WHS Compliant Contractor Management

Engaging contractors at UNE requires compliance with work health and safety legislation.

Whether engaging tradespeople, consultants, or managing construction projects, the University has legal obligations to protect the health and safety of all workers, including contractors and their employees.

This resource provides the policy framework, tools and guidance to support compliant contractor management.

Your responsibilities:

Contract Engagers and Contract Supervisors play a critical role in meeting UNE's WHS obligations. This system provides clear guidance for each stage of the contractor engagement lifecycle.

Three key components:

  1. Policy requirements – Understand UNE's obligations and your role
  2. Practical toolkit – Step-by-step guidance, checklists and templates
  3. Risk-based categorisation – Determine the appropriate WHS requirements for each engagement

Key Resources

WHS Contractor Management Policy – Policy framework and responsibilities

Contractor Management Toolkit – Comprehensive guidance for contractor engagement lifecycle

Contractor Categorisation Matrix – Risk-based assessment tool for determining WHS requirements

WHS Contractor Induction

Contact WHS Team – For guidance and support: whs@une.edu.au

Why effective contractor management matters

Beyond meeting legal obligations, managing contractors well delivers tangible benefits:

  • Stronger partnerships – Professional engagement processes build trust and positive relationships with our community of suppliers and repeat contractors
  • Operational efficiency – Clear expectations and communication from the outset prevent costly rework and project setbacks
  • Better outcomes – Contractors with strong WHS systems typically deliver higher quality work with fewer delays
  • Compliance assurance – Documented processes provide evidence of due diligence for audits and regulatory reviews

Legislative context

Under the Work Health and Safety Act 2011 (NSW), contractors are defined as "workers." UNE, as a PCBU, shares responsibility for contractor safety, and contractors have obligations for the safety of UNE staff and students. Effective contractor management ensures compliance and protects all workplace participants.

Contractor WHS Lifecycle Process Overview & Guides

Planning the Works

WHS risks must be identified before purchasing goods or services to ensure good procurement outcomes and avoid unforeseen hazards. Contract engagers/supervisors must identify potential risks and control measures using the UNE WHS Risk Management Protocol, including:

  • Identifying hazards associated with work activities, location, and context
  • Considering work complexity and required competencies/licences
  • Assessing potential harm severity and likelihood
  • Identifying reasonably practicable control measures

Contractor Categorization

Contract engagers must categorize contractors using the Contractor Categorization Matrix (Appendix 2) before engagement. The matrix classifies contractors into five risk-based categories, determining required induction, identification, registration, and risk management:

  1. Low Risk Deliveries & Services – Mail, couriers, light deliveries
  2. Consultants and Contract Workers – Labour hire, auditors, lecturers, event staff
  3. Contracted Suppliers – Long-term contracts (cleaning, security, waste)
  4. Maintenance & Construction Work – Building maintenance, repairs, trade works
  5. Principal Contractor – Construction projects, new buildings, major infrastructure

Key Planning Considerations

  • Is it 'construction work' or a 'Construction Project' (value over $250,000)?
  • Known hazards, risk controls, and legislative obligations
  • Work methods, personnel, equipment, and monitoring requirements
  • Consultation arrangements and access to asbestos register/management plan
  • Required safety documentation (WHS Management Plans, Project Plans)

Risk assessments must identify hazards based on activities, location, and work complexity, with control measures for University-controlled components included in the scope/specification.

Planning Tools

Appendix 1 - Guide to Selecting and Engaging Contractors: supports this Contractor WHS Lifecycle Toolkit and provides a 5 step process to assist contract engagers/supervisors meet their WHS responsibilities when selecting, engaging and management of contractors.

Appendix 2 - Contractor Categorization Matrix: provides practical guidance to contract engager/supervisors on the risk management controls required based on the category of contracted work to be undertaken.

Appendix 3 - Contractor Risk Management Planning Reference Tool: provides contract engagers/supervisors with a tool to assist in the identification of the contracted works risks.

Appendix 4 - Contractor Safety Evaluation Checklist: provides contract engagers/supervisors with a checklist to assess the suitability of a contractor prior to engagement (for category 3, 4, and 5 contractors).

Contract Specification

WHS legislation requires all PCBUs to work safely together. WHS requirements must be documented in contract specifications, regardless of procurement value.

Contract Specifications

Where health and safety risks are identified, specifications must clearly state:

  • Inherent hazards associated with the work and work environment
  • UNE's mandatory WHS policies, procedures, and practices
  • Key WHS performance indicators

Contract engagers, in consultation with local area representatives, ensure appropriate WHS context is included in the scope of works.

Principal Contractor – Construction Projects Over $250,000

Tender specifications and contracts must clearly nominate the Principal Contractor. When nominating a contractor, their ability to assume workplace control must be considered. If effective control cannot be achieved (e.g., work across occupied buildings without physical barricades), UNE cannot relinquish control.

UNE must verify the Principal Contractor has necessary expertise, safety systems, and is performing work safely. UNE must provide hazard/risk information (asbestos registers, chemical contamination, underground services).

The Principal Contractor coordinates and manages all contractors on site.

Construction Work Under $250,000

UNE can authorise a contractor to have management and control of a workplace. The contractor does not inherit Principal Contractor duties under WHS Regulation, but UNE can add similar contractual requirements (e.g., WHS Management Plan, safe work method statements). UNE must ensure the contractor can assume workplace control.

