WHS Systems
Date
24 July 2026
Category
Industry
Residential high-rise construction
Location
Inner Brisbane
Deliverables
Compliance obligation schedules, emergency response plan rebuild, first aid and emergency risk assessments, site inductions, plant movement plan and daily obligation workflow packs
Reference
WHS Act 2011 (Qld), WHS Regulation 2011 (Qld), Queensland Codes of Practice, AS/NZS ISO 45001:2018
Findings
Major
Moderate
Minor
WHS Management Plan Audit - Case Study 03
Background
Background
OHSE Consultants was engaged by the principal contractor on an inner Brisbane residential high-rise construction project after its WHS Management Plan had deteriorated over the course of the build. Personnel details, role titles and legislative references had fallen out of date as the project progressed. OHSE Consultants was brought in to manage the project WHS system, including document control, inductions, reporting and support for leadership governance.
Scope
Scope
OHSE Consultants was engaged to conduct a clause-by-clause audit of all 20 sections of the WHS Management Plan and map the project's compliance obligation schedules. The engagement also covered rebuilding and maintaining the site-specific emergency response plan, first aid and emergency risk assessments, site induction development, plant movement and delivery documentation, and daily workflow packs, with findings delivered as an audit report.
Findings
Findings
The audit identified 73 findings across the WHS Management Plan's 20 sections: 8 major, 27 moderate and 38 minor, against 17 areas found compliant with legislative requirements. Major defects included outdated personnel and role titles, superseded NOHSC references, a committee formation timeframe stated as two months against the 28 days required under the WHS Act 2011 (Qld), and missing Schedule 5A toilet requirements.
Guidance
Guidance
OHSE Consultants recommended corrective action for all 73 findings, prioritised by risk: the eight major defects first, then the 27 moderate and 38 minor findings identified in the plan. Recommendations covered reconciling personnel and role titles, replacing superseded NOHSC references, correcting the safety committee timeframe to 28 days under the WHS Act 2011 (Qld), inserting Schedule 5A toilet requirements, and versioning the plan as a controlled document.
Outcomes
Outcomes
The rebuilt WHS Management Plan restored legal compliance and aligned with actual site-specific conditions, producing a functioning project WHS system with clear WHS evidence and repeatable processes. The engagement established a governance framework supporting the principal contractor's officer due diligence obligations under section 27 of the WHS Act 2011 (Qld), enabling the plan to become fully compliant with regulatory and client systems comatability.
Conclusion
Conclusion
The WHS Management Plan had not been updated as personnel, legislation and the site conditions changed. The principal contractor was running a construction site on non-compliant paperwork. OHSE Consultants rebuilt the WHS plan against current legislation, current personnel and revised site conditions, then signed and versioned it as a controlled document the contractor entered into their IMS.
Background
Background
OHSE Consultants was engaged by the principal contractor on an inner Brisbane residential high-rise construction project after its WHS Management Plan had deteriorated over the course of the build. Personnel details, role titles and legislative references had fallen out of date as the project progressed. OHSE Consultants was brought in to manage the project WHS system, including document control, inductions, reporting and support for leadership governance.
Scope
Scope
OHSE Consultants was engaged to conduct a clause-by-clause audit of all 20 sections of the WHS Management Plan and map the project's compliance obligation schedules. The engagement also covered rebuilding and maintaining the site-specific emergency response plan, first aid and emergency risk assessments, site induction development, plant movement and delivery documentation, and daily workflow packs, with findings delivered as an audit report.
Findings
Findings
The audit identified 73 findings across the WHS Management Plan's 20 sections: 8 major, 27 moderate and 38 minor, against 17 areas found compliant with legislative requirements. Major defects included outdated personnel and role titles, superseded NOHSC references, a committee formation timeframe stated as two months against the 28 days required under the WHS Act 2011 (Qld), and missing Schedule 5A toilet requirements.
Guidance
Guidance
OHSE Consultants recommended corrective action for all 73 findings, prioritised by risk: the eight major defects first, then the 27 moderate and 38 minor findings identified in the plan. Recommendations covered reconciling personnel and role titles, replacing superseded NOHSC references, correcting the safety committee timeframe to 28 days under the WHS Act 2011 (Qld), inserting Schedule 5A toilet requirements, and versioning the plan as a controlled document.
Outcomes
Outcomes
The rebuilt WHS Management Plan restored legal compliance and aligned with actual site-specific conditions, producing a functioning project WHS system with clear WHS evidence and repeatable processes. The engagement established a governance framework supporting the principal contractor's officer due diligence obligations under section 27 of the WHS Act 2011 (Qld), enabling the plan to become fully compliant with regulatory and client systems comatability.
Conclusion
Conclusion
The WHS Management Plan had not been updated as personnel, legislation and the site conditions changed. The principal contractor was running a construction site on non-compliant paperwork. OHSE Consultants rebuilt the WHS plan against current legislation, current personnel and revised site conditions, then signed and versioned it as a controlled document the contractor entered into their IMS.
Issues encountered during WHS plan audit
Major findings
Moderate findings
Minor findings
| Component | Work performed | Reference |
|---|---|---|
| Compliance obligation schedules | Obligations mapped to source sections and scheduled by required frequency and system component | WHS Act s 27; ISO 45001 cl 9 |
| Emergency response plan | Rebuilt and maintained as the site office relocated and the building progressed | WHS Reg s 43 |
| First aid and emergency risk assessment | Reviewed and reissued as site population and structure changed | First aid in the workplace Code of Practice 2021 |
| Site induction | Site-specific induction maintained and reissued as site conditions changed | WHS Act s 19(3)(f); WHS Reg s 39 |
| Plant movement and delivery plan | Movement, delivery and exclusion zone controls documented for mobile plant | WHS Reg Part 5.1 |
| Daily briefs and toolbox packs | Site briefings and toolbox training notifications prepared and delivered | WHS Act ss 47 to 49 |


