Quick answer: Section 19(3)(f) of the WHS Act requires a business to provide the information, training, instruction or supervision necessary to protect people from risks arising from the work. Section 39 of the WHS Regulation requires it to be suitable and adequate for the work, the risks and the controls in place, and provided in a way the person can readily understand. The law doesn't prescribe one induction format for every workplace. What matters is that each worker, including casuals and labour hire workers, gets what they need for their work before they start, and that they understand it.
Why the hiring peak matters
The lead-up to Christmas is when many Queensland businesses take on extra hands. Retail, hospitality, warehousing, transport and events all bring in casuals and labour hire workers to cover the peak, often at short notice. These workers are new to the site, the equipment and the people around them, and they don't yet know where the hazards are.
When time is short, induction is often the first thing squeezed. A quick walk-around and a form to sign can feel like enough. Legally, the question is whether the worker received the information, training, instruction and supervision they needed to work safely.
What the law requires, and what it doesn't
Neither the WHS Act nor the WHS Regulation sets out a standard induction that every business must deliver. The duty is to provide information, training, instruction and supervision that is suitable for the work your workers will do, the risks they will face and the controls you rely on. A two-person office and a busy distribution centre will meet that duty in very different ways.
Section 7 of the WHS Act defines a worker broadly. It includes employees, contractors and subcontractors and their employees, outworkers, apprentices and trainees, work experience students, volunteers, and labour hire workers placed with a host business. A worker who is with you for a single shift is owed the same duty as someone who has been there for ten years.
Labour hire: overlapping duties
When a labour hire provider places a worker with a host business, both are businesses with duties to that worker for the same work. Neither can hand its duty to the other. Section 46 of the WHS Act requires them to consult, cooperate and coordinate so that, between them, nothing is missed.
In practice, the provider usually knows the worker's skills, licences and training history, while the host knows the site, the tasks and the hazards. A sensible arrangement agrees in writing who delivers which parts of the induction, how the provider will check the host's site and work arrangements, who supervises the worker day to day, and how incidents and concerns will be reported to both businesses. Our guide to engaging contractors and shared WHS duties explains how overlapping duties work more generally.
What a good induction covers
Every business is different, but an induction that meets the legal test usually covers the following before the worker starts the job:
- Emergency procedures, exits, assembly points and first aid arrangements
- How to report hazards, incidents and near misses, and who to report them to
- The main hazards of the job and the controls in place for each one
- Required PPE, how to use it and where to get replacements
- Who their supervisor is and how to reach them
- Site rules, including traffic zones, restricted areas and no-go areas around mobile plant
- How consultation works on site, including any health and safety representatives
- How to raise a safety concern, and what to do if they believe work is unsafe
- Licences and competencies the work requires, checked before the work starts
Licences and competency are not the same thing
Some work needs a high risk work licence. Schedule 3 of the WHS Regulation sets out the licence classes, which cover work such as operating forklifts, certain cranes and hoists, boom-type elevating work platforms with a boom length of 11 metres or more, scaffolding, rigging and dogging, and operating certain boilers and pressure equipment. Under section 85, a business must not direct or allow a worker to carry out high risk work unless it has seen written evidence that the worker holds the relevant licence.
Plenty of hazardous work doesn't need a licence at all. Operating many types of mobile plant, using a chainsaw or working with hazardous chemicals may have no licence class, but the worker still needs to be competent. That can be shown through training records, a verification of competency or a supervised assessment on your site. Construction is a further case: under sections 316 and 317, a worker must have completed general construction induction training (the general construction induction card, formerly the white card) before carrying out construction work. That card is a general induction to the industry. It doesn't replace the site-specific induction.
Workers' right to stop unsafe work
Workers should be told how to raise safety concerns, but inductions sometimes overstate the right to stop work. Under section 84 of the WHS Act, a worker may cease, or refuse to carry out, work if they have a reasonable concern that carrying it out would expose them to a serious risk to their health or safety from an immediate or imminent exposure to a hazard. Under section 85, a worker who stops work must notify the business as soon as practicable and remain available for suitable alternative work. An induction should explain both the right and how to use it.
Signed is not the same as understood
Section 39 of the WHS Regulation requires information, training and instruction to be provided in a way that is readily understandable, taking account of language, literacy, age and experience. A young worker in their first job and an experienced tradesperson new to your site need different inductions.
A signature on an induction form shows the induction happened. It doesn't show the worker understood the hazards and controls. Asking workers to show you where the exits are, walk the pedestrian route, or explain how they would isolate the machine they will use gives you much better evidence.
Supervision and records
Section 19(3)(f) lists supervision alongside information, training and instruction. New workers need closer supervision until they show they can do the work safely, and a busy peak is exactly when supervisors are stretched. Decide before the peak who will supervise new starters, how closely and for how long.
Records should be proportionate to the risk. For low-risk work, a dated record of what was covered and who delivered it may be enough. For higher-risk work, also keep evidence of licences and competencies, how understanding was checked, the supervision arrangements, and when the worker was signed off to work without close supervision. If something goes wrong, these records are your best evidence of what was provided. Our post on what WHS documents a Queensland business needs covers record keeping more broadly.
Illustrative example: A distribution centre takes on 15 casuals through a labour hire provider for the Christmas peak. The provider and host agree in writing that the provider confirms licences and general training, and the host runs the site induction. On day one, the host covers forklift traffic zones, manual handling controls, emergency procedures and how to report hazards. Each casual is paired with an experienced worker for their first two shifts, the supervisor checks understanding by asking each person to walk the pedestrian route and point out the exclusion zones, and the two forklift operators' licences are sighted and copied before they start.
Frequently asked questions
Do casual and labour hire workers need the same induction as permanent staff?
They need the information, training, instruction and supervision necessary for the work they will do and the risks they will face. That doesn't have to be identical to a permanent employee's induction, but it can't be less than they need to work safely. A shorter engagement is not a reason for a thinner induction.
Is a signed induction form enough to show we've met our duty?
A signed form shows an induction took place, but not that the worker understood it. The WHS Regulation requires information and training to be provided in a way the person can readily understand, so it's worth checking understanding, for example by asking the worker to show you key controls, and recording how you checked.
If a task doesn't need a licence, do we still need to check competency?
Yes. High risk work licences only cover the classes listed in the WHS Regulation. For other plant and tasks, you still need to be satisfied the worker is competent, for example through training records, a verification of competency or a supervised assessment.
Sources: Work Health and Safety Act 2011 (Qld) ss7, 19(3)(f), 46, 84 and 85; Work Health and Safety Regulation 2011 (Qld) ss39, 85, 316 and 317 and Schedule 3; WorkSafe Queensland, General construction induction; Managing the Risks of Plant in the Workplace Code of Practice 2021 (section 2.4).
This article is general information, not legal advice. Last reviewed 6 November 2026.