Pedestrian-Controlled (Walk-Behind) Forklift SWMS

Pedestrian-controlled (walk-behind) forklifts — including walkie stackers, pallet movers and low-lift order pickers — are widely used across warehousing, retail back-of-house, cold storage and light manufacturing for low-bay pick, staging and dock transfer tasks. Although tiller-steer units under 750 kg lift capacity do not require a High Risk Work licence under WHS Regulation 219, they remain powered mobile plant under Chapter 4 Part 4.5 and have caused numerous Australian fatalities through crush, run-over and tip-over incidents. WHS Regulation 291 requires a Safe Work Method Statement before operating powered mobile plant where a person could be struck or crushed, and Regulation 39 requires the SWMS to be prepared in consultation with workers and kept available for inspection. This SWMS documents tiller-arm positioning, crush-zone exclusion, floor-condition assessment, battery handling, pedestrian segregation and emergency stop ('belly button') procedures so the PCBU can demonstrate compliance and operators can work without exposure to the foreseeable crush and impact risks inherent to walk-behind plant.

Hazards identified

7 hazards covered, sorted by priority.

Control measures

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

1. 1Elimination — Redesign pick layout to use gravity flow racking or conveyor for high-frequency lines, removing the need for walk-behind plant in congested zones entirely.
2. 2Elimination — Prohibit walk-behind forklift use on gradients exceeding manufacturer-rated incline and on external uneven surfaces by physical route barriers and signage.
3. 3Substitution — Where lift heights exceed 1.8 m or loads exceed 750 kg, substitute pedestrian unit with rider-operated counterbalance forklift operated under LF High Risk Work licence.
4. 4Engineering — Specify units fitted with belly-button emergency reverse stop, automatic park brake on tiller release, anti-creep, and audible/visual travel alarms compliant with AS 2359.2.
5. 5Engineering — Install mirrors at blind corners, pedestrian-exclusion bollards at aisle ends, line-marked walkways and Perspex viewing panels at swing doors per AS 1742.3 traffic management principles.
6. 6Engineering — Provide dedicated battery charging bay with mechanical ventilation, eyewash station, spill containment and insulated lifting equipment for battery exchange per AS 2676.1.
7. 7Administrative — Verify operator competency through documented in-house training and assessment to AS 2359.2 Appendix A; record on training matrix and reauthorise every two years.
8. 8Administrative — Conduct pre-start inspection each shift using manufacturer checklist covering forks, tiller controls, e-stop, horn, brakes and battery; tag out defects under WHS Reg 213.
9. 9Administrative — Enforce Traffic Management Plan segregating pedestrians, exclusion of mobile phone use, 6 km/h site speed limit, and no-go zones during pedestrian peak movements.
10. 10PPE — Mandate AS/NZS 2210.3 Class I steel-cap safety footwear with metatarsal guard, hi-vis vest to AS/NZS 4602.1, and AS/NZS 1337.1 safety glasses plus chemical apron during battery service.

Applicable Codes of Practice

High-Risk Construction Work triggered

Worked example

At a regional grocery distribution centre, a despatch supervisor runs the morning pre-start brief for four pickers commencing a pallet staging shift using two walkie stackers in the chilled goods aisle. The supervisor opens the Pedestrian-Controlled Forklift SWMS on the toolbox tablet and walks through the hazard register, pausing on the tiller-arm crush hazard because overnight cleaning has left aisle 7 partially blocked by a stillage. Together they assess the floor — still damp near the chiller threshold — and decide to apply the substitution control by re-routing through aisle 9 until the wet floor is squeegeed and signed. The supervisor confirms each operator's competency record is current, demonstrates the belly-button reverse stop on unit WS-04, and points out the mirror at the aisle 9 / main drag intersection. Each picker signs the SWMS sign-on register acknowledging the controls, including mandatory metatarsal-guard footwear which the supervisor visually verifies. Mid-shift, a delivery arrives requiring a battery exchange on WS-02. The picker stops, retrieves the SWMS, follows the documented battery-bay procedure — ventilation on, eyewash checked, insulated lifter engaged — and logs the exchange. When a maintenance contractor enters the zone unannounced, the picker halts work, escalates to the supervisor, and the SWMS is amended on the spot to add a temporary spotter control before resuming, with the amendment initialled by all four operators.

Related legislation

• WHS Act 2011 (model)
• WHS Regulation 2025
• AS 2550 — Cranes, hoists and winches; AS 1418 series

Frequently asked questions