Executive Summary
This report presents the findings of a work health and safety (WHS) compliance audit of a distribution centre operated by a hypothetical third-party logistics provider, referred to throughout as Harbourline Distribution Pty Ltd (the operator). The site, at Eastern Creek in Western Sydney, receives, stores and dispatches palletised consumer goods across two shifts, employs approximately 135 workers, and runs counterbalance forklifts, reach trucks and powered pallet trucks alongside pedestrian order pickers. The audit assessed the operator’s arrangements against the model Work Health and Safety Act 2011 and Work Health and Safety Regulations 2011, the associated Safe Work Australia codes of practice, and the management-system requirements of AS/NZS ISO 45001:2018 (Standards Australia 2018).
Eight management-system elements were rated. The operation returned an overall conformance score of 54 per cent, placing it in the partially conformant band and indicating that significant improvement is required. Strengths were evident in visible leadership, WHS policy and incident investigation. However, the audit identified one element, mobile plant and traffic management, as a non-conformance, and the associated hazard, a forklift or reach truck striking a pedestrian in shared aisles, was assessed as an Extreme risk (score 20). Repetitive manual order picking and storage racking integrity were rated High risks. A corrective action plan built on the hierarchy of controls reduces every priority risk to a Medium or Low residual rating, contingent on sustained verification. The single non-conformance is material: under section 19 of the model Act it exposes the operator to enforcement by SafeWork NSW and, in the event of injury, to elevated workers compensation costs.
Audit Scope and Objectives
Under section 19 of the model Work Health and Safety Act 2011 (Cth), a person conducting a business or undertaking (PCBU) owes a primary duty to ensure, so far as is reasonably practicable, the health and safety of workers and of others affected by its work. Harbourline Distribution is the PCBU with management and control of the Eastern Creek site, and its directors are officers with a due diligence duty under section 27 to acquire and keep up to date knowledge of WHS matters and to verify that resources and processes are in place. Warehousing sits within the transport, postal and warehousing sector, which records serious-claim rates well above the national average, with body stressing from manual handling the single largest mechanism of injury (Safe Work Australia 2023). The audit was therefore commissioned as a proactive assurance exercise rather than as a response to a notifiable incident.
The objective of the audit was to evaluate the extent to which the operator’s WHS management arrangements conform with legal obligations and with AS/NZS ISO 45001:2018, to quantify the level of conformance, to identify and rate residual risks, and to recommend prioritised corrective actions. The scope covered the receiving, storage, order-picking and dispatch functions across both shifts and addressed plant, traffic management, hazardous manual tasks, storage racking, emergency preparedness, consultation, incident management and training. It excluded the adjoining transport yard’s on-road operations, dangerous goods storage (not held in bulk at this site) and corporate WHS governance above site level, which were reviewed only insofar as they bear on site conformance. The audit criteria, methods and limitations are set out below.
Audit Methodology
Audit criteria and approach
The audit applied the Plan-Do-Check-Act (PDCA) structure that underpins AS/NZS ISO 45001:2018, illustrated in Figure 1. Systematic auditing against explicit management-system criteria, rather than reliance on lag indicators such as injury counts alone, is central to modern occupational safety management (Reese 2018). Evidence was gathered over a two-day site visit using four methods: review of documented information (the WHS policy, risk register, safe work procedures, plant maintenance and forklift high-risk work licence records, and the training matrix); physical inspection of the warehouse floor, racking, docks and pedestrian routes; observation of live order-picking and forklift operations on both shifts; and structured interviews with the site manager, two supervisors, three elected health and safety representatives (HSRs) and a sample of eight workers. Triangulating documentary, observational and interview evidence limits the risk that a well-documented system is mistaken for a well-implemented one, a recurring theme in the safety-management literature (Hopkins 2019).
Conformance scoring
Eight management-system elements aligned to the model laws and to AS/NZS ISO 45001:2018 were each rated on a four-point scale: Conforms (3), Substantially conforms (2), Partially conforms (1) and Does not conform (0). The overall conformance score is the sum of element scores expressed as a percentage of the maximum available, and is interpreted against four bands: 85 to 100 per cent conformant, 65 to 84 per cent substantially conformant, 45 to 64 per cent partially conformant, and below 45 per cent non-conformant. The percentage is a communication device for management and helps discharge the officers’ section 27 duty to understand the operation’s hazards; it does not override the significance of any single non-conformance, a limitation examined with the findings.
