Developing a safety management plan
New safety management framework for all road-based public passenger services
20 February 2026—The new framework started. Existing industry service providers who continue to comply with the previous framework will have 6 months to transition. New service providers must comply straight away.
20 August 2026—All industry service providers must comply, and safety management plans are mandatory.
This page explains the changes that started with the new framework. Learn more about the new safety management framework.
As a responsible duty holder, when you develop your safety management plan (SMP), you should consider the safety hazards relating to the people involved in providing the service, the vehicles used and how the service is operated. It may include any policies, procedures, processes and practices relevant to providing the passenger service.
Requirements for SMPs
Consider your existing safety documentation before developing your SMP. You don't need to create a whole new, separate plan if your existing documents already cover what's required.
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.
To ensure SMPs are consistent and effective, the following rules apply.
The SMP for a road-based public passenger service must:
- be in writing
- state the day it takes effect
- be accessible to duty holders, along with all relevant documents, policies, procedures, systems, records, controls, and other documents mentioned in the SMP
- be fully reviewed at least every 3 years
- be reviewed to the extent needed in other circumstances—such as safety incidents, changes in the service, or in response to new or changing risks
- be developed or reviewed in consultation with other duty holders for the service.
Follow the requirements for:
Learn more about the steps involved in completing a risk assessment for your SMP.
SMP example template
We have created an SMP example template to show you what your SMP could look like. Using this template is optional—you can use a plan format that suits you, such as an existing plan, or a new plan specially designed for your business, so long as it meets the legal requirements for an SMP.
You can use the example template as a guide, or as a starting point and change it to suit the individual needs of your business. For example, you may need additional pages to capture all the relevant hazards in your business. The identification, assessment and treatment of risks needs to be considered by operators having regard for their own operations.
Make sure you attach copies of any documentation you reference in your SMP. For example, if one of your risk mitigation strategies is to use a daily inspection checklist, attach a copy of this to your plan.
Download the SMP example template
Developing your SMP
We suggest that your SMP has 3 sections:
- Administrative details
- Risk assessment
- People
- Vehicles
- Other factors
- Reviews and consultation
1. Administrative details
Record basic administrative details such as:
- your business name
- who the responsible duty holders are
- the date the current version of the plan starts.
You can also use this section to record details of:
- the development of your plan
- who was consulted
- the version history.
The version history helps you keep track of the changes you've made to your plan, and which version of the plan was applied at a particular point in time.
Example of version control
| Version number | Date | Changed by | Reason for change | New or amended documentation | Consulted with | Approved by | Approval date |
|---|---|---|---|---|---|---|---|
| 1.01 | 12/09/2026 | John Smith | New risk identified by driver regarding standing passengers. | Amended driver training and introduced new signs on bus for passengers. | Drivers | Joe Bloggs, Director | 13/09/2026 |
| 2.0 | 23/07/2027 | John Smith | Comprehensive review as required every 3 years. | No new hazards but risk controls updated. | Drivers and administrative staff | Joe Bloggs, Director | 24/07/2027 |
2. Risk assessment
There are 4 steps involved in completing a risk assessment for your SMP:
- Identify and describe hazards.
- Assess the level of risk associated with the hazard.
- Decide on actions which can either eliminate or reduce the risk (controls).
- Nominate someone or a group of people responsible for taking the action.
Step 1. Identify and describe hazards
Start by identifying potential hazards to your passenger service. A hazard is something that can cause damage or harm to a person or property.
To identify hazards for your service, you could:
- consider past events and risks that your service has encountered
- think about possible future changes to your business
- look at past hazard logs, incident reports and customer feedback
- consult with drivers or staff
- research common risks online, including our guides
- check any incident or near-miss report records available to you.
We suggest dividing hazards into 3 sections: people, vehicles, and other factors. This helps make sure all parts of the service are covered by the risk assessment. If you think a hazard could fit into multiple sections, decide which one feels most appropriate.
To describe the hazard, think about and record the potential harms that could result from each hazard. It may be helpful to think through practical 'what if' scenarios. For example, what if a driver got distracted by their phone or a passenger? This might prevent them from reacting properly while driving, potentially causing a serious accident.
To help you develop your SMP, we've provided a list of common hazards for road-based public passenger services that may be relevant to your service. This list is not a replacement for conducting your own risk assessment but is designed to help you identify and start thinking about potential hazards specific to your service.
Example: Identify and describe hazard—for improper luggage storage
Carrying, hauling or storing luggage improperly includes issues such as overloading luggage compartments or failing to secure items properly, which can pose safety risks during travel.
Harm the hazard could cause
- Luggage could fall and injure passengers, or block exits and create tripping hazards.
- Wrongly placed luggage may impede the movement of passengers with mobility issues.
- Overloaded luggage compartments could affect weight limits and/or the distribution of load.
Step 2. Assess the level of risk associated with the hazard
Rate the consequence—the severity of harm a hazard could cause
Assign a score between 1 and 5 to each hazard you've identified. This score represents how severe the consequences could be if the hazard isn't controlled and an incident happens. This is called the 'consequence' score.
Use the definitions in this table to help you determine the most accurate consequence score.
| Consequence (severity of harm the hazard can cause) | Score |
|---|---|
Catastrophic—multiple fatalities or severe permanent disablement (physical or psychological) to multiple people | 5 |
| Major—single fatality or substantial injuries, or severe permanent disablement (physical or psychological) | 4 |
| Moderate—medical treatment required, or injury (physical or psychological) requiring time off work or restricted work duties | 3 |
| Minor—first aid treatment or wellbeing check in required | 2 |
| Insignificant—no treatment required | 1 |
Rate the likelihood—how probable it is that the hazard will occur
For each hazard you've identified, think about how likely it is to happen if no controls or safety measures are in place. Also consider whether it has occurred before in your business or industry.
