Work Health and Safety (Hazardous Manual Tasks) Code of Practice 2015

The Work Health and Safety (Hazardous Manual Tasks) Code of Practice 2015 is an approved code of practice made under section 274 of the Work Health and Safety Act 2011. It gives practical guidance on how to identify hazardous manual tasks and control the risks of workers being affected by musculoskeletal disorders, often called MSDs.

The Code describes itself as a practical guide to achieving the standards of health, safety and welfare required under the WHS Act and the WHS Regulations. In most cases, following an approved code of practice would achieve compliance with the relevant duties for the subject matter covered by the code. But the Code also makes clear that it does not cover every hazard or risk that may arise at work, and businesses still need to consider all work health and safety risks, not only those specifically covered by a code.

The legal significance of the Code is important. It is admissible in court proceedings under the WHS Act and Regulations. Courts may regard it as evidence of what is known about a hazard, risk or control, and may rely on it when deciding what was reasonably practicable in the circumstances. Inspectors may also refer to it when issuing improvement or prohibition notices.

The Code does not stop a business from using another method. The official text says compliance with the WHS Act and Regulations may be achieved by following another method, such as a technical or industry standard, if it provides an equivalent or higher standard of work health and safety than the code.

The Code says it applies to all types of work and all workplaces where manual tasks are carried out. That is deliberately broad. It is not limited to factories, warehouses or construction sites. The introduction says most jobs involve some type of manual task using the body to move or hold an object, people or animals, and gives examples including stacking shelves, working on a conveyor line and entering data into a computer.

The main audience is the person conducting a business or undertaking, or PCBU, because the Code provides practical guidance on how a PCBU should manage the risk of musculoskeletal disorders arising from hazardous manual tasks in the workplace. But the Code also says the guidance is relevant for designers, manufacturers, importers and suppliers of equipment, materials and tools used for work, as well as designers of workplaces where manual tasks are carried out.

The Code also identifies duties for officers and workers. Officers, such as company directors, must exercise due diligence to ensure the business has and uses appropriate resources and processes to eliminate or minimise risks from hazardous manual tasks. Workers must take reasonable care for their own health and safety, avoid adversely affecting others, comply with reasonable instructions and cooperate with reasonable workplace policies and procedures.

In practical terms, if your business controls work that involves lifting, lowering, pushing, pulling, carrying, holding, restraining, typing, reaching, gripping, supporting, operating vibrating tools or driving over rough terrain, you should assume this Code may be relevant and then check the details against your actual tasks.

The Code adopts the WHS Regulations definition of a hazardous manual task. It is a task that requires a person to lift, lower, push, pull, carry or otherwise move, hold or restrain any person, animal or thing involving one or more of these characteristics: repetitive or sustained force, high or sudden force, repetitive movement, sustained or awkward posture, or exposure to vibration.

These characteristics directly stress the body and can lead to injury. The Code explains that MSDs can occur gradually through wear and tear to joints, ligaments, muscles and discs caused by repeated or continuous use of the same body parts, including static body positions. They can also occur suddenly through strenuous activity or unexpected movements, such as when a load moves or changes position suddenly. Sometimes both mechanisms are involved.

The Code gives many practical examples. Repetitive force can include lifting and stacking goods onto a pallet. Sustained force can include pushing or pulling a trolley around hospital wards, holding down a trigger to operate a power tool, or carrying objects over long distances. High force can include lifting a heavy object, pushing or pulling an object that is hard to move or stop, or restraining a person or animal. Sudden force can include recoil from a large nail gun, carrying an unstable load that suddenly moves, or handling frightened animals or patients who suddenly resist.

Repetitive movement can include painting, lifting goods from a conveyor belt and packing them into cartons, typing and other keyboard tasks, or repeatedly reaching for components. Sustained posture can include supporting plasterboard while it is fixed in place. Awkward posture can include squatting while servicing plant, working with arms overhead, kneeling while trowelling concrete, or bending the neck or back to see around bulky items on a trolley. Exposure to vibration can involve whole body vibration from operating mobile plant or driving over rough terrain, and hand-arm vibration from tools such as chainsaws, grinders, drills and impact wrenches.

