Policy University Management WHS-PRO-025 Contractor Safety Management Procedure

WHS-PRO-025 Contractor Safety Management Procedure

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To document and communicate James Cook University’s (JCU) minimum work health and safety (WHS) requirements for contractor safety management.

The intention of this Contractor Safety Management Procedure is to provide clear guidance for James Cook University to:

  • Embed work health and safety requirements into the management of contractors by the University; and
  • Fulfil JCU’s obligations to its contractors under the Work Health and Safety Act 2011 (Qld) (the Act).


This procedure applies to all services being delivered by contractors and their subcontractors on JCU managed and controlled sites.

This Contractor Safety Management Procedure applies to all JCU staff, students, contractors, affiliates and visitors involved in JCU business operations and activities.

This Procedure has been written to complement the FMPM 711 – Procurement Procedure and should be read in conjunction with this document.

This Contractor Safety Management Procedure excludes:

  • Matters concerning contractor management that are not related to work health and safety;
  • Management of contractors engaged by a JCU Controlled Entity; and
  • Tenants of JCU.

Different legislative requirements apply depending on whether JCU engages an entity or an individual to carry out services and the nature of the services themselves.

When a third party is being considered to carry out services or undertake consultancies for JCU, an assessment must be performed to identify whether individuals who may be the service provider, or perform work on behalf of an entity that is a service provider, will be treated as an employee or a contractor.





For the purposes of this Procedure, a contractor is a PCBU and its Workers (including Subcontractors and its Workers), that are engaged by JCU for the purpose of performing work or providing a service under a contractual agreement.

Contractor Kiosk Nominated physical location on worksite where contractors sign in and sign out and keys are dispensed and returned.

Construction Project

Any project that involves construction work where the cost of the construction work is $250,000 or more.

Construction Work

Includes any work carried out in connection with the construction, alteration, conversion, fitting-out, commissioning, renovation, repair, maintenance, refurbishment, demolition, decommissioning or dismantling of a structure.  Refer to Section 289 of the Work Health & Safety Regulation for the full definition.

General Construction Induction Training

Means training delivered in Australia by an RTO for the specified VET course for general construction induction training.

High Risk Construction Work

Definition as per Section 291 of Work Health and Safety Regulations 2011 (Qld).

Construction work that:

a)  Involves a risk of a person falling more than 2m; or

b)  Is carried out on a telecommunication tower; or

c)  Involves demolition of an element of a structure that is load-bearing or otherwise related to the physical integrity of the structure; or

d)  Involves, or is likely to involve, the disturbance of asbestos; or

e)  Involves structural alterations or repairs that require temporary support to prevent collapse; or

f)  Is carried out in or near a confined space; or

g)  Is carried out in or near

  • a shaft or trench with an excavated depth greater than 1.5m; or
  • a tunnel; or

h)  Involves the use of explosives; or

i)   Is carried out on or near pressurised gas distribution mains or piping; or

j)   Is carried out on or near chemical, fuel or refrigerant lines; or

k)  Is carried out on or near energised electrical installations or services; or

l)   Is carried out in an area that may have a contaminated or flammable atmosphere; or

m) Involves tilt-up or precast concrete; or

n)  Is carried out on, in or adjacent to a road, railway, shipping lane or other traffic corridor that is in use by traffic other than pedestrians; or

o)  Is carried out in an area at a workplace in which there is any movement of powered mobile plant; or

p)  Is carried out in an area in which there are artificial extremes of temperature; or

q)  Is carried out in or near water or other liquid that involves a risk of drowning; or

r)   Involves diving work.

High Risk Work Licence

Any work set out in schedule 3 of the Work Health and Safety Regulation 2011 (Qld) as requiring a high risk work licence and includes:

  • Scaffolding work;
  • Dogging and rigging work;
  • Crane and hoist operation;
  • Asbestos;
  • High voltage;
  • Forklift operation;
  • Pressure equipment operation.
JCU Contractor Portal (JCP) An electronic system for contractor registration, induction and sign in/out functions.

JCU Controlled Entity

Refer to JCU Controlled and Non-Controlled Entities Policy.

JCU Representative

Designated person who engages a contractor to undertake work and manages and supervises the contract.

