WHS & SWMS Software for Australian Oil, Gas & Energy Contractors
A signed SWMS is not evidence that its controls were used. BasinCheck ties the SWMS to the pre-starts, Take 5s, inspections, and closed actions that prove it — across Queensland, WA, SA, and NSW onshore work.
Written by Jacob Szyszka, Founder of BasinCheck. Regulatory detail links to Safe Work Australia, Business Queensland, and state regulator sources.
What the Regulations Actually Ask of a SWMS
Four duties, and most findings land on the last two — accessibility and review — rather than on whether a document exists.
A SWMS must be prepared before high risk construction work starts. The categories of high risk construction work are set out in regulation 291 of the model WHS Regulations — work at height above two metres, confined spaces, live electrical work, demolition, mobile plant movement, and pressurised gas mains among them.
Regulation 299 sets the content: identify the high risk construction work, the hazards, the control measures, and how those controls will be implemented, monitored, and reviewed. Part 6.3 of the Regulations holds the wider duty set for the PCBU carrying out the work.
A copy goes to the principal contractor before the work starts, and the SWMS must be readily accessible to the workers doing the job. A SWMS in a ute glovebox that nobody reads is a documented control that was never implemented.
The SWMS has to be reviewed and, if needed, revised when the work changes, when a control fails, or after an incident. Keep it while the work continues; if a notifiable incident occurs in connection with the work, retain it and treat it as evidence.
Regulation numbers above refer to the model WHS Regulations as adopted in your jurisdiction. Check your own regulator's text — Safe Work Australia publishes the model laws, but each state enacts its own version.
Harmonised Does Not Mean Identical
Most of the country runs on the model WHS laws. Resource-specific legislation and one unharmonised state mean a crew crossing borders carries more than one rulebook.
Petroleum and Gas Inspectorate + WHS Queensland
Onshore gas work sits under the Petroleum and Gas (Production and Safety) Act 2004 and Petroleum and Gas (Safety) Regulation 2018. Operating plant requires a safety management system for each stage of the plant. Surat and Bowen Basin CSG operations layer this over ordinary WHS duties.
Work Health and Safety Act 2020 (WA)
WA adopted harmonised WHS law from 31 March 2022, with separate general industry, mining, and petroleum regulations. Perth Basin and Carnarvon onshore work involves long drives, remote camps, and no coverage for hours at a time.
SafeWork SA / SafeWork NSW
Both operate harmonised WHS legislation. Cooper Basin service work frequently crosses the SA–QLD border, which means one crew, two regulators, and one set of records that needs to satisfy both.
OHS Act 2004 / OHS Regulations 2017
Victoria did not adopt the model WHS laws. It runs its own regime with different terminology and its own high risk construction work list under regulation 322 of the OHS Regulations 2017. Don't assume a national SWMS template lands cleanly in Victoria.
Offshore is a different instrument
Offshore petroleum facilities in Commonwealth waters answer to NOPSEMA and operate under an accepted safety case. BasinCheck is built for onshore contractor crews and does not attempt to manage a facility safety case.
The Duties Behind the Paperwork
SWMS get the attention, but the duties that generate audit questions are broader — and several of them are about proof, not intent.
PCBU duty
The person conducting a business or undertaking owes a primary duty of care to workers and others. Duties overlap on a shared site — the operator has one, the principal contractor has one, and you have one. Nobody's duty cancels out anybody else's.
Officer due diligence
Officers must exercise due diligence, including acquiring knowledge of WHS matters and verifying that resources and processes are actually being used. In practice, this means directors need visibility into whether field controls are happening — not just a policy asserting they should.
Notifiable incidents
Deaths, serious injuries or illnesses, and dangerous incidents must be notified to the regulator immediately after becoming aware of them, and the site must generally be preserved. Records supporting the notification need to hold up months later.
Consultation
Consultation with workers is a duty, not a courtesy. Pre-starts, Take 5s, and toolbox talks are where it happens — and where it either gets recorded or evaporates.
Five Steps to Records That Hold Up
Not more paperwork. The same work, captured so that it survives the six months between the job and the question about it.
Build a SWMS library, not one-off documents
Standardise SWMS by task type so crews start from a reviewed base and adapt it to the site, rather than retyping the same hazards and controls each job.
Make site-specific adaptation visible
A generic SWMS signed without change is a regulator's favourite finding. Capture what was actually adjusted for this site, this plant, this crew.
Put pre-starts and Take 5s in the same system
The daily records prove that the SWMS controls were used. Kept separately in paper books, they prove nothing six months later.
Close corrective actions with evidence
Every hazard raised gets an owner, a due date, and closure evidence. Officer due diligence is much easier to demonstrate when closure rates are visible.
Keep records retrievable by site and worker
When a regulator or client asks about a specific job on a specific day, you should be producing the SWMS, the pre-start, and the crew sign-on within minutes.
No reception, no problem
Built for remote onshore sites. SWMS sign-ons, pre-starts, photos, and signatures all work offline and sync later.
Actions that close
Hazards raised on a Take 5 become tracked actions with owners and closure evidence, not notes in a book.
SWMS library with version history
Standard task SWMS you adapt per site, with a record of what changed and who approved it.
Incident detail on the day
Notifiable incidents need facts captured immediately. Photos, witnesses, and immediate actions recorded on site.
Frequently Asked Questions
SWMS, harmonisation, and resources-sector questions from Australian contractors.
Disclaimer: This page is educational and is not legal advice. Each Australian jurisdiction enacts its own WHS or OHS legislation, and regulation numbering and content can differ from the model laws. Confirm your duties with your state or territory regulator and a competent WHS adviser.
Content maintenance: last checked against the model WHS laws, Business Queensland petroleum and gas SMS guidance, and state regulator pages on July 25, 2026.
Prove the Controls, Not Just the Document
BasinCheck links SWMS to the daily records that show the controls were used — pre-starts, Take 5s, inspections, and closed actions, captured offline in the field.