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Conduct structured, practical SWMS (Safe Work Method Statement) compliance reviews against Australian WHS legislation for QLD, NSW, TAS, VIC, and WA jurisdictions. Typically routed to by the request-router skill when a SWMS is detected, or invoked directly by name (e.g. "run a SWMS review", "review this SWMS using swms-review"). Also trigger when users explicitly ask about SWMS content requirements, HRCW categories, or whether a SWMS meets regulatory standards. This skill references the safetysure-whs-legislation plugin for jurisdiction-specific WHS Act and Regulation checker skills to verify all legislative references before citing them. Produces prioritised, practical findings using a P1/P2/P3 framework based on risk level and timing.
How this skill is triggered — by the user, by Claude, or both
Slash command
/safetysure-swms:swms-reviewThe summary Claude sees in its skill listing — used to decide when to auto-load this skill
Conduct thorough, practical SWMS compliance reviews for Australian construction
Conduct thorough, practical SWMS compliance reviews for Australian construction and maintenance work across supported jurisdictions (QLD, NSW, TAS, VIC, WA). This skill handles any work type — not only those with predefined Work Type Modifiers. When a SWMS describes work that does not match an existing modifier, use Freestyle Review Mode (see below) to research and address work-type-specific hazards.
Findings must be grounded in verified legislative provisions — never cited from memory alone. The safetysure-whs-legislation plugin contains jurisdiction-specific WHS Act and Regulation checker skills. Always read the relevant skills from that plugin before citing any provision.
Findings are organised by priority and written in plain language suitable for direct communication to a contractor or principal contractor.
This skill supports QLD, NSW, TAS, VIC, and WA jurisdictions. Regulation section numbers (e.g. rr 289–303) are harmonised across QLD, NSW, TAS, and WA — the numbers are the same, only the Act and Regulation names differ by state. Victoria (VIC) is non-harmonised. VIC operates under the OHS Act 2004 (Vic) and OHS Regulations 2017 (Vic), which use different regulation numbers, terminology (e.g. 'employer' instead of 'PCBU'), and file naming conventions. When the detected jurisdiction is VIC, use the VIC-specific regulation numbers and chapter file names listed in Step 2 below. The VIC regulation cross-reference is provided in the ohs-regulation-checker-vic SKILL.md.
Jurisdiction detection workflow:
Jurisdiction Mapping Table:
| QLD | NSW | TAS | VIC | WA | |
|---|---|---|---|---|---|
| WHS/OHS Act | WHS Act 2011 (Qld) | WHS Act 2011 (NSW) | WHS Act 2012 (Tas) | OHS Act 2004 (Vic) | WHS Act 2020 (WA) |
| WHS/OHS Regulation | WHS Regulation 2011 (Qld) | WHS Regulation 2025 (NSW) | WHS Regulations 2022 (Tas) | OHS Regulations 2017 (Vic) | WHS (General) Regulations 2022 (WA) |
| Act checker skill | whs-act-checker-qld | whs-act-checker-nsw | whs-act-checker-tas | ohs-act-checker-vic | whs-act-checker-wa |
| Regulation checker skill | whs-regulation-checker-qld | whs-regulation-checker-nsw | whs-regulation-checker-tas | ohs-regulation-checker-vic | whs-regulation-checker-wa |
| Regulator | WHSQ | SafeWork NSW | WorkSafe Tasmania | WorkSafe Victoria | WorkSafe WA (Commissioner) |
| Electrical safety | Electrical Safety Act 2002 (Qld) | WHS Regulation 2025 (NSW) Ch 4 | Electricity Supply Industry Act 1995 (Tas) | Electricity Safety Act 1998 (Vic) | Electricity Act 1945 (WA) |
| Public health | Public Health Act 2005 (Qld) | Public Health Act 2010 (NSW) | Public Health Act 1997 (Tas) | Public Health and Wellbeing Act 2008 (Vic) | Public Health Act 2016 (WA) |
| Environmental | Environmental Protection Act 1994 (Qld) | POEO Act 1997 (NSW) | EMPCA 1994 (Tas) | Environment Protection Act 2017 (Vic) | Environmental Protection Act 1986 (WA) |
Note: Throughout this document, references to 'the Act' and 'the Regulation' mean the WHS/OHS Act and WHS/OHS Regulation for the detected jurisdiction. Regulation numbers (e.g. rr 289–303) are consistent across QLD, NSW, TAS, and WA. For VIC, regulation numbers differ — see the VIC column in the loading tables below. The term 'PCBU' is used throughout this skill; for VIC, read 'employer' in place of 'PCBU'.
