Principal contractor obligations on a Queensland construction project

Short answer: Under section 292 of the Work Health and Safety Regulation 2011 (Qld), a construction project is construction work costing $250,000 or more. That project has one principal contractor (section 293). Before work starts, the principal contractor must prepare a written WHS management plan, including the site rules (section 309), and must make sure each person who is to carry out construction work is made aware of that plan before they start (section 310). The principal contractor must take all reasonable steps to obtain a safe work method statement before high risk construction work starts (section 312). Signs must identify the principal contractor (section 308). Securing the workplace from unauthorised access is a duty of a person with management or control of the workplace (section 298). It is not limited to jobs of $250,000 or more. WorkSafe Queensland says you should keep a record of who was inducted and when. These duties sit on top of the duties of a person conducting a business or undertaking. They do not replace them.

This page is plain English for small and mid-sized contractors on commercial and civil projects in Queensland. It sets out what the Act, the Regulation and WorkSafe Queensland say, with links, and a practical checklist. It is not a complete statement of every construction duty.

General information only, checked against official sources on 21 October 2026. It isn't legal advice. Always check the current law and WorkSafe Queensland guidance for your job.

When a principal contractor exists

Section 292 says: "In this chapter, a construction project is a project that involves construction work where the cost of the construction work is $250,000 or more." The section does not mention GST, and it does not say the test is limited to commercial or civil work.

WorkSafe Queensland's principal contractors page says this figure went up from $80,000. WorkSafe says the cost can be determined by the contract price, and that the kinds of costs included are project management costs, the cost of fittings and furnishings, and any taxes, levies or charges payable in connection with the work, excluding GST. Treat the GST point as WorkSafe's guidance. Do not read it into the words of section 292.

Under $250,000. WorkSafe says work valued at less than $250,000 is not a construction project, and that a principal contractor cannot be appointed. Part 6.4 of the Regulation applies in relation to a construction project (section 307), so the extra principal contractor duties in that part do not arise. The general duties still do. See how this sits with PCBU duties below.

Do not mix this up with the $150,000 levy. WorkSafe says the Building and Construction Industry (Portable Long Service Leave) Act 1991 provides for a work health and safety levy, collected by QLeave, on certain building and construction work valued at $150,000 or more. That is WorkSafe's note. It is not the construction project test in section 292. This page does not set out the levy. WorkSafe also says the WHS Regulation does not require Workplace Health and Safety Queensland to be notified of a principal contractor appointment, and that notification must still be made to QLeave.

Section 289 defines construction work for the chapter. It is any work carried out in connection with the construction, alteration, conversion, fitting-out, commissioning, renovation, repair, maintenance, refurbishment, demolition, decommissioning or dismantling of a structure. Subsection (3) lists what is not construction work, including testing, maintenance or repair work of a minor nature. Read section 289 before you assume a job is in or out.

Who the principal contractor is

Section 293(1): the person conducting a business or undertaking (PCBU) that commissions the construction project is, subject to that section, the principal contractor. That is often the client. It is not automatically the builder on site.

Section 293(2): if that commissioning PCBU engages another PCBU as principal contractor and authorises that PCBU to have management or control of the workplace and to discharge the duties of a principal contractor under the chapter, the PCBU so engaged is the principal contractor. Both the management-or-control authorisation and the authority to discharge the duties are in the section. WorkSafe recommends that any authorisation or appointment be documented and signed. That recommendation is not a form prescribed by section 293.

Section 293(3) is a different case. If the owner of residential premises is an individual who directly or indirectly engages a PCBU to undertake a construction project in relation to the premises, the person engaged is the principal contractor if that person has management or control of the workplace. Do not use subsection (3) as the rule for a commercial client.

Section 293(4): a construction project has only one principal contractor at any specific time. The note to section 293 says a person with management or control of a workplace must comply with section 20 of the Work Health and Safety Act 2011 (Qld).

