This guide explains how large PCBUs can prioritise critical risks in their work under the Health and Safety at Work Act (HSWA).
This guidance applies from 1 April 2027
Key points
- Large PCBUs must prioritise the management of critical risks when meeting their duties under HSWA.
- A critical risk is a risk that is likely to result in:
- death
- a notifiable injury
- a notifiable illness
- a notifiable incident
- a specified occupational disease¹
or, - is managed by regulations under HSWA.²
- Large PCBUs must manage all risks but must give priority to critical risks.
- This means you must prioritise the management of critical risks, rather than those that might be easier to manage.
Who is a Large PCBU
You are a large PCBU, if you:
- have 20 or more workers, or
- are in a sector or type of business where worker numbers fluctuate during the year, and:
- you reasonably expect to have 20 or more workers in more than 3 months of the current financial year, or
- you have not been operating for the whole of the current financial year, you reasonably expect your worker numbers to be 20 or more in more than 3 months of the following financial year.
There are no requirements for you to keep a record of worker numbers. However, you may use existing business records to determine how many workers your business has.
For more information see Am I a small or large PCBU?
What does ‘prioritising critical risks’ mean?
You must also meet your other HSWA obligations, but you must prioritise the management of critical risks.
You can prioritise critical risks by:
- managing critical risks before managing other risks
- monitoring, reviewing, and revising control measures relating to critical risks more often than control measures relating to other risks
- applying a higher proportion of risk management resources to the management of critical risks compared with other risks.
For more information about critical risk, see What is a critical risk?
Practical examples
Example 1: Construction company
A large construction PCBU identifies the following risks:
- falls from height (critical risk)
- minor slips/trips in their office environment (other risk).
They prioritise managing fall from height by:
- engineered edge protection and exclusion zones
- frequent inspections of fall protection systems
- dedicated supervisors for high-risk work.
After they are satisfied that they have managed the critical risk of falls from height, they then look at managing the other risk of minor slips trips and falls by:
- making sure the office floors are kept dry and free of clutter.
Example 2: Manufacturing business
A manufacturer identifies the following risks:
- exposure to moving machinery (critical risk)
- manual handling of lightweight boxes in the storeroom (other risk).
They prioritise managing exposure to moving machinery by:
- interlocked guarding and isolation procedures
- routine verification of lockout/tagout systems
- higher investment in machine safety upgrades.
After they are satisfied that they have managed the critical risk related to moving machinery, they then look at managing the other risk of manual handling by:
- rotating workers around tasks.
Footnotes
¹ As listed under Schedule 2 Accident Compensation Act 2001(external link)
² As listed under Schedule 1A HSWA(external link)
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