Always load the relevant skill files before citing any provision. Never
rely on training memory for section or regulation numbers. Read the
jurisdiction-specific Act checker and Regulation checker skills from the
safetysure-whs-legislation plugin as the source of truth (e.g.
whs-act-checker-qld and whs-regulation-checker-qld for Queensland
work — see jurisdiction mapping table for other states).
Verify, don't assume. If information is absent from the SWMS (e.g. no licence number, no SDS attached), state it is absent — do not assume it exists elsewhere. Absence of evidence in the SWMS is a finding.
Work type drives the review. Before running the checklist, identify the specific nature of the work. Different work types carry hazards that a generic checklist will miss (see Work Type Modifiers below).
Cross-regulatory thinking. The WHS Act and Regulation are not the only instruments. Flag when other legislation may apply. Refer to the jurisdiction mapping table for the equivalent supplementary legislation — e.g. electrical safety, public health, and environmental legislation for the detected jurisdiction.
Precision over breadth. Pinpoint the exact task step(s) where a gap exists rather than making a general recommendation. "Add hot work permit reference to Steps 8, 9, 10 and 14" is more useful than "add a welding task step."
Conservative, factual language. Describe what the regulation requires and what the SWMS does or does not contain. Avoid subjective terms like "significant risk" or "serious concern."
Australian English spelling throughout.
Flag and ask when uncertain. If you encounter an unfamiliar work type, chemical, piece of equipment, standard, or hazard that you cannot confidently assess using the core checklist, loaded legislation, and web search results — stop and ask the reviewer before recording a finding or marking an item as met. Do not guess. Present what you found, what you are uncertain about, and ask for direction. It is better to pause than to produce an inaccurate finding.
Use web search to fill knowledge gaps. When the SWMS references a product, chemical, Australian Standard, code of practice, piece of plant, or work methodology that you are not confident about, use web search to verify. Typical searches include:
Verify the Action By column against competency requirements. For every task step, check whether the person or role nominated in the Action By column can actually perform the controls listed. "All Workers" is insufficient where a control requires a Licensed Electrician, Licensed Rigger/Dogger, Competent Person (as defined under the WHS Regulation), or OEM technician. The Action By must nominate the specific role or person with the authority and competency to implement the control.
Treat scope exclusions as excluded — do not analyse. When the user or the planning documentation explicitly states that a hazard category is not part of the scope (e.g. "no hot works"), the review comment for that hazard row must state "not applicable — remove this row" and direct removal from the SWMS. Do not analyse the adequacy of controls for excluded hazards. Do not hedge or qualify. If a hazard is out of scope, say so plainly and move on.
Systemic findings are more effective as single overarching comments. Where a deficiency applies across multiple or all steps (e.g. hierarchy of controls overreliance on administrative controls and PPE), raise it as a single systemic finding rather than repeating it at every step. This avoids diluting the message with repetitive findings and makes the systemic nature of the issue clear to the reader.
Hazard-first approach — identify hazards independently, then test controls against legislation. Do not limit the review to what the SWMS author has listed as hazards. Independently consider what hazards the activity would present based on the scope, equipment, environment, and methodology described. For each hazard identified: (a) determine the applicable hazard category (electrical, falls, manual handling, noise, dust/chemical, confined space, plant/lifting, hot works, stored energy, etc.); (b) load and check the relevant legislative provisions from the dependency skills for that hazard category; (c) assess whether the documented controls are adequate to meet compliance with the legislation governing that category; (d) where controls are absent, inadequate, or do not match the legislative requirements, raise a finding citing the specific provision. This ensures hazards the SWMS author has failed to identify are still captured, and that controls are tested against the correct legislative requirements rather than accepted at face value.
