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Guide

Inducting a labour hire worker in Queensland: who is responsible

Short answer: In Queensland, inducting a labour hire worker is a shared duty. The labour hire provider and the host business can both owe it, and neither can hand the duty to the other. They have to consult, cooperate and coordinate. Safe Work Australia's guidance on the model laws says the provider should consider giving a WHS induction before placement, and the host should consider giving a site-specific induction for that workplace. On construction work, the white card and the site induction are two further, separate steps.

General information only, checked against official sources on 26 October 2026. It isn't legal advice. Always check the current law, WorkSafe Queensland guidance, and Labour Hire Licensing Queensland for your arrangement.

Who is responsible

The worker is a worker of the host as well as the provider

Section 7(1)(d) of the Work Health and Safety Act 2011 (Qld) says a person is a worker if they carry out work in any capacity for a person conducting a business or undertaking, including work as an employee of a labour hire company who has been assigned to work in that person's business or undertaking. The How to manage work health and safety risks Code of Practice 2021 uses the same idea. Its glossary describes a worker as including an employee of a labour hire company placed with a host employer.

Section 19(1) requires a person conducting a business or undertaking (PCBU) to ensure, so far as is reasonably practicable, the health and safety of workers engaged, or caused to be engaged, by the person, and workers whose activities in carrying out work are influenced or directed by the person, while those workers are at work in the business or undertaking. Section 19(3)(f) says that duty includes the provision of any information, training, instruction or supervision that is necessary to protect all persons from risks to their health and safety arising from work carried out as part of the business or undertaking.

Section 19(1)(a) is the limb for workers the PCBU engages or causes to be engaged. Section 19(1)(b) is the limb for workers whose activities the PCBU influences or directs. Section 7(1)(d) makes an assigned labour hire employee a worker of the business they are assigned to. The Work health and safety consultation, cooperation and coordination Code of Practice 2021 puts it this way in its example of sharing the same workers: the host business has a duty to the labour hire workers engaged to do the work, and the labour hire firm has a duty to the labour hire workers it provides. Each duty is subject to what is reasonably practicable.

The duty cannot be passed across in the contract

Section 14: a duty cannot be transferred to another person. Section 16: more than one person can concurrently have the same duty. Each duty holder must comply with that duty to the standard required by the Act even if another duty holder has the same duty. Where more than one person has a duty for the same matter, each person retains responsibility, and must discharge the duty to the extent to which the person has the capacity to influence and control the matter, or would have had that capacity but for an agreement or arrangement purporting to limit or remove that capacity.

The risks code says the same thing in plain language: you cannot transfer your responsibilities to another person. It also says that if you engage labour hire workers as part of your workforce, you share a duty of care to these workers with the business that provides them, and you must discuss the hazards and risks associated with the work and what precautions will be taken. It says never to assume that someone else is taking care of a health and safety matter.

Safe Work Australia's Labour hire: duties of persons conducting a business or undertaking is guidance on the model WHS laws. It says a host PCBU has the same health and safety duties to labour hire workers as to other workers, must consult, cooperate and coordinate with the labour hire PCBU, and cannot contract out of or transfer its WHS obligations. It says a labour hire PCBU must ensure, so far as is reasonably practicable, the health and safety of workers during their placement. Treat that document as national guidance. The Queensland duties are the sections of the Queensland Act cited here.

Consultation, cooperation and coordination

Section 46: if more than one person has a duty in relation to the same matter, each person with the duty must, so far as is reasonably practicable, consult, cooperate and coordinate activities with all other persons who have a duty in relation to the same matter. Maximum penalty: 200 penalty units.

The consultation code, section 4.4, says that if you have employees of a labour hire company as part of your workforce, you owe them a duty of care, and any business providing those workers also owes them a duty of care. Both businesses have a duty to consult those workers on work health and safety. You must consult, cooperate and coordinate on the arrangements for that consultation, so far as is reasonably practicable. The risks code makes the same point from section 47 of the Act: the broad definition of worker means a PCBU must consult, so far as is reasonably practicable, with on-hire workers who are, or are likely to be, directly affected by a health and safety matter.

The consultation code's example of a labour hire placement shows one way to do that. The two businesses consult each other about the job requirements, the skills required, the risks, and what each will do to control the risks. They clarify who provides equipment, including personal protective equipment, and they agree to consult before changes that affect the workers' health and safety. The host allows the provider to visit and check the controls, and allows the workers to keep in contact with the provider. They coordinate how the workers will be consulted and represented, and how incidents will be reported and investigated. That is an example in the code. The legal duty is section 46, read with section 16.