Risk scoring
Hazards associated with each finding were assessed using a semi-quantitative 5×5 risk matrix, a standard risk-analysis technique in which a likelihood rating (L1 Rare to L5 Almost certain) is multiplied by a consequence rating (C1 Insignificant to C5 Catastrophic) to give a risk score from 1 to 25 (Bahr 2015). Scores map to bands of Low (1-4), Medium (5-9), High (10-16) and Extreme (17-25). Ratings reflect the risk remaining after existing controls, consistent with the risk-management process in the model code of practice (Safe Work Australia 2018). The audit is a point-in-time sample and cannot observe every task or shift; it tests but does not independently reconstruct the records it relies on; and risk scores are an ordering device informed by judgement rather than a precise measurement.
Audit Findings
Table 1 records the conformance rating and supporting evidence for each of the eight elements. Ratings range from full conformance in leadership and incident management to a non-conformance in mobile plant and traffic management.
Table 1: WHS management-system conformance findings against the model laws and AS/NZS ISO 45001:2018
| Element | Requirement (source) | Conformance rating | Evidence observed |
|---|---|---|---|
| Leadership and WHS policy | Endorsed policy; officer due diligence (WHS Act s 27; ISO 45001 cl 5) | Conforms (3) | Current signed policy displayed; managers attend the WHS committee; due-diligence reporting to directors evident |
| Worker consultation and HSRs | Consultation, HSRs and committee (WHS Act ss 47-49) | Substantially conforms (2) | HSRs elected and committee active, but the afternoon shift is under-represented and several raised issues remain open |
| Hazard identification and risk management | Systematic identification, assessment, control and review (WHS Reg rr 34-38) | Partially conforms (1) | Risk register exists but has not been reviewed within 12 months; several routine tasks are unassessed |
| Hazardous manual tasks | Manage risks of hazardous manual handling (Hazardous Manual Tasks code) | Partially conforms (1) | Manual order picking with no mechanical aids or task redesign; reliance on lifting technique and PPE |
| Mobile plant and traffic management | Separate pedestrians from powered mobile plant (WHS Reg; SafeWork NSW guidance) | Does not conform (0) | Forklifts and reach trucks share undivided aisles with pickers; no barriers or marked walkways; speed limits posted but unenforced |
| Storage racking integrity | Racking inspected, rated and maintained (AS 4084) | Partially conforms (1) | Impact damage to several uprights; no competent-person inspection regime; load ratings not displayed |
| Emergency preparedness and response | Emergency plan, drills and clear egress (WHS Reg r 43) | Substantially conforms (2) | Documented plan and an annual drill, but two egress routes were partly obstructed by stock at the time of audit |
| Incident notification and investigation | Notify and investigate incidents (WHS Act s 38) | Conforms (3) | Notifiable-incident procedure understood; structured investigations completed with corrective actions tracked |
The overall conformance score is calculated from the rubric set out in the methodology as follows.
Conformance score = (sum of element scores / (number of elements x maximum score per element)) x 100
= (3 + 2 + 1 + 1 + 0 + 1 + 2 + 3) / (8 x 3) x 100
= (13 / 24) x 100
= 54.2 per cent
At approximately 54 per cent the operation falls in the partially conformant band, indicating that significant improvement is required. The result must be read with care. A single element, mobile plant and traffic management, scored zero because forklifts and reach trucks share undivided aisles with pedestrian order pickers, with no physical segregation, no barriered walkways at the pick faces, and speed limits that are posted but not enforced. This is the element most directly linked to the potential for a fatality, yet in a simple average it carries no more weight than any other. The percentage is therefore a useful summary for the operator’s officers but cannot substitute for the risk rating that follows. The strengths, by contrast, are genuine: a current, endorsed WHS policy with demonstrated management engagement, and an incident system that applies structured investigation to notifiable events under section 38 of the model Act, both scored full conformance.
Three elements scored a partial conformance and share a common cause, namely a management system that is documented but not consistently maintained or verified. The risk register had not been reviewed within the preceding 12 months and omitted several routine tasks; manual order picking relied on worker technique rather than task redesign or mechanical aids, contrary to the Hazardous Manual Tasks code (Safe Work Australia 2016); and storage racking showed impact damage to several uprights with no evidence of the periodic inspection by a competent person expected under AS 4084 (Standards Australia 2012). Worker information, training and supervision are themselves explicit duties under the model laws and are more reliably delivered where they are systematised rather than left to individual supervisors (Bluff 2019). Each partial conformance is examined as a rated risk in the next section.