The practical point for businesses is that a task does not need to look dramatic to be hazardous. A workstation that causes prolonged reaching, a trolley with poor wheels, a low bench, a vibrating hand tool, or a repetitive keyboard task may all fall within the Code if the task characteristics create MSD risk.

The Code links hazardous manual task management to the general WHS risk management process. The official text states that a PCBU must manage risks to health and safety relating to a musculoskeletal disorder associated with a hazardous manual task. To manage risk under the WHS Regulations, a duty holder must identify reasonably foreseeable hazards, eliminate the risk so far as is reasonably practicable, or if elimination is not reasonably practicable, minimise the risk so far as is reasonably practicable by implementing control measures in accordance with the hierarchy of control, then maintain and review those controls.

In day-to-day business terms, the trigger is not only an injury. You should act when work involves manual tasks with hazardous characteristics, when workers report discomfort or fatigue, when incidents or claims suggest a pattern, when equipment is difficult to use, or when changes to layout, stock, tools, staffing or workflow create new demands on the body.

The Code specifically says consultation with workers is necessary at each step of the risk management process. It also says workers should be encouraged to report problems with manual tasks and signs of discomfort immediately so risks can be managed before an injury occurs. That means early warning signs matter. Waiting for a formal injury report is too late.

The Code also highlights planning-stage triggers. It says businesses should consult workers as early as possible when planning to introduce new tasks or change existing tasks, select new equipment, refurbish, renovate or redesign existing workplaces, or carry out work in new environments. If your business is making any of those changes, that is a practical point to review hazardous manual task risks.

The Code says the first step is to identify tasks that have the potential to cause MSDs. Hazards from manual tasks generally involve interaction between the worker, the work tasks and how they are performed, the tools, equipment and objects handled, and the physical work environment. That means businesses should look at the whole task, not just the object being handled.

The Code recommends four practical ways to identify hazardous manual tasks. First, consult workers. Workers who perform the task can provide valuable information about discomfort, muscular aches and pains that may signal potential hazards. The Code suggests asking workers to identify tasks that are difficult to do, more tiring than they should be, awkward or dangerous, or that cause discomfort.

Second, review available information. The Code says records of workplace injuries and incidents, inspection reports and workers compensation claims for MSDs should be reviewed to help identify which manual tasks may cause harm. It also warns that not all hazardous manual tasks will be associated with reported incidents, so businesses should gather additional information rather than relying only on past reports.

Third, look for trends. The Code says trends may show that certain tasks have more hazardous characteristics, that some characteristics are more common in certain jobs, or that workers in one location are exposed to more hazardous manual tasks than workers elsewhere. That may point to a problem with the design or layout of the work area or the way work is carried out there.

Fourth, observe manual tasks. The Code says hazardous manual tasks can be identified by looking at how people actually work and focusing on their postures and movements. It specifically says to look out for changes that have resulted in new manual tasks or a changed environment, tasks involving tools, machinery or equipment that do not work properly or are difficult to use, and worker improvisations to avoid discomfort, such as stacking mats or flattened cartons to stand on.

The Code says you should carry out a risk assessment for any manual task identified as hazardous, unless the risk is well known and you know how to control it. The purpose of the assessment is to examine the characteristics of the task in more detail and decide whether the forces, movements and postures involved give rise to MSD risk.

According to the Code, a risk assessment can help determine which postures, movements and forces pose a risk, where during the task they pose a risk, why they are occurring and what needs to be fixed. The Code recommends involving the workers who do the task, their health and safety representative if there is one, and management who control how the task is done.

The whole task should be examined, although the Code says it may help to look at the task in stages. Its stationery storage example shows why. Collecting boxes from the delivery dock, transporting them, unpacking them and placing supplies on shelves may each involve different sources of risk. Looking at each stage helps identify what should be changed to control the risk.

The Code also allows group assessment of similar tasks, but only where the tasks are sufficiently similar and do not expose a worker to a different risk than if individual assessments were carried out. For more complex situations, the Code says expert or specialist advice may be useful.

The Code sets out practical questions for assessing risk factors. It asks whether the task involves repetitive movement, sustained or awkward postures, or repetitive or sustained forces. As a general guideline, the Code says a movement or force is repetitive if it is performed more than twice a minute, and a posture or force is sustained if it is held for more than 30 seconds at a time.

