FAQs about High Risk Work

We are often asked questions about High Risk Work.  Here are some of our most frequent queries.  If you have a different question please feel free to contact TRANZnet.

Can an Assessor assess someone who does not reside in the same state?

An applicant must reside in the state to which they are making their HRW licence application (for new applications and renewals). If an applicant resides outside that state circumstances must exist to justify a licence being issued. Often, pre-approval of the regulator to assess must be obtained by the RTO prior to enrolling the applicant in training.

If the applicant does not live in the state or territory, the assessor must not conduct an assessment in that HRW licence class without approval from the regulator. The form of the approval may change from one jurisdiction to another.

RTOs should apply for approval prior to enrolling an applicant with an interstate address in the training course.

Note: an applicant must be able to provide at least one piece of acceptable EOI to show residency.

What is the time-frame for applicants to submit their Notice of Satisfactory Assessment (NSA)

An application that is submitted in excess of 60 days from the assessment date will be rejected.

RTOs and Assessors must advise all applicants to lodge their HRW licence application documents within 60 days of the date of assessment including:

The original proof of successful assessment form issued by the Assessor or RTO, and
An Application for a national licence to perform high risk work form, and
Original and acceptable evidence of identity (EOI) documents totalling at least 100 points, and
Colour, passport size photo, and
The prescribed application fee(s).
Applicants who do not lodge documents within 60 days of the assessment date must re-enrol with a RTO and undergo a full licence assessment - and usually pay an additional fee.

Medicare cards and many bank/credit cards list an applicant’s first name, middle initial only and WorkCover Position

Yes, a middle initial only is acceptable on these documents. If the customer has a middle name then this must be provided to the assessor and Australia Post on at least one form of identification. For example, the full middle name is usually listed on a drivers licence, passport or birth certificate.

My RTO would like to obtain a copy of the scaffolding diagrams to assist them to source equipment

Relates only to NSW

WorkCover Position:

Yes. Assessors may provide a copy of the diagrams in the scaffolding assessor version of the instruments (only) to their RTOs to allow them to source equipment. RTOs may also show these diagrams to an Engineer or other appropriate third party to validate requirements and safety of applicants. They must not however be provided to the applicant.

NSW. Do I have to request permission to assess a person whose licence expired under the No Photo

Condition 41 states “If the applicant has answered ‘Yes’ to question 4(b) on the CA1 form ‘Have you ever been issued with a NSA by an accredited assessor for an HRW licence class(es) to which the application applies?’ The assessor must not conduct an assessment in that HRW licence class without prior approval from 3PM. RTOs should apply for approval via thirdparty@workcover.nsw.gov.au prior to enrolling applicants in the HRW licence VET course (or UOC)”.

WorkCover Position:

Permission to assess is no longer required for old-style licences that expired prior to 31 December 2012 under the No Photo, No Valid Expiry, No Licence campaign, as these are unable to be renewed. However, if an applicant was issued an NSA within the last 5 years RTOs/Assessors must obtain permission to assess from the Third Party Management Unit, who will check whether a licence was issued and if so, if it is current. Additionally, as per Condition 42, if the applicant’s licence was suspended or cancelled, approval will also need to be obtained.

What Categories Require A High Risk Licence

Licence to Perform High Risk Work is a nationally recognised, regulator issued licence required for the following categories of high risk work:

Forklift and Orderpicker operation

Crane and Hoist operation

Scaffolding work

Rigging and Dogging

Pressure equipment operation

Who Requires a HRW Licence

A licence is required for any person performing work with high risk equipment or plant. The licence is valid in every Australian state and territory, enabling the holder to operate or work with high risk equipment under consistent standards anywhere in Australia.

All “Old Licences” issued up until mid 2007 have now expired, and anyone holding one of these licences cannot lawfully work in the high risk occupations. They must stop work in any high risk activity, and take immediate steps to get a licence under the new system or upgrade via their appropriate licence Regulator.

What does the new HRW system involve?

Licences are now issued by regulators under the WHS Regulations or the National Standard for Licensing Persons Performing High Risk Work to people in the applicable occupations. This is the consistent standard applied across Australia.

To be eligible for a licence, an operator must be trained. The training must be done via a Registered Training Organisation (RTO). To find an approved RTO search the TGA website at www.training.gov.au

The Regulations or National Standard set out :

the training and assessment requirements for a person performing high risk work, and
the arrangements for issuing a licence to a person performing high risk work.

Who does the High Risk Licensing rules apply to?