This skill relies on the safetysure-whs-legislation plugin for verified legislative
text and one reference file for hazard-specific domain knowledge. The legislation plugin
contains ten jurisdiction-specific skills: Act and Regulation checker skills for QLD,
NSW, TAS, VIC, and WA. Based on the detected jurisdiction, this skill loads from the corresponding
Act checker skill (parts/ directory) and Regulation checker skill (chapters/ directory).
For QLD, NSW, TAS, and WA, file naming conventions are identical (e.g. pt02-duties.md,
ch06-construction.md). For VIC (non-harmonised), the skills are ohs-act-checker-vic and ohs-regulation-checker-vic — note the different file naming conventions (e.g. ch05a-construction.md instead of ch06-construction.md).
Additionally:
references/fsc-hazard-benchmarks.md in this
skill's directory. Contains hazard-specific benchmarks derived from the Federal
Safety Commissioner's Audit Criteria (Version 1.5, April 2024). These
benchmarks describe what a "good" safe system of work looks like for each
hazard category (H1–H19) and are used in Step 4 to supplement Work Type
Modifiers with domain-specific knowledge about expected controls.Read the specific part/chapter files listed in Step 2 before citing any provision. Do not load all files — read only what the work type requires.
Extract:
Identify the work type from the scope — this determines which Work Type Modifiers to activate in Step 3.
Determine jurisdiction first (see Jurisdiction section above). Based on the detected jurisdiction and work type, read the minimum necessary files from the jurisdiction-specific dependency skills in the safetysure-whs-legislation plugin.
For example, if the detected jurisdiction is NSW, [regulation checker] → chapters/ch06-construction.md means loading from the whs-regulation-checker-nsw skill. All file naming conventions are identical across jurisdictions.
Always load for any SWMS review:
| Jurisdiction | Regulation checker chapter | Key regulations |
|---|---|---|
| QLD / NSW / TAS | chapters/ch06-construction.md | rr 289–303: construction work definition, HRCW definition (r 291), SWMS content requirements (r 299), compliance (r 300), copy to PC (r 301), review (r 302) |
| VIC | chapters/ch05a-construction.md | rr 321–329: construction work definition (r 321), HRCW definition (r 322), SWMS definition (r 324), SWMS content and compliance (r 327), SWMS review (r 328), copy to be kept (r 329) |
Load based on work type:
Paths below use [regulation checker] and [act checker] as shorthand for the jurisdiction-specific skills (e.g. whs-regulation-checker-qld for Queensland work, whs-regulation-checker-nsw for NSW work, etc.).
| Work involves... | Harmonised (QLD/NSW/TAS) | VIC (OHS Regs 2017) |
|---|---|---|
| Falls > 2 m / rope access | [regulation checker] → chapters/ch04-hazardous-work.md (rr 78–80) | [regulation checker] → chapters/ch03b-falls.md (rr 41–49) |
| Demolition / dismantling | [regulation checker] → chapters/ch04-hazardous-work.md (rr 142–144F) + ch12-13-transitional.md for Schedule 19 | [regulation checker] → chapters/ch05a-construction.md (rr 349–373) |
| Confined spaces | [regulation checker] → chapters/ch04-hazardous-work.md (rr 62–78) | [regulation checker] → chapters/ch03c-confined-spaces.md (rr 50–77) |
| Noise / grinding / cutting | [regulation checker] → chapters/ch04-hazardous-work.md (rr 57–59) | [regulation checker] → chapters/ch03a-manual-handling-noise.md (rr 29–40) |
| Hazardous manual tasks | [regulation checker] → chapters/ch04-hazardous-work.md (rr 60–61) | [regulation checker] → chapters/ch03a-manual-handling-noise.md (rr 26–28) |
| Hazardous chemicals | [regulation checker] → chapters/ch07-hazardous-chemicals.md (rr 330–392) | [regulation checker] → chapters/ch04a-hazardous-substances.md (rr 140–171) |
| Crystalline silica / cement | [regulation checker] → chapters/ch08a-crystalline-silica.md | [regulation checker] → chapters/ch04d-crystalline-silica.md (rr 245–260) |
| Asbestos disturbance | [regulation checker] → chapters/ch08-asbestos.md | [regulation checker] → chapters/ch04c-asbestos.md (rr 206–244) |
| Plant / lifting equipment | [regulation checker] → chapters/ch05-plant-structures.md | [regulation checker] → chapters/ch03d-plant.md (rr 78–127) |
| PCBU/officer duties | [act checker] → parts/pt02-duties.md | [act checker] → parts/pt03-duties.md |
| Consultation obligations | [act checker] → parts/pt05-consultation.md | [act checker] → parts/pt04-consultation.md |
| Incident notification | [act checker] → parts/pt03-incident-notification.md | [act checker] → parts/pt05-incidents.md |
Work through every item. For each, record: ✓ Met / ⚠ Caution / ✗ Gap / N/A.
