WHS management plans for construction projects: what's required

On larger construction projects, a Safe Work Method Statement for each high-risk activity is not enough on its own, the principal contractor must also prepare a written WHS management plan for the project as a whole. This guide explains when a WHS management plan is required, who prepares it, what it must contain, how it relates to the SWMS beneath it, and how to keep it current. Requirements are set under the model WHS Regulations and administered by each state and territory regulator, so check the rules where you work.

When is it required?

Under the model WHS Regulations, a WHS management plan is required for a construction project, construction work where the cost of the work is $250,000 or more. At that threshold the project must have a principal contractor, and the principal contractor must prepare the WHS management plan before construction work starts and keep it for the duration of the project.

Who is the principal contractor?

For a construction project, the person who commissions the work (the PCBU) is the principal contractor unless they appoint another PCBU to that role, which is the usual arrangement, where the head contractor is engaged and appointed as principal contractor. Only one principal contractor can exist for a project at any given time, and the WHS management plan duty sits with them. Understanding who holds that role matters, because the plan, the site safety rules, and the obligation to obtain and manage each trade's SWMS all flow from it.

What the plan must contain

The WHS management plan must set out the names, positions and health-and-safety responsibilities of everyone at the workplace whose position or role involves specific WHS responsibilities; the arrangements for consultation, cooperation and coordination between the duty holders on the project; the arrangements for managing WHS incidents; and any site safety rules, including how those rules are communicated to everyone at the workplace. It must also describe how safe work method statements for high-risk construction work will be obtained, collected, assessed, monitored and reviewed. In other words, the plan is where the project sets out how safety will be run, and the SWMS are the task-level methods that sit under it.

The plan and the SWMS beneath it

It helps to think of two layers. The WHS management plan is the project-level framework, who is responsible, how people consult and coordinate, how incidents and site rules are handled, and how SWMS are managed. Each SWMS is the method for a specific high-risk activity by a specific trade. The principal contractor obtains and reviews the SWMS through the mechanism the plan describes, and ensures high-risk work is carried out in accordance with them. One without the other leaves a gap.

Keeping it current

A WHS management plan is a living document, not a one-off at mobilisation. As subcontractors come and go, as activities change, and as the site progresses, the plan and its supporting SWMS must be kept up to date and readily accessible to everyone at the workplace. Where a worker needs to review the plan, the principal contractor must ensure they can. Keeping the plan, the SWMS register, the site rules and the duty-holder responsibilities live and in one place, rather than in a binder that was accurate only on day one, is what makes the plan a real safety instrument. That is what construction compliance software is built to support.

WHS management plan quick reference

• Required for a construction project, work costing $250,000 or more
• Prepared by the principal contractor before construction work starts
• Covers duty-holder responsibilities, consultation/cooperation/coordination, incident management and site safety rules
• Describes how SWMS for high-risk construction work are obtained, reviewed and kept
• Sits above the task-level SWMS as the project framework
• Kept current and accessible for the life of the project

Related reading: our SWMS guide, onboarding subcontractors, and construction compliance software. You can keep your WHS management plan, SWMS and subcontractor records in one place with Complys, free for 30 days.