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WHS Consultation, Cooperation & Coordination

The "three Cs" — talk to your workers, talk to other duty holders, plan activities together so safety doesn't fall through the gaps.

Quick Take
  • Consult workers on every WHS decision that affects them — six statutory triggers, see §3.
  • Cooperate with other PCBUs sharing the duty; coordinate activities so controls don't conflict.
  • On a construction site, the Principal Contractor's WHS Management Plan must document the 3C arrangements.
  • Workers must be given a reasonable opportunity to express views — agreement is not required, but views must be considered.
  • Keep meeting minutes, HSR election records and consultation outcomes — they're the paper trail regulators look for.

1. Who's responsible​

PCBU duties

  • s.47 — Consult workers (employees, contractors, on-hire, apprentices, volunteers) directly affected by WHS matters.
  • s.46 — Consult, cooperate, coordinate with all other PCBUs sharing the same duty.
  • s.16 — When duties overlap, each PCBU keeps their duty; discharge it to the extent you can influence the matter.
  • Reg 309 — Principal contractors document the 3C arrangements in the WHS Management Plan.

Officer due diligence (s.27)

  • Verify the PCBU has working processes for worker consultation and inter-PCBU coordination.

Worker duties (s.28)

  • Take reasonable care; comply with reasonable instructions; cooperate with safety procedures.

2. The three Cs​

Consultation — sharing information, listening, considering views, advising the outcome.

  • With workers: anyone the matter directly affects.
  • Views must be considered, not necessarily accepted — but if rejected, explain why.

Cooperation — responding to reasonable requests from other duty holders, not obstructing them, complying with shared procedures.

Coordination — planning and sequencing work so each duty holder's controls complement (not undermine) the others'. Ongoing through the work, not just at the start.

Consultation is what and who. Cooperation is willingness. Coordination is timing and sequence.

3. When you must consult workers (s.49 — six triggers)​

  1. Identifying hazards and assessing risks of work being or to be done.
  2. Deciding on controls to eliminate or minimise those risks.
  3. Adequacy of facilities for workers' welfare (toilets, water, eating, change rooms).
  4. Proposing changes affecting WHS — new plant, substances, systems of work, restructuring.
  5. Developing procedures for: consultation, issue resolution, health monitoring, training.
  6. Deciding the procedures for consultation itself.

Regular forums (toolbox talks, pre-starts, fortnightly meetings) usually beat case-by-case consultation — issues surface earlier.

4. HSRs and HSCs​

Health and Safety Representative (HSR)​

  • Established when workers ask for one. The PCBU and workers negotiate work groups; election follows.
  • Powers: represent the work group, attend WHS consultations, request information, undertake approved training, issue PINs and direct unsafe work to cease (after training).
  • PCBU duty: alert workers to their right to elect an HSR; include the elected HSR in all WHS consultations.

Health and Safety Committee (HSC)​

  • Must be established within 2 months of a request from 5+ workers or an HSR; PCBU may also establish voluntarily.
  • Composition: at least half the members must be workers not nominated by management. HSRs may join (not mandatory).
  • Role: facilitate cooperation, develop and review WHS policies/procedures across the workforce.
  • Disputes on composition: either side may ask the regulator to appoint an inspector.

HSRs work the issues for their work group. The HSC works the system across the whole organisation.

5. Issue resolution​

  • Default procedures (in WHS Regulations) apply unless the PCBU and workers agree alternative procedures in writing.
  • Custom procedures must: be in writing, be communicated to all affected workers, allow workers to express views, and not strip HSR or HSC powers.
  • If another duty holder refuses to consult: confirm they understand their duty, put the requirement in the contract, escalate with documented evidence.
  • Keep records of consultation — what was discussed, decisions made, outcomes advised.

6. Multi-PCBU situations (construction example)​

A construction site typically has: principal contractor, subcontractors, building owner, manager, equipment hirers, deliverers.

  • The principal contractor documents the 3C arrangements in the WHS Management Plan.
  • Each PCBU still consults its own workers and HSRs — that duty doesn't transfer.
  • Identify all duty holders early; share information about your activities and hazards; coordinate sequencing (e.g. don't schedule overhead work above active ground crew).

Other shared-workplace examples:

  • Shopping centre — owner + tenants + cleaners + maintenance.
  • Multi-tenanted office — landlord + tenants + lift contractor.
  • Supply chain — consignor + carrier + receiver.

7. Records to keep​

Records aren't always mandatory, but they protect you:

  • Consultation log: matter, who was consulted, key issues, decision, reasons, outcome advised.
  • HSR/HSC meeting minutes: agenda, actions, owners, deadlines — circulate promptly.
  • HSR election records: work-group definition, nominations, outcome.
  • Training records: induction, HSR training, toolbox talks, procedure rollouts.
  • Written consultation procedure (if alternative to default).

Display: noticeboards, intranet, email summaries, posted action checklists with timelines.

8. Common pitfalls / quick wins​

Do

  • Share information early — workers need time to consider, discuss and feed back.
  • Set a regular cadence (pre-starts, toolbox talks) rather than ad-hoc consultation.
  • Document and explain decisions — including ones you couldn't take up.
  • Allow paid time for consultation; trial proposed changes before locking them in.
  • Make consultation accessible: stagger times for shift workers; translate where needed.

Don't

  • Withhold technical info because it's "complex" — simplify, diagram, translate.
  • Assume the principal contractor (or anyone else) is handling 3C for you.
  • Treat consultation as a formality after the decision is already made.
  • Skip consultation on changes "for speed" — changes affecting WHS require it.
  • Ignore HSR alerts; failing to act undermines the whole system.

9. Cross-references​

  • See also: [[risk_management_process]], [[workplace_environment_and_facilities]]
  • Glossary: [[glossary_and_key_concepts]]
  • Construction multi-PCBU specifics: [[02 - Construction Work/general_construction_work]]

Source: WHS_consultation_cooperation_coordination.md (Safe Work Australia, model Code of Practice, CC-BY-NC 4.0). Edition: February 2022. Last verified against SWA: 2026-04-27.