Plant Risk Assessment Review: Why Once a Year Is Usually Not Enough

12 October 2026

Most earthmoving operators treat a plant risk assessment as an annual job. Book it, file it, forget it for twelve months. It is a tidy habit, and on a machine that actually works for a living it usually leaves gaps.

The reason is that Australian safety law does not give you a twelve-month clock. It gives you a list of circumstances that make a plant risk assessment review necessary — and on an excavator that changes attachments, moves between sites and picks up new operators, those circumstances come around several times a year. A yearly assessment is a sensible floor. It is rarely the whole obligation.

This one is written for earthmoving and heavy machinery — excavators, tipper trucks, front-end loaders, skid steers and track loaders. Here is what actually triggers a review, how often that works out to in practice, and what your paperwork needs to show.

Where the twelve-month habit came from

Ask around a civil site and you will hear that plant risk assessments last twelve months. It is repeated in inductions, written into contractor prequalification portals, and printed on more than a few assessment covers.

It is a convention, not a section of the regulations. Principal contractors adopted it because a date is the one thing they can verify at a gate in ten seconds, and because a year is long enough to be workable and short enough to catch most drift. It does a job, and you will still be asked for it.

What it is not is a definition of your duty. Reading “twelve months” as “I am covered until next August” gets the obligation backwards. A fixed annual deadline would actually be the easier standard to meet — one date, one booking, done. The real duty is more demanding than that, because it attaches to events rather than to the calendar, and events do not wait for your renewal date.

What actually triggers a plant risk assessment review

In the harmonised states and territories, regulation 38 of the WHS Regulations sets out when control measures must be reviewed and revised. The SafeWork NSW code of practice for managing the risks of plant in the workplace (available here as a PDF) spells them out. Victoria words its duties differently under Part 3.5 of the OHS Regulations, but lands in much the same place.

Something is about to change

A review is required before a change that is likely to create a new or different risk your existing measures may not cover. The word “before” is doing real work there — this is not something you catch up on at the next annual booking. Common examples on civil and earthmoving jobs:

Fitting a different attachment — a hydraulic hammer, auger, mulcher, tilt hitch or grab changes the crush, entanglement and stability profile of the base machine.
Moving a machine to a site with overhead powerlines, live traffic, pedestrians or confined access.
Night work, or any shift to conditions the assessment did not consider.
A modification or repair that alters guarding, controls, visibility or the operator station.
New operators with different experience, or a change in how the machine is used day to day.

In Victoria this is written explicitly: employers must review control measures before any alteration to the plant, or to the way the plant is used. WorkSafe Victoria sets out the full duties on its plant and legal duties page (worksafe.vic.gov.au).

A control has quietly stopped working

If a control measure is not controlling the risk so far as is reasonably practicable, it needs revising. This is the trigger people miss, because nothing announces it. A reversing camera that fogs up every winter morning. An isolation procedure everyone works around because it adds twenty minutes. A guard that gets left off because it makes daily greasing impossible. Each of those is a control that exists on paper and has stopped existing in practice, and only someone looking at the machine will find it.

A new hazard or new information turns up

A near miss, an incident on a similar machine, a manufacturer safety bulletin, a recall notice, or a hazard raised by an operator all count as new information. So does a regulator alert about a machine type you run.

Consultation says so, or an HSR asks

If consultation with workers indicates a review is necessary, that is a trigger in its own right. A health and safety representative can also request one where they reasonably believe another circumstance applies, or that a control has not been properly reviewed in response to it. This is not a courtesy. It is a duty, and it is the trigger most likely to be raised after something has already gone wrong.

What that adds up to on a working machine

Put those triggers against a normal year for one excavator and the annual habit starts to look thin. A machine that swaps between a bucket, a hammer and an auger, moves across three jobs, takes on a new operator in autumn and has one near miss with a service location has met the threshold for a review on six separate occasions — none of which fall on the anniversary of its last assessment.

That is not an unusual year. That is a machine earning its keep.

None of it means six full assessments. It means six moments where someone competent should have looked at what changed and decided whether the existing controls still hold. Most of those checks are short. The problem is not that they are onerous — it is that when the only prompt in the system is an annual renewal date, they do not happen at all, and the gap between what the paperwork claims and what the machine is actually doing widens all year.

Victoria and the harmonised states are not identical

Australia does not have one safety law. If you run machines across borders, the framework changes underneath you even though the practical expectations are similar.

Jurisdiction	Governing law for plant	Regulator
Victoria	OHS Act 2004 and OHS Regulations 2017, Part 3.5	WorkSafe Victoria
NSW, Qld, SA, Tas, ACT, NT, Commonwealth	WHS Act and WHS Regulations based on the model laws, including regulation 38	State or territory WHS regulator
Western Australia	Work Health and Safety Act 2020, a WA version of the model laws	WorkSafe WA

Victoria is the only state that has not adopted the model WHS laws. Western Australia adopted its own version in 2022. The triggers are worded differently but cover the same ground, so an assessment built around substance rather than section numbers will travel. If your machines work interstate, say so when the assessment is written. Safe Work Australia publishes the model code of practice for managing the risks of plant (safeworkaustralia.gov.au) as the national reference point.

