Plant Maintenance Records: What WorkSafe Reviews After a Guarding Notice.
When WorkSafe
comes back, it
asks for your records
After a guarding improvement notice — or a notifiable plant incident — the return visit is a documentation review. The inspector wants the maintenance and service history for the machines named in the notice. Most operators can't produce it. The gap becomes the finding.
A return visit after a guarding notice is not a re-inspection of the guard alone. WorkSafe reviews the documentation for the plant connected to the notice — service history, maintenance records, inspection frequency, the register itself. If those records don't exist, their absence is what gets recorded.
REF-PM-01Four layers sit behind one return visit
Two things get confused constantly, and the confusion is expensive. The duty to maintain plant is not the same as the duty to keep a record of that maintenance. And the plant that is notifiable when it fails is a prescribed list — not every machine you own. Getting these three ideas into the right boxes is what makes a return visit survivable.
Under the OHS Act, plant is defined broadly: any machinery, equipment, appliance, implement or tool, any part of those things, and anything fitted or connected to them. It captures the conveyor, the packaging machine, the forklift and the hand-held power tool alike.
An employer must, so far as is reasonably practicable, provide and maintain plant that is safe and without risks to health, including its use, handling, storage and transport. This is the duty a guarding notice enforces.
r.74 sets which types of plant Part 3.5 applies to. Within it, employers who use plant must identify hazards (r.97), control risk (r.98), and apply specific controls — guarding (r.99), operator controls (r.101), emergency stops (r.102). Guarding escalates: a permanently fixed physical barrier where access isn't needed during operation, maintenance or cleaning; an interlocked barrier where access is required; tool-removable or presence-sensing systems only where those aren't reasonably practicable.
Plant must be used and maintained properly (r.105), and plant not in use must be managed so it doesn't create a risk (r.107). Risk control measures must be reviewed and revised — including after an incident, or where the controls aren't adequately controlling the risk (r.121). Employees must receive information, instruction and training (r.122), and anyone involved in a plant activity must be given the information they need to do it safely (r.123).
And then r.106 — the one people misread. For specified plant, the employer must keep a record of inspection and maintenance. Note carefully what r.106 does and does not do. It does not create the duty to maintain — that sits in s.21 and in r.98, r.105 and r.121. r.106 requires you to keep the record of it. The maintenance duty is what you must do; the record is how you prove you did it.
Part 5 of the OHS Act (incident notification) applies to the collapse, overturning, failure or malfunction of, or damage to, plant prescribed by the regulations — not to any and all plant. r.124 is the regulation that does the prescribing, and it points back to categories in r.74.
From 1 July 2024, that prescribed list was expanded. Notification is required where an incident involving the following immediately or imminently exposes a person to a serious risk to their health or safety:
- Plant that lifts or moves persons or materials
- Pressure equipment
- Tractors
- Earthmoving machinery
- Scaffolds
- Temporary access equipment
- Explosive-powered tools
- Turbines
- Amusement structures
This is the distinction most operators miss. A conveyor system moves materials, so a failure that exposes someone to serious risk is likely notifiable. A bench-mounted machine that doesn't fall in a prescribed category may not be — even though the duty to guard it, maintain it and control its risks applies in full either way. The notification list is narrower than the maintenance duty. If you are unsure whether an incident is notifiable, treat it as notifiable and call WorkSafe.
The Plant compliance code gives practical guidance on meeting the Act and Regulation duties above. If you comply with the code, you are deemed to comply with the duty it covers — which is the standard an inspector measures your records and controls against.
Sources: OHS Act 2004 (Vic); OHS Regulations 2017 (Vic); WorkSafe Victoria, Compliance Code: Plant; WorkSafe Victoria guidance on plant and equipment incident notification (in effect from 1 July 2024).
What most operators actually have
The businesses that get a guarding notice are rarely negligent. They're busy. The information WorkSafe wants usually exists — it's just scattered, informal, and not framed as safety. Here's the usual state of play.
Records live as email threads with the technician who came out when a conveyor or packaging machine broke down — not as a maintained log anyone can produce on request.
No one place lists every machine, tool and item of powered plant in the workplace — even though the asset or depreciation register already holds most of it.
Nothing states how often each item is checked, by whom, and against what — so there's no evidence maintenance is planned rather than reactive.
A reported breakdown gets fixed, but there's no record that it was reported, tracked, rectified and root-caused. Recurring faults hide in plain sight.
On the return visit an inspector will ask three things: show me the plant in this workplace; show me the inspection and maintenance history for the machines named in the notice; and show me how a fault gets reported and closed out. You don't win that conversation with assurances that maintenance happens. You win it with the record that proves it.
You already own the list — pull it
This is where the pressure drops. You don't build a plant register from scratch. Somewhere in your accounting system sits a list of assets you depreciate over time — valuable equipment that earns for the business. That list is most of your plant register. The work is pulling it out and adding a few columns.
add the safety columns
- Pull the asset list from your accounting or depreciation records onto a spreadsheet — every machine, tool and item of powered plant.