JCU Tenant

A person or organisation who occupies land or property rented from JCU

Notifiable Incident

An incident that arises out of the conduct of a business or undertaking; that results in the death, serious injury or serious illness of a person, or involves a dangerous incident and therefore needs to be reported to Workplace Health and Safety Queensland (WHSQ).


A person who makes decisions, or participates in making decisions that affect the whole or a substantial part of a business or undertaking or has the capacity to significantly affect the financial standing of the business or undertaking.

If a person is responsible only for implementing those decisions, they are not considered an Officer under the Work Health and Safety Act 2011 (Qld).

Holders of the following JCU positions are considered Officers:

  • Members of Council;
  • University Executive, Directors and Deans.


Visitors to a JCU controlled property and students not performing work experience or paid or unpaid work.

Person conducting a business or undertaking (PCBU)

A person conducting a business or undertaking alone or with others, whether or not for profit or gain.  A PCBU can be a sole trader, a partnership, company, unincorporated association or government department of public authority.

Principal Contractor

JCU as the PCBU commissioning a Construction Project is the Principal Contractor, unless JCU engages another PCBU as the Principal Contractor.

JCU can choose to engage, under contract, another PCBU as the Principal Contractor authorising it to have management and control of the workplace and to discharge the duties of a principal contractor for a Construction Project (>$250,000).

JCU may also authorise a contractor to have management or control of a workplace for construction work that is valued less than $250,000 through a formal contractual agreement.

Senior Officer, of a Person Conducting a Business or Undertaking

(a) If the person is a corporation—an executive officer of the corporation; or

(b) otherwise—the holder of an executive position (however described) in relation to the person who makes, or takes part in making, decisions affecting all, or a substantial part, of the person’s functions;

(c) As per Work Health and Safety Act 2011 34A.


This is a PCBU that enters into a contract with a contractor or Principal Contractor to undertake specified work.


A person who carries out work in any capacity for JCU, and includes working as:

  • an employee;
  • a volunteer;
  • an apprentice or trainee;
  • a student gaining work experience (paid or unpaid);
  • a contractor or subcontractor and their employees;
  • labour hire company employees assigned to work for JCU.


A workplace is the place where work is carried out for JCU and includes any place where a Worker goes, or is likely to be, while at work.

Table of Contents

1Duty, Obligations and Responsibilities6.1.3Site / Area Specific Induction
1.1James Cook University6.1.4General Construction Induction Training
1.2Officer6.2WHS Documentation Review
1.3Senior Officer6.3Sign In Sign Out
1.4Work Health Safety6.4Pre-start Meeting
1.5JCU Representative6.5Permits to Work
1.6Contractor6.6Implementation of Contractors Safety Documentation
1.7Subcontractor7Monitoring of Contractors
1.8Workers and Others7.1Works Completion
2Types of Contractors Engaged by JCU8Incident Management
3Planning8.1Notifiable Incident at JCU Controlled Site
4Contract Specification8.2Notifiable Incident on a Site Controlled by a Principal Contractor
4.1Principal Contractor8.3Incidents that are Not Notifiable
5Contractor Evaluation and Selection8.4Safety Breaches
5.1Training and Licences8.5Construction Work
5.2Insurance9Evaluation and Retention
6Contractor Engagement10Monitoring
6.1Contractor Registration11Training
6.1.1Induction12Related Policy Instruments
6.1.2JCU Contractor Health and Safety InductionOther documents and legislation
  Schedules / Appendices

Duty, Obligations and Responsibilities

1.1 James Cook University

As a Person Conducting a Business or Undertaking (PCBU), JCU has a legal duty to ensure, so far as is reasonably practicable, that workers and others are not exposed to health and safety risks arising from the business or undertaking.  Workers include Contractors and Subcontractors.

JCU may appoint a Contractor to manage and carry out work on their behalf, however JCU and its Workers cannot contract out their WHS duties.

Under WHS legislation, if the Contractor has been appointed as the Principal Contractor, then they will also have the responsibilities and duties of the PCBU.

In addition, JCU must, so far as reasonably practicable, consult, cooperate and coordinate activities with all Principal Contractors, Contractors and their Workers on shared work health and safety matters.

1.2 Officer

An Officer of JCU has a duty under the Act to exercise due diligence to ensure that JCU complies with its duties and obligations under the Act. To do this, officers will be responsible for ensuring the requirements of this Contractor Safety Management Procedure and any other requirement(s) prescribed by the JCU Health and Safety Management System (HSMS) are implemented within their area of responsibility.

