OH Consultant

Construction: WHS Management That Works When You're Not Looking

Respirable crystalline silica drops to 0.025 mg/m³ on 1 December 2026, and diesel particulate gets a limit for the first time. With 14 Codes of Practice becoming legally binding on 1 July 2026, the compliance burden for construction PCBUs has never been heavier — and the fines have never been less insurable.

$287,000
Average SafeWork NSW construction fine
SafeWork NSW Prosecution Database 2022-24 (construction sector average)
14
Codes of Practice becoming binding
SafeWork NSW — Section 26A, commencing 1 July 2026
5+
New substance limits
Safe Work Australia WEL List, May 2025

What keeps construction managers up at night

Silica exposure in an era of tighter limits and mandatory registers

The respirable crystalline silica WEL drops 50% to 0.025 mg/m³ from December 2026, and the silica worker register has been mandatory since October 2025. Cutting, grinding, and drilling concrete generates silica dust at concentrations that may exceed the new limit unless controls are reassessed. A site that was compliant at 0.05 mg/m³ may find workers overexposed at 0.025 mg/m³ with identical processes. The Managing Risks of Respirable Crystalline Silica Code of Practice (February 2026) — now one of the newest codes and legally binding from July 2026 — requires documented assessment of every silica-generating task.

WHS Regulation 2025, Part 8A.1 (Silica worker register); Code of Practice — Managing risks of RCS (Feb 2026)

SWMS across multiple trades on one site

A principal contractor managing 12 subcontractors has 40+ active SWMS across the site. Each subcontractor submits their own, often in different formats, with varying levels of detail. The principal contractor must review every SWMS before high-risk construction work begins. When a process changes mid-project, the SWMS should update — but on a busy site, the updated document may never reach the workers who need it. If SafeWork NSW investigates an incident and finds the SWMS did not reflect the actual work being performed, the principal contractor shares liability.

WHS Regulation 2025, s.299-303 (SWMS for HRCW); 19 categories of high-risk construction work

Falls remain the leading cause of construction fatalities

Working at heights remains the most prosecuted area in NSW construction. Falls from scaffolding, leading edges, penetrations, and roofs account for a disproportionate share of SafeWork NSW improvement notices and prosecutions. Two separate codes — Managing Risks of Falls at Workplaces and Managing the Risk of Falls in Housing Construction — will both become legally binding on 1 July 2026. A principal contractor who cannot demonstrate they followed these codes (or documented a better approach) faces a prosecution where the code itself becomes the benchmark.

Code of Practice — Managing risks of falls at workplaces; Code of Practice — Managing the risk of falls in housing construction

What's changing for construction in 2026

WEL Impact (5 substances affected)

SubstanceCurrent WESNew WELChangeEffective
Silica (RCS)0.05 mg/m³0.025 mg/m³-50%1 December 2026
Diesel particulate matterNo current WES0.1 mg/m³NEW1 December 2026
Wood dust (inhalable)1 mg/m³0.5 mg/m³-50%1 December 2026
Formaldehyde1 ppm0.3 ppm-70%1 December 2026
Portland cement10 mg/m³PNOS appliesReclassifiedOngoing

Section 26A Applicable Codes (14)

Construction work
The primary code for all construction activity, covering site setup, hazard management, and coordination between trades
Managing risks of falls at workplaces
Covers scaffolding, edge protection, safety nets, harnesses, and administrative controls for all fall risks above 2 metres
Excavation work
Governs trench support, ground assessment, proximity to structures, and worker protection during any excavation
Managing risks of respirable crystalline silica
The newest code (Feb 2026), directly applicable to concrete cutting, grinding, drilling, and demolition
Moving plant on construction sites
New code (Dec 2025) covering exclusion zones, visibility, and traffic management for mobile plant

Penalty Exposure

Max Individual
$2,318,844 (Category 1) or $447,122 (Category 2)
Max Body Corporate
$11,150,183 (Category 1) or $2,235,363 (Category 2)
Uninsurable Since
10 June 2020
Recent Prosecution
Rahme Civil Pty Ltd was fined $400,000 and its director $50,000 after a sandstone footing was undermined during excavation, causing a brick wall to collapse and partially bury a 23-year-old worker (SafeWork NSW, November 2024).