- Last inspected / maintained — the date, and by whom.
- Service manual · technical manual · operator manual — held, and where.
- Inspection frequency — how often it's checked, and against what.
- Test & tag / design registration status — where the plant type requires it.
- Is it prescribed for incident notification? — flag the plant in a notifiable category, so the right call gets made under pressure.
You're not duplicating work. You're surfacing information you already hold and making it visible in one place. Something may fall through the cracks on the first pass — add it when you find it. A partial list is a stronger position than no list.
From scattered emails to a defensible position
Five steps. None of them require a safety background — they're operational housekeeping that happens to discharge the duty. Work through them in order.
Export the asset or depreciation list, or walk the floor and write down everything that can break down, affect operations, or harm someone if it doesn't run properly.
- Every machine, conveyor, packaging line, power tool, lifting device
- Note the energy type — electrical, hydraulic, pneumatic, mechanical
- Flag anything that handles or uses chemicals
Turn the asset list into a plant register by adding inspection, maintenance and documentation columns against each item.
- Last inspected and maintained, and by whom
- Service, technical and operator manuals — held and accessible
- Any test-and-tag or design-registration status
Once you know what exists, decide how often each item is looked at, so maintenance is planned rather than reactive. Controls must be reviewed and revised where they aren't working, or after an incident.
- Frequency per item, tied to use and manufacturer guidance
- Who performs the check, and what they check against
- Priority to the plant named in any current notice
If someone reports a machine issue — forget "safety" for a moment — what happens next? Make it trackable and closed out.
- Log the report the moment it's raised
- Capture the technician's service report — what failed, what was replaced, why
- Record the root cause, so recurring faults surface instead of hiding
Mark the plant in your register that falls within a prescribed notification category. That way the decision isn't being made from scratch on the worst day.
- Flag prescribed plant — lifting or moving plant, pressure equipment, tractors, earthmoving machinery, scaffolds, temporary access equipment, explosive-powered tools, turbines, amusement structures
- Test against the threshold: did it immediately or imminently expose someone to a serious risk?
- If in doubt, notify — and preserve the incident site until an inspector directs otherwise
Once you have the list and you're maintaining to a schedule, you start seeing issues before they become failures — the slowdown in production, the delay, the noise a machine makes when it isn't running right. You fix those, and there are fewer breakdowns. Fewer breakdowns means fewer incidents. Fewer incidents means it's less likely someone gets hurt.
Harm is the last domino to fall. By the time it does, several operational signals were already there to be read. A maintained plant register and a working fault loop aren't safety paperwork — they're how you catch the problem upstream, protect the operation, and put a record on the table the day WorkSafe comes back.
Plant records & the return visit
The return visit looks at whether the guarding issue is resolved and whether you can show the plant is being properly maintained. Expect requests for the inspection and maintenance history of the machines named in the notice, your inspection frequency, and a list of the plant in the workplace. The documentation is as much the focus as the guard itself.
Not quite — and the distinction matters. Regulation 106 requires you to keep a record of inspection and maintenance for specified plant. The duty to actually maintain plant and control its risks comes from the general duty in the OHS Act and from the plant regulations covering control of risk, use of plant, and review of control measures. In practice you cannot demonstrate you've met those duties without records — which is exactly why the record-keeping obligation exists, and exactly what an inspector asks for.
No. Notification is triggered by the collapse, overturning, failure or malfunction of, or damage to, plant prescribed under the regulations, where the incident immediately or imminently exposes a person to a serious risk to their health or safety. The prescribed categories include plant that lifts or moves persons or materials, pressure equipment, tractors, earthmoving machinery, scaffolds, temporary access equipment, explosive-powered tools, turbines and amusement structures. That list was expanded on 1 July 2024. If you're unsure whether an incident meets the threshold, treat it as notifiable and contact WorkSafe.
The regulations require a record of inspection and maintenance for specified plant, and they require you to identify plant hazards and control the risks. A plant register is the practical way to hold all of that in one place and to show it on request. Most of it can be built from the asset list you already keep for accounting purposes.
Scattered emails show maintenance happens, but they're hard to produce on request and don't demonstrate a system. Pulling them into a single register with dates, manuals held and inspection frequency turns the same information into evidence an inspector can read in one place. You're not creating new work — you're surfacing what you already hold.
There's no single number — frequency depends on the item, how hard it's used, and the manufacturer's guidance. What matters is that a frequency is set for each item, someone is responsible, the checks are recorded, and the controls are reviewed where they aren't working or after an incident. The Plant compliance code is the deemed-to-comply reference for how to approach it.
That's exactly the point. A maintained plant list, scheduled inspections and a fault-tracking loop are ordinary operational discipline — the safety duty is discharged as a by-product. The responsibility sits with the employer or self-employed person. It can be delegated to someone in the business, but the duty itself cannot be handed off.
Get your plant records ready before the return visit
Bring the notice and whatever records you have. We'll map your plant, close the documentation gaps, and set up a register and fault loop that stands up when WorkSafe comes back.
Book a free 30-minute consultation