Officers should be conversant with WHS-PRO-001 WHS Responsibilities Procedure to understand all their work health and safety statutory responsibilities and how they apply to JCU operations.

1.3 Senior Officer

Senior Officers will be responsible for ensuring the requirements of this Contractor Safety Management Procedure and any other requirement(s) prescribed by the JCU Health and Safety Management System (HSMS) are implemented within their area of responsibility.

1.4 Work Health and Safety (WHS) Unit

The WHS unit has an advisory function in relation to the work health and safety management of Contractors at JCU.  This is done by:

  • Developing and implementing this Contractor Safety Management Procedure across the JCU business;
  • Developing and maintaining the JCU Contractor Health and Safety Induction;
  • Providing advice throughout the planning phase to assist the JCU representative to determine the category of contractor and the associated minimum health and safety risk controls required for the contracted work;
  • Providing WHS support and advice to JCU representatives in relation to the management of contractors;
  • Auditing and approving safety management systems for Construction Projects;
  • Providing training on the use of JCU Contractor Portal and overseeing the management of the portal;
  • Assisting with monitoring contractor compliance with the contracted work health and safety risk controls by reviewing incidents and onsite inspections and audits; and
  • Assisting with resolving WHS incidents on RiskWare.

1.5 JCU Representative

The JCU representative is the primary individual responsible for engaging, liaising with and monitoring the contractor on behalf of JCU.

The JCU representative is responsible for:

  • Attending training on the use of JCU Contractor Portal and safe management of contractors;
  • Considering WHS requirements in procurement and contractor management;
  • Obtaining and reviewing all relevant safety management documentation, evidence of training and insurance documentation that is required for the category of contracted work prior to the engagement of the contractor;
  • Considering contractors based on their commitment to work health and safety and their ability to safely carry out the required work;
  • Ensuring the contractor receives the appropriate contractor safety onboarding documentation including access to the JCU contractor induction;
  • Providing the contractor with the JCU policies, procedures and any supporting documents relevant to the work being undertaken;
  • Facilitating a pre-start meeting where required;
  • Consult, cooperate and coordinate – ensuring clear lines of communication are established with the contractor regarding WHS issues affecting the works;
  • Monitoring the contractor’s safety performance to ensure the contracted work is carried out in accordance with the safety requirements prescribed by the contractual agreement;
  • Reporting to the JCU Procurement Unit if a contractor safety performance is unsatisfactory and a decision has been made by JCU to no longer use the contractor, using the reporting mechanism approved by JCU Procurement; and
  • Recording all incidents and injuries in relation to the contracted works.

1.6 Contractor

A contractor must take reasonable care for their own health and safety and take reasonable care that their acts or omissions do not adversely affect the health and safety of others.  Specifically, a contractor must:

  • Comply with WHS related legislation and the JCU contract specific WHS requirements;
  • Demonstrate that they have an effective WHS management system;
  • Provide information to JCU on how health and safety risks have been eliminated or minimised so far as is reasonably practicable prior to work commencing;
  • Consult, cooperate and coordinate with JCU and any other PCBUs with whom it shares duties;
  • Provide such information, instruction, training and supervision to its workers (including subcontractors) as necessary to ensure that the services are provided in a manner that is safe and without risks to health;
  • Ensure the provision and maintenance of safe systems of work, safe plant and the health and safety of workers and others at any workplace under the contractor’s management or control;
  • Take all reasonable steps to ensure that all employees, subcontractors and employees of subcontractors comply with all:
    • legislation relating to the contracted work; and
    • work health and safety requirements that have been agreed to with JCU for the contracted work;
  • Notify the JCU Representative of any incident or injury which occurs during or associated with the provision of the contracted work;
  • Notify the JCU Representative when a change of scope occurs in particular if new hazards are identified during works;
  • If undertaking construction work, keep their general construction induction training card available for inspection or if awaiting a decision on their application for a general construction induction training card, keep their general induction training certification available for inspection; and
  • coordinate and facilitate safety in design workshop and provide a written report when required.

