Who has to do a manual handling risk assessment?

The duty sits with the person conducting the business or undertaking — in practice the employer. Under the WHS Regulations they must manage the risks of hazardous manual tasks, and a risk assessment is how that is normally done and demonstrated. The person who carries it out is usually a supervisor, WHS adviser or manager, and it should involve the workers who actually do the task.

Is a written risk assessment legally required?

The WHS Regulations do not prescribe a written form for hazardous manual tasks in every case, but recording what you assessed, decided and changed is what shows the duty was met if a regulator or an insurer asks. Most sites keep a short written record for that reason.

How often should it be reviewed?

Whenever the task, the load, the equipment, the layout or the people change, after an incident or a reported discomfort, and otherwise on whatever cycle your WHS system sets. A risk assessment written once and filed is the most common failure mode.

Does training count as a control?

Yes, but as the last one. The hierarchy puts eliminating or redesigning the task first, then equipment and layout changes, then administrative measures such as rotation and procedures, with training and instruction supporting all of them. A risk assessment whose only control is "train the workers" has not finished.

Can this course substitute for an assessment?

No. This is non-accredited awareness training that helps workers recognise hazardous tasks and handle loads more safely. It does not assess your site, and it is not a risk assessment or a control. It can form part of the training and instruction that supports your controls.

Manual handling guide

How to do a manual handling risk assessment

Find the tasks that carry risk, work out what about them is risky, change what you can, and check whether it worked. That is the whole method, and the code of practice gives you a structure for the middle step: four sources of risk to look at for every task. What follows is that process applied to warehouse work, where the hazardous task is rarely the one everybody expects.

By Warehouse Handling Academy · Published 12 October 2026

Start with the tasks, not the weights

The most common way to get this wrong is to go looking for heavy things. Weight is one factor among several, and on a distribution floor it is usually not the one that causes the injury. A task becomes hazardous when it involves repetitive or sustained force, high or sudden force, repetitive movement, sustained or awkward posture, or vibration — so a 5 kg carton lifted six hundred times in a shift qualifies, and a one-off 20 kg lift from waist height with a clear path may not.

Three things find the tasks worth assessing faster than walking the floor cold:

Ask the people doing the work. They can name the jobs they dread, and that list is nearly always the right one.
Read your own records. Incident reports, near misses, early discomfort reports, and anything that has generated a claim.
Watch a full cycle, not a lift. Risk accumulates across a wave, a rotation or a shift, and a thirty-second observation cannot see that.

The four sources of risk

For each task you have identified, the code of practice asks you to look at four things. Taking them one at a time is what stops an assessment collapsing into "it's heavy".

Source	What to look at	Warehouse examples
The work area	Floor condition and level changes, lighting, space to turn, distance carried, temperature, how far loads sit from the body at pick and set-down.	Dock plates, meltwater at chamber doors, bottom and top racking slots, aisles too narrow to turn a cage.
The load	Weight, size, shape, grip points, stability, whether contents shift, whether it is live or unpredictable.	Shrink-wrapped mixed pallets, unlabelled cartons, drums, long items that need two hands wide apart.
The task	Posture, force, repetition, duration, whether it is sustained, and whether the worker controls the pace.	Wave picking against a trailer cut-off, repetitive bending at a bottom pick face, carrying while scanning.
The worker and the system	Experience, training, rotation, fatigue, whether equipment is available and near, whether there is pressure to skip it.	Casual starters copying the fastest person, a step platform two aisles away, targets that measure throughput only.

The fourth row is the one most often skipped, and it is where the controls that actually work tend to live. Equipment that exists but sits two aisles away is, in practice, equipment that does not exist.

Ranking what you find

You will find more than you can fix at once. Two questions put the list in order without needing a scoring matrix: how likely is harm, and how bad would it be? A task that exposes a dozen people every shift to a posture that accumulates damage outranks a task that one person does badly once a month, even though the second one looks more dramatic.

Be honest about duration and frequency when you rank. These are the two factors that separate work that is merely physical from work that injures people, and they are the two that a walkthrough is least able to see.

Controls, in the order that works

The hierarchy is not advice about what is nicest. It is ordered by how reliably each control holds when people are tired, rushed or new.

Eliminate or redesign the task. Deliver to the point of use. Order in a different pack size. Slot fast-moving lines at waist height instead of the floor.
Change the equipment or the layout. Lift tables, pallet positioners, trolleys, scissor lifts, step platforms kept where the work is.
Change how the work is organised. Rotation between different movement patterns, realistic pacing, two-person procedures for defined loads.
Train and instruct. Technique, hazard recognition, when to stop and ask. This supports everything above it and substitutes for none of it.

A risk assessment whose only control is "remind workers to lift correctly" is the one regulators see most often, and it is the one that fails first. If technique is your whole answer, the assessment has stopped early.

Writing it down, and reviewing it

Record the task, who you spoke to, what you found against each of the four sources, what you decided to change, who owns it and by when. That is enough. The value is not in the form — it is in being able to show what you considered and what changed, and in having something concrete to check against later.

Then review it when something moves: new equipment, a new line, a layout change, a new crew, an incident, or a report of discomfort. The most common failure is not a bad assessment. It is a good one, filed, while the floor changed around it.

Where training fits

Once the controls are in place, workers still need to recognise a hazardous task and know when to stop and ask. Our free eight-module course covers exactly that, with warehouse scenarios, and the employers page explains how sites use it alongside their own induction.

Questions people ask

Who has to do a manual handling risk assessment?: The duty sits with the person conducting the business or undertaking — in practice the employer. Under the WHS Regulations they must manage the risks of hazardous manual tasks, and a risk assessment is how that is normally done and demonstrated. The person who carries it out is usually a supervisor, WHS adviser or manager, and it should involve the workers who actually do the task.
Is a written risk assessment legally required?: The WHS Regulations do not prescribe a written form for hazardous manual tasks in every case, but recording what you assessed, decided and changed is what shows the duty was met if a regulator or an insurer asks. Most sites keep a short written record for that reason.
How often should it be reviewed?: Whenever the task, the load, the equipment, the layout or the people change, after an incident or a reported discomfort, and otherwise on whatever cycle your WHS system sets. A risk assessment written once and filed is the most common failure mode.
What is a hazardous manual task?: Any task requiring a person to lift, lower, push, pull, carry, hold or restrain something, where it involves repetitive or sustained force, high or sudden force, repetitive movement, sustained or awkward posture, or exposure to vibration. It is the characteristics of the task that make it hazardous, not the weight alone — a 5 kg carton lifted six hundred times qualifies.
Does training count as a control?: Yes, but as the last one. The hierarchy puts eliminating or redesigning the task first, then equipment and layout changes, then administrative measures such as rotation and procedures, with training and instruction supporting all of them. A risk assessment whose only control is "train the workers" has not finished.
Can this course substitute for an assessment?: No. This is non-accredited awareness training that helps workers recognise hazardous tasks and handle loads more safely. It does not assess your site, and it is not a risk assessment or a control. It can form part of the training and instruction that supports your controls.

Sources and further reading

Model Code of Practice: Hazardous Manual Tasks — Safe Work Australia — the four risk sources, the risk management steps and worked examples
Model WHS Regulations — Safe Work Australia — the duty to manage risks from hazardous manual tasks, and what must be considered
How to Manage Work Health and Safety Risks — Safe Work Australia — identify, assess, control, review — the general process this guide follows
WorkSafe Victoria — Victoria runs its own OHS Act and hazardous manual handling regulations

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This is non-accredited general awareness training and does not issue a nationally recognised Statement of Attainment. Always confirm your employer's specific training requirements.