Quick answer: An excavation contractor in Australia generally needs SWMS for excavation and trenching work, Dial Before You Dig and underground services search records, a ground or geotechnical assessment, trench shoring or benching design documentation, a plant register with operator licences, WHS policy, site induction records, incident register, and evidence of current insurances. Excavation deeper than 1.5 metres and work near underground services are both high risk construction work — SWMS are mandatory before starting.
Last reviewed: 12 June 2026
Excavation contractors work in one of the most hazardous segments of the construction industry. Trench collapse, contact with underground services, plant and equipment incidents, and ground instability are among the leading causes of serious injury and fatality on excavation sites. Accordingly, the WHS document obligations for excavation contractors are substantial — and regulators treat gaps in documentation as a serious indicator of broader risk management failures.
This guide sets out the core WHS documents that excavation contractors commonly need in Australia, explains why each document is required, and highlights the specific obligations that arise from working with excavation as a high risk construction work activity.
Note: WHS legislation in Australia is based on the model Work Health and Safety Act 2011 developed by Safe Work Australia, but each state and territory has its own laws and regulators. Always check the requirements in your jurisdiction.
At a glance
| Activity type | Key document obligations |
|---|---|
| All excavation work | WHS policy, SWMS, plant register, incident register, induction records |
| Excavation deeper than 1.5 metres | SWMS mandatory (HRCW), shoring or benching design, geotechnical assessment |
| Work near underground services | SWMS mandatory (HRCW), Dial Before You Dig records, potholing records, services drawings |
| Notifiable construction work | WHS management plan required (principal contractor obligation) |
| Employer (with workers) | Training register, operator licences, return-to-work program |
Core WHS documents required
The following table summarises the documents most commonly required or expected for an excavation contractor operating in Australia.
| Document | Why it is needed |
|---|---|
| WHS Policy | Demonstrates leadership commitment to health and safety; required for businesses with workers |
| SWMS — Excavation and Trenching | Required before commencing any excavation deeper than 1.5 metres (HRCW) |
| SWMS — Work Near Underground Services | Required before commencing work near underground services (HRCW) |
| Dial Before You Dig / Services Search Records | Documents that underground services have been identified before breaking ground |
| Underground Services Drawings and Markouts | Site-specific plans and physical markouts of services locations in the work area |
| Ground / Geotechnical Assessment | Documents ground conditions, soil classification, and risks such as instability or groundwater |
| Trench Shoring or Benching Design | Engineered or competency-based documentation of the support system used in deep excavations |
| Plant and Equipment Register | Tracks excavation plant, inspection status, and whether operators hold required licences |
| Operator Licences and High Risk Work Licences | Evidence that operators are licensed for the class of plant they are operating |
| Site Induction Records | Demonstrates all workers and visitors have received site-specific safety information |
| WHS Management Plan | Required for notifiable construction work; prepared by the principal contractor |
| Hazard / Risk Register | Documents identified hazards, risk ratings, and controls |
| Incident Register | Records all incidents, near misses, dangerous occurrences, and injuries |
| Training Register | Records qualifications, licences, tickets, and training completed by workers |
| Contractor / Subcontractor Register | Documents businesses engaged on site, their insurances, and safety compliance |
| Emergency Plan | Sets out emergency response procedures, including rescue from a collapsed trench |
| Insurance Records | Evidence of current public liability and workers compensation insurance |
| Toolbox Talk Records | Documents safety briefings conducted with workers |
SWMS and high risk construction work
Excavation work frequently triggers the high risk construction work (HRCW) provisions under the model WHS Regulations. A SWMS must be prepared and implemented before commencing any HRCW activity. For excavation contractors, the two most commonly triggered categories are:
- Excavation deeper than 1.5 metres — any trench, pit, shaft, or earthworks that reaches this depth requires a SWMS
- Work near underground services — work in proximity to gas mains, electricity cables, telecommunications infrastructure, water and sewer mains, or other buried services
A SWMS for excavation and trenching work must identify the specific HRCW activities involved, the hazards associated with them, and the controls that will be applied. Controls for deep excavations typically include ground assessment, shoring or benching, exclusion zones for plant, spoil management, and emergency rescue procedures.
For work near underground services, the SWMS must address how services have been located, the stand-off distances that will be maintained, the method of exposure (potholing, hand digging), and how service owners or asset managers will be notified.