WorkSafe says that if a client commissions two or more construction projects and appoints a different principal contractor to each, the workplaces have to be defined as separate and distinct. WorkSafe says only one PCBU can have management or control of a defined workplace at any given time, that each principal contractor must contract directly with the client (one cannot be a subcontractor to the other), and that the PCBUs must consult, cooperate and coordinate. Where a physical boundary is not practical, WorkSafe says both principal contractors must be able to show how they manage people crossing the boundary, and how the duty to secure the workplace against unauthorised access is met. That adjacent-project detail is WorkSafe's page, not extra words in section 293.

How this sits with PCBU duties

A principal contractor is a PCBU. The opening words of Part 6.3 say that, because a principal contractor is a PCBU, that part also applies to a principal contractor. Part 6.4 then adds duties. Section 307 says Part 6.4 applies in relation to a construction project and imposes duties on the principal contractor that are additional to the duties in Part 6.3.

• A duty cannot be handed off. Section 14 of the Act says a duty cannot be transferred to another person. WorkSafe makes the same point for work under $250,000: a PCBU can authorise a contractor to have management or control of a construction workplace, but cannot transfer a duty of management or control under the Act.
• One person can hold more than one duty. Section 15 of the Act says a person can have more than one duty by being in more than one class of duty holder. A principal contractor can be, at the same time, a PCBU with the primary duty and a person with management or control of the workplace.
• Other businesses still have their own duties. Section 16 says more than one person can have the same duty at the same time. Each must comply to the standard the Act requires, even if another duty holder has the same duty. An agreement that purports to limit or remove a person's capacity to influence and control the matter does not reduce the duty (section 16(3)). The note to regulation section 314 points back to section 16.
• The primary duty still applies. Section 19(1) requires a 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 work the person influences or directs, while those workers are at work in the business. Section 19(2) covers other people put at risk by the work. Section 19(3)(f) includes the provision of any information, training, instruction or supervision that is necessary to protect people from risks arising from the work. That training duty is the PCBU's. It is not a principal-contractor-only duty, and it is not limited to construction projects.
• Information has to be fit for the person. Regulation section 39 applies for section 19 of the Act to a PCBU. The information, training and instruction must be suitable and adequate having regard to the work, the risks, and the control measures (section 39(2)). So far as is reasonably practicable, it must be provided in a way that is readily understandable by any person to whom it is provided (section 39(3), maximum penalty 60 penalty units).
• Management or control of the workplace. Section 20 of the Act requires a person with management or control of a workplace to ensure, so far as is reasonably practicable, that the workplace, the means of entering and exiting, and anything arising from the workplace are without risks to the health and safety of any person. Section 20(1) defines that person as a PCBU to the extent the business or undertaking involves the management or control, in whole or in part, of the workplace. It does not include the occupier of a residence, unless the residence is occupied for the purposes of, or as part of, the conduct of a business or undertaking, and it does not include a prescribed person.

Part 6.3 also requires a PCBU to manage risks associated with carrying out construction work in accordance with part 3.1 (section 297). The note points to section 19 of the Act. Section 297 does not state its own maximum penalty in the text checked for this page.

The WHS management plan and the site rules

Section 309(1): the principal contractor for a construction project must prepare a written WHS management plan for the workplace before work on the project commences. Maximum penalty: 60 penalty units.

Section 309(2) says the plan must include:

1. the names, positions and health and safety responsibilities of all persons at the workplace whose positions or roles involve specific health and safety responsibilities in connection with the project;
2. the arrangements between any PCBUs at the workplace for consultation, cooperation and the coordination of activities in relation to compliance with their duties under the Act and the Regulation;
3. the arrangements for managing any work health and safety incidents that occur;
4. any site-specific health and safety rules, and the arrangements for ensuring that all persons at the workplace are informed of these rules;
5. the arrangements for the collection and any assessment, monitoring and review of safe work method statements at the workplace.