Risk Assessment
The hazards underlying the lower-rated elements were entered into the site risk register and scored with the 5×5 matrix (bands: Low 1-4, Medium 5-9, High 10-16, Extreme 17-25). Table 2 presents the five highest-rated entries. The worked score for the top-ranked hazard is Risk = Likelihood x Consequence = L4 x C5 = 20 (Extreme), reflecting the frequency of forklift-pedestrian interaction in shared aisles across two shifts and the catastrophic consequence of a pedestrian being struck by a counterbalance forklift. Racking collapse (R3) shows a different profile, Risk = L3 x C4 = 12 (High), where accumulated impact damage makes structural failure credible and a collapse of loaded high-bay racking would have major consequences for anyone nearby.
Table 2: Risk register extract, with likelihood, consequence and calculated risk score (after existing controls)
| Ref | Hazard | Likelihood | Consequence | Score (L x C) | Rating |
|---|---|---|---|---|---|
| R1 | Pedestrian order picker struck by forklift or reach truck in shared aisles | L4 Likely | C5 Catastrophic | 20 | Extreme |
| R2 | Musculoskeletal injury from repetitive manual order picking and lifting | L4 Likely | C3 Moderate | 12 | High |
| R3 | Collapse of loaded high-bay racking from accumulated forklift impact damage | L3 Possible | C4 Major | 12 | High |
| R4 | Fall from a trailer or unprotected dock edge during load restraint | L3 Possible | C3 Moderate | 9 | Medium |
| R5 | Impeded evacuation due to obstructed egress routes and a blocked exit | L2 Unlikely | C4 Major | 8 | Medium |
Two features of the register warrant comment. First, the forklift-pedestrian interaction (R1) is the only Extreme risk and is the operational counterpart of the traffic-management non-conformance in Table 1; it is consistent with national data identifying mobile-plant incidents as a leading cause of warehouse fatalities and being hit by moving objects as a frequent mechanism of serious claims in the sector (Safe Work Australia 2023). Second, the High rating for manual order picking (R2) reflects the dominance of body stressing across the sector: musculoskeletal disorders account for the largest share of serious work-related injuries in Australia (Australian Bureau of Statistics 2022), and their cumulative nature means the consequence is enduring disability and lost-time claims rather than a single dramatic event. These two risks alone account for a substantial part of the operation’s likely claims exposure through the New South Wales workers compensation scheme, in which premiums are experience-rated so that claims history directly affects future cost (State Insurance Regulatory Authority 2022).
Corrective Action Plan
The corrective action plan in Table 3 assigns treatments to each priority risk, ordered by the hierarchy of controls required under regulation 36 of the model WHS Regulations: higher-order engineering controls are preferred over administrative controls and personal protective equipment, and measures are combined where a single control is insufficient (Safe Work Australia 2018). Each action is re-scored to a residual risk that assumes full implementation.
Table 3: Corrective action plan with hierarchy-of-controls level, accountability and residual risk re-score
| Ref | Corrective action (hierarchy level) | Responsible | Timeframe | Residual risk |
|---|---|---|---|---|
| R1 | Physical barriers and segregated, marked pedestrian walkways; exclusion zones at pick faces; one-way traffic plan; enforced speed limits; forklift proximity-warning systems (engineering, administrative) | Site and Operations Manager | Immediate (0-4 weeks) | L1 x C5 = 5 (Medium) |
| R2 | Height-adjustable trolleys and mechanical lift assists; slot heavy, high-volume lines at power-zone height; picker rotation; task redesign (engineering, administrative) | Warehouse Supervisor | Short term (1-3 months) | L2 x C3 = 6 (Medium) |
| R3 | Competent-person inspection to AS 4084; upright protectors and column guards; load-rating signage; damage-reporting with quarantine of affected bays (engineering, administrative) | Facilities and Site Manager | Immediate to short term (0-8 weeks) | L2 x C4 = 8 (Medium) |
| R4 | Dock-edge protection and self-closing gates; fall-restraint or edge protection for trailer-top work; eliminate climbing where practicable (isolation, engineering) | Dispatch Supervisor | Short term (1-3 months) | L1 x C3 = 3 (Low) |
| R5 | Clear-egress housekeeping standard; per-shift egress verification; unobstructed marked exits; evacuation drill each shift (administrative) | Site WHS Coordinator | Immediate (0-4 weeks) | L1 x C4 = 4 (Low) |
The residual ratings are deliberately conservative for the high-energy hazards. For the forklift-pedestrian risk (R1), physical segregation, barriered walkways, exclusion zones at pick faces, a one-way traffic plan and proximity-warning technology reduce the likelihood of a strike from Likely to Rare, but because the consequence of any residual contact remains catastrophic the residual settles at L1 x C5 = 5 (Medium) rather than Low. The same logic applies to racking (R3), where competent-person inspection, upright protectors and a damage-reporting and bay-quarantine procedure lower the likelihood while a major consequence persists, giving L2 x C4 = 8 (Medium). Lower-energy hazards can reach Low: dock-edge protection and restraint controls take the fall risk (R4) to L1 x C3 = 3, and a clear-egress standard with per-shift verification takes the evacuation risk (R5) to L1 x C4 = 4. The arithmetic carries a management message consistent with the Check and Act stages of Figure 1: a Medium residual against a catastrophic-consequence hazard is a standing obligation that depends on continuous verification, not a matter that has been closed.
