Chapter 12.4: Contractor Safety Management
Abstract
This chapter examines the critical challenges and opportunities in managing contractor safety within contemporary workplaces. Contractors, particularly in high-risk industries, experience elevated injury and fatality rates driven by precarious employment arrangements, complex subcontracting chains, and systemic issues in safety management. The chapter highlights the legal framework underpinning contractor safety obligations. It explores the limitations of traditional contractor safety management practices, including overreliance on documentation as evidence of operational safety management. It explores the misinterpretation of legal duties leading to contractor safety management that often fails to have the safety of contractors at its core. A contemporary approach is proposed, emphasising the need for proactive procurement strategies, collaborative safety cultures, and clearly defined roles and responsibilities, better reflecting the intention of WHS legislation. Through practical insights and evidence-based approaches, the chapter provides a framework for improving contractor safety outcomes while maintaining compliance and fostering effective working relationships between among principal contractors, clients, and subcontractors to improve safety outcomes for contractors and those who hire them.
Keywords
contractor safety management, procurement, safety, principal contractor, subcontractors
First Year of Publication: 2026
Chapter 12.4: Contractor Safety Management
Table of Contents
| 1 | Introduction |
| 1.1 | Definitions |
| 2 | Factors Affecting Contractor Safety |
| 3 | Contemporary Safety Systems Thinking and Contractor Safety Management |
| 3.1 | Complex Adaptive Systems (CAS) |
| 3.2 | Safety Clutter – Over-reliance on Safety Artefacts |
| 2.3 | Case Studies of Contractor Safety Management Failures |
| 4 | Critical Legal Concepts in Contracotr Safety Management |
| 4.1 | Person Conducting a Business or Undertaking/Concurrent Duties |
| 4.2 | Contractors as Workers |
| 4.3 | Limits on duties owed – reasonable practicability |
| 4.4 | Limits on duties owed – management and control |
| 4.5 | Non-Delegable Duty |
| 4.6 | Consultation and Cooperation |
| 4.7 | Varying Degrees of Control |
| 5 | The Stages of Contractor Safety Management |
| 5.1 | Prequalification/ Procurement |
| 5.2 | Contract Mobilisation and Onboarding |
| 5.3 | Monitoring/ Assurance |
| 5.4 | Performance Review |
| 6 | Implications for Practice |
| 6.1 | The Role of the OHS Professional |
| 6.2 | Practical Management of Contractors – Complex Adaptive Systems |
| 7 | Summary |
| 8 | References |
| Appendix 1 | Case Studies |
| Appendix 2 | Case law on the degree to which a PCBU manages and controls work in respect of the supervision of independent contractors |
Chapter 12.4: Contractor Safety Management
Authors
Sue Bottrell, AIHS Fellow, ChOHSP, Msc Laws
Sue Bottrell has worked in health and safety and workers’ compensation rehabilitation for the past 20 years. Sue is a suitably qualified OHS professional as defined by WorkSafe Victoria (2008) and has qualifications to Master level in both health and safety and law. Sue was the first safety professional in Australia to become a Certified Chartered Generalist OHS Professional Member of the Australian Institute of Health and Safety (AIHS). She has also served as AIHS Treasurer from 2009 – 2010 and as a National Board Member from 2013 – 2015. She has been instrumental in the advancement of the safety profession’s standing in the community.
She has worked with hundreds of businesses, including Executives and operations, to simplify and improve safety management and compliance with respect to contractor safety management.
Sue is a practising lawyer in safety and is the leading legal expert in the management of contractor safety. Sue pre-empted the landmark decision of the High Court in 2012 in Baiada Poultry v the Queen that confirmed the entitlement of principal contractors to rely upon the expertise of the contractor to manage safety in respect of their expert work in her 2011 article published by the AIHS.
Jon Harper-Slade, CFIOSH, GM Health & Safety Innovation, CHASNZ
Jon Harper-Slade is the Senior Director of Health, Safety, and Wellbeing (HSW) within the Entertainment Business Unit at Qiddiya Investment Company (QIC), having commenced the role in February 2026. Jon leads strategic HSW initiatives that support Qiddiya’s ambition to set new global benchmarks in safety performance across one of the world’s most innovative entertainment destinations.
Prior to joining Qiddiya, Jon served as General Manager of Health & Safety Innovation at CHASNZ until early 2026, where he played a pivotal role in delivering initiatives that advanced construction health and safety across New Zealand. Before CHASNZ was formed, Jon was the General Manager of the Construction Safety Council.
Jon’s career is driven by a passion for helping people and improving safety outcomes. Since moving to New Zealand in 2014, he has worked across construction and transportation sectors in both client and contractor organisations. Previously, Jon held the position of Head of Health, Safety, and Environment in the UK for a global research and consultancy firm operating across the Middle East and Africa. His earlier career included work as a Pavement Engineer and valuable experience in the UK military specialising in Ammunition and Explosives.
Jon currently resides in Riyadh, Saudi Arabia, where he is soon to be joined by his wife Liz. He describes himself as a keen but below-average surfer and golfer. He enjoys running, cycling, and swimming to stay fit—and occasionally ties all three together in triathlons.
Jon is a Chartered Fellow of the Institute of Occupational Safety and Health (CFIOSH) and has completed degree-level qualifications in health, safety, and environmental management, alongside postgraduate studies at Griffith University in Brisbane, Australia. Jon continues to explore future opportunities for research and innovation in safety practice, maintaining strong links with the Safety, Health and Innovation Network (SHINe) based out of RMIT, Melbourne, and the Construction Safety Research Alliance (CSRA) based at the University of Colorado Boulder.
Technical Advisors
Paul Breslin, Regional OHS Manager, Multiplex Constructions
Mike Wilson, (Former) Head Environment, Health and Safety, BINGO Industries
Melissa Pollock, (Former) General Manager Health and Safety, Abergeldie
Michael Eather, Director, MicroRisk Group Pty Ltd
Learning Outcomes: Contractor Safety Management
The OHS Body of Knowledge takes a conceptual approach, which enables it to be applied in different contexts and frameworks.
To optimise its value for education and professional development learning outcomes have been developed for each technical chapter in the Body of Knowledge.
The learning outcomes as described give an indication of what should be the capabilities of an OHS professional; it is up to those developing OHS education programs, OHS professionals planning their CPD or recruiters or employers selecting or developing people for the OHS function to consider the required breadth vs. depth.
Please read the section on using the learning outcomes before delving into the learning outcomes of the individual chapters.
The numbers against each learning outcome refer to the chapter number of the BOK download page. No learning outcomes have been developed for the chapters considered introductory or underpinning knowledge (that is, chapters 1, 2, 3, 4, 5, 6, 7, 1, .13, 14, 15.)