If supplying goods:

  • Supply compliant products that are designed and manufactured to eliminate or minimise risk so far as is reasonably practicable;
  • Ensure safe installation / construction of plant or structures; and
  • Provide relevant information on the safe operation, handling, storage, maintenance and disposal of the product.

1.7 Subcontractor

Subcontractors must comply with both the duties of a worker and of a contractor.

1.8 Workers and Others

Workers and others must always:

  • Take reasonable care for their own health and safety;
  • Take reasonable care that their acts or omissions do not adversely affect the health and safety of other persons; and
  • Comply with any reasonable instruction and cooperate with any reasonable policy or procedure relating to health and safety at the workplace.

Types of Contractors Engaged by JCU

There are numerous circumstances in which contractors and subcontractors are engaged in the University's operations due to the diversity of University activities.

Contractors have been classified into five categories. Contractor categorisation determines the manner of induction, identification, registration and risk management required.

The five contractor categories are:

  • Deliveries;
  • Consultants and Contract Workers (labour-hire, consultant auditors, guest or contracted lectures, work experience personnel, event entertainers, vendors and stall operators);
  • Contracted Suppliers (e.g. cleaning, security, waste collection, printer and multi-function device management);
  • Maintenance and Construction Work; and
  • Principal Contractors.

Appendix 1 Contractor Categories – WHS Requirements provides practical guidance on JCU contractor management expectations for WHS requirements based on the contractor category.

3 Planning

It is important that all contracted works are adequately scoped and planned to ensure all potential risk factors are considered to ascertain the work health and safety requirements connected to the contracted work and to determine the approved process to manage the risks to ensure compliance.

The planning risk assessment needs to identify the hazards associated with the work, based on activities to be conducted, location of the work and complexity of work organisation.  At this stage, the JCU representative shall identify risk controls for the components of the work that the University has control over for inclusion in the scope / specification. The WHS-PRO-CHK-025b Contractor Risk Management Quick Reference Tool can be used to assist with planning the risk assessment.

The more complex and hazardous the works to be performed, the greater the need for a detailed plan.

Items that may need to be considered during the planning phase are:

  • Is the work ‘construction work’?
  • Is it a ‘construction project’ (value over $250,000)?
  • Dos the construction work suit engagement of a principal contractor?
  • Identification of hazards and risks associated with the work;
  • Legislative obligations to be met (including Codes of Practice);
  • Responsibilities of the PCBU involved;
  • Work methods, people and equipment to be used;
  • Contractor monitoring requirements;
  • Consultation arrangements;
  • Access to the asbestos register / asbestos management plan;
  • Safety documentation required, for example:
    • Construction WHS management plans;
    • SDS chemicals, equipment manuals;
    • Safe work method statements for high risk construction work – specific to work;
    • Job specific risk assessments;
    • A construction/demolition plan;
    • Permits to work;
    • Copies of licences/certifications;
    • Insurance documents;
    • Specialist design or technical data;
    • Safety in design reviews;
    • Monitoring certificates (e.g. asbestos / mould);
    • Adherence with Australian / relevant standards;
  • JCU may choose to coordinate a series of contractors in a project.  In this case, a plan must be developed to coordinate the works.

Contract Specification

The WHS legislation requires all PCBUs to work safely together.  To ensure all PCBUs are aware of their role in managing risks while working for JCU, it is critical that WHS requirements are documented in the contract specification.

WHS risk is not linked to the value of the procurement. Where potential health and safety risks are identified in relation to contracted works, the contract specification shall clearly state the health and safety requirements as identified in the planning phase.  The more complete and hazardous the works to be performed, the greater the need for a detailed contract specification that clearly defines the obligations of the parties.

4.1 Principal Contractor

4.1.1 Construction Project (construction work valued over $250,000)

For Construction Projects, the tender specification and contract must clearly nominate the Principal Contractor.  JCU can be nominated as the Principal Contractor, however in most cases it will be another PCBU.

When nominating a contracted company as the Principal Contractor the ability for the contractor to assume control of the workplace must be considered.  If the contractor cannot effectively control the work area then JCU cannot relinquish control.

An example of a construction project where control cannot be relinquished is construction work across a number of occupied buildings where the sites cannot be physically barricaded from JCU staff/students or members of the public.

