Multiple WHS Duties, One Workplace: What Leaders Must Get Right
WHS law does not operate in silos. It assumes complexity. People wear more than one hat and responsibilities overlap.
This is why consultation is not optional. It is a legal requirement.
One Person, Multiple Duties
It is entirely possible for one individual to be:
A PCBU and a worker, or
An officer and a worker, or
A contractor and a worker in another business.
Each role carries its own obligations. Meeting one does not cancel out the others.
This matters because businesses often assume responsibility flows neatly down an organisational chart. WHS law does not work that way.
Consultation Is a Legal Duty, Not a Courtesy
The WHS Act requires:
PCBUs to consult with workers, and
All duty holders to consult, cooperate and coordinate with each other.
Consultation is about sharing information, making decisions together where risks overlap and ensuring controls work across boundaries. It is particularly critical where multiple PCBUs operate in the same space.
Failure to consult is one of the most common compliance breakdowns we see. It is also one of the easiest to prevent when leaders understand their role.
Control Determines Responsibility
Each duty holder must discharge their duty to the extent they can influence or control the matter. This means:
Senior leaders are accountable for resourcing and systems.
Supervisors are accountable for how work is organised.
Workers are accountable for how work is performed.
No one gets a free pass.
What Strong WHS Leadership Looks Like
Organisations that manage this well:
Clearly define who holds which duties.
Train leaders and workers on their specific obligations.
Build consultation into everyday operations, not just incidents.
Align WHS responsibilities with decision making authority.
This is where WHS shifts from compliance to capability.
Key takeaway - Shared responsibility does not dilute accountability. It increases it. Leaders who understand this build safer, more resilient workplaces.
