Hazardous Manual Tasks Under WHS Regulations Part 4.2

Definition and scope under Part 4.2

A hazardous manual task is defined as a task that requires lifting, lowering, pushing, pulling, carrying or otherwise moving, holding or restraining anything. This definition includes activities involving repetitive or sustained force, high or sudden force, repetitive movement, sustained or awkward posture, or exposure to sustained vibration. The term ‘hazardous manual tasks’ replaces the older term ‘manual handling’ to encompass a wider range of activities beyond just lifting. A musculoskeletal disorder (MSD) is an injury to, or a disease of, the musculoskeletal system, which can include back injuries, sprains, strains and chronic conditions. WHS primary duty (s.19) requires persons conducting businesses or undertakings (PCBUs) to manage risks associated with these tasks.

Part 4.2 of the model WHS Regulations applies to all workplaces where hazardous manual tasks are carried out. PCBUs must apply the hierarchy of control under regulation 36 to manage these risks, prioritising elimination, substitution, isolation, engineering controls, administrative controls and personal protective equipment (PPE). This approach aims to minimise the risk of musculoskeletal disorders (MSDs) arising from hazardous manual tasks.

Guidance on managing hazardous manual tasks is available through codes of practice. The Model Code of Practice: Hazardous manual tasks is admissible as evidence in court and outlines what is reasonably practicable in managing these risks. For tasks involving working at height, refer to Working at heights (WHS Part 4.4).

Identifying hazardous manual tasks

Regulation 60 requires the Person Conducting a Business or Undertaking (PCBU) to identify tasks that may pose a risk of musculoskeletal disorders (MSDs) to a worker. This identification process should consider risk factors such as the duration, frequency, and severity of the postures, movements, and forces involved in the task. The Hazardous Manual Tasks Code of Practice provides a Manual Tasks Risk Management Worksheet to assist in this identification and assessment. Plant safety (WHS Chapter 5) may also be relevant where plant is involved.

Common high-risk tasks include manual lifting of loads over 20 kg, repetitive bricklaying, healthcare patient handling, and repetitive process-line work. These tasks often involve a combination of awkward postures, forceful exertions, and repetitive movements. High Risk Work Licences may be required for some of these activities.

Worker consultation is a mandatory requirement when identifying hazardous manual tasks and selecting appropriate controls (section 47 WHS Act). Workers can provide valuable insight into the nature of their work and may report symptoms such as discomfort, pain, and fatigue, which are early indicators that existing controls are not adequate.

Risk control hierarchy for manual tasks

Risk control for hazardous manual tasks should follow a hierarchy of controls. Elimination is the most effective approach, removing the risk entirely; for example, using powered conveyors instead of manual lifting. Substitution involves changing aspects of the task or environment to reduce risk, such as adjusting workstation layout or using lighter materials. WHS primary duty (s.19) requires employers to consider all reasonably practicable controls.

Isolation strategies aim to separate workers from the hazard. This may involve using automated handling equipment or creating distance from vibration sources. Engineering controls provide physical changes to the workplace or tools, such as height-adjustable benches, lift-assist devices, trolleys, and ergonomic tool design.

Administrative controls involve managing the way work is done. Examples include job rotation, providing rest breaks, training in safe techniques, and limiting the amount of time workers spend in fixed postures. Personal protective equipment (PPE), such as anti-vibration gloves, represents the lowest level of control and should not be used as a substitute for higher-order controls; WHS hazardous chemicals (GHS) principles apply to risk assessment.

Worker consultation, training and enforcement

PCBs must provide information, training and instruction to workers on the safe performance of manual tasks. This ensures workers understand how to minimise risk when undertaking these activities. Workers compensation by state and Comcare federal workers compensation schemes provide support for injuries sustained, with musculoskeletal disorders (MSDs) representing more than 30% of serious workers compensation claims annually.

Consultation with workers and Health and Safety Representatives (HSRs) is a legal requirement. This consultation must occur during the identification, assessment and control of manual task risks. Risk assessments and implemented controls should be reviewed when workplace changes occur, following an MSD incident, or when a worker expresses a concern.

State and territory regulators regularly focus on manual tasks during inspection campaigns. Failure to comply with regulations, including those related to hazardous manual tasks, can result in penalties. These penalties can be up to $30,000 for an individual and $150,000 for a body corporate, classifying such breaches as a Category 3 offence.