When engaging a Principal Contractor, the JCU Representative is required to:

  • Verify the Principal Contractor has the necessary expertise for the work (such as licences, qualifications, level of experience, etc.);
  • Verify the Principal Contractor has their own systems in place for carrying out the work safely (for Construction Projects, this must be audited and approved by the JCU WHS Unit);
  • Verify the Principal Contractor is carrying out the work safely as per their own stated procedures;
  • Continue to consult, coordinate and cooperate with the Principal Contractor;
  • Verify that the work being performed will have no negative impact on the immediate surroundings e.g. dust, noise, falling objects, etc.
  • Provide the Principal Contractor with any hazard / risk information that JCU is aware of, e.g. asbestos registers, chemical contamination, underground services, etc.

The WHS Regulation states that a construction project can have only one principal contractor at any specific time.

If a Principal Contractor is nominated for a Construction Project, the Principal Contractor is responsible for coordinating and managing all contractors on that site.

4.1.2 Construction Project (construction work valued under $250,000)

For construction work under the value of $250,000, JCU can authorise a contractor to have management and control of a workplace. In this situation, the contractor does not inherit the additional duties of a Principal Contractor under part 6.4 of the WHS Regulation. JCU can add additional WHS requirements in the contract similar to those duties imposed on a Principal Contractor e.g. providing a WHS Management Plan and managing safe work method statements. JCU must ensure that the Contractor is able to assume control of the workplace when authorising a contractor to have management and control.

Contractor Evaluation and Selection

The contractor must provide the required safety information as part of the procurement process (e.g. tender submission, quotation). The safety information shall be considered when determining the contractor suitability to perform the contracted work.  This process is outlined in FMPM 711 Procurement Procedure.

All safety documentation must be evaluated to ensure the potential contractor is able to meet legislative and JCU minimum standards by the JCU representative. Support is available from the WHS unit on request.

Where a potential contractor’s system is deemed to be below the acceptable standard, the JCU representative engaging the contractor must provide direction in the use of the university WHS-PRO-002 Work Health and Safety Risk Management Procedure and request the potential contractor to resubmit their WHS risk management documentation.

Contractors should be able to demonstrate as a minimum:

  • A good understanding of hazards and risks relevant to the scope;
  • Licences, certificates and trade qualifications (as applicable to the work);
  • Plant and equipment registrations / maintenance records;
  • The ability to undertake risk assessment for the work being undertaken;
  • Current insurance policies for Workers Compensation, Public Liability, and Professional Indemnity;
  • The contractor, its employees and sub-contractors have completed appropriate training with respect to the type of construction work and / or activities; and
  • Construction work related legislative requirements e.g. safe work method statements for high risk work.

Higher risk contracts may require:

  • a formally developed WHS management system;
  • WHS safety plans;
  • reporting on WHS performance.

5.1 Training and Licences

The contractor must be able to produce evidence of the training and licenses required to perform the work activities.

This may include, but is not limited to:

  • General Construction Induction Card (mandatory for all persons who perform construction work);
  • Food business licence;
  • Australian high risk work licences;
  • Electrical work licenses;
  • Queensland Building and Construction Commission (QBCC) licences; or
  • Work activity specific competency certificates (including high risk construction work related competencies).

The JCU representative is responsible for identifying these requirements as part of the planning WHS risk assessment.

5.2 Insurance

Contractors must hold certificates of currency prior to commencing and for the duration of the work.  If necessary, contractors will be asked to provide evidence of certificates of currency.

Types of insurance required may include, but is not limited to:

  • Workers Compensation insurance / personal accident insurance;
  • Public Liability insurance;
  • Motor vehicles;
  • Professional indemnity.

Contract terms and conditions specify insurance requirements.  For further information refer to the FMPM 711 Procurement Procedure.

Contractor Engagement

On completion of the planning, evaluation and selection stages, the JCU representative engaging the contractor must ensure that a contractual agreement and approval is completed as detailed in FMPM 711 Procurement Procedure. Depending upon the nature, duration and cost of works, JCU may use anything from a purchase / work order to a detailed construction contract to engage a contractor.

6.1 Contractor Registration

All contractors must register using the JCU Contractor Portal (JCP), prior to commencing work for JCU, unless not required based on the contractor category as defined in Appendix 1.

The JCU representative is responsible for the invitation to the contractor to register - refer to Appendix 2 - JCP Flowchart.