The WHS Regulations and National Standard apply to:

people performing high risk work, and
people who engage or employ others to perform high risk work, and
people or organisations responsible for training and assessment activities

What are the options for performing high risk work?

There are only two options. All persons performing high risk work must either;

1. hold (or applied for) a licence in accordance with the regulations of the jurisdiction where they work, or

2. be engaged in formal training with a Registered Training Organisation (RTO).

An employer or person conducting a business or undertaking (PCBU) must not direct or allow a worker to carry out high risk work unless they sight written evidence that the worker satisfies one of the above options.

Can a person train in the workplace, or must they go off-site to a training facility?

Training can take place in the workplace, at a training facility, or a mixture of both. Online training can also be used in conjunction with practical training in a "blended" program

A formal training program will be available at a training facility with the correct resources and accredited training personnel. Licence assessment can then be arranged via an approved assessor.
After entering into a training arrangement with an RTO and commencing formal training, a person can gain practical experience in a workplace under the supervision of a competent licence holder. These arrangements will vary from one RTO to another.
It is expected that a trainee will be working under a reasonable timetable with the aim of achieving a satisfactory assessment of competency, and applying for the relevant licence.
In some circumstances, it may be appropriate for a mixture of training arrangements as the best option. This is particularly the case for workplaces with limited resources, where the full range of training activities cannot be provided on-site.

Who can provide the training?

Training and Assessment for high risk work licensing can only be carried out by an approved and accredited RTO.

Accredited assessors conduct licence assessments on behalf of an RTO. The previously commonplace practice of providing informal training arrangements in workplaces is no longer legal.
Workplace training can still take place, but it must be under a formal training program.

Where can I find out what the expected level of achievement and knowledge is that needs to be gained

The required knowledge and expertise is set out in a Unit of Competency for each type of licence. This information is readily available on a government website at www.training.gov.au via use of their search engine.

The Unit of Competency is broken down into “elements” and tell us what is required to successfully meet each requirement. The full details and expectations should be clearly outlined by the RTO at the start of the training.

Can I arrange assessment directly with an assessor, and bypass the training organisation?

No. You may be able to get credit or recognition for experience you have gained in the workplace previously, but you will have to satisfy the assessor that you have achieved sufficient competence and experience to be able to successfully undertake the assessment. This is normally in the form of a training record (logbook) and formal RTO statement. You could also apply to undertake a process of Recognition of Prior Learning (RPL).

As a condition of their accreditation, licence assessors are not permitted to conduct an assessment for a HRW licence unless they sight evidence of formal training and supervised practical training or experience in some form acceptable to the RTO.

How old must I be to apply for the HRW licence?

You must be at least 18 years of age to apply. Training can be undertaken for persons younger than 18, under a formal arrangement with an RTO, and where supervision by a competent licensed person is part of the training program, but you cannot be assessed for the licence until you turn 18 years.

What about my old licence, which I was told was a “lifetime” licence?

Those licences or certificate have now expired, and a licence must be obtained to perform high risk work. Every licence must now be renewed every 5 years, and the holder must ensure they can demonstrate competence.

Is a licence required for a person loading or unloading high risk plant onto or from a transport

Yes, in some jurisdictions. There are a couple of differences across states and territories, so it is best to check with your Regulator. Persons who transport this plant across borders (and load/unload) would be prudent to make sure they hold the appropriate licence.

When don’t I need a licence?

Apart from those people in formal training or awaiting the issue of a licence after lodging an application, the following work does not require a HRW licence:

work carried out at a workplace solely for the manufacture, testing, trailing, installation, commissioning, maintenance, servicing, repair, alteration, demolition or disposal of the plant or moving the plant within the workplace, and the plant is operated or used without a load except when standard weight loads with predetermined fixing points are used for calibration of the plant, and work with a crane or hoist if the work is limited to setting up or dismantling the crane or hoist and the person holds the appropriate rigging licence (ie. a crane licence is not required), and work carried out with a heritage boiler.

Can a licence holder be instructed to perform high risk work in a manner other than under the Nat

This is a question best directed to the Regulator in each jurisdiction, but it is noted that penalties can apply to PCBU’s that encourage, induce or cause a licence holder to carry out high risk work in a manner other than the way the licence holder was taught.

Can a person with a licence continue to supervise those without a licence while doing high risk w

No, unless the trainee worker is enrolled in a formal training course through an RTO, leading to a HRW licence in that class of high risk work.

