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Middle managers and supervisors

For: Employers and managers Information seekers

Middle managers and supervisors are responsible for managing, leading and supporting workers to understand and meet work health and safety policies and procedures.

The role of middle managers explained

Definition of a middle manager

A middle manager or supervisor has responsibility for managing other workers. They usually report to a senior manager or to another middle manager.

The role and influence a person has in a business or undertaking determines if they are an 'officer' under work health and safety laws. An officer makes, or participates in making, decisions that affect the whole, or a substantial part, of a business or undertaking.

Given their role and influence, middle managers and supervisors can be 'officers' in their business or undertaking. Officers have a duty to be proactive and continuously ensure that their business or undertaking complies with relevant duties and obligations.

Duties of a middle manager or supervisor

As a worker

All workers, including middle managers and supervisors, have duties and responsibilities under the Work Health and Safety Act 2011 (WHS Act). These include:

  • taking reasonable care for your own health and safety
  • taking reasonable care that your actions or omissions do not harm the health and safety of others
  • reporting any hazards or work practices you feel may be unsafe. If it looks wrong or unsafe, report it
  • complying with any reasonable instruction, policy or procedure relating to health and safety in the workplace, such as
    • follow safety manuals and procedures
    • participate in safety training
    • wear personal protective equipment
    • exercise a level of care and responsibility in your work.
  • reinforcing and influencing safety behaviours in your workplace
  • working with management to identify safety problems and find solutions
  • understanding and following internal incident reporting processes
  • acting upon health and safety matters where you have control or influence
  • working with colleagues to promote health and safety so that it becomes a part of your daily work
  • contributing to quality data and information which measures health and safety compliance over time – this can be used to identify trends and target preventative actions and improvements.

As a middle manager

As a middle manager or supervisor (and an 'officer' under work health and safety laws), the scope of your duty is directly related to the influential nature of your position in the organisation and with the workers you manage.

Middle managers or supervisors:

  • ensure that health and safety is integrated into team planning and does not get downgraded based on competing priorities, budgetary constraints, or a lack of resources
  • promote and encourage open discussions on health and safety at all levels of the business to ensure that workers can achieve outcomes based on open communication, consultation, negotiation and agreement
  • engage with workers in an open honest and meaningful way to ensure they understand what safety standards are expected of them
  • encourage feedback and communication channels between workers, middle managers and senior managers
  • ensure that work health and safety practitioners and senior managers are made aware of issues or concerns on safety, especially hazards or flaws in any operational procedures
  • model safe work practices to workers and other managers
  • involve and assist workers in any change management process
  • helping other duty holders to meet their work health and safety legislative obligations.

For a full list of duties, see the Work Health and Safety Act 2011 (WHS Act).


If you do not follow the required procedures, you could face non-compliances under the WHS Act which may include penalties such as criminal prosecution, fines and jail sentences.

Key duties

Notifying the regulator

As a manager, you are often the first to hear about or witness an incident so you can play an important role in helping the 'person conducting a business or undertaking' (PCBU), who is usually your employer, meet their legal requirements.

It is vital that you ensure clear, effective and workable reporting processes that enable the PCBU to meet their obligation to notify Comcare of serious incidents.

As part of this, you must also ensure workers are aware of:

  • the PCBU’s obligations to notify the regulator for certain serious injuries or illnesses that arise out of work and dangerous incidents that occur at a workplace
  • the need to report incidents through the internal policies and procedures
  • the need to preserve the incident site and not disturb it until an inspector attends the site or advises otherwise.

Communicating and consulting with workers

Managers need to ensure that workers are consulted and involved in any health or safety matter that will, or may, affect them. Workers should also be given opportunities to raise issues or provide ideas and feedback to you as their manager, or a HSR, WHS practitioner or adviser, or senior leaders.

Under the Work Health and Safety Act 2011 (WHS Act), consultation is required when::

  • identifying hazards and assessing risks arising from work
  • making decisions about ways to eliminate or minimise those risks
  • making decisions about the adequacy of facilities for the welfare of workers
  • proposing changes that may affect the health or safety of workers
  • making decisions about the procedures for resolving health or safety issues
  • monitoring the health of workers or workplace conditions, information and training or consultation with workers
  • carrying out any other activity prescribed by the WHS Regulations.