A labour hire licence sits beside these duties

The Labour Hire Licensing Act 2017 (Qld) is a licensing scheme. Section 7(1) says a person provides labour hire services if, in the course of carrying on a business, the person supplies, to another person, a worker to do work. Section 10 says a person must not provide labour hire services unless the person holds a licence. Section 11 says a person must not, without a reasonable excuse, enter into an arrangement with a provider for the provision of labour hire services unless the provider holds a licence. For each of those offences the maximum penalty is 1034 penalty units or 3 years imprisonment for an individual, and 3000 penalty units for a corporation. Section 11(2) says it is a reasonable excuse if, when the arrangement was entered into, the provider was shown on the register as the holder of a licence.

Section 7(3)(b) says a person does not provide labour hire services merely because the person is a contractor who enters into a contract to carry out construction work within the meaning of the Building and Construction Industry Payments Act 2004, section 10, and engages subcontractors to carry out the work. Whether a particular arrangement is labour hire is a question under that Act. WorkSafe Queensland's poultry processing and labour hire campaign page says information on the labour hire licensing scheme is at labourhire.qld.gov.au. WorkSafe's labour hire page is the health and safety collection for businesses that supply workers.

A licence does not replace the WHS duties. Section 28 of the Labour Hire Licensing Act says it is a condition of a licence that the licensee must comply with all relevant laws applying to the licensee. The dictionary defines a relevant law to include a provision of an Act or law imposing an obligation on a person in relation to workers, including ensuring the health and safety of workers. The examples named in the Act include the Work Health and Safety Act 2011.

Provider induction and host site induction

Safe Work Australia's labour hire guidance uses "should consider" for the steps below. Before placement, the labour hire PCBU should consider providing workers with suitable, adequate and readily understandable WHS induction and training, including any risks it has identified and the consultation methods it has established with the workers and the host. It should also consider verifying, with the host, that site-specific and task-specific induction, training and personal protective equipment are provided in a way that is suitable, adequate and readily understandable.

For the host, the same guidance says that before engagement you should consider making sure general health and safety information about the work, the workplace and the work environment has been given to the workers, in a way they can understand, and giving the labour hire PCBU detailed information about the work. That information includes the work environment, the tasks, known hazards or risks, plant or equipment, the skills, knowledge, licences and qualifications required, and the supervision arrangements. During the placement, the host should consider providing a site-specific safety induction outlining WHS duties, policies, procedures and practices in the workplace, including consultation methods, and providing adequate supervision so the work is performed safely.

WorkSafe Queensland's training and supervision page states the timing in stronger words. Before they start work, you must give new workers training to help them become familiar with their tasks, their place of work, and the people working around them. WorkSafe says this responsibility is covered by the primary duty of care in the Work Health and Safety Act 2011. Induction topics should include:

  • workers' responsibilities regarding health and safety
  • what hazards and risks are in the workplace and how to control them
  • safe work procedures and how to use equipment safely
  • emergency procedures, such as how to evacuate, assembly points, exit locations and fire wardens
  • where to find the first aid kit

WorkSafe also says to give contact details for people with health and safety responsibilities, such as the first aid officer, the health and safety representative, the return to work coordinator, and the employee assistance program. WorkSafe says to make sure every new worker demonstrates that they understand the training. Workers also need supervised, hands-on training in the tasks they will perform, before they start that job, and they need to be able to demonstrate the safe work procedures.

Construction work adds a site-specific induction. WorkSafe's site specific induction page says a person must have a site-specific induction before starting construction work, other than housing construction work. The induction needs to address the WHS management plan, including the site-specific health and safety rules. What that plan has to include, and what a principal contractor has to do before work starts, is in the Queensland site-specific induction guide and the principal contractor guide.

WorkSafe's labour hire page lists a longer guide, "Host employers: Managing the safety of labour hire workers" (PDF, 28 August 2020). This page does not restate that PDF. Use it with the Act and the codes above.

White card and site induction

The white card is not the provider's induction, and it is not the host's site induction. WorkSafe's general construction induction page says that if you are working in the construction industry, you need to complete general construction induction training with a registered training organisation. The unit is CPCCWHS1001 Prepare to work safely in the construction industry. WorkSafe says the training gives a basic knowledge of work health and safety laws, common site hazards, and how to control the associated risks. After the unit, the organisation issues a general construction induction training card. In Queensland that card was previously known as a white card. You must keep it with you whenever you are on site.

Section 316 of the Work Health and Safety Regulation 2011 (Qld): a PCBU must ensure general construction induction training is provided to a worker engaged by the person who is to carry out construction work, if the worker has not completed that training, or completed it more than 2 years previously and has not carried out construction work in the preceding 2 years. Section 317: a PCBU must not direct or allow a worker to carry out construction work unless the worker has completed that training and, if the training was more than 2 years ago, has carried out construction work in the preceding 2 years. The PCBU must also ensure the worker holds the card, or a certification issued within the preceding 60 days if the worker has applied and the card has not been issued yet. Neither section sets out a housing exception.

