WHS Regulation 2025, Part 3.1 and Part 6

Regulation

Work on or adjacent to trafficked road

HRCW Category

Vehicle-pedestrian interaction at workplace

Trigger

Separation of pedestrians and vehicles

Primary Control

Must be in WHS management plan

Construction Sites

Qualified traffic management designer

Public Roads

You need a traffic management plan whenever pedestrians and vehicles interact at your workplace, or whenever multiple vehicles operate in the same area. This is one of the most broadly applicable WHS obligations because vehicle-pedestrian interaction occurs at construction sites, warehouses, factories, distribution centres, retail premises with car parks, farms, mine surface areas, and virtually any workplace where goods are delivered or vehicles are parked. On construction sites, a traffic management plan is required as part of the WHS management plan for the project. Work on or adjacent to a road or railway used by traffic is a HRCW category that triggers SWMS requirements under Regulation 291. The traffic management plan must address the separation of pedestrians and vehicles, the control of vehicle movements including speed limits, one-way systems, and reversing procedures, and the management of intersections, loading areas, and pedestrian crossings.

You do not need a formal traffic management plan when there is no interaction between pedestrians and vehicles at your workplace and no risk of collision between vehicles. A small office with no on-site parking and no delivery area may not require a traffic management plan. However, the threshold for triggering a traffic management obligation is low because even a single vehicle delivery to a workplace creates a pedestrian-vehicle interaction risk. If delivery vehicles reverse into your premises, if forklifts operate in areas accessible to pedestrians, or if workers walk through car parks to access the workplace, you should have traffic management controls in place and they should be documented. The risk assessment process will determine whether a formal traffic management plan is required based on the frequency and nature of vehicle movements and the level of pedestrian activity.

A traffic management plan must identify all vehicle types that operate at or access the workplace, including trucks, light vehicles, forklifts, mobile plant, and any other powered mobile equipment. It must identify all pedestrian routes and areas where pedestrians may be present. It must show how vehicles and pedestrians are separated, which is the primary risk control. Separation can be achieved through physical barriers, designated walkways, exclusion zones, time-based separation where vehicles and pedestrians do not occupy the same area simultaneously, and traffic control devices including signs, line marking, and traffic lights. The plan must address reversing, which is the most common cause of vehicle-pedestrian incidents at workplaces. Controls for reversing include eliminating the need to reverse through one-way traffic flows, providing spotters for reversing heavy vehicles, installing reversing cameras and proximity alarms, and designating reversing areas that are excluded from pedestrian access. The plan must include a site plan showing vehicle routes, pedestrian routes, separation measures, speed limits, and signage.

Traffic management on construction sites involves additional complexity because the site layout, vehicle routes, and pedestrian areas change as the project progresses through different phases. The traffic management plan must be updated to reflect each phase of construction, with revised plans issued whenever significant changes to site layout, access, or traffic flow occur. On projects where construction work is carried out on or adjacent to a public road, the traffic management plan must comply with the relevant road authority requirements, which typically require the plan to be prepared by a person holding a traffic management design qualification. Workers performing traffic control on public roads must hold the appropriate traffic control competency. The principal contractor must ensure that all workers on site are inducted on the traffic management plan and understand the designated vehicle routes, pedestrian routes, speed limits, and exclusion zones. Delivery drivers and visitors must also be informed of the site traffic rules.