November is when two things collide on a lot of our clients' sites. The pre-Christmas volume ramps up, so extra crews are brought in. And the first properly hot days arrive, in sheds that were never built to be cool. The people most likely to be caught out are the ones who started last week.
Heat isn't a niche hazard in warehousing. Safe Work Australia is blunt about it: working in heat can be hazardous, and if you are a person conducting a business or undertaking (a PCBU), you have a duty to keep workers and your workplace safe from those risks. That covers indoor workplaces as well as outdoor ones.
So what does that look like when the workers are on-hired? Here is how we think about it, and what we'd want settled before a crew starts.
Both of you owe the duty
With labour hire, the agency employs the worker and the host runs the site. Safe Work Australia's guidance says both are PCBUs, both are responsible for the worker's health and safety, and neither can contract out of or transfer those duties to the other.
In practice the split is usually sensible. The host controls the building, the dock doors, the fans, the break room and the roster, so the host is the one who can actually fix a hot shed. The agency controls who it sends, how it briefs them and how it checks in. The law asks both to cooperate and coordinate.
In Victoria the host goes further. WorkSafe Victoria says a host employer is taken to be the employer of the labour hire worker for OHS purposes, and owes them the same duties as any other employee. No contract can exclude either party from providing a safe place of work.
For heat, that means "the agency covers it" is not a plan, and neither is "it's their worker".
Think about the control hierarchy, not just a water jug
Safe Work Australia's managing-risks page sets out an order of preference. You aim to eliminate the hazard first (its example is cancelling outdoor work when temperatures are high). Then consider substitution, isolation and engineering controls such as shade tents and air conditioners. Administrative controls come after that, for example scheduling physically demanding work for the cooler parts of the day. Protective measures, such as light breathable clothing, come last.
For a warehouse or container yard, that translates roughly like this:
- Move the heavy work. Put manual unloading, picking from hot upper racks and outdoor work in the early part of the shift. WorkSafe Victoria's advice is to reschedule strenuous work to a cooler part of the day.
- Change the task. Use mechanical aids to reduce physical exertion, another control WorkSafe Victoria lists.
- Cool the space. Air conditioning and blinds where you have them, shade and rest spots outdoors.
- Give people somewhere cool to stop. WorkSafe Victoria calls for plenty of cold water and a cool place to take a break, plus extra rest breaks in a cool area when it's hot.
- Check the temperature, don't assume. WorkSafe Victoria says employers have a duty to monitor conditions in their own workplace, and recommends regularly monitoring the temperature.
It also flags indoor workers specifically, especially in spaces without air conditioning or ventilation, where heat can be retained for longer and exceed the temperature outside. That is a fair description of a lot of sheds and the inside of a container.
Why new starters are the weak point
None of the sources we've read set a one-size-fits-all rule for easing new people into hot work, so we won't invent one. What we can say from experience is that a brand-new person on a hot site has the least information of anyone: they don't know where the cold water is, who the first aid officer is, which areas run hottest, or whether it's normal to ask for a break.
That is where Safe Work Australia's labour hire guidance is useful. The host PCBU must make sure workers have adequate and accessible facilities and access to first aid equipment and trained first aid officers, and must keep an emergency plan in place. The agency has to check that the host is actually providing those things. So asking "where is the water and who is the first aider?" on a site visit isn't being fussy; it's the agency doing its job.
Workers need to know the warning signs too. WorkSafe Victoria's list includes nausea, vomiting, dizziness, weakness, pale skin, heavy sweating, headaches, convulsions and clumsiness. Its advice is that people should be educated to recognise heat-related illness in themselves and in others. Tell the new crew in the induction, not after the first hot afternoon.
A one-page heat plan to agree before day one
Before a crew starts in summer, we'd want the host and provider to settle:
- Trigger points. At what temperature, or what forecast, does the site change its roster or its tasks, and who makes the call?
- Start times. Can the heaviest tasks be scheduled early?
- Water, shade and a cool break area. Where they are, and who keeps them stocked.
- First aid. Named first aid officers on each shift, and confirmation the new crew knows who they are.
- Warning signs and what to do. Covered in the site induction, in plain language and in the languages your crew actually speaks.
- Who the worker tells. A named person on site and the agency contact, so a worker who feels unwell has someone to tell without worrying about their next shift.
- Who is checking. A named person doing a temperature check and a walk-around on hot days, plus a quick call from the agency to see how the crew is going.
That is not a lot of paper. It is mostly a conversation, and a good provider will start it.
Consultation counts too
The model WHS duties include consulting workers who are likely to be affected by a health and safety matter, and consulting, cooperating and coordinating with other duty holders. WorkSafe Victoria's advice for intense weather is to consult with workers and health and safety representatives and prepare a strategy tailored to your circumstances. If on-hired workers make up a large share of your floor in December, they belong in that conversation. Ask your provider how they collect feedback from their people on site.
Where this fits with the rest of your peak-season plan
Heat is one of several things that get squeezed in a rush. Our piece on safety duties for hosts covers the wider split of responsibilities, and unloading containers by hand goes into the container-specific side. If you're adding shifts, what that does to your rate is worth reading before the roster is locked in. You can also see how we crew these sites on our warehouse and distribution labour hire page.
This is general information, not legal advice. Your duties depend on your state, your site and the work being done, so check with your WHS regulator or get advice on your situation. If you'd like to talk through a heat plan for your site, get in touch.
General information only, current at the time of writing — not legal advice. Workplace and licensing laws change; confirm anything decision-critical with the relevant regulator or a qualified adviser.
