Labelling packages

This guidance may help employers reduce risks to employees whose work involves repetitive manual labelling of packages in the food manufacturing industry.


Use solutions with the least risk

There are many types of repetitive manual labelling techniques used in the food manufacturing industry. They often involve poor wrist and forearm postures and movements, and high hand forces.

The following solutions can help employers control risks to employees labelling packages. These solutions may help eliminate or reduce the risk of employees developing a musculoskeletal disorder (MSD).

Solutions are listed in order, from those considered most effective to those considered less effective.

Employers should make sure employees use the handling solutions with the least risk, so far as reasonably practicable.

Solutions with reduced risks are an alternative only if least-risk methods are not reasonably practicable.

Employers should start implementing risk controls for the heaviest or highest-volume products first.

The following guidance also describes high-risk actions that can cause an MSD. Employers have a duty to eliminate or reduce the risk of MSDs and should make sure employees do not perform high-risk actions.


So far as reasonably practicable, employers must consult with employees and any health and safety representatives (HSRs) when identifying hazards and providing risk control measures. Consultation should include discussions about how employees will label packages, making sure that risk control measures do not create new hazards. WorkSafe has guidance on consultation, including consultation with HSRs.

Labelling packages

High-risk actions that can cause an MSD

  • Twisting or turning actions with the hands or arms, exerting force with one hand or one side of the body, awkward wrist postures and holding or supporting a tool:
    • more than twice per minute or
    • for more than 30 seconds at a time

    for more than 30 minutes continuously or more than 2 hours over the whole shift. These actions may occur in the situations listed or in combination with other work activities.

Potential sources of risk

  • Holding the labelling gun.
  • Position where label is applied on the box.
  • Position of product delivered to the labelling station.

Handling solutions

Preferred solution with the least risk

  • Provide pre-labelled cartons and packages or use an automatic printer that can print barcodes.

A machine which automatically prints labels
Automated labelling process.

Solutions with a reduced risk

  • Provide labelling guns designed to reduce force required on the trigger and use a counterbalance.
  • Label the carton prior to assembly.
  • Ensure that the package is labelled at a height and position to keep wrist and forearms as neutral as possible.
  • Provide product at the labelling station in the easiest orientation for labelling.
  • Introduce appropriately designed job rotation, in combination with other risk controls that improve postures and movements.

    Note: Job rotation does not eliminate manual handling hazards. WorkSafe has guidance to help eliminate or reduce the health and safety risks associated with job rotation.

Your legal duties


The Occupational Health and Safety Act 2004 (OHS Act) requires employers to provide and maintain a working environment that is safe and without risks to health, so far as reasonably practicable. An employer contravenes this duty if they fail to:

  • provide or maintain plant or systems of work that are, so far as reasonably practicable, safe and without risks to health
  • make arrangements for ensuring, so far as reasonably practicable, safety and the absence of risks to health in connection with the use, handling, storage or transport of plant or substances
  • maintain, so far as is reasonably practicable, each workplace under the employer's management and control in a condition that is safe and without risks to health
  • provide, so far as is reasonably practicable, adequate facilities for the welfare of employees at any workplace under the management and control of the employer
  • provide information, instruction, training or supervision to employees of the employer as is necessary to enable those employees to perform their work in a way that is safe and without risks to health

Employers also have an obligation to consult, so far as is reasonably practicable, with employees and any HSRs on matters related to health and safety that directly affect them, or that are likely to directly affect them. This duty to consult also extends to independent contractors, including employees of the independent contractor, engaged by the employer in relation to matters over which the employer has control.


While at work, employees also have duties under the OHS Act to take reasonable care for their own health and safety and the health and safety of others who may be affected by their acts or omissions in the workplace. Employees must also co-operate with their employer's actions to make the workplace safe and comply with the OHS Act and Regulations.

The WorkSafe website has guidance about the occupational health and safety (OHS) responsibilities of employers and employees.

Related pages

This information is from 'Manual handling in the food manufacturing industry: A guide for employers'. The complete guide is available in two formats.

Website version PDF version