WHS Management System Manual

The WHS Act does not require a document called a management system, but it requires what a system produces: a business must ensure health and safety so far as is reasonably practicable (WHS Act 2011 (NSW) s19), and its officers must exercise due diligence, which includes ensuring there are processes to manage risk and verifying that they are used (s27). This manual is that system in writing, ready to implement in a small or medium business. It follows the clause structure of ISO 45001:2018, which is the structure client prequalification questionnaires follow, and covers the policy, named responsibilities and an officer due diligence table, consultation and issue resolution, the risk management procedure, the legal register, objectives, training and induction, document control, thirteen operational procedures, incident management, inspections, internal audit, management review and corrective action. Fourteen registers and forms are included, with a cross-reference to each ISO 45001 clause. It is a manual for the whole business. It is not a project WHS management plan and it is not a SWMS.

Hazards identified

10 hazards covered, sorted by priority.

Control measures

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

1. 1Legal requirements table mapping the duties in the Act and Regulation to the sections of the manual
2. 2Signed health and safety policy with the commitments ISO 45001 requires
3. 3Responsibilities table for the director, coordinator, supervisors, workers, health and safety representative and contractors
4. 4Officer due diligence table: the six due diligence steps, how each is carried out and the evidence kept
5. 5Consultation procedure, including health and safety representatives, committees and a five-step issue resolution procedure
6. 6Hazard identification and risk management procedure with a risk matrix, required actions and review triggers
7. 7Legal register procedure and annual objectives and targets
8. 8Competence, induction and training procedure with a training matrix
9. 9Communication table and document and record control, with a retention schedule
10. 10Thirteen operational procedures: safe work procedures and SWMS, plant, contractors, purchasing, hazardous chemicals, manual tasks, facilities, PPE, fitness for work, psychosocial hazards, remote work, management of change, and emergency and first aid
11. 11Incident management: reporting, notifiable incidents, investigation and return to work
12. 12Monitoring schedule, health monitoring, internal audit and management review procedures
13. 13Nonconformity and corrective action procedure
14. 14Fourteen appendices: hazard register, legal register, objectives, training matrix, induction checklist, contractor, plant and chemical registers, incident report, corrective action register, inspection checklist, audit checklist, management review minutes and the ISO 45001 cross-reference

Applicable Codes of Practice

Worked example

A 25-person fabrication business was asked for its WHS management system in a prequalification questionnaire for a principal contractor. It had toolbox talks, a first aid kit and good habits, and no policy, no hazard register and no record of training. The questionnaire scored it at 31 percent and the work went elsewhere. With the manual completed, the owner had a signed policy, a hazard register built with the workshop staff, a training matrix that showed two expired forklift licences, and after three months an internal audit and a set of management review minutes to attach to the next questionnaire.

Related legislation

• Work Health and Safety Act 2011 (NSW) — s19 primary duty of care; s27 duty of officers; s28 duties of workers
• Work Health and Safety Act 2011 (NSW) — ss38 and 39 notifiable incidents; s46 consultation between duty holders; ss47 to 49 consultation with workers
• Work Health and Safety Act 2011 (NSW) — Part 5 health and safety representatives, committees and issue resolution
• Work Health and Safety Regulation 2025 (NSW) — ss34 to 38 identifying hazards, hierarchy of control, maintaining and reviewing controls
• Work Health and Safety Regulation 2025 (NSW) — s39 information, training and instruction; ss40 to 48 facilities, first aid, emergency plans, PPE and remote or isolated work
• Victoria: Occupational Health and Safety Act 2004 (Vic) — ss21 to 25, 35 to 39 and 144 (the Victorian edition is written against these as an OHS management system manual)

Frequently asked questions