Last Updated on October 15, 2026 by Team TBH
Manufacturing sits in an awkward middle in Australian safety data. It is not the deadliest industry, but it is one of the most consistently injurious, and the gap between those two facts is where most compliance efforts get misdirected.
Safe Work Australia recorded 15 worker deaths in manufacturing in 2025, at a rate of 1.7 per 100,000 workers. That is above the national rate of 1.5, but it is a long way below the rates for transport or agriculture.
The injury picture is different. Manufacturing accounts for 9.6% of all serious workers’ compensation claims in Australia, the third-largest share of any industry. It sits inside the group of four industries that generate just over half of all serious claims while employing roughly a third of the covered workforce.
Put plainly, manufacturing hurts a lot of people without killing many of them. And when a regulator arrives after one of those injuries, the conversation quickly turns to records.
The Three Records a Regulator Asks For
There are three record systems that an Australian manufacturer is expected to produce, and almost every site holds all three in some form.
The first covers the plant itself. The second covers who is competent to operate and maintain it. The third covers the risk assessments that justify how the work is set up.
The problem is rarely that one is missing. It is that the three are maintained separately, by different people, on different cycles, and nobody owns the question of whether they still agree with each other.
Record System One: The Plant Itself
Under the model WHS Regulations, a person with management and control of a plant that requires design or item registration must keep records of every test, inspection, maintenance activity, commissioning, decommissioning, dismantling and alteration. Those records are kept for as long as the plant is in use, or until control of it passes to someone else.
Two details in that obligation catch people out.
The records must be available for inspection, meaning they are retrievable rather than merely existing. And when the plant is sold, the records should go with it. A seller who cannot produce the history faces both regulatory and commercial problems.
The Code of Practice sets out what a complete plant record looks like, and the list is longer than most registers hold.
Unique plant identification number. Design registration information. Commissioning data. Compliance statements and test certificates. Manufacturer specifications and user manuals. Inspection results. Test results, including mechanical guarding tests and stop time measurement. Maintenance and major repairs. Major modifications. Any use that deviates from the intended operating or design conditions.
That last field is the one almost nobody captures, and it is the one that explains the most incidents.
There is a separate, stricter rule for presence-sensing safeguarding systems, under which records of safety integrity testing must be retained for the life of the plant, or for five years where that does not apply.
Keeping all of this against the asset rather than in a maintenance folder is the practical fix, which is what asset management software for manufacturing is built to do.
Record System Two: Who Is Competent to Run It
Maintenance, inspection, and any necessary testing of the plant must be carried out by a competent person in accordance with the manufacturer’s recommendations. Where those recommendations are not available, a competent person’s recommendations apply instead. Where neither is reasonably practicable, inspection and testing must happen at least annually.
Competent is not a job title. It means the knowledge and skills for that specific task, acquired through training, qualification or experience. The test is whether you can evidence it, and the evidence is a record.
For a manufacturer, this usually means three overlapping populations. Operators who run the machine. Maintainers who work on it with guards removed. And supervisors who authorise both.
Training records for all three go stale in predictable ways. People move between lines. Agency and labour hire staff arrive with competencies nobody has verified. Refresher cycles lapse quietly because no system is counting. Holding this in a learning management system built for manufacturing, rather than in a spreadsheet, makes expiry visible before an auditor finds it.
Record System Three: The Risk Assessments Behind Both
The third system is the one most often treated as a one-off exercise. A risk assessment gets done at installation, filed, and never looked at again, while the machine is modified, the layout changes and the product mix moves on.
Assessments need to be reviewed when the work changes, when a control stops being effective, when a new hazard appears, when an incident occurs, and after a consultation raises an issue. The calendar is not the trigger. Change is.
Here is the part that ties this article together. The Code’s own list of what a plant record should contain includes the results of risk assessments carried out on the plant, the information, instruction, and training provided to workers, and the competencies of operators.
The regulations do not treat these as three separate filing problems. They treat them as a single record for one machine. Most manufacturers have split what the law describes as a single obligation across three systems that were never designed to talk to each other.
Why Three Systems Become Three Problems
Each record is usually accurate on its own. The failures happen in the joins.
A machine is modified, and the maintenance log is updated, but the risk assessment still describes the old guarding arrangement. An operator transfers to a different line, and the HR record follows them, while the competency record does not. A guard is replaced with a different type, and nobody retests the stop time because the test sat in a certificate; nobody re-reads.
None of those is negligence. They are the ordinary consequence of three systems, each owned by a different owner, with no shared trigger.
The Currency Test
There is a quick way to find out where you stand that takes about an hour.
Pick one machine. Not the newest and not the worst. Something ordinary that runs most days.
Then ask for four things. It’s the complete plant record, including the last inspection and any modifications. The current risk assessment for the task performed on it. The competency records for everyone who operated or maintained it last month. And the date each of those was last reviewed.
If the four arrive from four places and the dates do not line up, you have found the gap. If one of them takes longer than a day to produce, you have found a second one, because that is roughly the timeframe a regulator works in after a notifiable incident.
What Changes When They Connect
The fix is not more records. Most manufacturers already hold more than they can use.
The fix is a single trigger. When a machine is modified, that event should prompt a review of the assessment, a check to confirm that the controls described still exist, and a question about whether the people running it were trained on the version in front of them rather than the version in the manual.
That is a workflow problem rather than a documentation problem, and it is solvable without buying anything, provided somebody owns it.
The measure of whether it is working is simple. When something changes on the floor, how long before all three records know about it? On most sites, the honest answer is that they find out separately, at different speeds, and sometimes not at all.
Figures are from Safe Work Australia’s Key Work Health and Safety Statistics Australia 2026. Record-keeping requirements are set out in the model Code of Practice: Managing risks of plant in the workplace
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