Importing and supplying plant

Background

This guidance is for anyone who imports and supplies plant for use in Victoria. In this guidance, the term supplier includes workplaces that source plant from manufacturers outside Victoria that ‘import’ it into Victoria.

As a person who supplies plant, you can help reduce health and safety risks caused by the plant you import.

This guidance aims to help you:

• identify hazards
• eliminate or reduce risks
• meet your occupational health and safety obligations.

Definition of plant

The term plant is defined in the Occupational Health and Safety Act 2004 (OHS Act) and Occupational Health and Safety Regulations 2017 (OHS Regulations).

You can learn more on the Plant: Safety basics page. 

Persons considered suppliers

You’re considered a supplier if you‘re part of the distribution chain of goods from the manufacturer to the user. This includes importers.

‘Supply’ when referring to goods, can include:

• sale
• exchange
• lease
• hire
• hire-purchase.

The risk management process

The plant you supply can have an impact on your workplace and the workplaces that use your plant.

You have a duty under the legislation to provide safe plant as a supplier.

The plant you import may be designed and manufactured to international standards. Sometimes the manufacturer may not sufficiently eliminate or reduce the risks associated with the plant you’re supplied with.

This means you have to identify the hazards and control the risks, so far as is reasonably practicable.

‘Reasonably practicable’ is a legal concept and a requirement under the OHS Act and the OHS Regulations. Simply, it means doing what a reasonable person in the same position would do.

You may need to create additional risk controls. The easiest way is to let your manufacturer know what specific risk controls you need before plant is shipped.

As the importer, you decide on the factory specification. Safety features and risk control measures should be included. These should not be considered ‘optional extras’.

You should also confirm that any information the manufacturer gives you about the plant is appropriate.

Identify hazards

As a supplier of plant, you must identify hazards.

The plant you import will have different hazards to people at different stages of its use. This includes during:

• transport
• assembly, installation and commission
• setting, teaching, programming and/or process change over
• operation
• cleaning and maintenance
• fault-finding and troubleshooting
• dismantling, disabling and recycling or disposal.

You should consider the different sources of hazards associated with the plant you supply. Hazards can be:

• mechanical
• electrical
• thermal
• noise and vibration
• radiation
• material
• ergonomic
• environmental.

You can find more information on the general principles of risk assessment and reduction in the Australian and New Zealand Standard AS/NZS 4024.1201.

You can also identify, manage and eliminate risks by using our plant hazard checklist.

Assess risks

If you’ve identified one or more hazards, you’ll need to assess the associated risks. You don’t have to do a formal risk assessment if there is already information about the risk and how to control it.

Control risks

After you’ve identified risks, you need to put measures in place to control them.

If the risk can’t be eliminated, then you need to apply the hierarchy of risk controls for plant as shown in the following image.

Before implementing administrative controls or personal protective equipment (PPE), you must first substitute, isolate and / or implement engineering controls.

You can find out more on the hierarchy of control webpage.

Your duties as a supplier

Here are some things you must do to control the risks associated with importing and supplying plant.

Plant specifications

As the supplier, you decide on the factory specification of plant that arrives in Victoria. Make sure that any available and suitable risk-reducing features are included. Safety devices that control risk to health and safety can’t be optional extras. If they’re available and eliminate or reduce a risk, they must be included as standard features or equipment.

If the manufacturer doesn’t let you add the required risk controls to the factory specifications, then either:

• the plant should not be supplied
• implement your own by hiring a competent person to do this.

You can develop, source and implement your own controls before you supply it to any workplaces.

Implementing appropriate risk controls means that the risks associated with the plant are reduced.

Provision of information

You should have adequate information about the plant that you supply. You should give this information to the workplaces you supply plant to. This is to make sure the duty holders can manage any health and safety risks. You should review the information you receive from the manufacturer.

The documentation should include information about:

• safe use
• maintenance
• repair
• inspection
• cleaning.

There should be information for each different model of plant you supply. The information can also confirm if the risks associated with the plant have been controlled. This can be a service or operation manual.

Providing training

You, your agents and customers must provide appropriate training to employees. They should know how to use, maintain, clean and repair the plant safely.

The information you receive from the manufacturer or their representative should be enough for you to train staff yourself. Otherwise, you can ask your manufacturer to train your staff on the safe use of the plant. This can be either in-house or through an external training provider.

If the manufacturer can’t do either, you can hire someone to evaluate the plant. They should have knowledge of the plant and prepare appropriate information and training for all.

Design registration

Certain plant must be registered before it can be used in workplaces. You can find a list on the plant equipment design and registration page.

If the design has been registered, it will have a design registration number. If not, you as the supplier may need to register the plant design.

More information

WorkSafe also has industry standards and guidance for specific types of plants.