Plenty of contracting companies in central Queensland do civil work for a council on Monday and maintenance on a coal mine on Thursday. It is a sensible way to run a business — the work smooths out and the teams stay employed.
It also means running two compliance regimes at once, and the failure mode is quiet: a credential that seems like it should cover both, and doesn't.
Three frameworks, not one
Civil and construction work generally sits under the Work Health and Safety Act 2011 (Qld), regulated by WorkSafe Queensland. PCBUs, notifiable incidents, improvement and prohibition notices.
Coal mines sit under the Coal Mining Safety and Health Act 1999 — an entirely separate Act, outside the harmonised WHS framework, regulated by Resources Safety and Health Queensland. Operators and site senior executives rather than PCBUs. High potential incidents rather than notifiable incidents. Directives rather than notices.
Mineral mines and quarries sit under the Mining and Quarrying Safety and Health Act 1999 — parallel to the coal Act, similar architecture, separate instrument.
The Acts rhyme, which is the problem. They are similar enough that a procedure written for one reads plausibly against another, and different enough to be wrong in exactly the situations where it matters.
What does not transfer
A white card is not a Standard 11. The white card is the general construction induction under the WHS framework. Standard 11 is the recognised coal mine induction under the CMSHA. Neither substitutes for the other in either direction, and a worker holding only one of them will be turned around at the other kind of gate.
Standard 11 is not a quarry induction. A quarry under the MQSHA sets its own requirements. There is overlap in the underlying accredited units. There is not automatic transfer.
The coal mine workers' health assessment (formerly known as the coal board medical) is a coal requirement. The Coal Mine Workers' Health Scheme applies to coal mine workers. Quarries and mineral mines have their own health assessment arrangements, and individual operators frequently add their own. A worker moving between coal and quarry work can need more than one, on different cycles.
Site inductions never transfer, anywhere. Every operator runs its own, on its own validity. Four clients means four site inductions with four expiry dates — and a worker fully current for one may be short for another with identical qualifications.
Your incident procedure does not transfer. On the coal or quarry job you notify RSHQ about a high potential incident. On the council job you notify WorkSafe Queensland about a notifiable incident. Different triggers, different bodies, different timeframes.
That last one is the most dangerous, because it is used under pressure, at the worst moment, by whoever has the folder to hand.
What does transfer
Less than people hope, but not nothing.
High risk work licences. National, mutually recognised, five years. A forklift licence is a forklift licence in every state and on every kind of site. What does not transfer is a site's requirement for a verification of competency on their own plant — which most resources operators require regardless.
Underlying units of competency. The accredited units behind various inductions are nationally recognised, which is why some training can be credited across. Whether a specific operator accepts it is a question for that operator, not for the training provider selling the course.
Your own competence. Which is worth saying, because the frustration here is real. None of this is about whether your people can do the work. It is about which piece of paper proves it to whom.
The single-status trap
Here is where this becomes a systems problem rather than a knowledge problem.
Most compliance tracking records one status per worker: compliant, or not.
A contracting company working across civil, quarry and coal has workers who are simultaneously:
- fully current for the coal job;
- short of the specific induction for the quarry;
- fine for the council work, which requires neither.
All at once. All on different clocks.
A single status will show something, and whatever it shows will be wrong for two of the three. Worse, it will show green — because most systems mark someone compliant when they hold the credentials the system knows about.
The coordinator rosters them. They drive four hours. Somebody at a gate explains the problem.
What works instead
Hold requirements against the site, not against the worker.
The site knows what it needs. The worker holds what they hold. Compliance is the comparison of the two, computed per site, rather than a property somebody carries around.
That sounds like a technicality and it is the whole difference. It is the only structure that gives an honest answer to the question your operations team actually asks at five thirty in the morning, which is never "is Dave compliant" — it is "can Dave go to Blackwater today".
A few practical things that follow:
- Write the governing Act on the client record. It determines your incident procedure and your response to an inspector, and it should not be something a supervisor has to work out.
- Keep two incident procedures, clearly labelled by site type, and make sure people know which is which before they need to.
- Do not assume a credential covers a sector because it covers a hazard. Ask the operator.
- Track the white card's activity rule separately — it lapses after two years without construction work, and no date field will ever catch that.
None of this makes the work harder. It makes the answer available, which is the part that has been costing you.
