Safety for a Small Manufacturer With No Safety Manager: Start Here

Do you still have safety duties if there's no safety manager?

Yes — the OHS Act 2004 places duties directly on the employer, not on a job title, so a business with no dedicated safety manager has exactly the same legal duties as one that does (WorkSafe Victoria). The good news is you don't need to build a compliance department to meet them — you need a handful of things done properly and consistently, and to know where to get help for the rest.

Where do you actually start?

If nobody has looked at safety systematically before, start with what's most likely to hurt someone, not with paperwork. Walk the floor, ask your longest-serving workers where the near misses and awkward tasks are, and write down what you find. That single walk-through will usually surface most of your real risks faster than any generic checklist.

What free help is available?

WorkSafe Victoria funds a free program specifically for businesses in this position. The OHS Essentials program pairs eligible employers — Victorian businesses with 60 workers or fewer and a WorkCover insurance policy — with an independent OHS consultant who visits the workplace, identifies hazards, and helps build a practical safety action plan over three sessions across 12 months (WorkSafe Victoria). The consultations are confidential and the advice is tailored to your business, not a generic template.

What should you get right first?

1. A basic induction for every new starter — what the hazards are, what's expected of them, and where to raise a concern.
2. A way to record incidents and near misses, even a simple form, so patterns are visible before someone gets hurt.
3. Consultation with your workers — the OHS Act requires employers to consult employees on matters affecting their health and safety, and if there's a health and safety representative, they must be involved (WorkSafe Victoria). In a small business, this can be as simple as a regular five-minute conversation, documented.
4. Records of training and licences — who's been shown how to do what, and whether any licensed work, like forklift operation, is being done on a current ticket.
5. A working relationship with someone who knows the regulations — whether that's a consultant through OHS Essentials, an industry association, or an ongoing safety practitioner.

When do you need outside help?

A free consultation is a genuinely good starting point, but it's a fixed-term program, not an ongoing service — once your three sessions and 12 months are done, the responsibility for keeping the system current sits back with you. If your risk profile is higher, such as machinery, chemicals, or manual handling-heavy work, or you'd rather have someone accountable for keeping your systems current year-round, that's the point at which a managed safety arrangement, or at minimum a proper independent site assessment, tends to be worth the cost. You can book a site assessment if you'd like a clear picture of where your business actually stands.

FAQ

Am I breaking the law if I don't have a safety manager? No — there's no requirement to employ a dedicated safety manager. The OHS Act requires the employer to meet certain duties, such as a safe workplace, training and consultation; how you resource that is up to you, as long as it's actually happening.

Is the OHS Essentials program really free? Yes, for eligible Victorian employers with 60 workers or fewer and a WorkCover insurance policy — it's funded by WorkSafe Victoria and delivered by independent, confidential OHS consultants at no cost to the business.

What's the single biggest mistake small manufacturers make with safety? Treating it as a one-off task rather than an ongoing habit — doing an induction once, writing a policy once, and then not revisiting it as the business, equipment or workforce changes.

This article is general information for Victorian manufacturers, not legal advice. Last updated: 10 August 2026.