Give the hazard a score from 1 to 5—this is your 'likelihood' score. Use this table to choose the most accurate likelihood score.
| Likelihood (how likely it is that the hazard will occur) | Score |
|---|---|
| Almost certain—the hazard is almost certain to occur in most circumstances (more than once per month) | 5 |
| Likely—the hazard is likely to occur frequently (more than once per year) | 4 |
| Possible—the hazard might occur at some time (once every 1–10 years) | 3 |
| Unlikely—the hazard is unlikely but could happen (once every 10–50 years) | 2 |
| Rare—the hazard may occur only in rare or exceptional circumstances (less than once every 50 years) | 1 |
Calculate the risk rating for each hazard
The risk rating is a number that shows the level of risk for a specific hazard, helping you prioritise risks and decide what actions are needed to eliminate or reduce them.
To work out the risk rating, multiply the consequence score by the likelihood score. This will give you a number between 1 and 25. Check the table below to see what the risk rating means for each hazard and review the suggested actions.
| Risk rating | Outcome |
|---|---|
| 16–25 Very high | Consider immediately stopping any activity that leads to the hazard until you can put in place procedures or policies to eliminate the hazard, or where this is not reasonably possible, reduce the risk to an acceptable level. |
| 10–15 High | Action is required as soon as possible to prevent any further injury or illness. |
| 4–9 Medium | Action is required within a reasonable time period, or when practicable, to prevent any further injury or illness. |
| 1–3 Low | Action is required but not urgently. Consider strategies to reduce the risk. |
Example: Assess the level of risk—for improper luggage storage
This example is provided as a guide only and is not intended to replace your own risk assessment of a hazard.
In this scenario, improper luggage storage has been identified as a hazard.
Consequence score
After consulting with other duty holders and conducting research, you've determined that the worst possible consequence would be 'moderate', as falling luggage could lead to a physical injury requiring medical treatment. Based on the consequence scale, a moderate outcome is assigned a score of 3.
Likelihood score
You assess the likelihood of improper luggage storage causing harm and determine that, without safety controls, luggage is likely to fall and injure passengers about once a month. According to the table, this is classified as 'likely', which has a score of 4.
Calculating the risk rating
To calculate the risk rating for this hazard:
Consequence (3) x Likelihood (4) = 12 (High risk)
According to the table, a risk rating of 12 means that improper luggage storage is a high risk for the service and action is needed as soon as possible to prevent further injury or illness.
Step 3. Decide on actions which can either eliminate or reduce the risk (controls)
After you have calculated the risk rating for a hazard, decide on the actions you will take to either eliminate the hazard, or where this is not reasonably possible, reduce the risk. A hazard can be controlled in a number of ways, and through multiple actions taken by different people.
For some hazards in your business, this may be as simple as writing down what you are already doing to control a risk. For other hazards you may need to do some research or seek advice on the best course of action.
When deciding what actions to include, focus on what you and your duty holders can directly control to eliminate or reduce the risk of a hazard.
For example, for the hazard 'Road conditions' if a new pothole appears on a road, your actions might include having a policy requiring drivers to report it. You might also take steps like warning other drivers, advising them to slow down, and directing them to safely avoid the pothole until it’s fixed. You could also report the pothole to the council or the appropriate authority, but that doesn't remove the immediate risk for you, the driver, or passengers. Since fixing the pothole it is outside your control, it's not helpful to include that action in your SMP. Focus instead on what you can do right away to manage the hazard.
Step 4. Nominate someone or a group of people responsible for taking the action
Decide who is the person or people responsible for taking the actions to eliminate or reduce the risk. You can specifically name someone, put down a role (e.g. operator), or a group of people (e.g. drivers).
In some instances, more than 1 duty holder may be responsible for a control. For example, an operator and/or vehicle owner may be responsible for the driver procedures and equipping vehicles with appropriate tie-downs, and the driver may be responsible for ensuring the luggage is stored correctly.
Example: Actions and who will undertake them—for improper luggage storage
The hazard in this example might not apply to your service, and the suggested actions or people responsible may not be suitable for your SMP.
| Hazard | Action/s to eliminate or reduce the risk | Who will undertake the action/s |
|---|---|---|
| Improper luggage storage | Install signs to explain to passengers how to store luggage safely. | Operator |
| Increase luggage carrying capacity through use of trailers, tie downs or cargo netting if required/where appropriate. | Operator | |
| Have policies and procedures for monitoring and ensuring that luggage is carried, hauled or stored correctly. | Operator | |
| Ensure drivers follow the policies and procedures correctly. | Operator/Drivers |
3. Reviews and consultation
Your SMP should include a section to record details when you review your plan.
After completing a review, one of your actions may be to insert a new hazard or change the way a risk is managed. You can make changes in the 'risk assessment' section and label the plan as a new version (e.g. Version 1.0 to Version 1.1). If you make a change, you should consult the duty holders that the change affects. You should also keep superseded versions of your plan for at least 5 years from the day they are replaced.
Read more about reviewing and updating your SMP and consultation for SMPs.
Also consider...
- Learn more about safety management plans.
- Read about common hazards for road-based public passenger services.
- Find out more about safety duties for road-based public passenger services.