The site induction is the briefing for one workplace. WorkSafe says a person must have it before starting construction work, other than housing construction work. On a construction project, section 310 requires the principal contractor to ensure, so far as is reasonably practicable, that each person who is to carry out construction work is, before commencing work, made aware of the content of the WHS management plan and of their right to inspect it. Lost cards, interstate cards and the two-year gap are in the white card vs site induction guide.

Records, and repeating the induction

WorkSafe's training page says to use a checklist to make the induction easier and more thorough, and to keep the list on file as a record of employee training. It says to keep training records so you know who has been trained, how they performed, and what further training is required. The law requires training records for certain tasks, such as working in confined spaces and working with certain hazardous chemicals, and you need to keep copies of high risk work licences. WorkSafe says it is good practice to maintain records of all training, including induction, as well as any supervision and spot checks.

On a construction project, WorkSafe's site-specific induction page says: "As the principal contractor you should keep a record of the people inducted and the date it was given." That is "should". The duty in section 310 is to make people aware of the plan before they start. Section 313 deals with keeping the plan itself. The site-specific induction guide sets out that record.

WorkSafe says workers returning after a long absence should repeat the induction process to make sure they are aware of any changes to health and safety processes and procedures. The training page does not state a fixed interval, such as every 12 months. If the WHS management plan on a construction project is revised, section 311 requires the principal contractor to make people carrying out the construction work aware of the revision, so far as is reasonably practicable.

Checklist before day one

Use this as a briefing list. The words "must" and "should" below follow the source named on each line.

  • Licence. Section 10: the provider must hold a labour hire licence to provide labour hire services. Section 11: the host must not enter the arrangement unless the provider holds a licence, unless a reasonable excuse applies. Section 11(2) gives a reasonable excuse where the provider was shown on the register as licensed when the arrangement was made. Check the construction contractor exception in section 7(3)(b) before you treat an ordinary subcontract as labour hire.
  • Agree the split, in writing if you can. Section 46 requires consultation, cooperation and coordination. The risks code says you must discuss the hazards, the risks and the precautions with the labour hire firm. The consultation code's example includes who supplies equipment and personal protective equipment, and how incidents will be reported. An agreement does not transfer the duty. Section 14 and section 16(3) still apply.
  • Tell the provider about the job. Safe Work Australia says the host should consider giving the labour hire PCBU the work environment, the tasks, the hazards, the plant, the licences and skills required, and the supervision arrangements.
  • Provider induction before placement. Safe Work Australia says the labour hire PCBU should consider a WHS induction and training that the worker can understand, covering the risks it has identified and how consultation will work.
  • Host induction before they start. WorkSafe says you must give new workers that training before they start work, and that the topics listed above should be included. The worker has to demonstrate that they understand it. On construction work, other than housing construction work, WorkSafe says the person must have a site-specific induction before starting.
  • White card, if the work is construction work. Sections 316 and 317. Sight the card, or the certification if the card is still being issued. This check is separate from both inductions. A printable line for it is on the Queensland site induction checklist.
  • WHS management plan, on a construction project. Section 310: before they commence work, the principal contractor must make each person aware of the plan and of the right to inspect it, so far as is reasonably practicable.
  • Record it. WorkSafe says keep the induction checklist on file. For a principal contractor, WorkSafe says you should record the people inducted and the date. Keep the legally required training records for confined spaces, certain hazardous chemicals, and high risk work licences.
  • Repeat when the job or the person has changed. WorkSafe says a worker returning after a long absence should repeat the induction. The consultation code's example includes agreeing to consult before changes that affect health and safety. On a construction project, section 311 covers a revision of the plan.

How Set2Go can help

Set2Go runs the induction PowerPoint you already use. A labour hire provider can send a company induction with no site attached. A host can run the induction for a particular site. You invite the worker, and they receive a link they can open on their phone before day one.

  • Your deck, one slide at a time. The quiz stays locked until every slide on that attempt has been viewed. Set2Go timestamps when each slide was first viewed. That timestamp shows the slide was opened. It does not show how long someone looked at it, and it does not show that they understood it. You still choose the words on the slides, and you write the quiz.
  • Records and expiry. Contractor inductions is the inductions-only path: no gate QR. You set how long a pass lasts. The records view shows current, expiring soon, or expired, with the quiz score and the date. When a pass is about to expire, or has expired, the worker gets an email so they can redo it. You can export the register to CSV. A certificate is issued when they pass.
  • A gate, if the host uses one. Site sign-in is separate. Invited workers with a current induction scan the site QR code and enter their PIN.

