Understanding WHS responsibilities on construction projects
In Queensland the primary obligation for safety rests with the person conducting a business or undertaking (PCBU). The Work Health and Safety Act requires PCBUs to ensure, so far as is reasonably practicable, the health and safety of workers and others affected by the work. That duty extends beyond direct employees to contractors, subcontractors, visitors and the public who may be exposed to construction hazards.
Officers of PCBUs — company directors, senior managers and others who make decisions about how work is carried out — also have a duty to exercise due diligence. This includes ensuring appropriate resources, systems and processes are in place to manage risks. Workers must take reasonable care for their own health and safety and cooperate with reasonable policies, procedures and lawful directions.
Principal contractor obligations in Queensland
On multi-party construction projects the principal contractor (often the head contractor or main PCBU) has specific obligations to coordinate safety across the site. These include preparing and implementing a site-specific work health and safety management plan, ensuring consultation mechanisms are effective, and maintaining control over high-risk activities.
Practical responsibilities for a principal contractor include conducting site inductions for everyone who enters the site, maintaining a register of plant and safety-critical equipment, coordinating traffic and exclusion zones, supervising subcontractors, and ensuring that safe systems of work — such as permit-to-work systems and emergency procedures — are in place and followed.
Contractor compliance: pre-qualification, documentation and supervision
Principal contractors must not rely on verbal assurances. Effective contractor compliance starts with pre-qualification: check licences (including QBCC licensing where relevant), qualifications, training records, insurances and past safety performance. Require each contractor to provide evidence of their WHS management systems and relevant Safe Work Method Statements (SWMS) before work begins.
Contracts and scopes of work should allocate WHS responsibilities clearly. Require contractors to frequent toolbox talks, attend site safety meetings, and report incidents and hazards promptly. Regular audits and inspections are essential — they verify that the controls described in documentation are applied in practice and identify gaps that need correction.
Risk assessments and managing high-risk construction work
Risk assessment is the foundation of compliance. It must be systematic: identify hazards, assess the likelihood and consequence of harm, apply the hierarchy of controls and document decisions. For construction work, particular attention should be given to high-risk activities such as work at heights, excavation, working near energized services, lifting operations and asbestos removal.
Safe Work Method Statements are mandatory for high-risk construction work. A SWMS should describe the task, list hazards, specify control measures, and set out monitoring arrangements. But a SWMS is only effective when it is used as a live document — reviewed on task changes, after incidents, or when conditions change — and communicated clearly to workers performing the task.
Practical controls and hierarchy application
Apply the hierarchy of controls in this order: elimination, substitution, engineering controls, administrative controls, and personal protective equipment. Where elimination is not possible, use physical barriers, exclusion zones and engineered solutions (such as guardrails or edge protection) rather than relying solely on PPE. Administrative controls — permits, supervision, and work sequencing — support engineering controls but should not be the primary control for major hazards.
Examples of practical measures include: planning lifts with competent riggers and lift plans, isolating plant during maintenance, using certified scaffolding and edge protection for roof work, and employing monitored breathing apparatus and clearance procedures for confined space entry.
Consultation, training and workforce engagement
Consultation with workers and health and safety representatives (HSRs) is a legal requirement and a practical necessity. Establishing regular consultation forums, toolbox talks and clear hazard reporting pathways improves situational awareness and helps identify hazards early. Training must be specific to tasks and documented; generic induction alone is insufficient for skilled or high-risk tasks.
Encourage reporting of near-misses and hazards without blame. Use those reports to run quick investigations, capture lessons learned, and adjust the risk controls. Visible leadership — site visits by responsible officers, active participation in safety meetings and prompt corrective action — reinforces a culture of compliance.
Monitoring, incident management and continuous improvement
Monitoring programs should include routine inspections, scheduled audits, equipment checks and verification of contractor licences and competencies. When an incident occurs, ensure immediate response to preserve safety, then conduct a structured incident investigation to determine root causes and implement corrective actions. Notifiable incidents must be reported to Workplace Health and Safety Queensland as required by the Act.
Keep accurate records of risk assessments, SWMS, training, maintenance, incidents and audits. These records support continuous improvement, demonstrate due diligence and provide evidence in the event of regulator inquiries or prosecutions.
When to engage external support
Many Brisbane contractors and principal contractors engage external experts to help design and implement robust WHS systems, complete formal risk assessments, or conduct independent audits. A suitably experienced external advisor can also assist with training and with preparing documentation required by the regulator. For businesses seeking local expertise, professional assistance such as Stay Safe Consulting Brisbane can provide practical WHS support tailored to Queensland construction industry requirements.
A compliance checklist for principal contractors
To summarise, principal contractors should ensure they have: a site-specific WHS management plan; documented risk assessments and SWMS for high-risk work; verified contractor pre-qualification and licences; induction and training systems; inspection, audit and incident reporting processes; and active worker consultation mechanisms. Demonstrating these controls and acting on findings from audits and incidents are key to meeting legal obligations and reducing harm.
Final considerations
Compliance in the Brisbane construction industry is a continual process, not a one‑off exercise. The regulatory framework sets expectations, but practical, site-level application of those duties through risk-based decision making, competent supervision and clear documentation is what prevents injury and enforces the protection of workers and the public. Principal contractors who embed these practices position their projects to run more safely, more predictably and with reduced exposure to regulatory and commercial risk.
Gdańsk shipwright turned Reykjavík energy analyst. Marek writes on hydrogen ferries, Icelandic sagas, and ergonomic standing-desk hacks. He repairs violins from ship-timber scraps and cooks pierogi with fermented shark garnish (adventurous guests only).