Forklift Operation (Food Facility) SWMS

Forklift operations in food processing facilities present unique challenges compared to general warehousing. Workers operate on wet and contaminated floors that reduce traction, in cold rooms where visibility is reduced by condensation, and in production areas where pedestrian workers are performing manual tasks in close proximity. Food processing warehouses often have narrow aisles designed to maximise cold storage capacity, creating tight operating margins for forklift manoeuvring. The WHS Regulation 2025 requires High Risk Work Licences for forklift operators and specific traffic management plans for workplaces where forklifts and pedestrians share the same space.

Legal Requirements

regulation

WHS Regulation 2025 Part 4.5 — High Risk Work Licences and Part 4.7 — Plant

hrcw category

Work involving powered mobile plant

code of practice

Managing Risks of Plant in the Workplace (binding 1 July 2026 under Section 26A)

section 26a binding

Yes — effective 1 July 2026. Non-compliance is admissible as evidence of breach.

hrwl required

LF class licence for forklift operation

Hazards

Hazard	Consequence	Likelihood
Pedestrian strike in production areas and warehouse aisles	Crush injuries, fractures, death	Possible
Forklift tip-over on wet or contaminated floors	Crush injuries, operator death	Unlikely
Racking collapse from forklift impact	Multiple injuries, product damage, entrapment	Unlikely
Reduced visibility from condensation in cold room transitions	Collisions, pedestrian strikes	Possible
Load instability from wet or damaged pallets	Load drop, struck-by injuries	Possible
Carbon monoxide from LPG forklifts in enclosed spaces	CO poisoning, headaches, loss of consciousness	Possible

Controls (Hierarchy of Controls)

Verify HRWL currency for all forklift operators before work commences

Establish designated pedestrian and forklift zones with physical barriers where practicable

Install blue safety lights and audible reversing alarms on all forklifts

Reduce speed limits on wet floors and in cold room environments

Conduct pre-start inspections including tyre condition, brakes, and safety device functionality

Use electric forklifts in enclosed production areas to eliminate exhaust emissions

Install racking protection bollards and conduct annual racking integrity inspections

Implement condensation management procedures for cold room to ambient transitions

Recent Prosecutions

Inghams Enterprises Pty Ltd$450,000

Worker suffered serious injuries in food processing facility incident involving equipment and machinery.

2023 — SafeWork NSW v Inghams Enterprises Pty Ltd [2023]

Hilltop Meats Pty Ltd$750,000

Fatal worker incident at food processing facility with inadequate plant safety controls.

2025 — SafeWork NSW v Hilltop Meats Pty Ltd [2025]

What Your SWMS Must Include

✓HRWL verification records for all forklift operators

✓Traffic management plan showing pedestrian and forklift zones

✓Pre-start inspection checklist for food facility forklifts

✓Speed limits for wet floors, cold rooms, and production areas

✓Racking inspection schedule and damage reporting procedure

Need a compliant Forklift SWMS for Food Facilities?

Our WHS consultants build site-specific SWMS that address wet floor risks, cold room operations, and pedestrian safety for your food facility forklift operations.