Do You Need a Licence to Operate an Elevated Work Platform in Victoria?

Do you need a licence to operate an elevated work platform in Victoria?

It depends entirely on the type of machine and the length of its boom — not on how it's being used or where. If your plant uses a boom-type EWP to reach racking, roof plant, overhead services or building maintenance work, this is one of the more commonly misunderstood high risk work rules in Victorian manufacturing, and it's worth getting straight before your next hire or induction.

The licence class: WP, and the 11-metre trigger

Under Victoria's high risk work licensing system, operating a boom-type elevating work platform with a boom length of 11 metres or more requires a WP class high risk work licence. This is a national threshold, not a Victorian quirk — Safe Work Australia's guidance on elevating work platforms confirms the same 11-metre trigger applies across the model WHS jurisdictions, and Victoria's licence classes mirror it even though Victoria operates under its own OHS Act 2004 rather than the model WHS Act.

Two things matter here: "boom-type" and "11 metres or more." Both conditions have to be met.

• A boom-type EWP is a platform mounted on an extending, articulating or telescoping arm — a cherry picker, knuckle boom or telescopic boom lift.
• If the boom is under 11 metres, no HRWL is required, even though the employer still has to make sure the operator is competent and properly trained under the general OHS Regulations duties.
• Scissor lifts are not boom-type EWPs at all, so they fall outside the WP licence class regardless of platform height. WorkSafe Victoria is explicit on this: its high risk work licence guidance states plainly that you don't need a high risk work licence to operate a scissor lift, in the same breath as excavators and other earthmoving equipment.

This trips people up because the risk profile of a large scissor lift can look similar to a boom lift. But the licensing regime is built around the equipment class defined in the national high risk work licence structure, not a generic risk assessment you run yourself. If you're not certain whether a specific hired unit is a "boom-type" machine for licensing purposes, ask the hire company for the manufacturer's classification before it goes on site — don't guess from the picture on the quote.

The legal basis: OHS Regulations 128 and 129

The licensing requirement sits in the Occupational Health and Safety Regulations 2017 (Vic), Part 3.6 — High Risk Work.

Regulation 128 is the operator-facing duty: a person must not perform high risk work — which includes operating a WP-class EWP — unless they hold the appropriate high risk work licence. This regulation is made under section 40(4) of the OHS Act 2004 (Vic), which is the enabling provision for Victoria's high risk work licensing scheme generally.

Regulation 129 is the employer-facing duty, and it's the one that actually creates exposure for a plant manager or director: an employer must not allow an employee to perform high risk work unless that employee holds the appropriate licence. This is a standalone offence, separate from anything that might happen if the equipment is then operated unsafely. Simply rostering an unlicensed worker onto a boom lift with an 11m+ boom is enough to breach reg 129, whether or not anything goes wrong.

The maximum penalties for a reg 129 breach are 100 penalty units for an individual and 500 penalty units for a body corporate. At the current Victorian penalty unit value of $209.10 (2026–27), that's a maximum exposure of roughly $20,910 for an individual and $104,550 for a company — before any consideration of a more serious prosecution if the unlicensed operation led to an actual incident.

What "employer must not allow" means in practice

Reg 129 doesn't just apply to your direct payroll. If you engage a labour hire worker, a contractor, or even a visiting maintenance technician to operate a boom-type EWP on your site, the duty to confirm they're licensed sits with whoever is directing that work — which in most manufacturing settings is you, as the site controller, not just the worker's own employer. Engaging someone else's employee doesn't transfer your duty to verify they're competent and licensed for the specific task.

In practice, that means before any boom-type EWP with an 11m+ boom goes into operation on your site:

1. Sight the physical licence card or check it digitally. WorkSafe Victoria licences can be verified through myWorkSafe. Don't rely on a verbal assurance or an expired photocopy in someone's induction file.
2. Confirm the licence class matches the machine. A WP licence covers boom-type EWPs; it doesn't substitute for a crane licence, a rigging ticket, or any other class.
3. Record the check. The same training and competency record-keeping discipline that applies to forklift operators applies here — a dated note of who checked the licence and when is what you want to be able to produce if WorkSafe ever asks.
4. Re-verify on renewal cycles, not just at induction. HRWL licences lapse, and a worker who was licensed six months ago isn't automatically still current.

Where this sits in your broader plant compliance picture

An 11m+ boom-type EWP is exactly the kind of equipment that also tends to show up on a factory's registrable plant list, depending on its design registration status, so it's worth checking both obligations at once rather than treating licensing and plant registration as separate projects. And because EWP work is, by definition, work at height, the licensing requirement sits on top of — not instead of — your existing fall-prevention and rescue planning for elevated work generally.

Practical next steps

If your site uses or hires boom-type EWPs, run this as a quick audit rather than waiting for a WorkSafe visit to surface a gap:

• Pull a list of every boom-type EWP used on site in the last 12 months, including hired-in units, and check the boom length against the 11m threshold.
• Cross-check every worker who has operated one of those machines against a current WP licence record.
• Fix your induction paperwork so licence sighting is a mandatory, dated step before any boom-type EWP over 11m is signed out — not an assumption based on who normally does that job.
• If you rely on labour hire or contractors for this work, confirm your host-employer verification process actually covers high risk work licences specifically, not just general site inductions.

None of this is complicated once it's set up. The risk is almost always in the gap between "we assumed someone checked" and an actual dated record — and that gap is precisely what reg 129 is written to catch.