The duty is four words, and training is only one of them
Section 19(3)(f) of the model WHS Act requires a PCBU to ensure, so far as is reasonably practicable, "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 the work. The four words carry different weight on different days: information can be a toolbox talk, instruction a direction on the job, and supervision is what fills the gap while competence is still being built. Regulation 39 then supplies the test that separates real training from a certificate on a wall: what is provided must be suitable and adequate having regard to three things, the nature of the work the worker carries out, the nature of the risks at the time the training is provided, and the control measures implemented. It must also be delivered in a way that is "readily understandable by any person to whom it is provided", which is where generic English-only e-learning meets its legal limit on a multilingual workforce. A one-size induction bought off the shelf can fail all three limbs at once. Who holds this duty, and to which workers, is mapped on the WHS laws reference page.
Construction's door charge: the white card
Construction is the one industry with a mandatory entry-level course. Under regulation 316 a PCBU must ensure general construction induction training is provided to any worker who is to carry out construction work, and under regulation 317 must not direct or allow a worker onto construction work unless the worker has completed it, holds the card, or holds a certification issued within the preceding 60 days while the card application is pending. The training must be delivered by a registered training organisation against the specified VET course, and the construction work code notes the card is "commonly referred to within the construction sector as a 'white card'". Two details are routinely missed. The card can lapse in practice: if a worker completed the training more than two years ago and has not carried out construction work in the preceding two years, the PCBU must provide the training again. And it reaches everyone who carries out construction work, the code's own list running from labourers and tradespersons to managers, engineers and surveyors. A card issued in one jurisdiction is recognised in the others while it remains valid. The white card is the floor, not the ceiling: the code layers workplace-specific induction and task-specific training on top of it, and its supervision section expects supervisors to be "checking workers' competency to undertake the work" rather than assuming the card settles it. How the card fits the wider construction machinery, SWMS and principal contractors included, is on the construction safety page.
29 classes of work where training becomes a licence
Above the training duty sits authorisation. Section 43 of the model Act makes it an offence both to carry out work that the regulations require to be authorised without authorisation, and for a PCBU to direct or allow a worker to do so. Regulation 81 applies that to high risk work: no one may perform a class of it without the corresponding licence, and Schedule 3 defines exactly 29 classes.
The 29 high risk work licence classes of Schedule 3, model WHS Regulations (5 December 2025 consolidation), grouped as the schedule groups them. Each class maps to a specified VET course in Schedule 4; several stack (an advanced rigging licence requires the dogging and basic and intermediate rigging courses first).
| Group | Classes | What is in it |
|---|---|---|
| Scaffolding work | 3 | Basic, intermediate and advanced scaffolding |
| Dogging and rigging work | 4 | Dogging; basic, intermediate and advanced rigging |
| Crane and hoist operation | 15 | Tower, self-erecting tower, derrick, portal boom, bridge and gantry, and vehicle loading cranes; non-slewing and four capacity tiers of slewing mobile cranes; materials and personnel hoists; boom-type elevating work platforms with a boom of 11 metres or more; concrete placing booms |
| Reach stackers | 1 | Reach stackers over 3 tonnes handling shipping containers |
| Forklift operation | 2 | Forklift trucks; order-picking forklift trucks |
| Pressure equipment operation | 4 | Standard and advanced boilers; steam turbines; reciprocating steam engines |
The licensing pipeline is national and runs through the training system. Only a person who holds the Schedule 4 qualification may apply (regulation 86): training and assessment sit with registered training organisations listed on the National Register of Vocational Education and Training, and Safe Work Australia's guidance adds the operational facts, an applicant must be over 18, the statement of attainment must be no more than 60 days old at application, the licence lasts five years (regulation 92), and a licence not renewed within 12 months of expiry means training and assessment again. The exceptions in regulation 82 are deliberately narrow: a trainee may do the work under the supervision of a licence holder, and regulation 84 requires that supervision to be direct, meaning oversight that directs, demonstrates, monitors and checks the trainee's work, unless the task makes direct supervision impracticable or unnecessary and the reduced level puts nobody at risk. Notably absent from the list: electrical work, which never entered the harmonised licence scheme and remains each state's own licensing law, as the electrical safety page explains.
What the PCBU must sight, and when a certificate is not enough
The employer's end of the licence system is an evidence duty. Under regulation 85 a PCBU must not direct or allow a worker to carry out high risk work unless it has seen written evidence of the relevant licence, must see the equivalent evidence for trainees and their supervisors, and must keep a record of that evidence for at least a year after the work. This is the regulation behind the industry habit of verifying competency rather than filing certificates: a licence proves the holder passed the national assessment, while section 19's supervision limb and the construction code's expectation that supervisors check competency cover the distance between passing an assessment and doing this task, on this plant, at this workplace. The same distance is where regulation 39 does its quiet work across every industry with no licence in sight: whenever the work, the risks or the control measures change, the training that was suitable last year stops being suitable, which is why training records and refresher triggers belong inside the management system an officer is required to verify. One honesty note for multi-state operators: this page describes the model laws, which the model-laws hub records as implemented everywhere except Victoria. Victoria runs a parallel scheme under its own regulations, and it is not identical: WorkSafe Victoria lists 30 licence classes, the model's 29 plus a non-slewing telehandler class the model schedule does not carry. Check your regulator for the local text.
Sourcing note
Statutory wording is from the model Work Health and Safety Bill and model WHS Regulations, both in the Parliamentary Counsel's Committee consolidations of 5 December 2025: s 19(3)(f) and ss 43 to 45 of the Bill; regs 39, 81 to 93, 316 to 320 and Schedules 3 and 4 of the Regulations. Licence-class descriptions are condensed from Schedule 3; the schedule's full wording controls. Age, renewal and application-window details are from Safe Work Australia's high risk work licences guidance pages, and the Victorian class count from WorkSafe Victoria's high risk work licence page, all read 8 July 2026. Construction induction material is from the model Code of Practice: Construction Work, November 2024 edition, read in full. Model provisions bind only as enacted in each jurisdiction; penalties are expressed as tiers in the model and set locally.