How EHS Atlas solves this for construction

FileCheck
SWMS that workers sign before starting, not six months ago
professionally authored templates for high-risk construction work categories. Workers sign on their phone — GPS-stamped, time-stamped. When the process changes, the SWMS updates and workers re-sign before the next shift.
Subcontractor changes from wet cutting to dry cutting concrete. System flags the SWMS as requiring update. New version issued. Workers re-sign.
FlaskConical
Track silica, diesel particulate, and every other substance on site
Every hazardous chemical on site registered with current SDS. Automatically checked against incoming WEL. Substances without a current WES that gain a limit for the first time (diesel particulate) are flagged immediately.
Diesel generators run on site. System flags: diesel particulate gets a WEL of 0.1 mg/m³ from December 2026 — no current WES exists. Action required.
ClipboardCheck
Scheduled inspections with photo evidence and corrective actions
Configure templates for scaffolding checks, excavation inspections, plant pre-starts, and housekeeping. Findings link to corrective actions with owners and due dates.
Weekly scaffolding inspection finds missing toe board on level 3. Photo taken. Corrective action assigned. Tracked to completion before workers return.
AlertTriangle
From near-miss to notifiable incident
Structured incident logging with WHS Regulation classification. Notifiable incidents trigger immediate alerts with PCBU obligations and timeframes. Full investigation workflow.
Worker reports near-miss: excavation wall showed cracking. Logged. Investigation links to Excavation Code requirements. Preventive action assigned.
ShieldAlert
Risk assessments mapped to codes and regulations
Each assessment references specific WHS Regulation sections and applicable Codes. When a code becomes binding under s.26A, the system flags assessments for review.
Your excavation risk assessment references the Excavation Work Code. On 1 July 2026 the system confirms compliance status or flags gaps.
GraduationCap
Competency tracking for every trade on site
Track high-risk work licences, site-specific inductions, competency cards, and re-certification dates. Principal contractors see compliance status across all subcontractors.
Scaffolder's licence expires next week. System alerts the subcontractor and the principal contractor. Worker cannot access the site until renewed.
Scale
14 codes mapped to your construction operations
Track compliance status for each applicable code. Generate evidence of compliance or documented alternative approach for every code.
Moving Plant on Construction Sites code requires documented exclusion zones. Tracker confirms your site plan meets the code or flags where documentation is needed.

Your construction compliance calendar

January
Annual site safety management plan review
WHS Regulation 2025, s.309
Principal contractor obligation
March
Silica worker register update — new workers, new tasks
WHS Regulation 2025, Part 8A.1
Mandatory since October 2025
April
High-risk work licence audit — all trades on site
WHS Regulation 2025, Chapter 4
Unlicensed workers = immediate prohibition notice
June
Pre-July s.26A readiness — verify 14 codes documented
WHS Act s.26A
Non-compliance from 1 July 2026 is a breach
July
Section 26A takes effect — codes legally binding
WHS Act 2011 s.26A
Must follow code or document alternative
September
Principal contractor SWMS audit — all active SWMS reviewed
WHS Regulation 2025, s.299-303
Out-of-date SWMS = prosecution risk
November
Final WEL readiness — silica, diesel particulate, wood dust
Safe Work Australia WEL List
30 days to transition
December
WEL takes effect — all monitoring against new limits
WHS Regulation 2025 (as amended)
Immediate effect

See EHS Atlas configured for construction

Pre-loaded with construction SWMS templates, silica register integration, and your 14 applicable Codes of Practice — ready for a 15-minute walkthrough.