For each task step, assess whether the person or role in the Action By column can actually perform the controls listed. This check catches a common drafting failure where "All Workers" is entered as a default without considering the competency requirements of the controls.
This is a systemic check applied across the entire SWMS, not step by step. Raise it as a single overarching finding if the deficiency is systemic (Critical Rule 12).
Before running the Work Type Modifiers below, load
references/fsc-hazard-benchmarks.md and identify which FSC hazard categories
(H1–H19) apply to the scope of works. For each applicable category, run through
the FSC benchmark checklist items in addition to the Work Type Modifier checks.
The FSC benchmarks provide domain-specific knowledge about what controls, evidence, and documentation a competent safe system of work should address for each hazard type. They supplement the legislative checklist (Step 3) with practical expectations — for example, H1 (Working at Heights) requires that a SWMS relying on fall arrest must address rescue of a suspended worker; H12 (Electrical) expects a certificate of electrical compliance; H16 (Mobile Plant) expects a separate Plant Risk Assessment distinct from the SWMS.
Classifying FSC benchmark findings: Where a benchmark item relates to a legislative requirement (e.g. licensing, RCD protection, demolition plan), classify per the normal P1/P2/P3 framework based on the legislative provision. Where a benchmark item relates to a system or process expectation beyond the regulation (e.g. separate Plant Risk Assessment, calibration records for gas detection), note it as a best-practice gap with reference to the FSC benchmark and classify as P3 unless the absence creates a foreseeable safety gap that warrants P2.
Note: The FSC benchmarks represent what the Federal Safety Commissioner expects of accredited builders on Commonwealth-funded projects. For non-FSC work, they still represent recognised good practice and should be applied as best-practice recommendations rather than compliance obligations. Frame findings accordingly.
The Work Type Modifiers below are additional checks that activate based on the specific nature of the work. A generic checklist will not catch these — they address hazards that sit outside the standard WHS Regulation construction provisions.
Cooling towers are regulated under the applicable public health legislation for the detected jurisdiction (see jurisdiction mapping table) in addition to WHS legislation. The water in cooling towers can harbour Legionella pneumophila and other bacteria. Risk increases when water is disturbed.
Check:
Rope access work introduces specific requirements beyond the standard fall prevention checklist. The IRATA International Code of Practice (ICOP) and its Annex R (Rescue and Evacuation Planning, October 2024) apply in addition to WHS legislation.
Check:
Asbestos register threshold: Buildings constructed before 31 December 1989 are required to maintain an asbestos register under the Regulation, rr 425–427. For buildings constructed between 1 January 1990 and 31 December 2003, ACM installed before 31 December 2003 remains subject to management obligations under Chapter 8. Buildings constructed after 31 December 2003 are not expected to contain ACM.
Check:
Plant overhaul work involves disassembly, refurbishment, and recommissioning of complex mechanical and electrical equipment. It introduces hazards that a standard maintenance SWMS often fails to address because the scope crosses multiple trade disciplines and involves non-routine work on equipment in non-standard configurations.
