Construction projects bring together contractors, subcontractors, workers, plant, equipment and changing site conditions. Add temporary electrical supplies, power tools, extension leads, switchboards, overhead powerlines and underground services, and the potential for a serious electrical incident can increase quickly.
This is why a Work Health and Safety Management Plan should not be treated as another document prepared simply to satisfy a tender, client or auditor.
A good plan answers a much more practical question:
How are we going to manage health and safety on this project before everyone arrives and starts work?
For electrical safety in particular, planning before work starts can be the difference between identifying an electrical hazard early and discovering it when a worker, excavator, scaffold, crane or piece of equipment comes into contact with it.
When is a WHS Management Plan required?
The terminology and requirements differ between Australian jurisdictions.
New South Wales
In NSW, construction work valued at $250,000 or more is a construction project. A principal contractor must be appointed and must prepare a written WHS Management Plan before work commences.
SafeWork NSW states that the plan must include:
- names, positions and specific responsibilities of people with health and safety responsibilities
- arrangements for consultation, cooperation and coordination
- arrangements for managing health and safety incidents
- site-specific health and safety rules
- arrangements for ensuring people are informed of those rules
- arrangements for collecting, assessing, monitoring and reviewing Safe Work Method Statements (SWMS).
The plan must also be reviewed and kept up to date, and workers must be made aware of its contents before starting work.
Victoria
Victoria operates under the Occupational Health and Safety Act and Regulations, rather than the harmonised WHS legislation used in NSW.
For a Victorian construction project costing $350,000 or more, the principal contractor has duties relating to the preparation of a Health and Safety Coordination Plan before construction work commences. The plan must then be monitored, maintained and kept up to date throughout the project.
WorkSafe Victoria’s coordination plan guidance includes matters such as:
- who has specific health and safety responsibilities
- people’s OHS responsibilities
- arrangements for managing incidents
- site safety rules.
Although NSW and Victoria use different terminology and legislation, the practical objective is similar:
Plan how health and safety will be coordinated across the project before the risks become incidents.
What is the real value of the plan?
The greatest value of a WHS Management Plan is not the document itself.
Its value comes from forcing the project team to consider how the project will actually operate.
For example:
Who controls the site?
Who checks contractors before they start?
Who reviews SWMS?
Who conducts site inductions?
Who inspects the workplace?
How are hazards reported?
Who can stop unsafe work?
What happens when conditions change?
Who manages an emergency?
And importantly:
Who is responsible for electrical safety?
These questions become particularly important when several businesses are working at the same workplace.
Safe Work Australia emphasises the duties to consult with affected workers and to consult, cooperate and coordinate with other relevant duty holders.
A WHS Management Plan provides the framework for making those responsibilities clear.
Electrical Safety Must Be Part of Project Planning
Electricity presents a particular risk because an electrical hazard is not always obvious.
Electrical risks can arise from:
- temporary construction wiring
- switchboards
- extension leads
- portable electrical tools
- damaged electrical equipment
- incorrect or missing RCD protection
- overhead powerlines
- underground electrical services
- generators
- wet environments
- work on existing electrical installations
- energised equipment
- interaction between mobile plant and electrical infrastructure.
Safe Work Australia identifies electrical work as dangerous and requires PCBUs under the model WHS framework to manage electrical risks so far as is reasonably practicable. Its Model Code of Practice: Managing Electrical Risks in the Workplace provides practical guidance for businesses controlling electrical equipment or carrying out electrical work.
SafeWork NSW similarly identifies electric shock, burns, electrical fires and electricity acting as an ignition source as significant electrical hazards. Portable equipment, plugs, sockets, leads and equipment used outdoors or in wet conditions can present increased risks.
Therefore, electrical safety should be specifically addressed when developing the project WHS Management Plan rather than simply relying on an electrician or subcontractor to manage the issue later.
Identify the electrical hazards before work starts
The planning process should identify the electrical infrastructure that may affect the project.
This should include, where applicable:
- existing electrical installations
- overhead powerlines
- underground electrical services
- temporary power requirements
- switchboard locations
- generators and alternative power supplies
- electrical equipment that will be used
- areas where electrical equipment may be exposed to water, weather or damage
- locations where mobile plant may interact with electrical infrastructure.
Plans, site inspections and information from asset owners should be reviewed before work starts.
This becomes especially important before excavation, crane operations, scaffolding, concrete pumping, EWP operations or other activities where plant or structures may approach electrical services.
Temporary construction wiring and switchboards
Temporary electricity should never mean temporary safety standards.
The WHS Management Plan should identify how construction wiring and switchboards will be installed, inspected, protected and maintained.
In NSW, SafeWork NSW states that AS/NZS 3012:2019 Electrical installations – construction and demolition sites is called up as a mandatory standard under the WHS Regulation 2025.