Pricing is published at settogo.com.au/pricing. There's a 14-day free trial with no card required.

Important: Set2Go is safety administration software. It is not a statutory WHS system. Using it does not by itself mean you have met your obligations under the Work Health and Safety Act 2011 (Qld), the Work Health and Safety Regulation 2011 (Qld), or the Labour Hire Licensing Act 2017 (Qld). You are still responsible for the content of the induction, the white card check, consultation with the other duty holder, and the decision about who does what.

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FAQ

Who has to induct a labour hire worker in Queensland?

The labour hire provider and the host business can both owe the duty. Section 7(1)(d) of the Work Health and Safety Act 2011 (Qld) includes, as a worker, an employee of a labour hire company who has been assigned to work in the person's business or undertaking. Section 19 requires a person conducting a business or undertaking to ensure, so far as is reasonably practicable, the health and safety of workers it engages or causes to be engaged, and of workers whose activities it influences or directs. Section 19(3)(f) includes the information, training, instruction or supervision necessary to protect people from risks arising from the work. Section 14 says a duty cannot be transferred. Section 16 says more than one person can have the same duty at the same time, and each must still comply to the extent they have the capacity to influence and control the matter. Section 46 requires them to consult, cooperate and coordinate, so far as is reasonably practicable. The How to manage work health and safety risks Code of Practice 2021 says that if you engage labour hire workers you share a duty of care with the business that provides them, and you must discuss the hazards, the risks and the precautions.

Is the provider's induction the same as the host's site induction?

No. They cover different ground. Safe Work Australia's guidance on the model WHS laws says a labour hire PCBU should consider giving workers a suitable, adequate and readily understandable WHS induction and training before placement, including the risks it has identified and the consultation methods agreed with the workers and the host. The same guidance says the labour hire PCBU should consider verifying and working with the host so that site-specific and task-specific induction, training and personal protective equipment are provided in a way the worker can understand. It says the host should consider a site-specific safety induction that outlines the WHS duties, policies, procedures and practices at that workplace, including how consultation works. WorkSafe Queensland says that before they start work, new workers must be trained so they become familiar with their tasks, their place of work, and the people working around them.

Does a labour hire worker still need a white card and a site induction?

On construction work, the white card and the site induction are separate from each other, and separate from a provider's own induction. WorkSafe Queensland says a person working in the construction industry needs to complete general construction induction training, unit CPCCWHS1001, with a registered training organisation. The card issued after that unit was previously called a white card. Sections 316 and 317 of the Work Health and Safety Regulation 2011 (Qld) set the duties about that training. WorkSafe also says a person must have a site-specific induction before starting construction work, other than housing construction work. Sections 316 and 317 do not contain a housing exception. The detail is in the white card guide and the site-specific induction guide.

What induction records should be kept, and when is a repeat required?

WorkSafe Queensland's training and supervision page says to keep the induction checklist on file as a record of the training, and that it is good practice to keep records of all training, including induction. The same page says the law requires training records for certain tasks, such as confined spaces and certain hazardous chemicals, and that you need to keep copies of high risk work licences. On a construction project, WorkSafe's site-specific induction page says the principal contractor should keep a record of the people inducted and the date it was given. Should is WorkSafe's word. The same training page says workers returning after a long absence should repeat the induction so they know about any changes. That page does not state a fixed interval, such as 12 months.

Does a labour hire licence replace work health and safety duties?

No. Section 10 of the Labour Hire Licensing Act 2017 (Qld) says a person must not provide labour hire services unless they hold a licence. Section 11 says a person must not, without a reasonable excuse, enter an arrangement for labour hire services unless the provider holds a licence. Section 28 makes it a condition of a licence that the licensee complies with all relevant laws applying to the licensee. The dictionary says a relevant law includes a law that imposes an obligation in relation to workers, including ensuring the health and safety of workers, and the examples include the Work Health and Safety Act 2011. Holding a licence is one obligation. It does not stand in for the duties in that Act.

Does Set2Go make a labour hire induction compliant?

No. Set2Go delivers the induction PowerPoint you already have. You invite the worker and they open the link on their phone. Set2Go timestamps when each slide was first viewed, and the quiz stays locked until every slide on that attempt has been viewed. You can set how long a pass lasts. The records show current, expiring soon, or expired, and the worker gets an email when a pass is about to expire or has expired. Set2Go does not issue a general construction induction training card, write a WHS management plan, or decide that a duty has been met. It is safety administration software, not a statutory WHS system.

Sources (checked 26 October 2026)

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