The ACT Sex Work Code of Practice is relevant to builders, subcontractors and service tradies when they work at a premises where sex work is carried out. The Code applies to those workplaces and commenced on 5 February 2024, replacing the earlier 2011 Code.
For a construction or maintenance business, the practical message is straightforward: coordinate with the premises operator, understand the operating environment and control the interaction between your work and the people already using the workplace. Your normal construction, electrical, asbestos, plant and hazardous-substance controls still need to be addressed.
Information current: 14 August 2026.
Main hazards to consider
The hazards will depend on whether the premises is operating, partly occupied or vacant during the work. Common issues include:
- contact with blood, bodily fluids, contaminated waste or sharps
- violence, aggression, harassment or unauthorised entry
- remote or isolated work, especially after hours
- obstructed exits, disabled alarms or changes to security arrangements
- privacy risks caused by cameras, photographs, open work areas or exposed records
- interaction between clients, workers, tools, plant, dust, noise and temporary services
- slips, manual handling, electrical hazards and hazardous chemicals
- reduced access to amenities, first aid or emergency equipment during refurbishment.
The Code specifically addresses infection risks, PPE, bodily-fluid spills, remote or isolated work and work-related violence. These issues should be considered alongside the hazards created by the building or maintenance task.
What should be sorted before work starts?
Start with a walk-through involving the premises operator or manager. Where workers may be affected, consultation should give them a reasonable opportunity to explain how the workplace actually operates and where controls could fail.
Before mobilisation, agree on:
- whether normal operations will continue and which areas will remain occupied
- work zones, access routes, exclusion zones and secure storage
- the location and status of exits, alarms, communication devices and emergency equipment
- service isolations, permits and responsibility for restoring systems
- arrangements for sharps, spills, contaminated materials and cleaning
- privacy requirements, including restrictions on photography and recording
- check-in, duress and emergency arrangements for anyone working alone
- how incidents, hazards and changes to the job will be reported.
Contractors and the premises operator may hold overlapping WHS duties. Exchanging information and confirming who controls each issue helps prevent gaps, such as one party assuming the other has isolated a service or maintained an emergency exit.
What good controls and documents usually cover
Use the hierarchy of controls. Where practical, schedule disruptive work when the affected area is not operating, physically separate the work zone and keep clients and other workers away from tools, dust and exposed services. Administrative rules and PPE then support those higher-level controls.
Depending on the job, useful documents may include:
- a site-specific risk assessment, JSA or SWMS
- a concise induction covering access, privacy, alarms and emergencies
- electrical, service-isolation, hot-work or confined-space permits
- asbestos information and disturbance controls
- an emergency and work-related violence response procedure
- a spill, sharps and contaminated-waste procedure
- consultation, inspection, training and control-review records.
Information, instruction and training should match the work, risks and controls and be readily understandable to the people receiving it. Review the controls if the work area, occupancy, scope or security arrangements change, or if consultation or an incident shows they are not effective.
When does a SWMS commonly apply?
The Sex Work Code is not a substitute for construction documents. A task-specific SWMS commonly applies where the job involves high-risk construction work under the applicable jurisdiction's rules. Examples can include demolition, structural alteration, asbestos disturbance, work near energised services, confined spaces or work involving a serious fall risk.
For lower-risk servicing or maintenance, a site-specific JSA, safe work procedure, permit or risk assessment may be appropriate. The actual task, location, jurisdiction and site rules determine what is required. Check current regulator material before starting.
Practical warning signs
Pause and resolve the issue if:
- nobody can confirm whether the premises will remain operational
- workers have not been consulted about changed access or security
- exits, alarms or communications are blocked or unavailable
- an isolated worker has no reliable way to obtain assistance
- sharps, spills or contaminated materials have no agreed process
- the SWMS or risk assessment describes a generic site rather than the actual work area
- work starts after a major scope or occupancy change without reviewing controls.
How Blue Safe can help
Blue Safe provides compliant WHS documents tailored to the client's activities, applicable Australian WHS/OHS requirements, jurisdiction and industry. Blue Safe guarantees the document compliance of the WHS documents it provides, including eligible customer documents after Blue Safe has reviewed and upgraded them.
This can include site-specific risk documentation, SWMS, procedures, inductions and supporting records suited to the work and workplace interface. Customers actively put the compliant documents into practice through controls, consultation, training, actions, records and evidence.
Local requirements vary across Australia, so current regulator material and the requirements applying to the particular site and activity should be checked.