safety observation

Industry Insights

The Role and Responsibilities of WHS Managers in Construction

Learn how WHS Managers in construction identify, document, and resolve non-conformances and safety observations to maintain compliance and prevent incidents on-site.

An insider’s perspective from 20 years in the trenches.

If there’s one thing two decades in construction has taught me, it’s this: nothing trumps safety.

In an industry where risk is baked into the day-to-day — where we’re working at heights, around live electrical systems, with heavy machinery, and often in the elements — the presence of a skilled Work Health and Safety (WHS) Manager isn’t just a box to tick. It’s the backbone of a project's operational integrity and workforce welfare.

WHS Managers aren't just compliance enforcers. They're strategists, communicators, risk forecasters, and—most importantly—protectors. They shape how a project functions, how teams interact with hazards, and ultimately, how safely we send our people home each day.

This article unpacks the true role of a WHS Manager in construction—beyond the paperwork and toolbox talks. This is the real-world stuff: the tasks, responsibilities, and expectations that separate average sites from great ones.

What Is a WHS Manager?

A WHS (Work Health and Safety) Manager, sometimes referred to as a Safety Manager or HSEQ Manager (when covering Health, Safety, Environment and Quality), is responsible for the implementation, maintenance, and continuous improvement of health and safety systems on construction sites.

They ensure compliance with the WHS Act, WHS Regulations, Codes of Practice, and all other legislative requirements — but more than that, they create a culture of safety through leadership, engagement, and foresight.

Summary of WHS Manager Roles & Responsibilities

Category

Responsibilities

Risk Management

Conduct site risk assessments, manage Safe Work Method Statements (SWMS), implement control measures

Compliance & Documentation

Ensure WHS legislation compliance, maintain incident registers, manage audits

Training & Induction

Deliver site inductions, coordinate toolbox talks, ensure competency and licensing

Incident Management

Investigate incidents, near-misses, and hazards; report notifiable incidents to regulators

Communication & Culture

Lead by example, influence safety culture, consult with workers and subcontractors

Continuous Improvement

Review safety plans, apply lessons learned, identify training needs and trends

Non-Conformance & Raising Observations: Holding the Line on Standards

In the real world, things don’t always go to plan — and that’s exactly why non-conformance reporting (NCRs) and observational safety reporting are so critical to a functional WHS system on-site.

What Is a Non-Conformance?

A non-conformance is any deviation from expected procedures, safety controls, design specs, or compliance obligations. It doesn’t necessarily mean there was an incident — but it does mean something has gone off-track from what was approved, safe, or compliant.

Common examples on construction sites include:

  • Work being carried out without approved SWMS

  • Incorrect scaffolding erection

  • Use of damaged or untagged equipment

  • Temporary edge protection not installed per standard

  • Workers operating outside their licensed capabilities

When a non-conformance is identified, a WHS Manager must:

  1. Document the issue clearly, including photos, location, and nature of the deviation

  2. Assign corrective actions, with deadlines and responsible parties

  3. Track resolution, ensuring the issue is closed out effectively

  4. Escalate, if required, to Project Management or regulatory bodies depending on severity

Non-conformances aren’t about “getting someone in trouble” — they’re about realignment. It’s about saying: “Here’s where we veered off course, and here’s how we fix it before someone gets hurt or a costly mistake gets buried.”

Raising Observations: The Eyes and Ears of Prevention

Beyond formal NCRs, a WHS Manager should be constantly raising and encouraging observations — informal but meaningful notes about unsafe behavior, at-risk conditions, or improvement opportunities.

Here’s what that might look like:

  • Spotting a trip hazard near a heavily trafficked access point

  • Noticing a crew working in direct sun with no hydration protocol in place

  • Identifying confusion in pedestrian and vehicle separation zones

  • Observing fatigue or unsafe lifting practices during a concrete pour

These observations are logged — sometimes digitally via mobile apps or safety platforms — and should feed back into daily pre-starts, toolbox talks, or even site layout redesigns.

“The best WHS Managers I’ve worked with didn’t just wait for things to go wrong — they spotted the patterns early and corrected course quietly but firmly.”