Recommendations
- Treat the traffic-management non-conformance as the immediate priority: physically separate pedestrians from mobile plant with barriers and marked walkways, establish exclusion zones at pick faces, implement a one-way traffic plan with enforced speed limits, and revise the traffic management plan in consultation with workers before the next shift cycle (SafeWork NSW 2021). This is the highest-leverage action for preventing a fatality and for closing the section 19 exposure.
- Commission a competent person to inspect all storage racking against AS 4084, install upright protectors and load-rating signage, and introduce a damage-reporting procedure that quarantines affected bays pending repair.
- Redesign the manual order-picking task to reduce body stressing, introducing height-adjustable trolleys and mechanical lift assists, slotting heavy and high-volume lines at power-zone height, and rotating pickers, consistent with the Hazardous Manual Tasks code (Safe Work Australia 2016).
- Restore the risk-management cycle: complete and review the risk register at least annually and after any incident or change, and ensure all routine tasks are assessed as required under the model Regulations.
- Strengthen the Check and Act stages of the management system by tracking lead indicators, namely the proportion of verified controls, corrective-action close-out times and HSR-raised hazards, alongside lag indicators, and report them to officers to support the section 27 due diligence duty.
- Re-audit after implementation, with a target of moving from the partially conformant band into at least substantial conformance, and verify residual controls through the inspection and consultation cycle rather than through documentation alone.
Conclusion
The audit found a distribution operation with real WHS strengths, notably leadership commitment and incident investigation, but an overall conformance score of 54 per cent that places it in the partially conformant band. The headline figure, however, is less important than its composition. A single non-conformance in mobile plant and traffic management corresponds to the operation’s only Extreme risk, a forklift or reach truck striking a pedestrian, and it is this hazard, together with the High-rated manual handling and racking risks, that most threatens workers and exposes the operator to enforcement by SafeWork NSW and to higher workers compensation costs. The corrective action plan reduces every priority risk to a Medium or Low residual by preferring engineering controls over reliance on behaviour, but the Medium residuals against catastrophic-consequence hazards are standing obligations rather than resolved matters. Read against section 19 of the model Act, conformance here will be produced not by the audit score itself but by implementing the segregation, inspection and task-redesign controls and by verifying, through the Check and Act stages of the management system, that they continue to operate.
References
Australian Bureau of Statistics 2022, Work-related injuries, Australia, cat. no. 6324.0, Australian Bureau of Statistics, Canberra.
Bahr, NJ 2015, System safety engineering and risk assessment: a practical approach, 2nd edn, CRC Press, Boca Raton.
Bluff, E 2019, ‘How SMEs respond to legal requirements to provide information, training, instruction and supervision to workers about work health and safety matters’, Safety Science, vol. 116, pp. 45-57.
Hopkins, A 2019, Organising for safety: how structure creates culture, Wolters Kluwer, Sydney.
Reese, CD 2018, Occupational health and safety management: a practical approach, 3rd edn, CRC Press, Boca Raton.
Safe Work Australia 2016, Hazardous manual tasks: model code of practice, Safe Work Australia, Canberra.
Safe Work Australia 2018, How to manage work health and safety risks: model code of practice, Safe Work Australia, Canberra.
Safe Work Australia 2023, Key work health and safety statistics, Australia 2023, Safe Work Australia, Canberra.
SafeWork NSW 2021, Warehousing and storage: traffic management, SafeWork NSW, Sydney.
Standards Australia 2012, AS 4084-2012: steel storage racking, Standards Australia, Sydney.
Standards Australia 2018, AS/NZS ISO 45001:2018: occupational health and safety management systems, Standards Australia, Sydney.
State Insurance Regulatory Authority 2022, Workers compensation system guide, State Insurance Regulatory Authority, Sydney.
Work Health and Safety Act 2011 (Cth).
Work Health and Safety Regulations 2011 (Cth).