Your safety duty doesn't stop at your own payroll
Ask an operator how many people they are responsible for keeping safe and they will usually give you their headcount. Then a labour-hire crew arrives for the season, a contractor comes on for three days, a subcontractor brings their own people, and the real number turns out to be a lot larger than the payroll.
The duty follows the work, not the employment contract. If people are doing work you control, on your site, around your plant, your responsibility for their safety does not wait for them to be on your books. Most operators know this. Far fewer can show they have met it for anyone outside their own staff.
The way labour hire runs almost guarantees the evidence goes missing. A worker is inducted by the labour-hire company, then again by the host, then again at the next host, each time from scratch, each time on paper that stays with whoever ran the session. Nobody holds the whole picture. The worker has been inducted five times and nobody can say what, of any of it, actually stuck.
What is missing is a record that belongs to the worker rather than to one employer's filing cabinet. The host should be able to see what a person arriving on site has already been trained on and understood. The business that sent them should be able to see what the host has trained them on since. Right now that hand-off is usually a phone call and a hope.
This is not a paperwork nicety. When something goes wrong involving a contractor or a labour-hire worker, the first question asked is who was responsible for making sure they were safe to do the task. The answer is often more than one party, and all of them are now looking for evidence that lives somewhere else.
If your safety evidence describes only the people you employ, it describes a fraction of the people you answer for. The gap is not the training you ran for your own staff. It is everyone else who did the work and was never really inside your system.
