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Cooperation and Coordination with Other Duty Holders

Under section 46 of the WHS Act, a PCBU must consult, cooperate, and coordinate activities with all other persons who have a WHS duty in relation to the same matter, so far as is reasonably practicable.

Why Coordination Matters​

Construction projects typically involve multiple PCBUs:

  • Principal contractor
  • Subcontractors (electrical, plumbing, carpentry, steel, concrete, etc.)
  • Labour hire companies
  • Plant hire companies
  • Designers and engineers
  • Building owners

Without coordination:

  • Gaps occur (each PCBU assumes another is managing a risk)
  • Overlaps occur (duplicate controls waste resources)
  • Conflicts occur (one PCBU's controls interfere with another's work)
  • Risks increase (activities of one PCBU create hazards for others)

When Duty Holders Share Responsibilities​

Duty holders share WHS responsibilities when they have duties for:

1. The Same Workers​

Example - Labour Hire:

  • Labour hire company supplies workers to construction site
  • Principal contractor directs and supervises the work
  • Both have duties to the same workers

Coordination required:

  • Labour hire company ensures workers are inducted, trained, and competent
  • Principal contractor ensures site is safe and provides site-specific training
  • Both exchange information about hazards and incidents
  • Both consult workers about health and safety

2. The Same Workplace​

Example - Shared Building:

  • Multiple businesses occupy one building
  • Building owner manages common areas
  • Each tenant manages their workspace

Coordination required:

  • Agree on emergency procedures and evacuation plans
  • Coordinate maintenance affecting shared areas
  • Exchange information about hazards (e.g., one tenant's chemicals affecting others)
  • Coordinate access for deliveries and contractors

3. The Same Work Activities​

Example - Construction Site:

  • Multiple subcontractors working on same project
  • Work activities interact and overlap
  • Equipment and plant shared or used sequentially

Coordination required:

  • Schedule work to avoid conflicts (e.g., crane operations and work below)
  • Coordinate access and egress routes
  • Share information about hazards created (e.g., excavations, scaffolding)
  • Agree on common controls (e.g., traffic management, site access)

Three Elements: Consult, Cooperate, Coordinate​

Consult​

Share information about:

  • WHS hazards and risks
  • Control measures each PCBU will implement
  • Work activities and schedules
  • Incidents and near-misses
  • Changes affecting others

Cooperate​

Work together by:

  • Responding to information shared
  • Assisting other duty holders to fulfill their duties
  • Not creating unnecessary hazards for others
  • Accommodating others' WHS requirements

Coordinate​

Organize activities to:

  • Prevent conflicts between activities
  • Ensure controls complement each other
  • Avoid gaps in risk management
  • Minimize disruption while maintaining safety

Practical Coordination on Construction Sites​

WHS Management Plan​

Principal contractors must document in their WHS Management Plan:

  • All PCBUs at the site
  • Arrangements for consultation, cooperation, and coordination
  • Communication processes
  • Meeting schedules
  • Incident reporting procedures

Example WHS Management Plan - Coordination Section:

PCBUs at Site:
- [Principal Contractor name]
- [Electrical Contractor name]
- [Plumbing Contractor name]
- [Scaffold Hire Company name]
- [Crane Hire Company name]

Coordination Arrangements:
- Weekly site coordination meetings (Mondays 7:30am)
- Daily toolbox talks involving all trades on site that day
- Shared site induction for all workers
- Common incident reporting system
- Shared safe work method statements for overlapping work

Communication:
- Site WhatsApp group for urgent safety communications
- Email distribution list for SWMS and updates
- Site notice boards for hazard warnings
- Principal contractor site manager as coordination contact

Site Coordination Meetings​

Regular meetings bring together representatives from all PCBUs to:

  • Discuss upcoming work for the week
  • Identify interactions between work activities
  • Coordinate scheduling to avoid conflicts
  • Share information about hazards
  • Review incidents and near-misses
  • Resolve coordination issues

Example Agenda:

  1. Work planned for coming week (each PCBU presents)
  2. Interactions and conflicts identified
  3. Hazards created by each PCBU's work
  4. Control measures required
  5. Coordination of access, plant, and equipment
  6. Incident review and learnings
  7. Actions and responsibilities

Daily Toolbox Talks​

Before work starts each day:

  • All workers on site attend (or separate talks for each area/trade)
  • Discuss work planned for that day
  • Identify which PCBUs are working and where
  • Highlight interactions (e.g., "crane will be operating in Zone 2 all day")
  • Confirm exclusion zones and access restrictions
  • Emergency procedures and assembly points

Shared Systems and Procedures​

Consider common approaches for:

  • Site induction (one induction covering site-wide hazards)
  • Traffic management (all vehicles follow same routes and rules)
  • Emergency procedures (common assembly points and evacuation)
  • Incident reporting (one system, all PCBUs notify principal contractor)
  • Permit systems (hot work permits, confined space permits)

