Safe Work Australia will develop a climate strategy, and the review behind it recommends new model regulations on extreme heat

The short answer

• What was announced: a national strategy, to be developed by Safe Work Australia. Its chief executive, Marie Boland, told a research forum in Brisbane: Today, I’m pleased to announce that Safe Work Australia will develop a national strategy on the WHS impacts of climate change.
• Where it comes from: Recommendation 20 of the Best Practice Review of the model WHS laws, published in October.
• The part that would bind you: the review wants new model regulations on extreme heat, air quality and vector-borne diseases, progressed as a priority as part of the proposed model WHS Regulations modernisation project.
• This summer: the existing duty applies, unchanged. There is still no model heat code and no national stop-work temperature; our heat explainer sets out how the current duty is assembled.

Exhibit A · from the source

Safe Work Australia to develop a strategy on climate change which:

includes new model WHS Regulations to regulate extreme heat, air quality and vector-borne diseases

monitors how WHS laws are interpreted, applied and enforced in relation to extreme weather to identify any gaps in the model WHS Act, Regulations and Codes

What the review found wrong with the current rules

The review’s starting point is blunt: The model WHS Regulations do not explicitly refer to climate change or climate-related hazards. Climate hazards are still covered, it says, through the primary duty of care and through regulations written for other purposes, such as regulation 40 on extremes of heat and cold, ventilation, emergency plans and air monitoring. Its objection is that those rules deal with ordinary, “business as usual” risk, and not all of them have been updated for the way climate change is intensifying it.

It also leans on the International Labour Organization, which the review reports found that such general regulations are inadequate to respond to the challenges of a warming planet. The countries the ILO points to have legislated heat stress indicators, temperature thresholds and specific protections such as rest areas, hydration, training and PPE.

The three regulations it wants

Summarised from pages 121 to 125 of the final report. The hospitalisation figures and projections are the review’s, drawn from the cited national sources; we have not re-derived them.

The review is just as clear that regulations will not do all the work. Industries with outdoor work, it says, will particularly benefit from heat advice in industry codes of practice. It also cites a 2024 member survey by the Australian Institute of Health and Safety in which fewer than a quarter of respondents felt confident helping organisations manage climate-related WHS risks.

The ACT and NSW are not waiting

The review gives its own reason for a national approach: An absence of strategic engagement may see jurisdictions individually respond to climate-related risks, weakening harmonisation. It names two that already have.

The ACT approved a Managing the Risks Associated with Extreme Temperatures Code of Practice on 6 November 2025. It tells PCBUs that a workplace temperature management plan should be developed and implemented in consultation with workers and their HSRs, and that the plan should record the agreed conditions under which work stops. For building and construction it goes further than any national document: this threshold to stop work should consider whether temperatures are expected to be higher than 37 degrees. That is guidance, not a legal limit. The code itself says The word ‘should’ is used in this Code to indicate a recommended course of action.

In NSW, approved codes of practice have been the minimum standard since 1 July 2026, as we reported. The state’s Net Zero Commission expected that to give the work environment code’s heat content enforceable status, and in April said it was not enough on its own. Its Heat Stress Spotlight Report found that Strengthening SafeWork NSW regulations to prevent heat stress in the workplace would minimise the health and economic impacts of extreme heat on workers and businesses. It recommended mandating the development of heat stress prevention plans in high-risk industries, guidance on heat thresholds at which work is modified or stopped, better data on heat harm at work, and protections for independent contractors.

The NSW Government said in May that it will provide a response to that report within the statutory deadline of 21 October 2026. On 11 November we could not find a published response on the Commission’s report page or the NSW Government’s climate adaptation pages.

What this changes for you this summer

Nothing in the law yet. A strategy has to be written, the regulations drafted and consulted on, ministers have to agree, and each jurisdiction then has to adopt them. Until then, the duty is the one you already have: the section 19 primary duty and regulation 40’s requirement that workers in extremes of heat or cold can work without risk, with the work environment code and Safe Work Australia’s heat guide behind them.

If you run work in the ACT: the extreme temperatures code is the approved code there now. A written temperature management plan with agreed stop-work conditions is what it expects, and builders have a 37-degree reference point to plan around.

If you run work in NSW: where an approved NSW code covers your heat risk, its ‘should’ is now the standard you meet or beat, not advice. If the government adopts the Commission’s recommendation, heat stress prevention plans in high-risk industries would become a requirement.

Everywhere else: a heat plan agreed with workers before the first heatwave costs little, and both the ACT code and the Net Zero Commission build their approach around one.

Our read

This section is opinion, built on the documents cited above.

This is the right recommendation to act on first. Safe Work Australia’s own release calls rising temperatures and heatwaves the most immediate climate risk at work, the model regulations do not mention climate change at all, and the ACT has already shown that a code can name a number without turning it into a blunt legal threshold.

But the announcement is softer than the recommendation. Recommendation 20 says the strategy includes new model WHS Regulations to regulate extreme heat, air quality and vector-borne diseases. The 5 November release does not mention new regulations. It says the strategy will consider how the model WHS framework can continue to protect workers as our climate changes, and it gives no timetable. Those can both be true at once: Safe Work Australia cannot promise regulations that ministers have not agreed to. The test is the strategy itself. If it carries draft heat regulations, the national system will have caught up with the ACT. If it carries research and coordination only, expect more states to write their own rules, which is the outcome the review warns against. We will report the strategy’s scope and timetable when Safe Work Australia publishes them.