People who do not hold a HRW licence, or are not undergoing this training, are no longer able to do high risk work, even under the supervision of another licence holder.

Do I have to complete a Logbook while gaining practical experience?

The National Standard requires that a “record of training” is maintained, so that evidence can be provided to the assessor, or the assessment cannot go ahead. An easy way to record this information is in some form of a logbook, although other methods are equally suitable. There is specific information that needs to be recorded, and the formal arrangements may vary from one RTO to another.

How long must the training program be?

There are nominal times suggested for each type of high risk work licence, but every individual will achieve competency at a different rate and in a different way. Having practical experience with similar equipment will also affect the training time needed. The length of the training may vary from one person to another.

Training by RTO’s for HRW licences is monitored by the licence regulator and also by the relevant education department of each state and territory. Training programs are expected to focus on safety and competency, and to run over a reasonable period of time to achieve the required outcomes. RTO’s that do not provide training to the appropriate standard will be stopped from offering these services, and penalised.

When I am assessed as competent for a licence, can I then operate without any supervision?

This question requires a careful and considered response..

If you are assessed as competent you will no longer require direct supervision in the high risk tasks (unlike when under training) as long as you lodge documents within the 60 day limit and a Licence is issued to you.

If you fail to lodge your documents on time, you cannot carry out the tasks any longer, as you are not allowed to perform high risk work under a lapsed Notice. You will need to by re-assessed. (See other FAQs about this)

After you are Licensed the PCBU is still required to provide suitable supervision, instruction, information and training as appropriate to the tasks you perform, and your experience and level of proficiency.

What do I need to supply when I lodge the application for a HRW licence?

This is fully explained on the application form, and details should be provided by the RTO and assessor. If unsure, contact the licence regulator for further advice.

Typical requirements include;

100 points of ID
the Assessment Notice
passport photo
pay the fee
Sample signature

If I get another equipment licence, how will that affect my original licence expiry date?

The addition of new qualifications does not alter your original licence “start date”. It will still expire (become due for renewal) five years after the original issue date.

How do I apply for a high risk work licence?

Unfortunately, there is not a single answer to this question. Each state or territory Regulator has implemented their own system. You will have to ask your Regulator direct. Some variations are:

Lodge all paperwork with the RTO, and pay them the fee. They then forward on for processing and pay the fee to the Regulator.

RTO provides a formal Notice and a Tax Invoice, which is processed via a government service centre.

Lodge all paperwork and pay at an Australia Post outlet. They give a receipt and forward for processing.

Take all paperwork and lodge and pay at a government utility for processing.
Send the paperwork and the payment direct to the Regulator…..and so on.

What about licences for earthmoving equipment, small cranes, and other types of plant?

Some states and territories previously issued a licence for some or all of this equipment. The regulators stopped issuing these licences in 2012. The only plant licences now issued by the regulators are the HRW licences.

Regulations require employers and PCBU’s to ensure competency of the operator when plant is used, so far as is reasonably practicable – this is all part of the Duty of Care requirements.

Demonstration of competency may include a Statement of Attainment, Qualification Card, Certificate of Competency, or old regulator issued plant licence (Industry continues to refer to all of these as a “Licence” or “Plant Ticket” or similar terms). The regulators encourage formal competency based training and assessment for the operation of this equipment – this can only be provided by accredited and approved RTO’s through the vocational education and training system.

What is Verification of Competency (VOC)?

Regulations require employers and PCBU’s to ensure competency of the operator when plant is used, so far as is reasonably practicable.

Employers take their responsibilities very seriously, and are often requiring workers to demonstrate competency in the tasks they are to perform on the employers’ site. This also holds for contractors and their employees operating plant and conducting high risk work.

One method of satisfying this requirement is to require the operator to verify their ability to operate the vehicle or plant, or conduct the work in a safe and efficient manner – competently. Evidence may include records of assessment against the industry competency standards, refresher training, skills gap training, etc.

Verification of Competency is also often extended to the drivers of heavy vehicles and haul trucks.

Who should conduct VOC assessments?

Verification of Competency should be undertaken by trained professional assessors, with an understanding of the requirements of the industry competency standards in the national training packages.

It should be noted that holding a licence or a Qualification Card does not necessarily infer competency, but is a prerequisite to the conduct of a VOC. Persons who have recently received a licence, or received their “ticket” many years ago, may not be able to immediately verify their competency against the industry standard without some form of basic refresher training and assessment (an example of this may be demonstrating a sound knowledge of the current regulations governing the work they are required to undertake).