For more information, see Work Health and Safety Consultation, Co-operation and Co-ordination Code of Practice 2015.

The following steps can assist managers determine how to approach consultation and communication:


Ensure your workforce are more aware of risks and how they are controlled. This could be done by:

  • providing information during workplace induction
  • carrying out regular workplace briefings
  • using an interpreter or translation service if necessary
  • involving workers in all matters which affect their health and safety at work.

Instruction and training

Ensure your workers understand how to do their job in a way that does not put themselves of their colleagues at risk. This could be done by:

  • showing your commitment so that your employees recognise the importance of training. You may also need to appoint someone competent to conduct the training for you
  • supervising is particularly vital when workers are new, inexperienced or young. Even experienced workers can become complacent and take shortcuts.

Work with health and safety representatives (HSRs)

Health and safety representatives (HSRs) and other worker representatives can play a key role in getting people on board with new initiatives. They represent the interests and concerns of their fellow workers and provide valuable insight, skills and resources.

  • Give the HSR full support and access to necessary equipment and facilities.
  • Understand the role and function of the HSR and other representatives.
  • Involve HSRs as potential champions to assist in the promotion of work health and safety in your team
  • Consult regularly, even if it is informal.
  • Arrange specific meetings for key issues such as high risk areas, proposed changes in the workplace and health surveillance issues.
  • Arrange for health and safety to be part of other scheduled meetings, such as team meetings.

Consult workers

As workers are often the most aware of health and safety issues and solutions, it makes sense to listen to them. If your workers feel their ideas are valued, they will generally have a stronger commitment to tackling such problems.

Intro sentence:

  • conduct regular scheduled meetings
  • conduct tool box talks - an informal safety meeting that focuses on safety topics related to the specific job, such as workplace hazards and safe work practices. Meetings are normally short and held at the job site prior to the commencement of a job or work shift
  • engage in face-to-face discussions
  • set up focus groups to deal with specific issues.

Other ways could include:

  • undertake worker surveys
  • display information on noticeboards
  • log and respond to issues or concerns raised by workers
  • share information and good practice through newsletters and updates.

Joint problem solving

This can assist to improve health and safety standards and increase productivity, efficiency and motivation throughout the workforce. It can also boost co-operation and trust between workers, managers and senior leaders. You can:

  • involve workers and their representatives in tackling health and safety issues to create a genuine and valuable partnership
  • allow concerns and ideas to be freely shared and acted upon as the whole workforce aims for a healthier and safer environment
  • tell your workers about health and safety and they’ll know about it, involve them and they’ll understand.

Barriers to effective consultation

Finding the right time and delivering messages in the right way can be a challenge. Managers should establish a relationship with their workers that encourages open and honest discussion and mutual trust.

Consultation often fails due to:

  • lack of clarity of message
  • absence of emotional resonance in your message
  • inaccurate targeting
  • poor timing
  • no genuine feedback process.

Tips to reduce barriers through communication:

  • provide clear messages with concrete examples to help people focus their energies
  • think about what you say and how you say it
  • written material should be backed up by verbal communication
  • check the tone of the communication (edit, edit and edit again)
  • some news is better than no news
  • let people know what is happening, you are the key in communicating change, workers look to you to see if there is real acceptance.

Managers can use the following ways to ensure they are promoting and contributing to effective communication:

  • encourage worker contribution at meetings
  • seek information from your intranet and raise awareness on matters that may affect workers
  • establish an open and constructive approach to talking to your workers
  • consider the barriers to communication in remote and isolated work locations (such as shift work, working on your own, isolated by distance or working from home). Make daily contact with workers where possible.

Managing the worker to cease unsafe work

Managers should be aware that a worker may cease, or refuse to carry out, work if the worker has a reasonable concern that to carry out the work would expose them to a serious risk to their health or safety.

Workers who cease unsafe work must notify the relevant PCBU as soon as practicable after doing so.

PCBUs can re-direct workers who have ceased unsafe work to carry out suitable alternative work at the same or another workplace. The suitable alternative work must be safe and appropriate for the worker until they can resume normal duties.

