own pick faces, dock, aids and rates, so site-specific manual handling training is the host's responsibility. A site induction that covers emergency exits and the amenities but not the tasks a labour-hire worker will be doing that shift has missed the part that prevents injury. Module 2, Australian WHS Principles for Warehousing and Transport, covers the labour-hire arrangement in detail.
Sign-off on an induction is a record that the induction happened, not a substitute for it. If you are asked to sign for training you did not receive, do not sign, and tell your agency.
- The manual tasks the worker will actually do, and which ones are hazardous.
- The aids available for those tasks and hands-on instruction on them: pallet jacks, lift tables, roll cages, conveyors, tail lifts.
- Site trigger weights, team-lift rules and tasks that are off limits without authorisation.
- Which equipment needs a licence or site authorisation, including forklifts and powered pallet trucks.
- Where the floor, dock, ramps and cold rooms change the risk.
- How to report hazards, defects and early symptoms on this site, and to whom.
- Supervision arrangements while the worker is new.
What the agency must do
The agency cannot induct you on a site it does not control, but it holds duties it cannot delegate. It must satisfy itself that the host has a safe system of work and will provide site induction, task training and supervision; that the worker has the general knowledge and any licences the role needs; and that the host's arrangements are actually happening, which means checking in, visiting where practicable and acting on what workers report.
That is why many agencies ask new starters to complete manual handling theory before placement. It gives the agency evidence of the general knowledge part of the training, and it lets the host's induction focus on the site rather than starting from what a hazardous manual task is. It also means the worker arrives able to recognise when an induction has missed something.
The agency is also a reporting route. If a host does not induct you, pressures you to use equipment you are not authorised on, or ignores a hazard you have raised, the agency has its own duty to act, up to and including removing you from the placement.
What a certificate proves, and what it does not
A Certificate of Completion from this course shows that on a given date you completed eight modules of manual handling theory written for warehousing, freight and delivery work, and passed a twenty-question assessment. It carries a unique number that a host or agency can verify online. That is genuine evidence of the general knowledge part of the training duty, and it is portable between placements.
It is non-accredited workplace training. It is not HLTWHS005 Conduct manual tasks safely, is not Nationally Recognised Training and does not issue a Statement of Attainment. It is not a forklift or other high-risk work licence, and it is not a site induction. It cannot prove that you know where this site's aids are, what its trigger weights are or how its dock works, because no online course can.
Used properly, the certificate and the site induction are two halves of one arrangement. A host or agency that treats the certificate as the whole of manual handling training has not met its duty; a worker who has the certificate but no induction should say so.
If you turn up and there is no induction
It happens, particularly on night shifts and during peak. Ask the supervisor for the site's manual handling induction before you start picking, loading or using any aid. Do not operate powered equipment, a tail lift or a dock leveller you have not been shown on this site, whatever you used at the last one. If the induction does not happen, tell your agency the same day.
You are not being difficult. The host's duty to train you and the agency's duty to check are both the law, and a worker who reports a gap is doing what the WHS framework expects. Module 8, Reporting, Incidents and Ongoing Safety, sets out the escalation route for labour-hire workers, including what to do when the host and the agency each point at the other.
Our training is theory. The host's site-specific induction, the agency's checks and the guidance of your state or territory regulator take precedence over anything general in this course.
Common questions
Sources
- 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)
- National Heavy Vehicle Regulator — Chain of Responsibility — Loading and load restraint duties (not applicable in WA and the NT).
General information about Australian work health and safety duties, not legal advice. Your employer’s procedures and the regulator in your state take precedence.
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