Plant registration and pre-start checks in Australia

Plant, cranes, forklifts, pressure equipment, hoists, powered mobile plant and more, is behind a large share of serious workplace incidents in Australia, so the WHS Regulations place specific duties on anyone who designs, supplies, manages or uses it. This guide explains what plant registration is, the difference between design and item registration, what has to be registered, and the ongoing duties, risk assessment, guarding, maintenance, pre-start checks and operator competence, that apply to all plant, registered or not. Requirements are administered by each state and territory regulator, so check the rules where you work.

What "plant" means and the duty to manage its risks

Plant is a broad term covering machinery, equipment, appliances and tools, and the powered mobile plant, lifting equipment and pressure equipment used across construction and industry. For all plant, the PCBU with management or control must manage the risks, which starts with a plant risk assessment that identifies the hazards (entanglement, crushing, cutting, high-pressure fluid, mobile-plant collision, and so on) and the controls, including guarding, isolation and safe operating procedures. Registration, where it applies, sits on top of that general duty; it does not replace it.

Design registration vs item registration

Two distinct kinds of registration exist, and they are often confused. Design registration is registration of the design of certain higher-risk plant with the regulator, done once for that design, typically the responsibility of the designer, manufacturer, importer or supplier. Item (or plant) registration is registration of an individual item of plant for use, done by the PCBU with management or control of that item, and generally renewed periodically. Some plant needs both its design and each individual item registered; some needs only design registration; most plant needs neither but is still subject to the general duties.

What has to be registered

The Regulations set out the specific classes of plant that require registration. They include items such as tower cranes, certain mobile cranes, building maintenance units, concrete-placing booms, some hoists (including personnel and materials hoists in certain configurations), escalators and moving walks, certain pressure equipment and boilers, amusement devices, and prescribed pressure and lifting equipment. The exact list is set in the Regulations and applied by your state or territory regulator, so if you own or control higher-risk plant, check whether the specific item requires design registration, item registration, or both. Using registrable plant that is not registered is a breach.

Pre-start checks and maintenance

Beyond registration, all plant must be inspected, tested and maintained in line with the manufacturer's guidance and its risk assessment, and kept safe to use. Operators should complete a pre-start check before use, brakes, steering, guards, warning and safety devices, tyres or tracks, leaks and visible damage, and take out of service any plant that fails. A logged daily pre-start is both good practice and the evidence that the checks are actually happening; "we always check it" is not the same as a record showing it was checked. Guarding, isolation for maintenance (lock-out/tag-out) and safe operating procedures round out the day-to-day controls.

Operator competence

Many items of plant require a high-risk work licence or specific training to operate, forklifts, various cranes, boom-type EWPs of 11 metres or more, and others. Even where no licence is legally required (scissor lifts, smaller booms, much powered mobile plant), the operator must be trained and competent, often evidenced by a verification of competency. Matching each operator's licence and competency to the plant they run, and keeping both the operator records and the plant inspection and registration records current, closes the loop.

Keeping the plant record straight

Between registration, risk assessments, maintenance schedules, daily pre-starts and operator competencies, plant generates an ongoing stream of records, and a lapsed registration, an overdue service or an operator on plant they are not competent on is exactly the kind of gap that surfaces after an incident. Keeping a register of your plant with its registration status, service and inspection due-dates, pre-start logs and matched operator competencies, with reminders before anything lapses, is what plant and equipment register software and WHS compliance software are built for.

Plant registration quick reference

• All plant needs a risk assessment and safe controls, registration is additional, not a substitute
• Design registration (once, by designer/supplier) vs item registration (per item, by the PCBU in control)
• Higher-risk plant, tower cranes, certain pressure equipment, some hoists, amusement devices and more, must be registered
• Using registrable plant that is not registered is a breach
• Maintain to manufacturer guidance; log daily pre-start checks; guard and isolate for maintenance
• Match operator licences and competency to the plant
• Keep registration, service, pre-start and operator records current and produceable

Related reading: high-risk work licences, excavation SWMS (mobile plant), and WHS compliance software. You can keep your plant register, services and operator competencies in one place with Complys, free for 30 days.