The fifth item says "any assessment, monitoring and review". The plan has to state the arrangements. Section 309 does not, in those words, create a separate offence of failing to monitor a SWMS. Monitoring is covered again under SWMS below.

WorkSafe's WHS management plans page says the plan must be written so it is easy to understand, signed and dated by the principal contractor. Those words are on WorkSafe's page. They are not in section 309.

Section 311(1): the principal contractor must review and, as necessary, revise the plan to ensure it remains up to date. Maximum penalty: 36 penalty units. Section 311(2): the principal contractor must ensure, so far as is reasonably practicable, that each person carrying out construction work in connection with the project is made aware of any revision. Maximum penalty: 36 penalty units. WorkSafe describes the review as required if there are changes in how risks will be managed. The section's test is that the plan remains up to date.

Section 313(1): the principal contractor must ensure a copy of the plan is kept until the project is completed. Maximum penalty: 12.5 penalty units for an individual (printed in the compilation as 12 1/2), or 60 penalty units for a body corporate. If a notifiable incident occurs in connection with the construction project to which the statement relates, section 313(2) requires the person to keep the plan for at least 2 years after the incident. The same individual and body corporate penalties apply. Section 313(5) says the plan means the initial plan and all revised versions. For the period it must be kept, a copy must be readily accessible to any person who is to carry out construction work on the project (section 313(3), maximum penalty 36 penalty units) and available for inspection under the Act (section 313(4), maximum penalty 12.5 penalty units for an individual, or 60 penalty units for a body corporate).

Telling people before they start

Section 310: the principal contractor must ensure, so far as is reasonably practicable, that each person who is to carry out construction work in connection with the project is, before commencing work, made aware of the content of the WHS management plan and of the person's right to inspect the plan under section 313. Maximum penalty: 36 penalty units.

The people in section 310 are people who are to carry out construction work. The section does not say "every visitor".

WorkSafe's WHS management plans page says the principal contractor cannot allow work to start unless the plan has been discussed with, or a copy given to, all relevant people, and the plan is available or readily available for inspection. That is WorkSafe's wording. Section 310 is "made aware", so far as is reasonably practicable, before the person commences work.

The Regulation's Part 6.4 does not use the phrase "site-specific induction". WorkSafe's site-specific induction page does. WorkSafe says a person must have a site-specific induction before starting construction work, other than housing construction work, and that the induction needs to address the contents of the WHS management plan. WorkSafe also says a person entering a part of the workplace where construction work is being done must have been given a site-specific induction, or be accompanied by the principal contractor or someone who has been given one.

Housing. WorkSafe says site-specific induction is not compulsory where housing construction work is being carried out, and that the contents of the principal contractor's construction safety plan still need to be communicated effectively. WorkSafe uses "construction safety plan" in that sentence. The name in section 309 is the WHS management plan. Part 6.4 does not contain a housing exemption: section 307 says the part applies in relation to a construction project. Section 306A defines housing construction work with the words "In this division". That definition is for the division it sits in. It is not a definition of who a principal contractor is, and it is not a definition for Part 6.4. This page does not restate section 306A, and it is written for commercial and civil projects. If the job is housing, read WorkSafe's page and the current regulation, and do not treat this page as the housing answer.

What to record. WorkSafe says: "As the principal contractor you should keep a record of the people inducted and the date it was given." That is "should", on WorkSafe's site-specific induction page. Sections 309 to 313 do not separately require a register of names and dates. They do require the plan to be kept, as section 313 sets out. What a site-specific induction usually covers, and how firms run that briefing, is in the Queensland site-specific induction guide. The white card sits in Part 6.5. It is not one of the Part 6.4 principal contractor duties on this page. See white card vs site induction in Queensland.