The Code then asks whether the task involves long duration. As a general guideline, long duration means the task is done for more than a total of 2 hours over a whole shift or continuously for more than 30 minutes at a time. The Code also reminds businesses to consider that workers may use the same body parts to repeat similar movements across different tasks over time.

Another key question is whether the task involves high or sudden force. The Code says high force can cause MSDs even if it is not repetitive or sustained, so a task involving high force may be a risk even if it is only done occasionally or for short periods. The risk is related to the intensity of the force, the speed involved and whether the force is jerky or sudden.

The examples in the Code are useful because they show what to look for in real workplaces. Risk can increase where workers bend the back or head forward or sideways, twist the back or neck, work with hands above shoulder height, reach forward or sideways away from the body, reach behind the body, stand with most body weight on one leg, perform twisting or wringing actions with the hands or arms, work with fingers close together or wide apart, squat, kneel, crawl or lie in awkward positions, or perform very fast movements.

The Code notes that the risk increases as the degree of bending and twisting increases, and is greatest when postures and movements are extreme or feel uncomfortable for the worker. That is a practical reminder to assess the actual body position and effort involved, not just the written task description.

The Code says risks must be eliminated so far as is reasonably practicable. If elimination is not reasonably practicable, they must be minimised so far as is reasonably practicable by implementing control measures in accordance with the hierarchy of control. The table of contents and operative text show the Code deals with purchasing to eliminate or minimise risks, changing the design or layout of work areas, changing the nature, size, weight or number of items handled, using mechanical aids, handling people and animals, changing the system of work, changing the work environment and using administrative control measures.

For businesses, the practical message is to focus first on changing the job, the item, the layout or the equipment rather than relying only on worker behaviour. A better trolley, a redesigned workstation, different shelf heights, smaller package sizes, a mechanical aid, or a different workflow may reduce risk more effectively than simply telling workers to lift carefully.

Administrative controls still have a place, but the structure of the Code shows they are only one part of the control picture. If a more effective control is reasonably practicable, a business should not stop at instructions, reminders or informal workarounds.

The Code also points to purchasing decisions as a control opportunity. That matters for growing businesses because manual task risk is often built into the workplace by the equipment, packaging, layout or materials chosen at the start. Buying decisions can either eliminate risk early or lock in awkward, forceful and repetitive work for years.

The Code says consultation with workers and their health and safety representatives is necessary at each step of the risk management process. Under the WHS Act, the PCBU must consult, so far as is reasonably practicable, with workers who carry out work for the business and who are, or are likely to be, directly affected by a WHS matter. If workers are represented by a health and safety representative, the consultation must involve that representative.

The Code explains that consultation involves sharing information, giving workers a reasonable opportunity to express views and taking those views into account before making decisions on health and safety matters. It also says workers often know which tools and activities contribute to discomfort and may have practical suggestions or solutions.

Where more than one person has a duty in relation to the same matter, each must, so far as is reasonably practicable, consult, cooperate and coordinate activities with the others. The Code gives a practical delivery example. If a supplier visits your workplace to deliver goods, you should discuss how the goods will be handled, whether environmental factors such as stairs increase the risk, and what each party will do to control the risk.

The Code includes worksheets and appendices for identification and assessment. While the text extracted here does not impose a separate record-keeping rule for those forms, businesses should still keep practical evidence of what they have done. In real terms, that means keeping notes of consultation, observations, identified tasks, assessments where undertaken, chosen controls, maintenance actions and review outcomes. Those records help show the business has followed a systematic process and can also make later reviews much easier.

The instrument is named the Work Health and Safety (Hazardous Manual Tasks) Code of Practice 2015. It was approved by the Minister for Employment on 18 March 2016, registered on the Federal Register of Legislation on 30 March 2016, and commenced on the day after registration. The Federal Register entry identifies it as in force.

Because this is a model code developed for adoption by different Australian jurisdictions, businesses should not assume the Commonwealth instrument is the only relevant source. Before relying on this page, check the current position in the jurisdiction where the work is performed, including whether the model code has been adopted and whether any local regulator guidance should also be followed.