WHS Management Plans for Construction Over $250,000: Requirements & Practical Guide

Quick answer: Under model Regulation 309, the principal contractor for a construction project (work costing $250,000 or more, or certain asbestos demolition/refurbishment) must prepare a written WHS management plan for the workplace before the project commences. The plan must name safety roles, set site rules, describe incident and consultation arrangements, and — critically — explain how SWMS will be collected, assessed, monitored and reviewed for all high-risk construction work on site.

This is not a shelf document. It must be kept until the project completes (minimum 2 years if a notifiable incident occurs) and revised when circumstances change.

What counts as a "construction project"?

A construction project involves construction work where the cost is $250,000 or more (excluding GST in most regulator interpretations — confirm with your jurisdiction). Below that threshold, Part 6.4 principal contractor duties may not formally apply — but Section 19 primary duty of care always applies, and documentation gaps remain the most common aggravating factor in prosecutions.

Special case: projects involving demolition or refurbishment of structures with loose-fill asbestos (Mr Fluffy) are construction projects regardless of value.

Who is the principal contractor?

The PCBU that commissions construction may appoint another PCBU as principal contractor in writing — otherwise the commissioner may hold principal contractor duties. The appointed party must have management or control of the workplace and capability to discharge Reg 309–315 duties.

Mandatory content (Reg 309(2) — paraphrased)

Your WHS management plan must include:

Safe Work Australia's Construction Work Code of Practice Appendix G–I provides templates and a worked example.

Generic plans are allowed — but must be site-reviewed

A principal contractor may maintain a generic WHS management plan across projects — but must review and revise it for each project's hazards, site layout, trades and interfaces. Tender documents often require project-specific appendices.

SWMS arrangements — the operational heart

Regulators scrutinise how you implement item 6:

This connects directly to Reg 312 — obtain SWMS before HRCW starts — and your subcontractor review workflow.

Keeping the plan accessible and current

Relationship to other documents

Common failures in audits and prosecutions

WHSMP vs project safety plan vs client requirements

Tier-1 clients often request a Project Safety Plan or Construction Environmental Management Plan (CEMP) — these may exceed Reg 309 minimums. Map documents clearly:

Your WHSMP should reference where SWMS, permits and inductions live — not duplicate every SWMS in full.

When to revise the WHS management plan

Revise and communicate updates when:

Safe Work Australia Appendix I worked example shows revision history table — adopt the same pattern.

FAQ

Is $250k inclusive or exclusive of GST? Most regulator guidance treats contract value as the project cost threshold — confirm with your jurisdiction's guidance; many use excluding GST for the calculation.

Who prepares the WHSMP if there is no formal principal contractor appointment? The commissioning PCBU may hold principal contractor duties unless another PCBU is appointed in writing with management/control of the workplace.

Can the WHSMP be digital-only? Yes — if readily accessible to workers and inspectors for the project duration.

AxionSite: your WHS management plan, running live on site

Stop storing Reg 309 arrangements in a static Word doc. AxionSite is where Australian teams execute the plan every day:

One platform. One audit story. That's what a modern WHS management plan looks like in 2026.

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