6.1.1 Induction

All contractors must be either inducted prior to commencing work for JCU or be supervised by the / a JCU representative while on JCU sites.  Refer to Appendix 1 for induction requirements based on work category. Inductions must be refreshed every two years to remain current.

To work unsupervised, the contractor must, as a minimum requirement, successfully complete each of the following:

  • The relevant online JCU work health and safety induction via JCP;
  • Specific site/area induction that includes all areas where contracted works will be conducted; and
  • General Construction Induction Training (White Card), if the person is engaged to carry out construction work.

Where a principal contractor is engaged, and in order to maintain the control of the workplace, the principal contractor must:

  • Incorporate the approved JCU contractor induction into the safety management plan and induction for that site; and
  • Provide a health and safety induction to all workers, including subcontractors and their workers who are engaged on that workplace.

For JCU managed sites outside of the two main campuses (Cairns and Townsville), contractor inductions vary depending on the specific requirements of the site. Contact the JCU WHS Unit for contractor induction requirements.

6.1.2  Site / Area Specific Induction

When contractors are required to perform work in a restricted access area of JCU, e.g. laboratories, including vacated labs, plant rooms, server room. The JCU representative is to ensure the restricted area contact has been notified of the work and the contractor has undergone the specific induction for that area prior to commencement of work.

A site induction is specific to the area in which the contractor will be working to ensure the contractor:

  • Knows how to respond to an emergency particular to the site in which they will be working; and
  • Is aware of any hazards and risks specific to the area in which they will be working.

A site / area specific induction should include the following as a minimum:

  • The emergency escape routes;
  • The location of the appropriate Emergency Evacuation Assembly Point;
  • Any area specific hazards (e.g. there may be other contractors working in the area, service disruptions, increased pedestrian traffic at certain times coinciding with work they are undertaking, chemicals, radiation, asbestos); and
  • Details on accessing buildings and restricted access areas.

Records must be retained and be made available to the JCU Representative and / or WHS unit upon request.

6.1.4 General Construction Induction Training (construction work only)

Contractors must ensure all workers that are engaged to carry out construction work hold a general construction induction training card or a general construction induction training certification issued within the preceding 60 days.  For work, other than a ‘construction project’, the JCU representative is to consult with the contractor to ensure all workers meet this requirement.

6.2 WHS Documentation Review

Prior to commencing work activities, the engaged contractor shall supply safety documentation specific to the work being conducted via the JCP - refer to Appendix 2 - JCP Flowchart.  The JCU representative engaging the contractor is responsible for confirming that the safety documentation is complete and applicable to work. Where required, this may be reviewed in consultation with the JCU WHS unit. Please note: this information may have been reviewed as part of section 5.

The JCU representative engaging the contractor shall retain specified WHS documentation.  The retention of WHS documentation will be determined during the planning phase e.g. asbestos clearance certificates, mould remediation certificates.

6.3 Sign In / Sign Out

The sign-in and sign-out procedure for contractors is conducted using the JCU kiosks and JCP mobile app.

A manual process may be used on JCU remote worksites that do not have access to the JCU kiosk or mobile app.

6.4 Pre-start Meeting

Where required, the JCU Representative may need to conduct a pre-start meeting (NOTE: pre-start meetings are required for Construction and maintenance works.  Depending on the risks, pre-start meetings may be required for other contractor categories).  The purpose of this meeting is to consult with and inform all parties of WHS requirements for the work.  It is recommended that a documented record is maintained of this meeting e.g. diary notes, meeting minutes.

As a minimum, a pre-start meeting should include:

  • Confirmation of works being conducted;
  • Confirmation of job specific risk controls / methods;
  • Service interruptions;
  • Site specific hazards / risks;
  • Permit requirements and status;
  • Reporting requirements;
  • Critical hold / control points;
  • Public / JCU staff and student safety; and
  • Communication / consultation requirements specific to location / work.

NOTE:  a pre-start meeting may be combined with a site/area specific induction.

6.5 Permits to Work

The JCU representative must ensure that, where required, the applicable permits to work are completed by the contractor and authorised by the appropriate JCU permit issuer prior to commencement of work.

