Information, instruction, training and supervision in the sex industry
This guidance is for employers in the sex industry. It explains their duty to provide information, instruction, training and supervision. The guidance may also benefit employees and independent contractors.
Your sex work health and safety responsibilities
The Occupational Health and Safety Act 2004 is a law that helps keep workplaces safe. It's known as the OHS Act. The OHS Act places responsibilities on various people. They include employers, people who manage or control a workplace, self-employed people and employees. You will have different OHS Act responsibilities depending on your role. Find out about your role and workplace responsibilities.
A duty to provide information, instruction, training and supervision
The OHS Act places health and safety duties on employers and others. One duty requires employers to provide employees with:
As an employer, you have to meet a certain standard when fulfilling this duty. You must provide what is 'necessary' for employees to work safely and without risks to health. Under the OHS Act, your employees can include:
independent contractors you have engaged
employees of the independent contractors
What to provide
The degree of information, instruction, training and supervision that is necessary can vary. It will depend on the types of hazards in the workplace. It will also depend on how much employees already know about the risks and how to control them.
Information, instruction and training have to take into account employees' requirements. For example, skills or experience, disability, language, literacy and age.
A risk assessment will help you work out what is necessary.
You must provide supervision where supervision is necessary to work safely. This is particularly important for employees who are vulnerable. Vulnerable employees include, for example, sex workers who are:
from different cultural and language backgrounds
Again, a risk assessment will help you work out what supervision is necessary.
The induction of new workers should include details about the workplace. This includes details about the information, instruction, training and supervision provided. Ensure there are opportunities to ask questions, including after the induction period.
Examples of what to include
The information, instruction and training you provide should include, for example:
policies and procedures for your workplace
details about the workplace, including emergency exits and equipment and workplace practices
the risk management process
designated work groups, also called DWGs
health and safety representatives, also known as HSRs
how to deal with workplace emergencies, including violent or abusive customers or employees
information about identifying sexual and physical assaults and how to report them
information about sex worker exploitation, including how to identify and report it
the processes in place to deal with customers who refuse to pay or to adhere to agreed services
the procedures for an emergency evacuation
potential hazards in the workplace, including how to identify them and how to assess and control risks
safer sex practises
how to deal with exposure to blood and body substances
how to prevent hazardous manual handling
safe techniques for massage
how to provide safe bondage, discipline, sadism and masochism (BDSM) services
how to use, clean and maintain equipment
how to report a problem or maintenance issue and who to report it to
the procedures in place to protect sex workers' privacy
the procedures in place to prevent employees being stalked and harassed
information about customer coercion
This is not a complete list. What you provide will depend on the hazards in your workplace.
You might engage staff members to provide information, instruction, training and supervision. In this case, ensure those people have necessary skills and experience. Also ensure they are familiar with the business’s policies and procedures.
Review your instruction and training programs regularly. Also review them when:
there is change to work processes or equipment
there is an incident
new control measures are introduced
an HSR requests a review
relevant legislation changes
any other issues affect the way the work is done
Keep records of employee inductions and training. Provide regular refresher training, at least every 12 months.
WorkSafe Advisory Service
WorkSafe's advisory service is available between 7:30am and 6:30pm Monday to Friday. If you need more support, you can also contact WorkSafe using the Translating and Interpreting Service (TIS National) or the National Relay Service.