Pallet Jack / Manual Pallet Truck SWMS

This SWMS covers the full scope of manual pallet-truck and electric pallet-truck (EPT) operation across Australian warehousing, distribution, retail, and light-manufacturing environments — load pickup and break, trolley pushing and pulling, ramp ascent and descent, confined-aisle picking, stock replenishment, battery-swap on EPT fleets, lead-acid charging bay operation, and damaged-pallet quarantine. It is written for warehouse storepersons, grocery distribution-centre pickers, retail receivers, food-service and hospitality stock handlers, apprentice warehouse operators, and the PCBU whose duty of care extends to every worker who touches a pallet truck. Every control in this document has been authored against the Model WHS Regulation 2025 Part 4.2 Hazardous Manual Tasks, Part 4.5 Plant, and the Codes of Practice for Hazardous Manual Tasks (SafeWork Australia, 2020) and Managing the Risks of Plant in the Workplace (SafeWork Australia, 2020), with additional reference to AS 2359.1 Powered Industrial Trucks — General Requirements, AS 2359.2 Operations, AS/NZS 60335 Household and Similar Electrical Appliances — Safety (battery charging), and Schedule 1 of the WHS Regulation covering hazardous manual tasks.

Critically, pedestrian-operated pallet trucks — both manual and walk-behind electric — are excluded from the High Risk Work Licence framework. They are not "forklifts" under the WorkSafe Qld LF or LO licence definitions and no HRWL is required to operate them. This makes the SWMS the central compliance artefact: in the absence of a licence, the documented SWMS, the induction record, and the verification of competence are the evidence the PCBU relies on to show it has discharged its primary duty of care under Section 19 of the WHS Act. Pallet-jack work is not listed as High Risk Construction Work under Schedule 1 of the WHS Regulation and therefore does not trigger the mandatory Section 299 SWMS obligation, but the Part 4.5 plant duties and Part 4.2 manual-task duties apply to every PCBU whose workers operate a pallet truck. WorkSafe Victoria reports more than one worker per week is seriously injured by forklifts and pedestrian-operated load-shifting equipment in Victoria alone — the $40,000 Vic fine in October 2023 for a forklift leg-crush incident, and the broader May 2024 WorkSafe Vic guidance update, are the regulator signals that pallet-jack duty of care is actively enforced.

Hazards identified

12 hazards covered, sorted by priority.

Control measures

Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.

1. 1Eliminate manual pushing and pulling where reasonably practicable — deploy powered electric pallet trucks for any task requiring more than 500 kg moved more than 15 metres, or any repeated ramp ascent, and assess pallet-mover robotics for high-frequency point-to-point moves.
2. 2Pre-start inspection at the commencement of every shift: wheels, forks, hydraulic pump, tiller, dead-man control, emergency stop (on EPT), horn, and battery-state-of-charge. Any defect tags the jack out of service until rectified; pre-start log retained for 12 months.
3. 3Verify load weight against the jack's rated SWL before lifting. Where the load is unlabelled, a supervisor-approved pallet scale is used. Loads exceeding SWL are split or moved with an appropriate forklift under a separate SWMS.
4. 4Check load stability before the first movement: pallet condition, even distribution, strapping or shrink-wrap intact, no overhang of more than 50 mm, no upper-tier loose items. Quarantine damaged pallets to a designated area for controlled destruction.
5. 5Apply a documented no-riding policy — pallet trucks are not personnel carriers. Operators walk beside the jack with the tiller in the operating position, not in front of the load and not sitting on the forks.
6. 6Maintain a 1-metre exclusion zone between the operator's feet and the fork wheels at all times. AS/NZS 2210.3 safety footwear with a 200 J toe-cap rating is non-negotiable PPE — no exemption for contractor or casual workers.
7. 7Deploy EPT with dead-man tiller control, anti-rollback on slopes greater than 1:20, cushioned non-marking wheels, load backrest, and audible horn. Dead-man controls are tested on pre-start and inspected quarterly by a competent mechanic.
8. 8Plan and clear the transit route before load movement — check for pedestrians, rack legs, dock-edge proximity, wet patches, and overhead obstructions. Use a site-specific route map for high-frequency picks and communicate changes via daily pre-start.
9. 9Apply Hazardous Manual Tasks assessment (ManTRA or SafeWork Australia's Code of Practice risk-assessment tool) at every pick-face where operators perform more than 30 movements per hour, any ramp-push movement, or any cold-store pick below 5°C. Redesign pick-face height, aisle width, and pallet weight where ManTRA scores exceed threshold.
10. 10Damaged-pallet quarantine: operators report any split board, broken block, or protruding nail to the supervisor. Damaged pallets are removed from rotation and destroyed under a documented process; operators are not required to attempt repair.
11. 11Operate the EPT lead-acid battery charging bay per AS/NZS 60335-2-29: mechanical or natural ventilation sufficient to keep hydrogen concentration below 2% of LEL, no ignition sources within 1 metre, a dedicated SDS for the battery electrolyte, a spill kit within 10 metres, and an emergency eye-wash station plumbed to potable water within 10 metres.
12. 12Battery-swap protocol on multi-shift EPT fleets: swap at 50% state-of-charge or at the start of the next shift, whichever is earlier; battery lifting done with a rated hoist or battery-transfer cart, never by hand.
13. 13Training and competency: every operator completes a documented training programme covering pre-start, load stability, ramp protocol, pedestrian interaction, and emergency response. Competency is verified by a supervisor observation and sign-off; retraining every 24 months or after any incident. Note that no HRWL applies — this training record is the compliance evidence.
14. 14Apply psychosocial controls per WHS Regulation r55A-55D: pick-rate KPIs set with input from workers and the HSR, scheduled rest breaks every two hours, supervisor authority to pull an operator off the floor without penalty, and a no-blame near-miss reporting pathway.
15. 15PPE baseline: AS/NZS 2210.3 safety footwear (200 J toe-cap minimum), Class D/N hi-vis vest to AS/NZS 4602.1 in any area where MHE operates, AS/NZS 2161.3 mechanical-hazard gloves for load handling and damaged-pallet inspection, hearing protection in charging bays and high-noise dispatch areas, and AS/NZS 1337.1 eye protection during battery maintenance.
16. 16Daily pre-start toolbox talk covering scope, expected loads, route conditions, EPT battery-swap timing, ManTRA reassessment for any new pick-face, and any changes to the damaged-pallet quarantine procedure. Record attendance and any worker-raised issues.

