WHS Regulation 2025, Part 6.4

Regulation

$250,000 total project cost

Value Threshold

Any HRCW regardless of value

Alternative Trigger

Principal contractor

Responsible Party

Before work commences

Must Be Prepared

Kept at workplace, readily accessible

Accessibility

You need a WHS management plan when you are the principal contractor for a construction project and the total cost of the construction work is $250,000 or more, or the project involves any of the 19 categories of high risk construction work regardless of project value. The $250,000 threshold includes the total cost of all construction work on the project, not just your contract value. If multiple contractors are engaged on a project with a combined value exceeding $250,000, the principal contractor must prepare a WHS management plan. On projects involving high risk construction work, the WHS management plan is required regardless of value because the elevated risk profile of the work demands a coordinated safety management framework. The principal contractor is the person or business with management or control of the workplace, typically appointed by the client or developer.

You do not need a WHS management plan when the construction project value is below $250,000 and the work does not involve any high risk construction work categories. Small residential renovation projects, minor commercial fit-outs, and routine maintenance work that falls below both thresholds do not trigger the WHS management plan requirement. However, even when a WHS management plan is not required, you still have a duty under the WHS Act to manage risks to health and safety. A risk assessment, safe work procedures, and appropriate controls must still be in place for all construction work regardless of project value. If you are a subcontractor on a project where a principal contractor has prepared a WHS management plan, you must comply with the plan but are not required to prepare your own separate WHS management plan for the project.

The WHS Regulation 2025 specifies the mandatory content of a WHS management plan. The plan must include the names, positions, and health and safety responsibilities of all persons at the workplace whose roles or activities are covered by the plan. It must include the arrangements for consultation, cooperation, and coordination between all persons who have a work health and safety duty in relation to the construction project. It must include the arrangements for managing incidents at the workplace. It must include any site-specific health and safety rules and the arrangements for ensuring all workers are informed of those rules. It must include the arrangements for the collection and any assessment, monitoring, and review of safe work method statements. The plan must be kept at the workplace and be readily accessible to any worker engaged in construction work at the workplace. It must be reviewed and revised as necessary throughout the project.

Failure to prepare a WHS management plan when required is a breach of the WHS Regulation 2025 that can result in enforcement action by the relevant WHS regulator. Enforcement options include improvement notices requiring the plan to be prepared within a specified timeframe, prohibition notices stopping work until the plan is in place, and infringement notices imposing on-the-spot fines. In serious cases, prosecution can result in significant fines. Beyond regulatory penalties, the absence of a WHS management plan on a construction project creates practical risks including poor coordination between contractors, unclear safety responsibilities, inconsistent incident response, and a weakened due diligence position for officers of the PCBU. If a serious incident occurs on a project where no WHS management plan exists, the absence of the plan becomes evidence that the PCBU failed to take a systematic approach to managing WHS risks on the project.