SWMS for high risk construction work

Section 291 defines high risk construction work for the chapter. It means construction work that:

• involves a risk of a person falling more than 2m; or
• is carried out on a telecommunication tower; or
• involves demolition of an element of a structure that is load-bearing or otherwise related to the physical integrity of the structure; or
• involves, or is likely to involve, the disturbance of asbestos; or
• involves structural alterations or repairs that require temporary support to prevent collapse; or
• is carried out in or near a confined space; or
• is carried out in or near a shaft or trench with an excavated depth greater than 1.5m, or a tunnel; or
• involves the use of explosives; or
• is carried out on or near pressurised gas distribution mains or piping; or
• is carried out on or near chemical, fuel or refrigerant lines; or
• is carried out on or near energised electrical installations or services; or
• is carried out in an area that may have a contaminated or flammable atmosphere; or
• involves tilt-up or precast concrete; or
• is carried out on, in or adjacent to a road, railway, shipping lane or other traffic corridor that is in use by traffic other than pedestrians; or
• is carried out in an area at a workplace in which there is any movement of powered mobile plant; or
• is carried out in an area in which there are artificial extremes of temperature; or
• is carried out in or near water or other liquid that involves a risk of drowning; or
• involves diving work.

Who prepares it. Section 299 is a duty of the PCBU that includes the carrying out of the high risk construction work, not a duty that section 299 gives only to the principal contractor. Before the work commences, that PCBU must ensure a safe work method statement is prepared, or has already been prepared by another person. Maximum penalty: 60 penalty units. The statement must identify the high risk construction work, state the hazards and the risks to health and safety associated with those hazards, describe the control measures, and describe how those measures are to be implemented, monitored and reviewed (section 299(2)). It must be prepared taking into account all relevant matters, including circumstances at the workplace that may affect the way the work is carried out and, if the work is carried out in connection with a construction project, the WHS management plan prepared for the workplace (section 299(3)). It must be set out and expressed so it is readily accessible and understandable to the people who use it.

Who must follow it. Section 300: that same PCBU must put in place arrangements for ensuring the high risk construction work is carried out in accordance with the statement. If it is not, the person must ensure the work is stopped immediately or as soon as it is safe to do so, and resumed only in accordance with the statement. Maximum penalty for each of those duties: 60 penalty units.

Getting a copy to the principal contractor. If the high risk construction work is in connection with a construction project, section 301 says the PCBU carrying it out must ensure a copy is given to the principal contractor before the work commences. Maximum penalty: 12.5 penalty units for an individual, or 60 penalty units for a body corporate. Section 312 says the principal contractor must take all reasonable steps to obtain a copy before the high risk construction work commences. Maximum penalty: 36 penalty units. The note to section 312 points back to the cooperation arrangements and the SWMS arrangements in section 309(2)(b) and (e). Section 312 does not say "monitor".

Monitoring. Two different things use that word. Section 299(2)(d) says the statement itself must describe how the control measures are to be implemented, monitored and reviewed. Section 309(2)(e) says the WHS management plan must include the arrangements for the collection and any assessment, monitoring and review of safe work method statements. Separately, WorkSafe's WHS management plans page says the principal contractor must sign and date safe work method statements that have been received, keep them with the plan, and monitor their implementation. Quote that as WorkSafe. Do not quote it as section 312.

How long the SWMS is kept. Section 303 is a duty of a PCBU, not a duty the section names as the principal contractor's. A copy must be kept until the high risk construction work is completed, or for at least 2 years after a notifiable incident in connection with that work. For that period it must be readily accessible to any worker engaged by the person to carry out the work, and available for inspection under the Act. Section 302 requires a PCBU to ensure a statement is reviewed and, as necessary, revised if relevant control measures are revised under section 38. Maximum penalty: 36 penalty units.

Under $250,000 there is no construction project, so sections 301 and 312 do not operate. Sections 299, 300, 302 and 303 can still apply to the PCBU carrying out the high risk construction work.

Signage

Section 308: the principal contractor for a construction project must ensure signs are installed that show the principal contractor's name and telephone contact numbers, including an after hours telephone number; show the location of the site office for the project, if any; and are clearly visible from outside the workplace, or the work area of the workplace, where the project is being undertaken. Maximum penalty: 36 penalty units. If there is no site office, the section does not require you to invent one. It says "if any".