The Standard addresses minimum requirements for electrical installations supplying construction and demolition sites and the in-service testing of electrical equipment.
SafeWork NSW’s recent electrical safety work has specifically highlighted the need to improve compliance relating to construction switchboards and the inspection of construction wiring and switchboards by licensed electricians.
Victoria also provides specific industry guidance for electrical installations on construction sites, covering areas including switchboards, electrical circuits, construction wiring, generators, RCDs, emergency lighting and other electrical installations.
The project plan should therefore establish who is responsible for the construction electrical installation and how its ongoing compliance will be verified.
RCD protection
Residual Current Devices – commonly called RCDs or safety switches – are an important electrical safety control.
The project should establish:
- where RCD protection is required
- who is responsible for ensuring it is provided
- inspection and testing requirements
- how defective RCDs will be identified and removed from service
- how records will be maintained.
An RCD is an important control, but it should not be regarded as permission to use damaged or unsafe electrical equipment.
WorkSafe Victoria specifically warns that while RCDs minimise the risk of electric shock, they should not be relied upon as the only control.
Inspection and testing of electrical equipment
Construction environments can be particularly harsh on electrical equipment.
Leads are dragged across floors.
Tools are moved constantly.
Plugs can be damaged.
Equipment can be exposed to water, dust, vehicles and construction materials.
The project should therefore establish arrangements for inspection and testing of electrical equipment and clearly identify what happens when damaged equipment is found.
SafeWork NSW’s 2024 electrical safety findings highlighted the need for flexible cords, power tools and portable outlet assemblies to be inspected and tested in accordance with AS/NZS 3012.
A simple site rule should apply:
If electrical equipment is damaged, defective or suspected of being unsafe – stop using it, isolate it and report it.
Overhead powerlines
Overhead electrical lines should be identified during project planning – not after plant arrives on site.
Consider cranes, EWPs, excavators, concrete pumps, scaffolding, tip trucks, delivery vehicles and long conductive materials.
The plan should establish:
- location of overhead electrical assets
- required exclusion or No Go Zones
- plant operating areas
- delivery and unloading areas
- requirements for spotters
- requirements to contact the electricity network or asset owner
- permits or authorities required
- warning signs and physical barriers
- worker and operator training
- emergency arrangements following electrical contact or arcing.
Victoria has particularly detailed No Go Zone requirements. WorkSafe Victoria guidance states that for pole-mounted lines, work between 3 metres and 6.4 metres generally falls within the Spotter Zone and requires a registered qualified electrical spotter. Work within 3 metres requires permission from the relevant network operator and additional preventative measures. Different requirements can apply to higher-voltage and tower-mounted assets.
Importantly, equipment does not necessarily have to touch a powerline for someone to be electrocuted – electricity can arc across a gap.
Underground electrical services
Excavation is another area that should be addressed before work commences.
The plan should identify how underground services will be:
- identified
- located
- verified
- marked
- communicated to workers
- protected during excavation.
The process may include obtaining service information, engaging competent locating services, potholing or other verification methods and establishing exclusion requirements.
WorkSafe Victoria and Energy Safe Victoria provide specific guidance for work involving excavation or ground penetration where underground electricity and other services may be present.
The important principle is simple:
Never assume the location of an underground electrical service.
My young bloke was working on a site where there was supposed to be no underground services.
They started removing old pipes.
Oops, someone decided to feed electrical wires through the old pipe.
Electrical SWMS requirements
The WHS Management Plan should also explain when a SWMS is required and how SWMS will be reviewed and controlled.
Under the model WHS framework used in NSW, a SWMS is required for high-risk construction work.
For a construction project, the SWMS must take the WHS Management Plan into account and be provided to the principal contractor before the relevant high-risk construction work starts.
Electrical-related high-risk construction activities can include work on or near energised electrical installations or services and other high-risk activities involving electrical hazards.
The plan should therefore establish:
Plan → SWMS → Induct → Implement → Monitor → Review.
The SWMS should not simply be collected and filed.
Supervisors need to check that the controls described in the SWMS are actually being implemented on site.
Isolation and working de-energised
Where electrical work is required, the starting position should be to eliminate the electrical risk wherever reasonably practicable.
Project arrangements should address:
- isolation
- lockout
- tagout
- testing for dead
- preventing inadvertent re-energisation
- authorised persons
- communication between contractors
- handover and recommissioning.
These arrangements become especially important on refurbishment projects where workers may be dealing with existing electrical installations.
Electrical emergency response
Electrical emergencies should also be incorporated into project emergency planning.
Consider what workers should do following:
- electric shock
- contact between plant and powerlines
- electrical fire
- damaged electrical infrastructure
- arc flash or arcing
- loss of power affecting other safety systems.
