Prepare a safety case outline

Information for operators of a major hazard facility (MHF) on how to prepare a safety case outline within 90 days of being registered by WorkSafe.


What is a safety case outline

A safety case outline is a formal part of the planning process for the initial preparation of a safety case. It documents your plan for developing the safety case and is submitted and reviewed by WorkSafe as part of the registration process for new major hazard facilities.

The safety case is a comprehensive suite of documents that demonstrates how to effectively manage health and safety at your facility.

The objectives of the safety case outline are to ensure that operators:

  • understand the legal duties that apply to major hazard facilities under the Occupational Health and Safety Regulations 2017 (OHS Regulations)
  • understand the requirements for a safety case, and
  • will ensure that the work to produce the safety case is sufficiently planned and resourced so it can be delivered within 24 months of registering with WorkSafe your intention to operate a major hazard facility

Submission timeline

How WorkSafe evaluates a safety case outline

When reviewing an operator's safety case outline, WorkSafe expects that:

  • the operator's safety philosophy is reflected in the outline
  • the tasks required for preparing the safety case have been systematically identified
  • tasks have milestones and deliverables
  • there is a timetable for the sequence of tasks that demonstrates the operator’s understanding of the interactions and links between the tasks
  • adequate and appropriate resources have been allocated to each task
  • the balance between internal and external resources is appropriate to the operator’s ownership of the safety case
  • the outline will result in a safety case that is robust, satisfies legal requirements and will be delivered in a timely manner
  • methodologies for safety assessments and other tasks are suitable for the specific facility and are compatible with the operator’s safety philosophy
  • the basis for 'demonstration of adequacy', including risk criteria, is suitable for the specific facility and is compatible with the operator's safety philosophy
  • requirements and robust processes have been identified and established for consultation with, stakeholders, including health and safety representatives (HSRs), employees, emergency services, municipal councils and other MHFs as necessary
  • the outline explains how the results of consultation will be used in the safety case
  • milestones are built into the development phase of the safety case to allow for monitoring of progress against the plan

Additionally, when assessing the application for an MHF licence, WorkSafe has to be satisfied that the operator meets the following requirements:

  1. The safety case has been prepared in accordance with Division 8 of part 5.2 of the OHS Regulations.
  2. The applicant has complied with the safety duties of an operator under Divisions 6 and 9 of Part 5.2 of the OHS Regulations.

WorkSafe will work with the operator if the safety case outline needs to be changed to meet regulatory requirements related to the safety case.

What to include in a safety case outline

For the purposes of the outline, you do not need to develop the content for your full safety case; however you should explain how you will do so, including the human and financial resources that will be allocated to ensure you meet the submission deadline for the full safety case.  As per regulation 367, the safety case outline must include specific reference to each of the matters required by regulation 385, details of the scope of consultation that will be undertaken in preparation of the safety case, and a draft of the emergency plan you propose to include in the safety case.

We recommend that you contact WorkSafe before you start work on your safety case outline so we can guide you through the process. Contact the Major Hazards Program through WorkSafe Advisory.

Tips for developing a safety case outline

Getting safety case planning right

It is important that operators get their planning right when preparing the safety case outline. The safety case outline should provide a statement by the operator as to the current degree of compliance with the Part 5.2 (Major hazard facilities) of the OHS Regulations, for example through a gap analysis. It should also provide a statement of intent and a timetable for achieving full compliance.

A registered MHF must comply 'so far as is reasonably practicable' with the safety, consultative and property protection duties under Part 5.2 of the OHS regulations. The initial gap analysis, or equivalent, will show the areas where there is already compliance and where there is partial or non-compliance. Where the gap analysis shows full compliance, an operator cannot claim later that it is impracticable to achieve compliance in these areas. An operator should not overstate or understate the current degree of compliance in the safety case outline.

In areas where there is not yet full compliance, the safety case outline should have milestone dates for when full compliance will be achieved for each item. WorkSafe will then consider compliance by that date (and thereafter) to be reasonably practicable.

The outline should be accurate and the plan achievable by the deadline. If WorkSafe is of the opinion that it would not produce a safety case compliant with the OHS Regulations, the operator may be required to make amendments.

Once the operator submits the safety case outline to WorkSafe, milestones become obligations upon the operator. To amend these milestones, the operator would need to explain to WorkSafe why a milestone cannot be reached, the implications of this to the entire process and the steps being taken to rectify the situation. However, WorkSafe recognises that it may not be possible to get the safety case outline completely right at the first attempt and that, in practice, some methods may prove unsuitable or tasks may take longer than expected.

Following submission of a safety case outline, WorkSafe will review in detail the implementation of the safety case. If an operator cannot meet the milestones stated in their safety case outline, then it is unlikely that their operations will withstand scrutiny during this review, and notices or other enforcement action may result. You must complete and submit your safety case within 24 months of when you registered with WorkSafe your intention to operate a major hazard facility.