Isolation and stored energy:
Methodology changes during planning:
Lifting and mechanical handling during disassembly/assembly:
Commissioning and first energisation:
Handback:
Non-English-speaking workers:
Site-specific controls:
If the SWMS describes a work type that does not match any of the predefined Work Type Modifiers above, activate Freestyle Review Mode. This ensures every SWMS receives a thorough, work-type-aware review regardless of whether a specific modifier exists.
Procedure:
Identify the work type clearly. State the specific nature of the work (e.g. "scaffolding erection and dismantle", "excavation near services", "crane lift of mechanical plant", "waterproofing application", "traffic management for road works").
Use web search to research work-type-specific hazards and obligations. Search for:
Build an ad-hoc checklist based on:
Apply the ad-hoc checklist to the SWMS task steps in the same manner as the core checklist — record ✓ Met / ⚠ Caution / ✗ Gap / N/A for each item.
Flag uncertainty. If, after web searching and reviewing the loaded legislation, you are still uncertain about whether a specific requirement applies or whether the SWMS adequately addresses it, stop and ask the reviewer (Critical Rule 8). Present:
Important: Freestyle Review Mode is not a lesser review. It produces findings at the same standard and priority classification as a modifier-based review. The only difference is that the checklist is built dynamically rather than from a predefined template.
After a Freestyle Review: If the review identifies recurring work-type- specific checks that would benefit future reviews, note this in the output under a "Suggested Modifier" heading. This helps Safetysure build new Work Type Modifiers over time.
Use three priority levels:
P1 — Stop / Fix Before Proceeding Work should not continue on the affected task(s) until resolved. Use for:
P2 — Fix Before the Specific Task Commences Work on other tasks may continue; affected task cannot start until resolved. Use for:
P3 — Administrative Correction (next revision) Does not directly affect on-the-ground controls. Use for:
Structure the output as follows:
Tone: Plain language, directed to the contractor and principal contractor. Write as a practitioner communicating with a site team, not as a legal document. Specific is better than general — name the task step numbers, name the regulation numbers, name the product.
These are documented failure modes from previous reviews. They exist to prevent recurrence and explain the reasoning behind several of the rules above.
1. Work type modifiers are not optional. A cooling tower SWMS without a Legionella / biological hazard check is incomplete regardless of how thorough the WHS Regulation analysis is. Biological hazards in cooling systems are a known, regulated risk that sits outside the WHS Regulation. Always activate applicable Work Type Modifiers before finalising the review.
2. Verify chemical classification before flagging as hazardous. Do not assume a product is hazardous because it is listed in the chemicals table. The SWMS itself may have incorrectly included it. Check the SDS classification. If not classified as hazardous under the GHS/SDS regime, note this and recommend removal from the hazardous chemicals register rather than recommending additional controls.
3. Precision in recommendations. When a control (e.g. hot work permit) exists in the SWMS but is not applied at the right task steps, the recommendation is to cross-reference it at those steps — not to add a whole new section. Read what is already in the SWMS before recommending additions.
4. Licensing absence is a finding, not an assumption. If the SWMS contains no evidence of a required licence (demolition, asbestos, electrical), state that the licence is not demonstrated in the SWMS. Do not assume it exists. Absence of evidence in the only document available is a material finding.
5. Environmental conditions are occupational hygiene. Heat stress on an Australian rooftop in summer during heavy physical work is a foreseeable occupational health issue. If the SWMS covers a physically demanding outdoor or rooftop scope, check for heat stress management regardless of whether it is in the WHS Regulation checklist.
6. Cross-regulatory awareness. Always ask: is there legislation outside the WHS Act and Regulation that applies to this work type? Refer to the jurisdiction mapping table for the applicable electrical safety, public health, and environmental legislation. These do not need to be analysed in depth — flag their applicability and the specific obligation.
7. A generic rescue plan is not a site-specific rescue plan. r 80(2) requires emergency procedures including rescue procedures to be established in relation to the use of a fall arrest system. For rope access work, IRATA ICOP Annex R (October 2024) additionally requires rescue plans to be site-specific, including a description of the work environment, access points, safe zones, and site-specific rescue methodology. A competent generic company rescue plan covering basic and advanced rescue scenarios does not satisfy these requirements. The rescue plan must reference the actual building/structure, its working heights, and the designated safe zone(s) for casualty reception. This was identified in the Gecko Rope Access review (Job 3933, Riverside Centre) where a technically sound generic plan lacked any reference to the specific site.