6.6 Implementation of Contractors Safety Documentation

Implementation of the contractor’s safety documentation is the responsibility of the contractor.  It is also the responsibility of the contractor to ensure that their safety documentation is readily available for inspection and that all workers and sub-contractors are signed-on and following all WHS requirements. Contractors WHS may be subject to JCU Representative / JCU WHS unit inspection at any time.

Monitoring of Contractors

A lack of technical ability is one of the main reasons for contracting work, it is not considered ‘reasonably practicable’ that JCU have the capability to assess such contractors on their technical abilities.  However, JCU does have the skills to identify if contractors have safe systems through observation of activities and reviewing their safety documentation.

The JCU representative is required to monitor the work of the contractor while they are undertaking contracted work for the University.

Monitoring shall be conducted to ensure the contractors operations conforms with:

  • WHS legislation including codes of practice and standards;
  • Contract WHS requirements; and
  • Contractor job specific risk management plans.

The WHS unit will work alongside the JCU representative to monitor contract activities.

The extent of activities monitored will vary depending on the nature and circumstances of each contract.  Therefore, the frequency, degree and mechanism for the monitoring of contract activities are to be determined at the planning phase by the JCU Representative and should be documented in the specification.  Monitoring activities generally include (but are not limited to):

  • Scheduled inspections;
  • Random inspections;
  • Audits against contract documentation;
  • Walkthrough and discussion with contractor; and / or
  • Leadership walks by JCU senior management.

The JCU representative and / or the WHS unit may provide the contractor with safety performance feedback, post monitoring activity, to assist in the ongoing consultative and cooperative relationship with contractors as a shared duty holder.

Any JCU employee, student or visitor that observes breaches or has a complaint regarding contracted work and / or conduct are to report the concern to the responsible JCU representative and / or the WHS unit for action.

7.1 Works Completion

The JCU representative engaging the contractor will at the completion of the works;

  • Conduct an inspection of the area where the work was carried out to confirm it has been left free of hazards. If there are geographical restrictions, this inspection may be performed by another JCU employee;
  • Provide information to the WHS unit if required for updating of relevant WHS risk registers etc;
  • Make sure all isolations are removed and permits are signed off and closed out; and
  • Confirm all required documentation and training of new installations, including safety processes have been undertaken with all relevant stakeholders.

Incident Management

8.1 Notifiable Incident on JCU Controlled Site

Where a Notifiable Incident occurs on a worksite controlled by JCU, the JCU Representative must inform the WHS unit immediately.. Once the people involved in the incident are safe, the incident site must not be disturbed until WHSQ provide clearance.

The WHS unit must give the Regulator notice of the workplace incident immediately after becoming aware of the incident occurring and by the fastest means possible.

The WHS unit in consultation with the JCU representative will conduct the subsequent investigation into the incident and report the incident using the Regulator’s approved form within 24 hours of the incident occurring.

All work health and safety incidents must be managed in accordance with WHS-PRO-005 WHS Incident and Hazard Management Procedure.

8.2 Notifiable Incidents on a site controlled by a Principal Contractor

Where a notifiable incident occurs on a worksite controlled by a principal contractor appointed by JCU, the principal contractor must give the Regulator notice of the workplace incident.

This must occur immediately after the principal contractor becomes aware of the workplace incident occurring and by the fastest means possible. The JCU representative responsible for the construction work is to be informed of the incident at this time and given a copy of the incident report.

It is the JCU representative’s responsibility to then promptly record the incident and attach the incident notification form into JCU’s risk management system.

The JCU representative must advise the WHS unit as soon as possible of the Notifiable Incident.

The JCU representative and the WHS unit are to participate in or be kept informed of the progress of subsequent investigations. Subsequent investigation reporting is to be provided to the JCU representative and promptly attached to the incident in the risk management system.

8.3 Incidents that are not notifiable

For all incidents that are not notifiable, the contractor must record the incident and advise the JCU representative:

  • Within 24 hours of the incident occurring; or
  • Immediately of any incident which involves a JCU worker or a member of the public or JCU infrastructure.

Communication must be in the form of phone call, followed by email, followed by a report.

8.4 Safety Breaches

JCU reserves the right to order cessation of work, or request to modify work practice(s) in an effort to control any hazards impacting safety which the JCU representative or the WHS unit believes to be compromised.

This includes failure of the contractor to implement, monitor and / or enforce the required work health and safety requirements prescribed by the Act, applicable JCU procedure(s), contractual agreement and any reasonable instruction provided by the JCU representative or the WHS unit.