Contractor Evaluation & Selection

Procurement Process

UNE’s purchasing processes and responsibilities are outlined in the UNE Procurement Policy which include WHS requirements to be complied with to ensure any specific legislative requirements are met.

The contractor must provide the required safety documentation as part of the procurement process (e.g. tender submission, quotation).  The safety documentation should be considered when determining the contractors suitability to perform the contracted work.

All safety documentation must be evaluated to ensure the potential contractor is able to meet legislative and UNE minimum standards by the contract supervisor.

Contract Award

On completion of the planning and procurement phase, the contract supervisor must ensure that a contract for service agreement is in place prior to the contractor commencing the work.  Depending on the nature, duration and cost of works, UNE may use anything from a purchase/work order to a detailed construction contract to engage a contractor.

Estate and Built Environment (EBE) must be consulted prior to University Business Units /Directorates/Schools engaging a contractor to undertake any facilities related work, including works that will change the required operating conditions of the facilities e.g. installation of new equipment which impacts the heating, ventilation and/or cooling of an area.

A contract supervisor is appointed for each contract.  The contract supervisor may directly supervise the contractor and the work group, or day-to-day supervision may be delegated to another UNE representative to manage, monitor and report on the contractor WHS compliance and performance.

Contractor Onboarding & Mobilisation

All contractors must complete UNE's onboarding process before starting work. This includes registration through the UNE Digital WHS Management System, completing the UNE Contractor WHS Induction, and meeting site-specific requirements.

Key Requirements

Documentation: Contractors must provide relevant licences, qualifications, risk assessments, Safety Management Plans, and Safe Work Method Statements before commencing work.

Training and Licences: Contract supervisors verify contractor training, including Construction Induction Cards, trade licences, High Risk Work Licences (HRWL), and work-specific competencies.

Permits to Work: Hazardous activities require approved Permits to Work before starting. These include confined space entry, hot work, working at heights, electrical work, asbestos removal, and excavation.

Site Requirements: Contractors must sign in/out daily, wear identification, and may attend a pre-start meeting to review site-specific hazards, safety controls, and communication requirements.

Supervision: Contract supervisors are responsible for ensuring contractors meet all WHS requirements, coordinate with stakeholders, and maintain proper documentation.

Managing the Work

Contract supervisors must monitor contractor activities to ensure safe work practices are maintained. This includes reviewing WHS documentation, observing work activities, verifying work areas are properly signed and barricaded, and confirming high-risk work requirements are met.

WHS Breaches

Contract supervisors may direct contractors to cease or modify work to eliminate safety hazards. Unsafe behaviour must be raised as a WHS breach with the contractor, and work must not recommence until resolved.

All breaches must be recorded in the UNE Digital WHS Management System, discussed in performance meetings, and may result in contract termination for serious violations.

Incident Management

Notifiable Incidents (UNE Controlled Sites)
  • Contract supervisor immediately informs the WHS team, who notifies SafeWork NSW
  • Incident site must not be disturbed until clearance is provided
  • WHS team conducts investigation and provides report to regulator
  • Contract supervisor records incident in UNE Digital WHS Management System
Notifiable Incidents (Principal Contractor Controlled Sites)
  • Principal Contractor notifies the regulator immediately
  • Contract supervisor informs WHS team and records incident in system
  • Contract supervisor and WHS team participate in or monitor investigation
Non-Notifiable Incidents

Contractors must report incidents to the contract supervisor within 24 hours (immediately if involving UNE workers, staff, public, or infrastructure). Contract supervisors must record incidents in the UNE Digital WHS Management System, participate in investigations, and attach all relevant records.

Monitoring Tools

Appendix 5 - Contracted Works Monitoring Checklist: is provided for contract supervisors to observe and make notes against key WHS criteria within the Contract for Service Agreement or other UNE Procedures or Guidelines.

Appendix 6 - Contractor WHS Audit Checklist: for construction works or capital projects is provided for Contract Supervisors to check contractor conformance with their WHS Management Plan, SWMS, Permits to Work, etc.  The frequency of the checks is to be determined by the contract supervisor based on the level of risk, unless the frequency is specified in the contract.

Completion & Review

Upon completion, contract supervisors must confirm:

  • Work completed as per contract Scope of Work
  • Work areas hazard-free with waste removed
  • Isolations removed and Permits to Work closed out
  • Required documentation and training provided
  • WHS team informed to update risk registers

Contractor Evaluation

Contractors are reviewed at completion or agreed intervals to assess safety and quality performance. Reviews consider monitoring activities, performance meetings, WHS breaches, incidents, and KPIs. Outcomes inform future procurement decisions per the UNE Procurement Policy.

Training

UNE staff with contractor management responsibilities must receive training on their roles and obligations for contractor safety management.

Documentation and Records

Contract engagers and supervisors must maintain all WHS records per the UNE Document Control Rule, including:

  • Contracts, tenders, and service agreements
  • Pre-qualification forms and contractor registrations
  • Induction checklists
  • Risk assessments and Safe Work Method Statements
  • Incident investigation reports
  • Monitoring and evaluation checklists
  • Non-conformance records
  • WHS-related correspondence and notes