Can you please tell me what the rules are around storage above head height?
We understand that you are enquiring about your obligations in a harmonised work health and safety State or Territory, being NSW, Queensland, South Australia, Tasmania or Northern Territory (the legislation we refer to below does not apply in Victoria or Western Australia, although your duties will be similar).
There is nothing specific in the harmonised Work Health and Safety Act (Act) or Regulations (Regulations) regarding the storage of objects above head height (see links below).
A. General duty
In the first instance, you should be guided by the general duty under the Act, that is, as a person conducting a business or undertaking (PCBU), to ensure, so far as reasonably practicable, the health and safety of workers and other persons in the workplace (section 19).
As part of that duty, you must ensure, as far as reasonably practicable, among other things, the provision and maintenance of a work environment without risks to health and safety, the provision and maintenance of safe systems of work and the provision of any information, training, instruction or supervision that is necessary to protect all persons from risks to their health and safety arising from work carried out as part of the conduct of the business or undertaking.
What is reasonably practicable is set out at section 18 of the Act.
B. Managing risks to health and safety
Depending on your workplace and your operations, there are some foreseeable risks to health and safety when storing objects above head height, such as the risk of falls from ladders when accessing objects and the risk of employees injuring themselves when accessing items stored above head height. You should ideally conduct a risk
assessment to identify any reasonably foreseeable risks that may relate to storing objects above head height.
In managing these risks, you should have regard to part 3.1 of the Regulation, which sets out specific requirements for managing risks to health and safety, that is, to:
1. Identify reasonably foreseeable hazards that could give rise to risks to health and safety.
2. Eliminate the risk to health and safety so far as is reasonably practicable, and where that is not possible, minimise the risks so far as is reasonably practicable.
3. Implement control measures if it is not possible to eliminate the risk (see Reg 36).
4. Ensure that any control measure is maintained (see Reg. 37).
5. Review the control measure (see Reg. 38).
- Depending on the risks that you identify, the following regulations may be relevant to the risks to health and safety posed by storing objects above head height: Part 4.2, which relates specifically to managing the risks to health and safety relating to a musculoskeletal disorder associated with a hazardous manual task;
- Part 4.4, which relates to the management of the risk of falls in the workplace, which may be relevant depending on the heights at which objects are stored, and the use of ladders.
The following Safe Work Australia Codes of Practice provide further guidance on the management of those risks:
- Hazardous Manual Tasks, which sets out the risk management process for hazardous manual tasks, which pose a risk to musculoskeletal disorders. This could include lifting heavy loads from above head height or from other difficult to access areas (link below); and
- Managing the Risk of Falls at Workplaces, specifically part 7.1 regarding the use of ladders (link below).
Safe Work Australia Code of Practice Hazardous Manual Tasks:
Safe Work Australia Code of Practice Managing the Risk of Falls at Workplaces: