OH Consultant

General Manufacturing: WHS Management That Works When You're Not Looking

Manufacturing accounts for 12% of serious workers' compensation claims in NSW despite employing 6% of the workforce. With 12 Codes of Practice becoming legally binding on 1 July 2026 and exposure limits tightening across multiple substance classes on 1 December 2026, the compliance gap between what manufacturers do and what the law requires is about to get significantly wider — and the fines are uninsurable.

2x average
Serious claims rate vs workforce share
SafeWork NSW Statistical Bulletin
15+
Substances with WEL changes (manufacturing)
Safe Work Australia WEL List
12
Codes of Practice becoming binding
SafeWork NSW — Section 26A

What keeps manufacturing managers up at night

Diverse chemical hazards across production lines

General manufacturing encompasses metalworking fluids, adhesives, coatings, cleaning solvents, and process chemicals. Each product line may introduce different hazardous substances. The chemical register must capture every substance, maintain current SDS documentation, and assess each against incoming WEL changes. A facility using 50+ chemicals cannot reliably manage this in spreadsheets.

WHS Regulation 2025, s.346; Code of Practice — Managing risks of hazardous chemicals

Plant and machinery risks

Presses, lathes, CNC machines, conveyors, and packaging equipment present nip points, entanglement hazards, crush risks, and ejection hazards. The Managing Risks of Plant Code requires documented risk assessment for every piece of plant, maintenance schedules, and lockout/tagout procedures.

Code of Practice — Managing the risks of plant; WHS Regulation 2025, Chapter 5

Noise across the factory floor

Manufacturing environments routinely exceed 85 dB(A). The Managing Noise Code requires assessment, engineering controls, hearing protection programs, and audiometric testing. Noise is often the most widespread and least controlled hazard in general manufacturing.

Code of Practice — Managing noise and preventing hearing loss

What's changing for general manufacturing in 2026

WEL Impact (15 substances affected)

SubstanceCurrent WESNew WELChangeEffective
Formaldehyde1 ppm0.3 ppm-70%1 December 2026
Styrene50 ppm20 ppm-60%1 December 2026
Welding fume substancesVariousVarious (reduced)Up to -99%1 December 2026

Section 26A Applicable Codes (12)

Managing risks of hazardous chemicals
Governs chemical register, SDS management, risk assessment, and control measures for all hazardous substances in the facility
Managing the risks of plant
Covers risk assessment, maintenance, and lockout/tagout for presses, lathes, CNC machines, conveyors, and packaging equipment
Hazardous manual tasks
Addresses repetitive lifting, awkward postures, and sustained force across production and warehouse areas
Managing noise and preventing hearing loss
Requires formal noise assessment, engineering controls, hearing protection programs, and audiometric testing for environments exceeding 85 dB(A)
Confined spaces
Applies to work inside tanks, vessels, and enclosed process equipment requiring confined space entry procedures

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
Manufacturing sector average fines continue to increase, with Category 2 prosecutions routinely exceeding $200,000 for plant and chemical safety failures.

How EHS Atlas solves this for manufacturing

FlaskConical
50+ chemicals tracked against incoming WEL
Upload SDS documents and the system extracts GHS classification, hazard statements, and composition. Every chemical is automatically checked against the December 2026 WEL. Substances with significant reductions are flagged for immediate review.
A new metalworking fluid is introduced to the CNC line. The SDS shows formaldehyde as a releasing agent. EHS Atlas flags it: WEL dropping 70% to 0.3 ppm.
ShieldAlert
Plant, chemical, noise, manual handling
Structured risk assessments covering every hazard category in manufacturing. Each assessment maps to specific WHS Regulation sections and applicable Codes of Practice. When a Code changes, the system flags assessments for review.
Your press risk assessment references the Managing Risks of Plant Code. On 1 July 2026 the system confirms compliance status or flags gaps in guarding documentation.
FileCheck
High-risk tasks across production lines
professionally authored templates for manufacturing high-risk tasks. Workers sign on their phone before starting work. When a process changes, the SWMS updates and workers re-sign.
New coating process introduced on Line 2. System generates SWMS template covering chemical hazards, ventilation requirements, and PPE. Workers sign before first use.
ClipboardCheck
Plant guards, LEV, housekeeping, fire equipment
Configure inspection templates for machinery guarding, local exhaust ventilation, housekeeping audits, and emergency equipment. Schedule on a cycle or trigger by event.
Monthly plant guard inspection finds CNC guard interlock bypassed. Corrective action assigned. Machine locked out until guard reinstated and verified.
GraduationCap
Lockout/tagout, chemical handling, noise awareness
Every worker's training record in one place. Track competencies, expiry dates, and re-certification for lockout/tagout, chemical handling, noise awareness, and forklift operation.
New operator starts on the press line. System flags: lockout/tagout training, machine-specific induction, and hearing protection fitting required before first shift.
AlertTriangle
From near-miss to notifiable incident
Log incidents with classification against WHS Regulation categories. Notifiable incidents trigger immediate alerts. Investigation workflow with root cause analysis and corrective actions.
Worker reports near-miss: conveyor guard was found open during operation. Logged. Investigation identifies maintenance procedure gap. Corrective action assigned.
BarChart3
All substances prioritised by WEL impact
See every substance in your register mapped against the incoming WEL. Traffic light system prioritises action. Days-until-deadline counter for December 2026.
Dashboard shows 8 red substances across 3 production lines. You prioritise ventilation upgrades and schedule exposure monitoring for the highest-impact areas.

Your manufacturing compliance calendar

January
Annual plant risk assessment review — all machinery
Code of Practice — Managing the risks of plant
Unassessed plant = prosecution risk
March
Quarterly chemical register update — new products, discontinued stock
WHS Regulation 2025, s.346
Unregistered chemicals = improvement notice
May
Annual noise assessment — all production areas
Code of Practice — Managing noise
Noise-induced hearing loss is irreversible and compensable
June
Pre-July s.26A readiness — verify 12 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
Health monitoring review — Schedule 14 substances
WHS Regulation 2025, Chapter 7 Part 7.1 Div 6
Failure to provide health monitoring is a specific offence
November
Final WEL readiness — 30 days before December 2026 transition
Safe Work Australia WEL List
All substances must be assessed against new limits
December
WEL takes effect — all monitoring against new limits
WHS Regulation 2025 (as amended)
Non-compliance from day one is prosecutable

See EHS Atlas configured for manufacturing

Chemical register, plant risk assessments, and 12 applicable Codes of Practice — 15-minute walkthrough.