8. Residual risk ratings remaining HIGH require documented justification. If a task step's residual risk rating remains HIGH after controls are applied, this is the only step in the sequence where this occurs, or it is an outlier. Query whether the rating reflects the irreducible inherent risk profile of the activity, or whether additional risk reduction measures have been considered but not documented. This is a conversation to have with the contractor rather than an automatic finding — but the question should be raised.
9. Load rating verification for cord, rope, and haul systems. When a SWMS specifies a cord or rope for hauling items (e.g. "6 mm-rated cord" for hauling louvres to a roof via a progress capture system), confirm that the unit weight and dimensions of the items being hauled are stated. Without the item weight, there is no basis for verifying the cord/system is appropriately rated. This was identified in the Gecko Rope Access review where louvre specifications were absent.
10. IRATA/ARAA qualifications constitute competency-based assessment. When reviewing against an Appendix K-style SWMS checklist that asks whether "competency-based assessment" arrangements are in place, IRATA and ARAA qualifications satisfy this criterion. IRATA training involves "training and assessment by a third-party assessor" with practical demonstration of rescue techniques required at each tier level. Do not mark this as N/A for rope access SWMS where all personnel hold current IRATA/ARAA qualifications.
11. Anchor point approvals may not transfer between work types. If a SWMS states anchor points were "previously approved" for a different purpose (e.g. sign installation, BMU operations), do not assume the approval extends to rope access dynamic loading. Different work types impose different dynamic load factors on anchor points. The approval should be confirmed as applicable to the specific work type.
12. Pre-1990 vs pre-2004 asbestos thresholds. There are two distinct asbestos-related thresholds for existing buildings: (a) Buildings constructed before 31 December 1989 — must maintain an asbestos register (WHS Regulation rr 425–427). Failure to reference the register for work in these buildings is a P2 finding. (b) Buildings with ACM installed before 31 December 2003 — ACM remains subject to management obligations under Chapter 8. The earlier "pre-2004 construction" label in the Work Type Modifiers was imprecise. Both thresholds are now documented in the modifier.
13. Freestyle reviews must meet the same standard as modifier-based reviews. When Freestyle Review Mode is activated for an unfamiliar work type, the temptation is to produce a shallow review because no predefined checklist exists. This defeats the purpose. The ad-hoc checklist must be built from genuine research — web search for applicable codes of practice, WHSQ guidance, and industry standards — and applied with the same rigour as a predefined modifier. If the research does not yield enough information to build a competent checklist, flag this to the reviewer and ask for guidance rather than producing a superficial review.
14. Web search results do not replace verified legislation. Web search is a tool for filling knowledge gaps about products, standards, equipment, and industry practices. It does not replace the verified legislative text in the safetysure-whs-legislation plugin skills. If a web search result contradicts the loaded legislation, the legislation prevails. Always cite the legislative provision, not the web search result, when making regulatory findings.
15. Distinguish legislative requirements from good-practice recommendations. Not every desirable SWMS inclusion is a legislative requirement. For example, recording electrical licence numbers on the SWMS is prudent due diligence for competency verification, but neither the Regulation nor the applicable electrical safety legislation mandates that licence numbers appear on the SWMS document itself — the obligation is that the person performing the work holds the appropriate licence. Where the skill identifies an omission that is good practice rather than a regulatory requirement, it must be classified as P3 (administrative/good practice), not P2 or P1. The finding narrative must clearly state that no specific legislative provision requires the item to appear on the SWMS, and frame it as a recommended due diligence control. If uncertain whether an item is legislatively required or merely good practice, apply Critical Rule 8 (flag and ask) rather than defaulting to a higher priority classification.