Workers should understand not only how to raise the alarm but also what not to do.
For example, approaching plant that is in contact with an overhead powerline can expose another person to the same electrical hazard.
WorkSafe Victoria recommends that emergency response actions for powerline contact or arcing be included in the information and training provided to workers.
Electrical responsibilities must be clear
Finally, allocate responsibilities.
A good WHS Management Plan should make it easy to answer questions such as:
- Who checks electrical equipment?
- Who manages the electrical contractor?
- Who maintains testing records?
- Who inspects switchboards?
- Who monitors overhead powerline controls?
- Who checks SWMS?
- Who has authority to remove defective equipment from service?
- Who reviews electrical controls when the project changes?
Without clear responsibility, everyone can assume someone else is managing the risk.
Don’t Prepare the Plan and Put It in a Folder
Perhaps the biggest mistake is preparing an excellent WHS Management Plan before the project starts and then rarely referring to it again.
A construction project changes.
New contractors arrive.
Plant changes.
Excavations move.
Temporary power is relocated.
New switchboards are installed.
Access routes change.
Scaffolding is erected.
Different stages of construction introduce different hazards.
The management plan should therefore be a working document that supports inductions, SWMS, toolbox talks, inspections, contractor management, hazard reporting and project reviews.
This is consistent with the NSW requirement to review and keep the WHS Management Plan up to date, and with Victoria’s requirement for the Health and Safety Coordination Plan to be monitored, maintained, and kept current.
A Simple Electrical Safety Section for Your Project Plan
For a small- to medium-sized construction business, the electrical section does not need to be unnecessarily complicated.
As a minimum, consider documenting:
- Electrical responsibilities – who manages and monitors electrical safety.
- Existing electrical hazards – overhead, underground and existing installations.
- Temporary electricity – construction wiring, switchboards and generators.
- RCD protection – requirements, testing and records.
- Portable electrical equipment – inspection, testing and removal of damaged equipment.
- Electrical contractors – licensing, competency and contractor controls.
- Isolation – lockout, tagout and verification requirements.
- Overhead powerlines – exclusion zones, spotters, permits and plant movements.
- Underground services – plans, locating, verification and excavation controls.
- SWMS – identification and review of electrical-related high-risk construction work.
- Inspections – ongoing electrical safety inspections during the project.
- Emergency response – electric shock, fire, arcing and powerline contact.
- Training and induction – ensuring workers understand the electrical site rules.
- Records – inspections, tests, licences, SWMS, corrective actions and electrical maintenance.
- Review – triggers for reviewing the electrical risk controls as the project changes.
The Bottom Line
A WHS Management Plan should not be prepared because a regulation says you need a document.
It should be prepared because good projects plan how to manage risks before work begins.
Electrical risks demonstrate why this matters.
A powerline identified during planning can be avoided.
An underground service identified before excavation can be protected.
A damaged lead identified during an inspection can be removed.
A compliant switchboard and functioning RCD can protect workers.
A properly reviewed SWMS can prevent high-risk work proceeding without appropriate controls.
And clear responsibilities ensure everyone understands who needs to act.
For principal contractors and project managers, the objective should therefore be:
Plan the risk. Communicate the controls. Check they are being followed. Keep the evidence.
That turns the WHS Management Plan from paperwork into an active part of how the project is safely managed.
Key Australian references
Safe Work Australia
- Model Code of Practice: Construction Work
- Model Code of Practice: Managing Electrical Risks in the Workplace
- Model Code of Practice: How to Manage Work Health and Safety Risks
- High Risk Construction Work and SWMS guidance
SafeWork NSW
- Undertaking a Construction Project
- Construction Work guidance
- Managing Electrical Risks Code of Practice
- Electrical Practices – Construction and Demolition Sites
- Electrical Risks at the Workplace
- Electrical Safety in Construction inspection resources
- Work Near Overhead and Underground Electric Lines guidance
- WHS Regulation 2025
WorkSafe Victoria
- Health and Safety Coordination Plan guidance
- Electrical Installations at Construction Sites – Industry Standard
- Construction Safety Focus: Electrical Safety
- Using Powered Mobile Plant Near Overhead Assets
- Guide to Undertaking Work Near Underground Services
- No Go Zone guidance
- Occupational Health and Safety Act 2004
- Occupational Health and Safety Regulations 2017
Relevant standards
- AS/NZS 3012 – Electrical installations – Construction and demolition sites
- AS/NZS 3000 – Electrical installations (Wiring Rules)
- AS/NZS 3760 – In-service safety inspection and testing of electrical equipment and RCDs
Note: WHS/OHS and electrical safety requirements differ between jurisdictions. Project-specific requirements should always be checked against the legislation, regulations, codes, electrical safety legislation and regulator guidance applying in the state or territory where the work is undertaken.
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