Contractor Inductions: What a Victorian Manufacturer Is Responsible For

Taylor Scott, Victorian safety practitioner, Ardmor Operations — Last updated 1 August 2026·4 min read

Does the OHS Act 2004 actually cover contractors on your site?

Yes — under section 21 of the OHS Act 2004 (Vic), your duty to keep people safe extends to contractors working in your factory, not just your own employees. Subsection 21(3) makes you responsible for a contractor and their employees on matters you control, and a breach carries penalties up to 9,000 penalty units for a company.

Separately, sections 23 and 24 require employers and the self-employed to make sure people who aren't employees — visitors, delivery drivers, a contractor's site guests — aren't exposed to health and safety risks arising from your operation, so far as is reasonably practicable.

What must a contractor induction actually cover?

Section 21(2)(e) requires employers to give the information, instruction, training or supervision needed for people to work safely. For a contractor stepping onto your floor, that duty is usually met with a short, site-specific induction covering:

Site-specific hazards — machinery exclusion zones, forklift and pedestrian travel paths, noise, dust or chemical areas particular to your site.
Emergency procedures — evacuation routes, the assembly point, and who to contact if something goes wrong.
PPE requirements — what's mandatory in which zones, and where to get it if the contractor hasn't brought their own.
Permits and isolations — whether the job needs a permit to work, a lockout/tagout, or a hot works permit before tools come out.
Reporting line — who the contractor reports to on-site, and how to report a hazard or near miss while they're there.
Sign-off — a dated record that the induction happened, signed by both parties.

Scale this to the risk, not the clock. A ten-minute briefing on hazards, emergencies and PPE is enough for most short jobs; a longer contract or higher-risk task — hot work, confined space, work near live plant — warrants more.

Contractor or labour hire worker — does it change your duties?

It does, and the distinction matters. Since 22 March 2022, changes to the OHS Act mean labour hire workers are treated as employees of the host employer for OHS purposes — so you owe them the full range of employer duties, not just the narrower contractor duty.

Worker type	Scope of your duty	Relevant sections
Direct employee	Full employer duty	s.21, s.22
Independent contractor (and their employees)	Matters you have or should have control over	s.21(3)
Labour hire worker (as host employer, from 22 March 2022)	Full employer duty, same as a direct employee	s.21, s.22, s.23, s.26, s.35, s.35A

For an independent contractor engaged directly — not through a labour hire agency — your duty is narrower: it's limited to matters within your control under section 21(3), and the contractor keeps their own separate duties as an employer to their own staff. For a labour hire arrangement, you and the labour hire provider also now have a duty to consult, cooperate and coordinate with each other under section 35A.

What happens if you skip the induction and something goes wrong?

If a contractor is hurt doing work you control and you didn't provide the site information, instruction or supervision needed to do it safely, that's the same section 21 exposure as failing an employee — plus a section 23/24 exposure if anyone else on site is affected. In practice, an inspector reviewing an incident involving a contractor asks for the induction record first. No record makes it hard to demonstrate you met the "reasonably practicable" standard, regardless of how the job actually went.

What should you keep on file to prove it happened?

Keep it simple and consistent:

A signed induction record — contractor name, company, date, site, and who delivered it.
A checklist of what was covered (hazards, emergency procedures, PPE, permits).
Copies of any site-specific documents handed over, such as an SDS or a permit.
A review date, so the induction content gets checked when your site or process changes.

If you'd rather not chase down every contractor's induction record by hand, Ardmor runs practical, on-site safety assessments for Victorian manufacturers — including a look at how audit-ready your contractor records really are.

FAQ

Do I need to induct every contractor, even for a two-hour job? Yes. The duty in section 21 of the OHS Act 2004 (Vic) has no minimum time threshold — it applies to independent contractors and their employees for any matters you control, whether they're on site for two hours or two months. Scale the induction to the risk: a short briefing on hazards, emergency procedures and PPE satisfies the duty for most short jobs.

Is a labour hire worker the same as a contractor for induction purposes? No. Since 22 March 2022, labour hire workers are treated as your employees for OHS purposes, so you owe them the full range of employer duties — not just the narrower section 21(3) duty that applies to independent contractors. Induct both, but keep the fuller employer-duty records (health monitoring, information, consultation) for labour hire workers.

Who is responsible if a contractor's own employee gets injured on my site? You share responsibility for matters within your control. Section 21(3) extends your duty to a contractor's employees for things like site conditions, plant you supply and systems of work you set — but the contractor keeps their own duties as an employer to their own staff. Both duties can apply at once, which is why clear inductions and agreed responsibilities matter before work starts, not after an incident.

This article is general information for Victorian manufacturers, not legal advice. Last updated: 31 July 2026.