Site security

Section 298(1): a person with management or control of a workplace at which construction work is carried out must ensure, so far as is reasonably practicable, that the workplace is secured from unauthorised access. Maximum penalty: 36 penalty units.

In complying, the person must have regard to all relevant matters, including the risks to health and safety from unauthorised access, the likelihood of unauthorised access (the section's example is proximity to places frequented by children, including schools, parks and shopping precincts), and, to the extent unauthorised access cannot be prevented, how to isolate hazards within the workplace (section 298(2)).

This duty is in Part 6.3. It applies where construction work is carried out. It is not created by the $250,000 construction project test, and the section does not name "every PCBU". It names a person with management or control of the workplace. On a construction project, the note to section 307 says a principal contractor has management or control of a workplace, so the duty sits with the principal contractor as well as with anyone else who has that management or control.

WorkSafe's security page points to section 298. WorkSafe describes the duty holder as a PCBU assessing the risks of unauthorised access, and lists the same three matters. WorkSafe says temporary fencing is one of many ways to manage the risk. It does not say fencing is the only control. Where two projects sit side by side, WorkSafe's principal contractors page uses "secured against unauthorised access". The regulation's words are "secured from unauthorised access".

Other duties in Part 6.4

The duties above are the ones this page walks through. Part 6.4 does not stop there. Section 314 requires the principal contractor to put in place arrangements for ensuring compliance at the workplace with part 3.2, divisions 2, 3, 4, 5, 7, 8, 9 and 10, and with part 4.4. Maximum penalty: 60 penalty units. The note says all PCBUs at the construction project workplace have those same duties. WorkSafe's principal contractors page summarises this area as arrangements for specified requirements such as facilities and amenities.

Section 315 requires the principal contractor to manage, under part 3.1, risks to health and safety associated with the storage, movement and disposal of construction materials and waste at the workplace; the storage of plant that is not in use; traffic in the vicinity of the workplace that may be affected by the construction work; and essential services at the workplace. The section's note points to section 20 of the Act. The text checked for this page does not state a maximum penalty on section 315 itself.

Section 315A says schedule 5A states particular duties of a principal contractor about amenities, and requires an amenity provided under that schedule to be maintained in a hygienic, safe and serviceable condition. This page does not set out schedule 5A. Part 6.4 continues after that, including duties relating to falling objects. This page does not set those sections out.

A practical checklist

Use this as a working list for a commercial or civil project. It is not a substitute for reading the sections.

• Work out the cost of the construction work. If it is $250,000 or more, section 292 makes it a construction project. Use WorkSafe's note on what goes into that cost, including WorkSafe's exclusion of GST. The regulation text states the dollar figure and does not mention GST.
• Name the one principal contractor under section 293. If a builder is to be the principal contractor, the commissioning PCBU has to engage them and authorise both management or control and discharge of the principal contractor duties. Write that down. WorkSafe recommends a signed record. Do not assume the head contractor is the principal contractor.
• Before work starts, have a written WHS management plan with the five items in section 309(2), including the site rules and how people will be told about them, and the arrangements for collection and any assessment, monitoring and review of SWMS. WorkSafe also says to sign and date the plan.
• Before each person starts construction work, make them aware of the plan's content and of their right to inspect it (section 310).
• Keep a record of who was inducted and the date. WorkSafe says you should. The sections checked here do not make that register its own "must".
• Keep the plan until the project is completed, and for at least 2 years after a notifiable incident (section 313). Keep revised versions. Keep a copy readily accessible.
• When the plan needs to stay up to date, review and revise it, and make people carrying out the work aware of the revision (section 311).
• For high risk construction work, the PCBU doing the work has the SWMS prepared before it starts (section 299), has arrangements to follow it (section 300), and, on a construction project, gives a copy to the principal contractor (section 301). The principal contractor takes all reasonable steps to obtain that copy before the work starts (section 312).
• Put up the section 308 signs: name, phone numbers including an after hours number, and the site office location if there is one, visible from outside.
• If you have management or control of the workplace, secure it from unauthorised access so far as is reasonably practicable (section 298), including on jobs under $250,000.
• Leave the white card check, and any daily sign-in book, as separate steps. Neither one is the WHS management plan.