WorkSafe will be available to assist operators during the 90 day period when the safety case outline must be prepared. Operators should also consult with employees and other groups during this period to obtain site-specific guidance on developing their safety case outline and safety case. By seeking and incorporating such guidance, operators will be better prepared for the development of the safety case.

Scope of work

The scope of the work required to develop the safety case may be determined by a gap analysis or similar process. The gap analysis should compare the requirements of the relevant regulations with current practices at the facility, as well as what is required to be consistent with the safety case philosophy.

The list of tasks resulting from that process will be an initial list for completion during the safety case. The tasks may include work on hazard identification, safety assessment, emergency planning, identification and assessment of control measures.

When reviewing the existing status of safety management and related documentation, it is important to consider the detail, and not simply the existence, of management processes and safety documentation to ensure it fully meets requirements. Management processes, operational procedures and safety studies may all need to be revised or re-done to fully satisfy the requirements of the OHS Regulations. There are varied requirements for consulting and informing others about the safety case. The process of developing the safety case requires input from stakeholders, and the nature of this involvement should be set out in the safety case outline.

The work required is likely to extend beyond assessment and documentation as described above. Deficiencies in safety management and safety engineering may be identified and require corrective action before WorkSafe can grant a licence. As the nature and detail of these deficiencies would not be fully known at the planning stage and during preparation of the outline, contingency should be allowed to complete any corrective actions.


Once the scope has been determined, the required resources can be defined. The resources would be mostly employees, and the number, skills and competencies of these should be defined at an early stage and linked to each task in which they will be involved.

Depending on the magnitude and variety of the work, it may be necessary to have a core team supplemented by specialists as required. Depending on the size of the operator's organisation, assigned personnel may be full time or part time in that core team. It will be necessary to describe the roles of any external resources that will be used during the development of the safety case. WorkSafe expects an appropriate balance between internal and external resources as this will help ensure facility ownership of the safety case.

The operator should ensure that resourcing of the safety case is robust. At a minimum, resourcing should make allowance for other duties, leave, and any other reasonably foreseeable conflicting demands on the time of the assigned personnel. As well as personnel, there may be a need for other resources, such as technical information or computer software, which need to be sourced in a timely manner.

It is important to ensure senior management understand the safety case plan and required work, the timing and resource commitment required.

Coordinated safety cases

When events on one site may create or influence risks on neighbouring or connected sites, WorkSafe may require coordinated safety cases (refer to the guidance note 'Coordination between major hazard facilities'). Operators are informed of this requirement when their facility is registered. Coordination will add complexity to the process of developing a safety case and this should be reflected in the safety case outline. Planning for a coordinated safety case requires consultation with neighbouring or connected MHFs as well as WorkSafe.

Demonstration of adequacy

In preparing their safety case outline, an operator should consider what would constitute suitable 'demonstrations' for their facility and what activities will be required to support this (for more information refer to the guidance note 'Requirements for demonstration').

'Demonstration' requires sufficient information to show that:

  • control measures are adequate, and that the SMS required under regulation 372 of the OHS Regulations provides a comprehensive and integrated system for managing the control measures
  • there are links between major incidents, hazards and control measures

Demonstration has been found to be more straightforward when decisions and assumptions made in planning are carried through to safety case development and when linkages are built up and documented over the safety case development period, rather than tied together at the end. Hence, decisions and assumptions made in the planning stages will carry through to safety case development.

Size of the safety case outline

WorkSafe expects the safety case outline to be typically between 12 and 20 pages long, not including any detailed reports used in support (eg the report from a gap analysis, the draft emergency plan).

Continual improvement

The safety case should demonstrate that the operator has established a process for maintenance and improvement of the safety case and SMS. WorkSafe will test this 'improvement process' following submission of the safety case. Therefore, the safety case outline should describe how this process will be developed and implemented, and how it will reflect the operator's safety case philosophy.

Changes required by WorkSafe

WorkSafe may require amendments to the safety case outline if it is of the opinion that it is not fit for purpose. Amendments may include altering timeframes or inclusion of missing information. Before WorkSafe can require an amendment, they must first provide written notice to the operator informing them of the proposed amendments and consider any submissions made by the operator.

Changes requested by the operator

There are circumstances under which the operator may wish to alter the safety case outline, for example if the original approach proves ineffective or if the operator decides to alter the facility. The operator should discuss these cases with WorkSafe, and must provide WorkSafe with a copy of the amended outline as reasonably possible after the amendments are made.

Review and revision

The safety case outline does not have to be reviewed and revised before licence renewal. However, preparing a similar plan may assist MHF operators when they review and revise their safety case for licence renewal.

Compliance checklist

The following checklist lists the main requirements under the OHS Regulations relating to safety case outlines.

Modifying the facility while registered as an MHF

The operator of a registered MHF may wish to modify the facility before the safety case is due. Such changes may impact on the development of the safety case and changes may be required to the safety case outline.

For more information about the management of change under the MHF regulations and the DGS&H Regulations, see the guidance note 'Management of change at a major hazard facility'.

For information about the revision of existing safety cases, see the guidance note 'Revision of a safety case for a major hazard facility'.

More information