Safe Work Australia has released a Model Code of Practice on managing biological hazards. It applies far more broadly than most employers expect, to any workplace where workers may be exposed to organic matter, body fluids, waste, food, animals or other people. Here’s what it asks of you and where your HSRs fit in.
Not Just Hospitals and Labs
For years, biological hazard management was largely treated as a healthcare and laboratory issue. The Code makes clear that’s now outdated. It places obligations on employers across all industries to proactively identify, assess and control biological hazards.
Higher-exposure sectors include healthcare and aged care, childcare and education, agriculture and livestock, construction and waste management, food processing and hospitality, retail and customer-facing services, and emergency services. The simple test: if your work involves exposure to organic matter, body fluids, waste, animals, food or other people, the Code is relevant to you.
What Counts as a Biological Hazard?
Under the Code, biological hazards are substances and agents of biological origin that pose risks to human health, viruses and bacteria, parasites and prions, fungi (including mould), and allergens, irritants and toxins such as organic dust, plant sap and animal venom. They can arise from humans, plants, animals and the environment, indoors or outdoors.
The Four-Step Risk Process
The Code aligns with the existing model WHS framework and asks duty holders (PCBUs) to apply a structured risk management process:
- Identify the biological hazards in your workplace, the tasks, materials, environment and interactions with people.
- Assess the risks, the type of agent, the route of exposure (inhalation, skin contact, ingestion), how many workers are affected, and whether any are more vulnerable.
- Control the risks using the hierarchy of controls: elimination, substitution, engineering controls (ventilation, containment), administrative controls (safe work procedures, hygiene, training), and PPE as a last line of defence. The Code is clear that PPE alone is not enough; higher-order controls come first.
- Review and monitor, check controls remain effective, especially when work changes, new threats emerge, or after an incident.
Risk assessments and control measures must be documented, records help demonstrate due diligence and are admissible as evidence in WHS proceedings.
The Role of HSRs and Consultation
The Code reinforces the duty to consult workers throughout the risk management process. Workers have direct knowledge of the hazards they face and must be involved in identifying risks and developing controls. Health and Safety Representatives play a central role in facilitating that consultation, and, where safety obligations aren’t being met, HSRs can issue Provisional Improvement Notices.
Worker training is itself a core administrative control under the hierarchy. It ensures workers understand the hazards and the controls in place, and it supports the employer’s ability to demonstrate compliance with the Primary Duty under the WHS Act.
Where to Start
- Map where workers may contact biological agents, waste handling, poorly ventilated spaces, customer contact, work near organic materials.
- Add biological hazards to your WHS risk register if they’re not already there.
- Check your controls go beyond PPE.
- Brief your HSRs and safety committee on the Code and their role.
- Make sure worker training and inductions are current for at-risk roles.
Keep Your HSRs Current
- HSR Initial Training, Comcare (5-day)
- HSR Refresher Training, Comcare (1-day)
- HSR Initial Training, NSW (5-day)
- HSR Refresher Training, NSW (1-day)
For group or on-site training, contact Advance OHS or call (02) 9635 4444.
Source: Safe Work Australia, Model Code of Practice: Managing the Risks of Biological Hazards at Work; safeworkaustralia.gov.au. This article is general information only and does not constitute WHS or legal advice. Advance Consulting & Training Pty Ltd, RTO 91534.