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Health and safety in education: When paperwork alone doesn’t control risk

How Australian educational institutions can move beyond just paperwork to control health and safety risks, improve contractor oversight, and strengthen risk assurance.

Australian school sites bring together more people, in more varied roles, than almost any other workplace. On any given day, staff, students, volunteers, contractors, parents and visitors share the same spaces, often while maintenance, deliveries, events and learning activities run in parallel, supported by everyday plant and equipment.

This complexity creates a risk profile that is easy to underestimate. Education environments may lack the visible hazards of construction or heavy industry, but they are not low risk. Under Australian work health and safety (WHS) law, the definition of a worker extends to volunteers, contractors and work-experience students. The duty of care extends further still, to students, visitors and the public.

For those charged with governing these risks, the central question is not whether these obligations exist. It is whether the controls intended to manage risk are clear, practical and consistently applied and whether leaders can verify those controls.

Where the complexity lives

The concerns school leaders raise before anything goes wrong are often more revealing than incident registers. Across the education sector, the same themes appear repeatedly: plant and equipment, contractor and volunteer management, and work taking place in live environments.

These issues cut across multiple sites, users and changing conditions. Plant and equipment (including everyday assets like grounds-keeping machinery, kitchen equipment, workshop tools), and contractor and volunteer management, consistently generate the most uncertainty. Who owns the equipment a contractor brings on site? Who is responsible for its maintenance and guarding? Who supervises a volunteer using school-owned machinery? Who has authority to stop unsafe work?

These are not niche operational questions. They are recurring leadership and governance challenges. When local controls are unclear or inconsistently applied, even routine activities can escalate quickly.

Information of this kind is valuable because it acts as a leading indicator. It shows where uncertainty and governance pressure are concentrated before harm occurs, not simply which incidents have already happened. Boards and executives can use these insights to direct assurance efforts. Organisations that can present a forward-looking risk profile to insurers and regulators are in a materially stronger position than those relying on incident history alone.

A similar shift is occurring with psychosocial risk. Psychosocial hazard is now regulated across every Australian state and territory, with jurisdiction-specific regulations, codes and guidance. National claims data shows work-related violence, aggression and mental stress rising steadily. These risks are harder to see, but the same discipline applies: identify the hazards, assess the risk of harm, implement controls and verify that those controls are working.

Control of interfaces

The common thread across these recurring issues is not paperwork. It is control of interfaces, the points where third-party work, plant and everyday school activity meet.

Contractors and volunteers routinely work in live environments with children, staff and visitors nearby. Risk increases when roles, supervision and work boundaries are assumed rather than defined. The biggest exposures often come from ordinary tasks in shared spaces. The issue is rarely a lack of intent; it is inconsistent control at the point of work, where a gap in coordination can quickly lead to injury or health-related harm.

Under the model WHS framework, engaging a contractor does not transfer responsibility. Safe Work Australia is clear that a duty cannot be contracted out. Each party retains responsibility to the extent of its capacity to influence and control the work, and all parties must consult, cooperate and coordinate their activities.

When paperwork alone does not equal control

Consider a scenario drawn from a real education client. At 9:10 am on a wet Thursday morning, a cherry picker is parked beneath a school roofline so contractors can complete repairs. Overhead, live power lines arc close to the basket. The working-at-heights permit is in the site folder, half completed, technical and full of jargon. The principal reviews it and is unable to tell whether the controls are adequate. No one is injured that day.

This near miss exposes the gap that concerns leaders, business managers and parents alike. Paperwork existed but did not translate into practical control. A leader was asked to sign off on risk they could not confidently interpret, and contractor activity proceeded in a live environment with little margin for error.

It also shows how quickly a near miss could become an injury, a parent complaint, an insurance claim, adverse media coverage and a regulator notification.

WHS regulators can attend any site without notice. While documentation is reviewed, their focus is typically on whether leaders understand the controls, whether those controls have been implemented properly, and whether they are being verified in practice. Certified systems and comprehensive filing alone do not demonstrate due diligence.

What good looks like

Strong contractor and plant and equipment management does not require complexity. It requires a small number of disciplines, applied consistently:

Make high-risk work visible. Know when contractor, plant, electrical or work-at-height activities are happening and manage live environments differently from vacant sites.
Clarify who is in control. The site leader, contractor and responsible manager should each know their role, and the authority to stop work should be clear before work begins.
Convert paperwork into usable controls. Permits should be understandable, complete and verified, with critical controls visible at the point of work. A one-page permit that a principal or business manager can genuinely interpret is worth more than fifty pages of jargon.
Separate people from hazards. Students, staff, volunteers and visitors should not be exposed to avoidable interface risk. Timing, access control and barricading should be deliberate decisions, not afterthoughts.
Evidence assurance. Leaders should be able to show maintenance, inductions, isolations, supervision and close-out, with oversight focused on control effectiveness rather than document volume.

Questions for leadership

Schools should not wait for an incident to test their systems. Hazard data, near misses and routine work activities can all be used to test whether critical controls are understood and applied in practice.

The following questions help education leaders test their level of assurance:

Where could routine contractor work create serious harm in a live environment?
Which plant and equipment risks would concern us most if controls failed today?
Can principals, business managers and site leaders recognise whether critical controls are adequate?
Are we relying on paperwork, or verifying controls where the work happens?
If a regulator asked tomorrow, could we show clear evidence of due diligence?

The best-performing organisations are not those with the most paperwork. They are the ones that can show their critical risks are understood, controlled and governed. That capability supports fewer near misses and injuries, stronger regulatory readiness, more consistent safety practice across sites and faster, better-informed decisions on contractor engagement and high-risk work.

In practice, this typically involves centralised contractor governance and evidence management, site-specific induction and risk communication, review and verification of safe work method statements and permits to work, targeted oversight of higher-risk works and complex interfaces, and executive reporting that provides assurance rather than activity metrics.

How Marsh can help

Marsh works with Australian educational institutions to strengthen health and safety risk management, governance and regulatory readiness. Our education specialists combine deep sector knowledge with broader risk, insurance and advisory capability to help leaders identify priority exposures, strengthen critical controls and make decisions with greater confidence.

To discuss how Marsh can support your organisation, please contact your Marsh representative or our education team.

This publication is not intended to be taken as advice regarding any individual situation and should not be relied upon as such. The information contained herein is based on sources we believe reliable, but we make no representation or warranty as to its accuracy. Marsh shall have no obligation to update this publication and shall have no liability to you or any other party arising out of this publication or any matter contained herein. Any statements concerning actuarial, tax, accounting, or legal matters are based solely on our experience as insurance brokers and risk consultants and are not to be relied upon as actuarial, accounting, tax, or legal advice, for which you should consult your own professional advisors. Any modelling, analytics, or projections are subject to inherent uncertainty, and any analysis could be materially affected if any underlying assumptions, conditions, information, or factors are inaccurate or incomplete or should change.

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Health and safety in education: When paperwork alone doesn’t control risk