About safety management plans

What is an SMP

SMPs enhance the safety of public passenger services. Your SMP will identify hazards relevant to your service. Once you have identified the hazards, you will need to decide on the actions to be taken to eliminate or reduce risks. Your SMP will also show who is responsible for controlling the risks associated with the hazards you have identified.

Your SMP will help make sure you meet your legal safety responsibilities under Chapter 6A of the Transport and Other Legislation Amendment Act 2024.

Your SMP must:

• identify and describe each potential hazard related to providing the service
• assess the safety risks that might arise because of exposure to hazards
• outline the actions to be taken to eliminate or reduce the safety risks
• specify who is responsible for taking these actions.

Who must have an SMP

Responsible duty holders must have an SMP and ensure it is followed for the public passenger service.

There may be more than 1 responsible duty holder for the same public passenger service. Responsible duty holders can work together to decide who is best placed to develop and maintain the SMP. This decision can consider factors such as the:

• tasks or responsibilities the person carries out, whether they do so all the time or only occasionally
• type of safety risks involved in the activity
• person's capacity to eliminate, control or reduce those risks.

Even if someone else takes the lead in managing the SMP, each duty holder is still legally responsible for meeting their own safety obligations. These responsibilities can't be passed on to someone else.

Who must comply with the SMP

A duty holder must follow the SMP of the responsible duty holder as much as is reasonably practicable, where it applies to them. Duty holders for a road-based public passenger service include:

• an operator of a service
• a registered operator of a vehicle used to provide the service
• the driver of a vehicle used to provide the service
• a booking service provider for the service
• a driver contracted by a volunteer association
• a holder of a personalised transport service licence, including taxi service licence, limousine licence or booked hire service licence
• a local nominee—for foreign authorised booking entities.

A responsible duty holder must advise duty holders about their roles and responsibilities under the SMP. Ensure duty holders who are responsible for owning risks are aware of this.

Developing your SMP

If you already have documents that cover what's required of an SMP, you can use these instead of creating a whole new separate plan.

Your SMP may form part of a wider safety management system for your entire business. It may be similar to, be part of, or reference, any plans you already have in place under the Work Health and Safety Act 2011 (WHS Act) or the Heavy Vehicle National Law (HVNL).

We are creating an example SMP template to show you what your SMP could look like. It will be available early 2026. Using this template is optional, you can use existing or custom processes so long as they meet the legal requirements for an SMP.

We are also developing a list of common hazards that may apply, to help you develop your plan. These will also be available early 2026.

Read more about how to develop an SMP.

Requirements for your SMP

Your plan must be in writing and state the day it takes effect.

The duty holders of your service must be consulted and included in the development and review of your plan. You must make sure your plan is accessible to them, along with all relevant documents, such as policies, procedures, records and controls, and other documents mentioned in your plan.

You must fully review your plan every 3 years. You must also review your plan in response to certain events, such as:

• after safety incidents
• if your service changes
• new or changing risks.

Read more about the requirements for SMPs.

Consultation for SMPs

When creating or reviewing an SMP, you must, so far as reasonably practicable, consult with all duty holders for your service.

There are no specific requirements about how you should conduct your consultation—however it's important to keep a record of your consultation process. The best way to consult will depend on:

• the size and structure of your business
• when duty holders work and where they are located
• the needs and preferences of duty holders.

Make sure your consultation process provides opportunities for duty holders to share their views, questions and concerns. To do this, you could:

• give duty holders a draft copy of the risk assessment before consultation so they have time to think about it and form their feedback
• hold consultation at different times to cover duty holders working different shifts
• hold consultation through different formats (e.g. over video call) to cover duty holders with different work arrangements
• provide an opportunity for duty holders to provide anonymous feedback through surveys
• hold special meetings with staff who undertake specific tasks
• make translation or interpretation services available for culturally or linguistically diverse duty holders.

For smaller services, your consultation could be as simple as holding a meeting where you ask duty holders about new hazards or changes in risks, inform them of proposed changes and ask them to provide feedback.

For sole traders, where the responsible duty holder preparing the SMP is the only duty holder of the service, no formal consultation will be required, and your SMP should note that there is only 1 duty holder.

Make sure you consider all feedback received and communicate the outcomes of the consultation in a timely manner.

If there is more than 1 responsible duty holder, the consultation should clarify who will be in charge of creating and maintaining the SMP.

Your consultation does not require you to provide:

• personal or medical information about a person, without consent
• confidential commercial information
• information that is privileged or subject to a duty to maintain confidentiality under an Act.

Reviewing and updating your SMP

As a responsible duty holder, you must fully review your SMP at least once every 3 years to keep it up to date and to manage new hazards or changing risks. The review may be conducted internally or by an external provider—it could be scaled in a way that suits your business.

You must also review your SMP in response to certain events any time before the 3 years, to the extent needed:

• following a material change to the service, such as a new route, service, or vehicle
• if the operator has completed an incident report—for an operator of a service requiring operator accreditation
• when a duty holder has reported a notifiable incident about a vehicle, driver or passenger to the regulator under the Work Health and Safety Act 2011
• when a duty holder reports a hazard in writing that isn't already included in your plan, or hasn't been adequately addressed (you must keep this report on record)
• when a responsible duty holder becomes aware, or should be aware, that the SMP may not comply with the requirements for a SMP.

After each review, you must revise or replace your plan as soon as practicable.

The reason for each review and the outcome must be recorded in writing and these records need to be kept for at least 5 years. If you don't need to make changes, you can record this on your plan and note why.

Accessing SMPs

Your SMP and any related documents must be easy for all duty holders in the service to access, whether in hard copy or electronic form. Make sure the duty holders know how to access the SMP and ensure it's always available to them.

If asked, you must provide your SMP and related documents in either hard copy or electronic form, or allow your plan to be inspected. This request could come from the chief executive of the Department of Transport and Main Roads (TMR) or another authorised person, and you'll need to comply as soon as reasonably practicable.

SMP record keeping

Records must be kept for at least 5 years. This includes:

• each version of the SMP
• documentation about reviews and outcomes
• the most recent SMP after the responsible duty holder stops providing services in Queensland.

It is good practice to keep your plan and attached documents in a secure location and backed up.

Also consider...

• Learn more about developing a safety management plan.
• Read about safety obligations for road-based public passenger services.