Observations are also a fantastic way to involve the broader team. When workers feel safe to report unsafe conditions or behaviors, the site matures. A culture of shared accountability takes root.

From Observation to Action

Here’s the flow I typically follow:

  1. Raise the Observation – Briefly note the unsafe act or condition.

  2. Assess the Risk – Is it a critical risk that requires immediate action?

  3. Engage the Team – Discuss the issue directly with those involved, respectfully.

  4. Record the Observation – Whether digitally or manually, it needs to be documented.

  5. Follow Through – Track how the issue was resolved or escalated.

A Day in the Life: Real Safety Responsibilities in Context

1. Proactive Risk Assessment

Early mornings often begin with a site walkthrough. This isn’t a quick glance around — it’s a meticulous sweep of high-risk areas. I’m looking for evolving hazards: scaffolding shifts, wet surfaces, potential pinch points. Every construction site breathes and morphs daily. You need to stay ahead of that.

We also review SWMS and JSA (Job Safety Analysis) documents. Are the trades following procedure? Have they adjusted their approach to match the day’s site conditions?

2. Regulatory Compliance

WHS Managers need to know legislation like the back of their hand. That means staying up to date with SafeWork Australia guidance and local jurisdictional rules. On a typical week, I’m ensuring:

  • Plant and equipment are inspected and tagged.

  • PPE registers are current.

  • Licences for high-risk work (like rigging or crane operation) are verified.

  • Contractors are complying with WHS Management Plans.

Failing at compliance isn’t just a risk to people — it’s a reputational and financial bombshell waiting to drop.

3. Training and Induction

Every worker who sets foot on-site must go through a site-specific induction. This isn’t just handing them a hi-vis vest and a map. It’s making sure they understand site hazards, emergency procedures, who their safety reps are, and where they can raise concerns.

Toolbox talks are another cornerstone. Whether it's new equipment, weather changes, or a recent incident, these 10-minute sessions build awareness and keep safety front of mind.

4. Incident Response & Investigation

Even with the best systems in place, incidents can happen. When they do, the WHS Manager:

  • Secures the site of the incident

  • Interviews witnesses and involved parties

  • Collects evidence (photos, CCTV, logs)

  • Compiles reports for internal use and SafeWork

  • Identifies root causes and corrective actions

And here’s the part people often forget: it’s not just about “blame.” A great WHS Manager creates a no-blame culture so workers feel safe reporting close calls.

5. Culture Creation

I’ve walked onto plenty of sites where the safety manager sits in a trailer all day. That’s not safety leadership — that’s paperwork babysitting. A good WHS Manager is visible, approachable, and respected.

Culture is built through consistency, communication, and care. You influence how seriously people treat their harnesses, their lock-out/tag-out procedures, or even how they look out for their mates.

The Challenges WHS Managers Face

  • “We’ve done it this way for years.” This old-school mentality can resist new systems and safer practices.

  • Language barriers. Multicultural sites need WHS messaging in multiple languages or formats.

  • Contractor silos. Subcontractors may not adopt the main contractor’s systems unless actively managed.

  • Documentation fatigue. There's a lot of paperwork — but good WHS Managers simplify without compromising quality.

What Makes a Great WHS Manager?

Excellent Communicator
You need to speak the language of site crews, supervisors, project managers, and execs.

Highly Observant
It’s often the subtle things — a blocked fire exit, a worn lanyard clip — that spell danger.

Balanced and Fair
Enforcement is part of the job, but a heavy-handed approach breaks trust. You need fairness and consistency.

Resilient Under Pressure
When an incident happens, everyone turns to you. You need to act with clarity and calm.

Committed to Learning
WHS is evolving fast — from digital safety systems to AI-based hazard detection. Stay ahead.

Conclusion

The WHS Manager role isn’t for the faint-hearted. It’s not just forms, inductions, and checklists. It’s people’s lives. And in construction, that responsibility is amplified by the volatile, high-risk environment we work in every day.

If you’re a builder, project manager, or site supervisor — invest in your WHS people. Empower them, back them, and involve them early. If you’re a WHS Manager yourself — never underestimate the ripple effect of your actions. Every well-executed audit, every corrected unsafe act, and every conversation about risk contributes to a safer, smarter, and more sustainable industry.