What is an SOP?

What is a Standard Operating Procedure?

An SOP is your documented answer to the question: "What is the safe way to do this task?" It translates risk assessments into actionable instructions that workers can follow at the point of work.

Under Section 19 of the Model WHS Act (mirrored in all Australian jurisdictions), you have a primary duty to ensure worker health and safety. This specifically includes providing and maintaining "safe systems of work" and providing "information, training, instruction, or supervision."

Your SOP is the written embodiment of both requirements. Courts have long held that a "system of work" includes the organisation of tasks, sequence of operations, and instructions provided. The SOP makes this explicit and verifiable.

Unlike a SWMS (Safe Work Method Statement), which is legally mandated only for High Risk Construction Work, SOPs are not explicitly required by regulation. However, the absence of documented procedures for hazardous tasks is powerful evidence that you've failed your duty of care.

SOP vs SWMS vs JSA

These safety documents serve different purposes and have different legal status. Using the wrong document type can leave you non-compliant or create unnecessary safety clutter.

The relationship typically cascades: You might have an SOP for operating a circular saw. When that saw is used on a roof (fall risk over 2m), a SWMS becomes legally required. The SWMS references your SOP but adds site-specific controls like tethering requirements and exclusion zones below.

When Do You Need an SOP?

You need an SOP whenever a task involves hazards that require consistent controls to manage risk. The WHS Act doesn't mandate SOPs for every action—that would create safety clutter. Instead, focus on tasks where:

The task involves significant hazards: Operating machinery, working with chemicals, working at heights below SWMS thresholds, confined space entry preparation, vehicle operations, electrical isolation.

Consistency is critical for safety: Tasks where variation in method creates risk. Lockout/tagout procedures, emergency response protocols, equipment pre-start inspections.

Multiple workers perform the task: When several workers do the same job, an SOP ensures everyone follows the same safe method, preventing improvisation that could introduce risk.

Training and competency verification are required: SOPs provide the documented standard against which you assess worker competency. Without the SOP, how do you prove workers were trained in the correct method?

You don't need SOPs for low-risk, intuitive tasks like walking through hallways. Over-documenting creates "safety clutter"—procedures that exist for auditors rather than workers, diluting the importance of critical procedures.

How to Develop Effective SOPs

Creating a compliant and effective SOP requires rigorous methodology. The "cut and paste" approach—taking generic templates without adaptation—is insufficient and potentially negligent.

Step 1: Mandatory Consultation

Section 49 of the WHS Act explicitly requires consultation with workers when proposing changes affecting health and safety. This isn't optional—it's your legal duty.

Workers possess knowledge of "Work-as-Done"—the reality of how tasks are actually performed, including quirks of equipment, environmental constraints, and common pitfalls. An SOP written solely by managers reflects "Work-as-Imagined" and will fail in practice.

You must involve Health and Safety Representatives (HSRs) where they exist. Give workers genuine opportunity to express views and incorporate their feedback. Document this consultation—meeting minutes and draft review comments serve as evidence of compliance.

Step 2: Risk Assessment Integration

Your SOP is essentially a list of risk controls arranged in sequence. It must be based on formal risk assessment following the Code of Practice: How to Manage Work Health and Safety Risks.

Identify the task boundaries (start and end points). Analyse hazards at each step (entanglement, noise, chemical exposure, manual handling injuries). Determine controls using the hierarchy of controls—can you engineer the risk out? If not, what administrative step or PPE is required?

Each control becomes an instruction in your SOP. For example: Risk = "Eye injury from flying debris." Control = "Safety glasses." SOP Step = "Don safety glasses before engaging power."

Step 3: Structure and Components

Best practice from Safe Work Australia and state regulators suggests standardised structure for consistency and readability:

Header section: Title, unique ID number, version number, date of issue, next review date, responsible manager.

Purpose statement: Brief description of what the SOP covers and when to use it.

PPE requirements: Visual icons (safety boots, glasses, hearing protection, gloves) at the document top allow 5-second scanning. List minimum PPE requirements for the entire task.

Pre-operational checks: Steps to verify equipment is safe before use. "Check guards are in place," "Test emergency stop," "Verify electrical cord has no damage."

Operational steps: The core instructions. Numbered, chronological steps using clear command language. One instruction per step.

Prohibitions: Explicit "DO NOT" statements highlighting critical errors. "Do not wear loose clothing," "Do not bypass safety interlocks," "Do not operate if guards are damaged."

Emergency procedures: Immediate actions for failure modes. "If jam occurs: Press E-Stop, isolate power, wait for blade to stop before clearing blockage."

Post-task procedures: Shutdown sequence, isolation requirements, cleaning and housekeeping, defect reporting.

Step 4: Write in Plain English

Your SOP's effectiveness is limited by the literacy and cognitive capacity of your users. Australian Government style guides emphasise Plain English principles:

Use short sentences (15-20 words maximum). One instruction per step. Use active voice with command verbs: "Turn the valve," not "The valve should be turned." Avoid bureaucratic language—use "Stop" instead of "Cease," "Use" instead of "Utilise."

Visual dominance matters. An annotated photograph of machine controls is superior to text descriptions. Use whitespace generously—densely packed text causes cognitive fatigue and increases the likelihood workers skip steps.

Implementation and Training

Creating the document isn't enough. A "safe system of work" only exists when the SOP is implemented, understood, and followed.

Training Requirements

Section 19(3)(f) requires you to provide training. However, "training" differs from "presentation." Having workers sign an attendance sheet for a toolbox talk is weak evidence of competence.

Best practice requires practical Verification of Competency (VOC)—workers demonstrate the task under supervision, following the SOP step-by-step. An assessor confirms they can safely perform each step. Document these assessments rigorously.