Specific Coordination Scenarios​

Crane Operations and Work Below​

Hazard: Loads or tools falling from crane or rigging

Coordination required:

  • Principal contractor establishes exclusion zones during lifts
  • Crane operator communicates lift schedule
  • Other PCBUs plan work to avoid exclusion zones during lifts
  • Spotter/dogger ensures area clear before lifts
  • Workers below understand exclusion zones and stay clear

Excavation and Services Location​

Hazard: Damaging underground services during excavation

Coordination required:

  • Principal contractor arranges service location (Dial Before You Dig)
  • Service providers mark service locations
  • Excavation contractor uses non-destructive methods near services
  • Electrical, plumbing, gas contractors verify their services' locations
  • All PCBUs informed of excavation location and timing

Scaffolding and Multiple Trades​

Hazard: Scaffold loading, access conflicts, modifications

Coordination required:

  • Scaffold company provides load capacity information
  • All PCBUs using scaffold informed of load limits
  • Only scaffold company modifies or dismantles scaffold
  • Users report damage or defects to scaffold company
  • Principal contractor manages scaffold inspections and tags

Hot Work and Flammable Materials​

Hazard: Welding or cutting igniting flammable materials

Coordination required:

  • Welding contractor obtains hot work permit
  • Other PCBUs informed of hot work location and timing
  • PCBUs working nearby remove or protect flammable materials
  • Fire watch established
  • Fire extinguishers positioned
  • All PCBUs aware of emergency procedures

Resolving Coordination Issues​

When duty holders disagree or fail to cooperate:

1. Attempt to Resolve Directly​

Duty holders should discuss and attempt to resolve issues between themselves.

2. Escalate Within Organizations​

If site representatives cannot resolve, escalate to senior management of each PCBU.

3. Engage Principal Contractor (Construction Sites)​

Principal contractor has coordination responsibilities and can facilitate resolution.

4. Seek Regulator Assistance​

If resolution cannot be achieved and serious risks exist, contact SafeWork NSW for guidance or intervention.

5. Work Must Not Proceed Unsafely​

If coordination fails and work cannot proceed safely, work must not commence or continue until risks are controlled.

[!important] Duties Cannot Be Avoided A PCBU cannot avoid their WHS duties because another PCBU refuses to cooperate. Each PCBU must fulfill their duty to the extent they have capacity to influence and control the matter.

Documentation​

Document coordination arrangements and activities:

WHS Management Plan (principal contractor):

  • List all PCBUs and their roles
  • Coordination arrangements and communication processes
  • Meeting schedules and attendees

Meeting Minutes:

  • Attendees and PCBUs represented
  • Matters discussed
  • Coordination issues identified
  • Agreements reached
  • Actions and responsibilities

Shared SWMS:

  • Work activities of multiple PCBUs
  • Coordination requirements
  • Responsibilities of each PCBU
  • Communication protocols

Common Coordination Failures​

[!warning] Coordination Breakdowns

  • Not identifying all duty holders: Missing PCBUs means gaps in coordination
  • Inconsistent attendance: Different people at each meeting prevents continuity
  • No follow-up on actions: Agreements not implemented
  • Poor communication systems: Information doesn't reach the right people
  • Language barriers: Important information lost in translation
  • Assuming someone else is responsible: "I thought they were managing that risk"

Practical Example: Multi-Storey Construction​

Project: Four-storey commercial building

PCBUs on site:

  • Principal contractor (ABC Construction)
  • Structural steel contractor
  • Concrete and formwork contractor
  • Electrical contractor
  • Plumbing contractor
  • Crane hire company
  • Scaffold hire company
  • Labour hire company

Coordination in Action:

Week 3 - Structural Steel Erection:

Monday Coordination Meeting:

  • Steel contractor: Erecting columns and beams on Level 2 this week
  • Crane operator: Crane will be operating daily 7am-4pm, exclusion zone marked
  • Electrical contractor: Postponing conduit installation on Level 2 until steel complete
  • Concrete contractor: Formwork for Level 1 slab can proceed, below crane operations
  • Scaffold company: Installing scaffold on south face, requires crane time Thursday
  • Principal contractor: Coordinates crane bookings, confirms exclusion zones

Agreed Controls:

  • Exclusion zone around crane operations (barriers and signage)
  • Steel, scaffold, and concrete contractors coordinate crane bookings
  • Electrical work on Level 2 postponed to Week 4
  • Toolbox talks each morning confirm daily plan
  • All workers briefed on exclusion zones

Result:

  • Work proceeds safely with each PCBU fulfilling their duties
  • No conflicts or interference
  • Controls complement each other
  • All workers protected