Applicable Codes of Practice

Worked example

A grocery distribution centre in south-eastern Melbourne operates a two-shift pick-face aisle using 2.5-tonne electric pallet trucks. The B-shift operator commences at 22:00 with a fleet-assigned EPT. His pre-start checklist — wheels, forks, tiller, dead-man, emergency stop, horn, and state-of-charge — is completed in 3 minutes and logged on the fleet iPad. Over the 8-hour shift he completes 32 pallet lifts averaging 720 kg per pallet, all within the 2,500 kg SWL. At the 4-hour mark he swaps the battery in the dedicated charging bay — the bay has mechanical extract ventilation sized to keep hydrogen below 2% LEL, an SDS for the battery electrolyte posted on the wall, a spill kit within 5 metres, and a plumbed emergency eye-wash at the bay entry. AS/NZS 2210.3 safety footwear and Class D/N hi-vis are non-negotiable; mechanical-hazard gloves are donned for every load break where the pallet condition is questionable. At 02:15 he identifies a pallet with a split top-board during a pick; under the quarantine protocol he transfers the product to a fresh pallet and tags the damaged pallet red for end-of-shift destruction. He reports the event on the pre-start log, the supervisor reviews, and the damaged-pallet count is tracked on the weekly report as a leading indicator. No HRWL applies to his operation of the EPT — the completed SWMS, the induction record, and the supervisor's competency sign-off are the compliance evidence.

Related legislation

• Work Health and Safety Act 2011 (NSW) — Section 19 primary duty of care; Section 27 officer due diligence; Section 47 worker consultation; duty to provide information, training, and supervision.
• WHS Regulation 2025 (NSW) — Part 3.1 (risk management), Part 4.2 (hazardous manual tasks — Reg 60 risk assessment), Part 4.5 (plant — Reg 203-216), r55A-55D (psychosocial hazards).
• WHS Regulation Schedule 1 — Hazardous Manual Tasks definition and assessment requirements applicable to repeated pallet-truck operation.
• State-based high-risk work licence frameworks (SafeWork NSW, WorkSafe Vic, WorkSafe Qld) — confirmation that pedestrian pallet trucks are excluded from the LF/LO forklift licence definitions.
• Workers Compensation Act (state equivalents) — employer liability for musculoskeletal injury claims arising from pallet-truck operation.
• Safe Work Australia — Workplace Exposure Standards (transitioning to WEL on 1 December 2026) applicable to lead-acid battery electrolyte mist in the charging bay.

Frequently asked questions