See our excavation and trenching SWMS guide and underground services SWMS guide for detailed guidance on preparing these documents.
Dial Before You Dig and underground services records
Before any excavation commences, the contractor must take all reasonably practicable steps to identify underground services in the work area. In practice, this means:
- Submitting a Dial Before You Dig enquiry (or equivalent in your jurisdiction) and retaining the response, including any plans or drawings returned by service asset owners
- Reviewing as-built drawings and site plans where available
- Conducting physical verification such as potholing or vacuum excavation to confirm service locations before using mechanical plant near them
- Marking out identified services on the ground using paint or pegs
- Maintaining records of each step taken — search results, markout records, potholing logs, and any communications with asset owners
These records serve two purposes: they demonstrate due diligence if an incident occurs, and they form part of the SWMS documentation that supports the control measures in place for work near services. Regulators and courts have taken a serious view of excavation work near services carried out without adequate records of prior identification steps.
Geotechnical and shoring documentation
For excavations deeper than 1.5 metres, the ground conditions must be assessed before determining how the excavation will be supported. Relevant documentation includes:
Ground or geotechnical assessment
A ground assessment documents the soil classification, ground stability, the presence of groundwater or fill material, and any other site-specific factors that affect excavation risk. For minor works, this may be a brief written assessment by a competent person. For major or complex excavations — particularly those involving unusual soil types, high groundwater, surcharge loads from adjacent structures, or deep trenches — a formal geotechnical report from a qualified geotechnical engineer may be required.
Trench shoring or benching design
Where a trench or excavation cannot be adequately battered back to a safe angle, a support system must be designed and installed. The documentation for this system should record:
- The type of support system selected (e.g. hydraulic shoring, trench box, sheet piling, benching)
- The basis for selecting that system, including reference to soil classification and depth
- Where an engineered solution is required, the engineer's design and certification
- Inspection records confirming the support system was installed and maintained correctly
For standard excavations in Class 1 or Class 2 soils using proprietary shoring equipment, the manufacturer's documentation and a competent person's assessment may be sufficient. For more complex situations, engage a structural or geotechnical engineer.
Plant, equipment, and operator licences
Excavation contractors typically operate heavy plant including excavators, bobcats, backhoes, and civil compaction equipment. WHS obligations for plant include:
Plant and equipment register
A plant register should record each item of plant, its plant registration number (where required), the date of the last inspection or service, and when the next inspection is due. For registrable plant — which in most jurisdictions includes certain classes of earthmoving machinery — registration with the relevant state regulator may be required.
High risk work licences
Operators of certain classes of plant must hold a relevant high risk work (HRW) licence issued under the WHS Regulations. For excavation contractors, relevant licence classes may include:
- Excavator (EX) — for excavators above a certain operating mass depending on jurisdiction
- Skid steer loader (SS) — for skid steer loaders
- Forklift (LF) — if forklifts are used on site
- Dogging (DG) and rigging (RB/RI/RA) — if lifting operations are involved
Copies of current licences should be held on file and cross-referenced to the training register. Workers must not operate plant for which they do not hold the required licence.
Plant inspection records
Regular inspections of plant should be documented. Pre-start checks, periodic formal inspections, and any defect reports or repair records form part of the plant management documentation expected of a competent excavation contractor.
WHS policy, procedures, and management system documents
Beyond site-specific documents, an excavation contractor needs a broader set of WHS system documents that apply across the business.
WHS Policy
A WHS policy is a statement of commitment from the person conducting a business or undertaking (PCBU). It sets out who is responsible for WHS, what the business's obligations are, and how safety is managed. A written WHS policy is expected for any business with workers and is regularly requested by clients, principal contractors, and insurers.
WHS Procedures
Procedures describe how specific tasks and processes are carried out safely. Procedures relevant to excavation contractors typically include:
- Hazard identification and risk assessment
- Underground services identification and verification
- Plant pre-start inspection
- Incident reporting and investigation
- Emergency response, including trench rescue
- Contractor management
- Consultation and communication
Emergency plan
An emergency plan for an excavation site must address the specific emergencies that can arise — trench collapse, contact with a live service, plant rollover, worker entrapment, or flooding. The plan should include rescue procedures, contact details for emergency services and the relevant WHS regulator, and the location of first aid equipment.