As their manager or supervisor, the worker is likely to let you know of the unsafe work and you must consider how to provide suitable alternative work until the issue has been resolved.

You should also:

  • ensure that the safety practitioner or adviser is advised of the situation as soon as possible after becoming aware of the unsafe work. This will assist in meeting the notification requirements placed on the PCBU under the Work Health and Safety Act 2011 and to initiate a risk management processes
  • undertake an immediate risk assessment of the work area, in consultation with any health safety representatives, to ensure that no other workers are affected or at risk and that the risk is contained
  • communicate and consult with the work health safety team about appropriate options for dealing with the issue, such as risk controls.

Support work health and safety entry permit holders

The Work Health and Safety Act 2011 confers specific rights of entry on people who hold office, or are employees of a union. These rights are called work health and safety entry permits.

Work health and safety entry permit holders are allowed to enter workplaces and exercise certain powers while at a workplace.

As a middle manager or supervisor, you must not:

  • without reasonable excuse, refuse or unduly delay an entry permit holder from entering a workplace
  • intentionally and unreasonably hinder or obstruct an entry permit holder from entering a workplace or exercising any rights.

Supporting rehabilitation or return to work

Under the Safety Rehabilitation and Compensation Act 1988 (SRC Act), managers have a responsibility to support the recovery at, or return to work, of employees with a work-related injury or illness.

This may include:

  • fostering a workplace that encourages and supports safe work practices and the early reporting of injuries
  • advising the rehabilitation case manager when you become aware of an injury
  • taking steps to prevent further injuries by understanding their causes and putting safeguards in place
  • keeping contact with the employee with an injury or illness to support and identify available assistance to help them recover or return to work
  • working with the rehabilitation case manager to identify suitable duties for the employee
  • changing or modifying the work and environment for the employee
  • contributing to the return to work plan and promptly letting the rehabilitation case manager know of any concerns
  • working with the employee to ensure their return to work is sustainable.

For more information, see:

Practical strategies

Early intervention

Prevention and early intervention is timely action to minimise the impact and duration of emerging symptoms of work-related injury or illness. As a manager you can:

  • Recognise the early warning signs of worker distress and low morale.
  • Support the worker and demonstrate empathy by initiating a conversation that expresses concern and allows the worker to discuss their health or other concerns in private.
  • Contact the worker if there is an unplanned absence from work. Explore their reasons for non-attendance with them. Offer support. Stay in contact with the worker in cases of prolonged absence to maintain the connection with the workplace.
  • Seek assistance if you feel unable to provide positive support to an worker. This may be from your human resources department, rehabilitation case manager or through your organisation’s employee or manager assistance programs.
  • If there has been a harassment or bullying complaint made against you by the worker, arrange for someone else, for example, HR personnel, to provide support to the worker.
  • Involve the rehabilitation case manager if a worker needs assistance to return to work. They will help you work with the worker to resolve issues, facilitate recovery and develop a return to work plan.
  • Provide flexible workplace options that enable the worker to be safe and productive at work (such as changes to the way the work is organised, additional support through a mentor or buddy, adjustments to work hours or duties). Ensure that the worker is fully involved in planning options and has co-ownership of job-related decisions.
  • Meet with the worker on return to work. Welcome them back, confirm their contribution was missed and provide an update about developments that have occurred in their absence. Agree on any changes to the organisation of their work and how this should be communicated to the team.
  • Provide ongoing support until the worker has reached their former functional level.

For more information, see our early intervention checklist.

Supporting your workers during times of change

Organisation and workplace change can be challenging, and if not managed well, can affect morale and engagement. Consequences may include:

  • reduced work performance
  • increased absenteeism
  • potential for psychological or other injuries that may result in workers' compensation claims.

During times of organisational change it is important to consider the mental health and wellbeing of workers as part of an integrated approach to risk management and corporate planning. This includes considering workers who are away from the workplace as a result of injury or illness or taking part in a rehabilitation program.

Training for managers

We provide training through our learning management system called Comcare LMS.

To access our training, you first need to create an account in Comcare LMS (see the steps to create an account). Then, select the training item that you are interested in and login with your email and password.

For more information about the training we offer, see Training and learning.

More information

Page last reviewed: 25 June 2020
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Date printed 14 Aug 2022