16. "All Workers" in the Action By column is a reliability indicator. When every step of a SWMS lists "All Workers" as the responsible party, it reliably indicates the SWMS was drafted without mapping controls to competencies. This is not merely an administrative deficiency — it means no one has considered who actually performs each control. Checking the Action By against licensing requirements (Licensed Electrician under the applicable electrical safety legislation, Licensed Rigger/Dogger under the Regulation rr 207–216) and competency definitions (Competent Person under r 146) is a productive line of inquiry that frequently reveals P2 findings. This was identified in the River Sands Concetti Overhaul review (March 2026) where every step listed "All Workers" despite requiring electrical isolation, rigging work, OEM commissioning, and formal handback.
17. Scope exclusions must be handled cleanly — state N/A and direct removal. When a hazard category is explicitly excluded from the scope of work (e.g. "no hot works"), the review comment must say "not applicable — remove this row" and move on. The initial instinct is to still analyse the controls for that hazard "just in case" or to critique their adequacy while noting the exclusion. This creates confusion and contradicts the agreed position. If something is excluded, say so plainly. Do not hedge. This was a recurring correction in the River Sands review where the reviewer had to emphasise twice that hot works were not in scope.
18. Systemic hierarchy-of-controls deficiencies are best raised as one finding. When a SWMS relies predominantly on administrative controls ("ensure", "observe", "follow procedures") and PPE across multiple or all steps, this is a systemic issue — not a collection of individual step-level findings. Raising it once as an overarching finding (citing WHS Act s 17 and WHS Regulation r 36) is more effective than repeating the same point at every step. A single systemic finding makes the structural nature of the problem clear and avoids diluting the message with repetitive commentary.
19. Controls copied from generic templates often do not match the site. A common drafting failure is copying controls from a template library without adapting them to the actual work environment. Examples from the River Sands review: "work only to be carried out in daylight hours / ensure sufficient lighting" applied to work conducted entirely inside an enclosed industrial building with permanent artificial lighting; "ensure all handrails and walkways are in good condition" when the agreed methodology required temporary removal of a handrail section. Each control must be assessed for site-specific applicability, not just presence.
20. Commissioning is a distinct hazard phase requiring distinct controls. SWMS documents frequently treat commissioning/testing as a brief afterthought ("test and verify" or "observe procedures for testing"). First energisation after major mechanical and electrical work is one of the highest-risk phases of an overhaul. It requires: emergency stop verification, guard and interlock confirmation, progressive run-up, airborne dust/product management (especially where crystalline silica is present), and joint authorisation by the electrician, OEM technician, and site supervisor. The River Sands review identified five separate gaps in a single commissioning step.
21. Stored energy extends beyond electrical isolation. SWMS documents for plant overhaul work routinely address electrical isolation but fail to address other stored energy sources. Gravity-fed product in bins, hoppers, and chutes above the work area can release unexpectedly when mechanical connections are broken. Pneumatic and hydraulic accumulators retain pressure. Springs and counterweights store mechanical energy. VSD DC bus capacitors store lethal voltage for up to 15 minutes after electrical isolation. The isolation procedure must identify and address every energy source, not just electrical supply.
22. Deisolation and handback are safety-critical steps that SWMS documents routinely omit. Deisolation (the reverse of the isolation process) and formal handback to operations are frequently missing from SWMS documents. Deisolation requires: removal of all LOTO devices, verification that tools and personnel are clear, a controlled re-energisation sequence, and formal notification to operations. Handback requires a nominated person with authority to accept the completed work on behalf of the PCBU. Without these steps documented, there is no controlled process for returning the plant to service.
references/fsc-hazard-benchmarks.md) derived from the Federal Safety
Commissioner's Audit Criteria (Version 1.5, April 2024). Step 4 updated
to load and apply FSC hazard-specific benchmarks (H1–H19) alongside
existing Work Type Modifiers, providing domain-specific knowledge about
expected controls for each hazard category. FSC findings classified per
the existing P1/P2/P3 framework with guidance on distinguishing legislative
requirements from best-practice expectations.npx claudepluginhub teddychenfeiyang-png/safetysure-plugins --plugin safetysure-swmsCreates, edits, and optimizes skills for Claude Code, including drafting, evaluating with test prompts, iterating on performance, and improving skill descriptions for better triggering accuracy.