Maintain training records as evidence of due diligence. In incident investigations, regulators will ask: "When was the worker trained on this SOP? Who verified their competency? Where are the records?"

Supervision and Culture

Supervision ensures training is applied consistently. If supervisors observe workers bypassing safety guards or skipping SOP steps without intervention, they've effectively condoned the deviation.

This "normalisation of deviance" undermines your SOP's legal standing. Courts repeatedly find that "unwritten rules" (what supervisors accept) override "written rules" (the SOP) in determining liability. Your actual system of work is what happens, not what's written.

Accessibility at Point of Work

SOPs must be accessible where and when workers need them. Paper SOPs in dusty binders in site offices are often inaccessible.

Laminated SOPs attached directly to equipment work well. QR codes on machinery linking to digital versions on workers' phones provide immediate access. Digital platforms allow instant updates with version control and can support video demonstrations for complex tasks.

For remote or isolated work, workers need offline access via downloaded PDFs or printed copies. The test is simple: Can the worker access the current version when they need it?

Review and Maintenance

Your SOP is a living document. Regulation 38 of the Model WHS Regulations dictates specific triggers requiring review and revision.

Mandatory Review Triggers

You must review and revise your SOP when:

An incident or near miss occurs: If your SOP failed to prevent an incident, it's defective until reviewed. The incident may reveal a gap in the procedure or controls that are impractical.

Work processes change: New equipment, new chemicals, modified workspace layout, or changes in how the task is performed all require SOP updates.

New hazards are identified: Discovery of risks not previously considered (like new health data on chemical exposure) requires immediate review.

Workers request review: If workers or HSRs request review because the SOP is unworkable or unsafe, you must respond. Ignoring worker feedback creates the gap between Work-as-Imagined and Work-as-Done.

Health monitoring reveals control failure: If health surveillance (hearing tests, lung function tests, blood lead levels) shows controls are ineffective, your SOP must be revised.

Periodic Review

Even without specific triggers, review SOPs periodically (typically every 2-3 years) to ensure alignment with current industry standards and "state of knowledge."

This review should involve workers currently performing the task to capture any procedural drift or improvements in practice. You may discover workers have developed safer or more efficient methods that should be incorporated.

Common Challenges and Solutions

The Shelfware Problem

SOPs written for auditors, not workers. They're stored in binders and never opened. The fix: Involve workers from day one. If workers can't explain the SOP, it has failed.

Over-Prescription

SOPs that script every micro-movement ("lift hand 10cm, rotate wrist 45 degrees") remove worker agency and create malicious compliance where work slows to a halt. The fix: Focus only on steps that control risk. Don't document common sense.

Outdated Content

SOPs describing equipment replaced three years ago. The fix: Regular review cycles and version control. Digital platforms can flag SOPs approaching review dates.

Low Literacy and Language Barriers

Text-heavy documents are impenetrable to workers with low literacy or English as a second language. The fix: Use visual instructions with photos and diagrams. Provide translated versions for non-English speaking workers. Use verbal explanation with interpreter if needed.

The Gap Between Procedure and Practice

This is the most dangerous failure mode. When workers must violate the SOP to complete work (because it doesn't reflect reality), you're managing imagined risk while actual risk remains uncontrolled.

The fix: Regular "SOP walk-throughs" where workers perform tasks while following the written procedure. Any deviations or impossibilities are corrected immediately. This validates that Work-as-Done matches Work-as-Written.

Officers' Due Diligence Obligations

Section 27 of the WHS Act requires Officers (Directors, CEOs) to exercise due diligence ensuring your organisation complies with its duties. For SOPs, this means Officers must actively verify:

Do we have SOPs for our critical risks? Are they current and site-specific? How do we know they're being followed? What's our review process?

Officers can't be "hands-off." They need verification mechanisms like receiving audit reports on SOP compliance, reviewing incident investigations that examine SOP adequacy, and ensuring resources are allocated for SOP development and training.

Personal liability attaches to Officers who fail these obligations. The case of SafeWork NSW v Miller Logistics demonstrated that while Officers aren't expected to write SOPs themselves, they must have systems ensuring SOPs exist, are maintained, and are actually used.

Digital SOPs and Modern Workplaces

The regulatory framework is technology-neutral. Digital SOPs are fully compliant provided they meet accessibility and usability requirements.

Digital platforms offer advantages: instant updates with version control ensuring everyone has current procedures, multimedia support for photos and videos, usage tracking showing who accessed which SOP when, integration with training records and competency management.

However, devices must be safe to use in the environment. Intrinsically safe devices are required in explosive atmospheres. Workers need reliable access even if batteries die or network coverage fails.

For work-from-home arrangements, you must provide SOPs covering ergonomic setup, electrical safety (use of personal electrical equipment), and communication protocols. While you can't write SOPs for workers' private homes, you can specify minimum safety standards as conditions of remote work.

Why SOPs Matter

Legal Protection

When incidents occur, comprehensive SOPs demonstrate you identified risks and provided clear instruction. Courts view absence of procedures as evidence you failed your duty of care.

Consistency and Quality

SOPs ensure all workers perform tasks the same safe way, preventing improvisation that could introduce risk. This consistency improves quality and reduces rework.

Training Foundation

SOPs provide the documented standard against which you assess and verify competency. They're essential for inducting new workers and contractors.

Continuous Improvement

The process of writing and reviewing SOPs forces critical examination of work methods. You often discover opportunities to eliminate hazards through redesign rather than relying on procedures.

Operational Resilience

SOPs reduce dependency on individual workers' knowledge. When experienced workers are absent or leave, their knowledge remains documented and accessible.