The JCU representative and / or the WHS unit must address any unsafe behaviour directly with the contractor. Any request to modify work practices can only be made in consultation with the contractor.

Depending on the circumstances surrounding the safety breach, the JCU representative in consultation with the WHS unit and JCU Procurement, may decide to take steps to terminate the contract.

Any safety breach, whether an instance or repeated behaviour, may lead to the contractor not being suitable to undertake future work for JCU.

JCU Procurement shall update the contractor’s record to reflect the contractor’s safety performance record and note that the contractor is not to be engaged by JCU for future work.

Contractor safety breaches shall be recorded in the JCU risk management system (Riskware) by the JCU representative or WHS unit.

9 Evaluation and Retention

A review of contractors will be conducted periodically.

The intent is to assess the contractor safety performance to determine whether they will remain on, or be removed as a preferred JCU contractor.

The review will include data collected as part of JCU monitoring activities.

This may include, but not be limited to:

  • Safety audits and the close out of any non-conformances;
  • Formal review meetings;
  • Safety performance meetings;
  • Incidents and management;
  • Performance reporting.

10 Monitoring

The application of this procedure shall be audited in accordance with the WHS auditing processes.

11 Training

JCU representatives whom are responsible for overseeing contracts that involve construction work activities, must successfully complete general construction induction training.

Training will be provided in accordance with the WHS-PRO-004 Training and Competency Procedure.

Related Policy Instruments

JCU Records Management Policy

JCU Work Health and Safety Policy

FMPM 711 Procurement Procedure

WHS-PRO-002 WHS Risk Management Procedure

WHS-PRO-003 Consultation and Participation Procedure

WHS-PRO-004 Training and Competency Procedure

WHS-PRO-005 Incident and Hazard Management

WHS-PRO-008 Asbestos Management Procedure

WHS-PRO-009 Biosafety Procedure

WHS-PRO-013 Laboratory Safety Procedure

WHS-PRO-014 Ionising Radiation Procedure

JCU Design Guidelines

Other documents and legislation

AS 3000 – Electrical Installations (Wiring Rules)

AS 3012 – Electrical installations – construction and demolition sites

AS 3760 – In service safety inspection and testing of electrical equipment

Electrical Safety Act 2002

Electrical Safety Regulation 2013

Electrical Safety Office Queensland (ESO)

Queensland Building and Construction Commission

Queensland Codes of Practice (Worksafe Queensland)

Work Health and Safety Act 2011 (Qld)

Work Health and Safety Regulation 2011 (Qld)

Workplace Health and Safety Queensland (WHSQ)

Schedules / Appendices

Appendix 1: Contractor Categories – WHS Requirements

Appendix 2: JCU Contractor Portal (JCP) Flowchart

WHS-PRO-CHK-025b Contractor Risk Management Quick Reference Tool

WHS-PRO-CHK-025c Events Contractor Induction Checklist

WHS-PRO-TEM-025d Events Contractor Risk Assessment Form

WHS-PRO-INFO-025e Information about Electrical Test and Tag

WHS-PRO-TEM-002g Safe Work Procedure Template


NOTE:  Printed copies of this Procedure are uncontrolled, and currency can only be assured at the time of printing.

Approval Details

Policy DomainUniversity Management
Policy Sub-domain WHS Management

Policy Custodian

Deputy Vice Chancellor, Services and Resources

Approval Authority

Work Health and Safety Committee

Date for next review


Revision History


Approval date

Implementation date



22-1 24/08/2022 30/08/2022 Three year review. Minor changes only.  Removal of construction guideline reference. Changes to Principal Contractor section 4. Changes to the contractor categories. Principal Technical Advisor
20-1 03/08/2020 03/08/2020 New flow chart for Contractors developed, procedure amended to clarify registration and sign in/out process for Contractors. Contractor inductions to be renewed every 2 years (previously 3 years).  Procedure updated to reflect change of unit name from Health Safety and Environment to Work Health and Safety. WHS Training and Communications Advisor




Procedure established

HSE Training and Communications Advisor

Key words

Contractor, sub-contractor, notifiable incident, safety breaches, SWMS, Safe Work Method Statement, construction, JCP


WHS Advisor