What a review needs to look like on paper

A plant risk assessment review means someone competent looked at the actual machine and formed a view. A note in a folder saying “reviewed, no change” that nobody backed with an inspection is not a review — it is a record of not having done one, and it reads exactly that way to a regulator after an incident.

Documentation that holds up tends to include:

The machine identified properly — make, model, serial or fleet number. “Excavator 3” is not identification.
The date of the assessment and of each subsequent review, kept as a visible history rather than overwritten.
Who carried out the review and what makes them competent to do it.
What triggered it — attachment change, incident, site change, scheduled check.
Hazards, risk ratings and the controls applied, with the reasoning legible to someone who was not there.
Corrective actions with owners and due dates, and evidence they were closed out.
Attachments assessed alongside the base machine, not as an afterthought.

Keep the superseded versions. A history showing several reviews across a year, each tied to a real change, is far stronger evidence of a working safety system than one pristine document dated last month with nothing behind it.

Mistakes that show up again and again

Assessing the machine and ignoring the attachments. The base excavator is assessed; the hammer, auger and tilt hitch are not. Each one changes the hazard picture, and each one is its own trigger.

Copying an assessment between machines of the same model. Two identical loaders carry different guarding, different wear, different alarms and different histories. Model is a starting point, not a conclusion.

Filing it and never reading it again. An assessment that lives in a folder in the office does nothing for the operator in the seat. The controls it specifies have to reach the people applying them.

Closing corrective actions on paper only. If the assessment recommended a reversing alarm, someone needs to confirm it was fitted, confirm it works, and record both.

Letting the renewal date be the only prompt. If nothing in your system flags an attachment change or a site move, those reviews will not happen, and the annual booking will be reconstructing a year you can no longer see.

Frequently asked questions

How often should a plant risk assessment be reviewed?

Whenever a trigger occurs, and at least annually as a backstop. On a machine that changes attachments and sites through the year, that usually works out to several times — not once. The annual booking is the floor, and it is also what site gates and prequalification portals will ask you to produce.

Is there a legal expiry date on a plant risk assessment?

Not a fixed one. The regulations set out circumstances requiring review rather than a renewal interval, which in practice is a more demanding standard than an annual deadline because those circumstances arise unpredictably. Separate obligations such as plant registration and major inspections for certain equipment do carry their own timeframes. Earthmoving machinery is generally not registrable plant, but keep the two things apart — an inspection interval is not a review cycle.

Does fitting a new attachment require a new assessment?

It requires a review before the attachment is used, because it is a change likely to create new or different risks. Whether that becomes an amendment or a separate assessment for the machine and attachment combination depends on how far the hazard profile shifts. A quick-hitch bucket swap is not the same event as adding a hydraulic hammer.

Who can carry out a plant risk assessment?

The law does not licence assessors, but it does expect the work to be done by someone competent — with the knowledge, skills and experience to identify the hazards of that type of plant and judge whether the controls are adequate. In practice that means real technical knowledge of the machine, familiarity with the applicable regulations, and enough independence to write down an uncomfortable finding.

Can I use the manufacturer’s risk assessment?

It is a useful input, not a substitute. A manufacturer assesses the machine as supplied and as intended to be used. Your duty relates to the machine as it is now, in your workplace, with your attachments, your operators and your site conditions.

Do we need a plant risk assessment for hired machines?

The hire company has duties as the supplier, but that does not remove yours as the business directing the work. You still need to be satisfied the machine is suitable and controlled for your site and your task, and to record how you reached that view.

Does a plant risk assessment cover our SWMS obligations?

No. They are different documents doing different jobs. A plant risk assessment deals with the hazards of the machine itself. A safe work method statement deals with how a specific high risk construction activity will be carried out. One informs the other; neither replaces it.

What will a regulator actually look at after an incident?

Whether you identified the hazards, controlled the risks so far as is reasonably practicable, and reviewed those controls when circumstances required it. The date on the cover is where they start, not where they finish — and a twelve-month-old document covering a machine that has changed four times since will not carry the weight people expect it to.

Getting the timing right

The safest position is not a document that is technically in date. It is a machine whose controls still match the work it is doing, with a paper trail that shows how you know. Treat the annual assessment as the baseline, add a review whenever something on the machine or the job changes, and keep every version.

If you would rather have that done properly by someone who looks at the actual machine, Pro Training Australia carries out on-site risk assessments for earthmoving machinery — excavators, tipper trucks, front-end loaders, skid steers and track loaders — across Australia. We assess the base machine and its attachments together, document the controls and corrective actions in plain language, and remind you before your assessment falls due. Earthmoving plant is all we assess, which is why we know it well.

See what an assessment covers on our plant risk assessment page, or get in touch on 1300 280 753 to talk through your fleet.

This article is general information about Australian OHS and WHS duties, not legal advice. Requirements vary between states and territories and depend on your circumstances. Check the current requirements with the regulator in the jurisdiction where the plant is used.

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