A printable briefing list is the Queensland site induction checklist. For what Queensland law does and does not require of a daily sign-in register, see the QR code site sign-in guide.

Where Set2Go fits the records

Set2Go does not decide whether a job is a construction project, does not appoint a principal contractor, and does not write your WHS management plan. It keeps records of the induction you already have, and of gate check-in if you use a site. Companies that induct and do not run a gate can use contractor inductions without a QR check-in.

• The deck you already use. Upload your .pptx. Workers see it one slide at a time on their phone. Set2Go timestamps when each slide was first viewed on that attempt. The timestamp shows the slide was opened. It does not show how long someone looked at it. The quiz stays locked until every slide has been seen, and a certificate is issued when they pass.
• Who has finished. The induction records view lists the worker, the status, when it was completed, the quiz score, and when it expires. You can filter that view to current, expiring soon, expired, or not complete.
• Gate check-in. Workers join because you invite them. They don't self-register. At the site they scan the QR code and enter their own 6-digit PIN. If the site has rules they have not acknowledged at the current version, they step through the rules before the check-in button is available. The check-in row stores that acknowledgement. Check-in is refused when no induction applies to that site, or an applicable induction is not started, in progress, failed, or expired. A status of needs a retake is flagged, and check-in is still allowed. A live board shows open check-ins, so you can see who is on site. A worker check-in with no signal is queued on the phone and syncs later.
• SWMS you write. You can store a SWMS in Set2Go. The rows are yours. It does not draft the hazards or controls for you. An invited worker can acknowledge an active SWMS. The record stores that worker and the version they signed. If the site has the SWMS module on, the checked-in screen lists active SWMS that worker has not acknowledged and links them to sign. That prompt does not block the check-in button. A supervisor can save a monitoring record against the controls on an active SWMS, including whether a control was in place and any non-conformance.

None of that obtains a subcontractor's SWMS for you, and none of it is the WHS management plan or the arrangements in section 309(2)(e). Site sign-in is the gate product. The PowerPoint to phone induction guide covers the slide record in more detail.

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 doesn't by itself mean you've met your obligations under the Work Health and Safety Act 2011 (Qld) or the Work Health and Safety Regulation 2011 (Qld). You are still responsible for the WHS management plan, the site rules, the SWMS arrangements, and for meeting your duties as a PCBU or principal contractor.

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FAQ

Sources (checked 21 October 2026)

• WorkSafe Queensland, Principal contractors (page last updated 2 May 2017)
• WorkSafe Queensland, Work health and safety management plans (page last updated 10 November 2017)
• WorkSafe Queensland, Site specific induction (page last updated 25 January 2019)
• WorkSafe Queensland, Security (page last updated 2 May 2017)
• Queensland Legislation, Work Health and Safety Act 2011 (in-force compilation viewed 21 October 2026): sections 14, 15, 16, 19 and 20
• Queensland Legislation, Work Health and Safety Regulation 2011 (in-force compilation viewed 21 October 2026): sections 39, 289, 291, 292, 293, 297, 298, 299, 300, 301, 302, 303, 307, 308, 309, 310, 311, 312, 313, 314, 315 and 315A. Section 306A is cited only to record that its definition of housing construction work applies in the division that contains it.

Related

• Site-specific induction requirements for a QLD commercial job
• White card vs site induction in Queensland: what is the difference?
• Site induction checklist for Queensland construction sites (free template)
• QR code site sign-in: keeping an on-site register in Queensland
• Turn a PowerPoint induction into a phone induction
• Toolbox talk record template
• Contractor inductions
• Site sign-in
• All guides

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