Records and registers
Well-maintained registers demonstrate ongoing compliance and support incident investigation. Key registers for an excavation contractor include:
- Incident register: All incidents, near misses, dangerous occurrences, and work-related injuries or illnesses must be recorded. Serious incidents — including trench collapses, contact with underground services, and any hospitalisation — must be notified to the relevant WHS regulator.
- Plant and equipment register: Tracks all plant, its inspection status, and operator competencies, updated in real time.
- Training register: A current record of licences, inductions, and training completed by each worker. Particularly important for HRW-licensed plant operators.
- Toolbox talk records: Date, topic, presenter, and attendees for each safety briefing conducted on site.
- First aid register: Records first aid treatment provided, including the name of the person treated, the nature of the injury, and the treatment given.
Insurance records
Excavation contractors are typically required to hold and maintain evidence of current insurances. The most commonly required policies are:
- Public liability insurance: Required by most principal contractors and clients before granting site access. Coverage limits vary but are commonly $10 million or $20 million.
- Workers compensation insurance: Required in every Australian state and territory for businesses that employ workers.
Certificates of currency for both policies should be kept on file and updated when policies are renewed. Many principal contractors will request copies before allowing site access, and certificates should be readily available to provide on request.
Example scenario
Consider an excavation contractor operating in New South Wales with four full-time employees and a small fleet of two excavators and a bobcat. On a typical residential subdivision project, the business would typically hold:
- SWMS for excavation and trenching prepared before commencement, covering trench depths exceeding 1.5 metres, shoring systems, spoil management, and exclusion zones
- SWMS for work near underground services covering the Dial Before You Dig process, potholing requirements, and hand-dig exclusion zones around identified services
- Dial Before You Dig records for each site, including the search response, returned service drawings, and any markout records
- Geotechnical assessment for each site, documenting soil classification and the basis for the shoring system selected
- Trench shoring documentation for deep excavations, including the shoring system specifications and inspection records
- Plant register covering both excavators and the bobcat, with current operator licence numbers recorded and inspection dates tracked
- HRW licence records for each operator, cross-referenced to the plant register
- Site induction records signed by all workers before commencing on each new site
- Incident register maintained in real time, with any notifiable incidents reported to SafeWork NSW
- Toolbox talk records from pre-start briefings conducted each morning on site
- Insurance certificates of currency for public liability ($20 million) and workers compensation, available to provide to principal contractors on request
At the business level, this contractor would also hold a WHS policy, core WHS procedures, a training register, and an emergency plan — documents that apply across all projects rather than being site-specific.
Frequently asked questions
Does a sole trader excavation contractor need all these documents?
Yes — in most cases. Even a sole trader carrying out excavation work must have SWMS in place before commencing any high risk construction work, including excavation deeper than 1.5 metres and work near underground services. A WHS policy, incident register, plant register, and site induction records are broadly expected regardless of business size. Some documents such as a WHS management plan are triggered by the project type and value rather than the size of the business.
Is excavation always high risk construction work?
Not automatically — but excavation deeper than 1.5 metres is listed as high risk construction work (HRCW) under the model WHS Regulations, which means a SWMS is required before work commences. Work near underground services such as gas, electricity, or telecommunications mains is also HRCW. Many excavation jobs will trigger one or both of these categories, so contractors should review their activities against the HRCW list before mobilising to site.
Who is responsible for the Dial Before You Dig search — the excavation contractor or the principal contractor?
Either party may initiate a Dial Before You Dig search, but the excavation contractor carrying out the work typically holds responsibility for confirming services have been identified before breaking ground. Even where the principal contractor has conducted a search at the project planning stage, the excavation contractor should verify the records are current and cover the specific work area before commencing. Records of the search and any subsequent potholing or test trenching should be retained.
How often should excavation SWMS be reviewed?
SWMS should be reviewed before commencing work on each new site, and whenever site conditions change — for example, if unexpected ground conditions are encountered, groundwater is present, or the scope of the excavation changes. If work is suspended for a significant period, the SWMS should be reviewed before recommencing. Reviewing and re-signing the SWMS when conditions change is a practical way to demonstrate ongoing due diligence.
Get your excavation WHS documents in order
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This guide provides general information only and does not replace legal advice or consultation with the relevant WHS regulator. WHS document requirements may vary by state or territory, project type, contract conditions, and the nature of your role on site.