What a Code of Practice actually is
A Code of Practice is a document published by Safe Work Australia (and adopted, with minor variations, by every state and territory work health and safety regulator) that sets out the practical guidance a person conducting a business or undertaking — a PCBU, your employer — should follow to meet their obligations under the Work Health and Safety Act.
A Code is not, technically, a law. The law is the Act and its associated Regulations. The Code sits one rung below those: it is the regulator's published view of what good practice looks like, and it is what an inspector, a court, or a coroner will reach for when they need to decide whether a workplace did "what was reasonably practicable". A workplace that follows the Code is on safe ground; one that departs from it has to be able to explain why, and justify that the alternative was equally protective.
For first aiders, the Code that matters is the Model Code of Practice: First Aid in the Workplace, published by Safe Work Australia and adopted by every Australian jurisdiction in some form. It is freely downloadable from the Safe Work Australia website, and it is the single document that defines what a "first-aid arrangement" in an Australian workplace is supposed to look like.
§ Instructor's note
Learners often confuse "code of practice" with "law" — and the distinction matters because the wrong word makes the whole framework feel either softer or harder than it actually is. The Code is not mandatory in the strict sense: a PCBU can depart from it. But a PCBU who departs from it carries the burden of proving their alternative was equally safe, and that is a hard burden to discharge. In practice, the Code is the floor.
What the First Aid Code covers
The Model Code of Practice: First Aid in the Workplace covers the practical detail that most workplace first aiders run into:
- First-aid risk assessment — how a workplace identifies the kinds of injury and illness it is likely to see (the hazards in the place, the number of workers, the location, the distance from emergency services, the working hours, and the vulnerability of any of the people present).
- First-aid kit contents — the minimum contents of a workplace first-aid kit, scaled to the size and type of workplace. See the first aid kit contents chapter for the operational detail.
- First-aid facilities — when a workplace needs a dedicated first-aid room (typically larger workplaces or those with significant injury risk), what it must contain, and where it should be located.
- Number and training of first aiders — the recommended ratio of trained first aiders to workers, and the recognised training they should hold (HLTAID009 / 010 / 011 / 012). The Code references the same nationally-recognised units of competency this site is built around.
- Procedures for accessing first aid — signage, accessibility, who to call, how to summon emergency services, how to record and report incidents.
- Mental health and psychological first aid — newer editions of the Code include provisions for supporting workers' mental health, recognising that workplace incidents often have psychological consequences as well as physical ones.
The Code is written to be read by employers, but it is a useful read for first aiders too — it tells you what your employer is supposed to have already put in place, and gives you the language to ask about gaps.
The legal framework above the Code
The Code sits inside a larger structure that is worth knowing in outline:
- Work Health and Safety Act 2011 (Cth and most states/territories) — the head Act. Sets the duties of PCBUs, workers, and others. Establishes that a PCBU must, so far as reasonably practicable, ensure the health and safety of workers and others affected by the work.
- Work Health and Safety Regulations 2011 — the binding rules made under the Act. Specifies things like first-aid requirements, hazardous chemicals, manual handling, plant.
- Codes of Practice — published by Safe Work Australia, adopted by jurisdictions. Practical guidance on how to comply with the Act and Regulations. Admissible in court as evidence of what is reasonably practicable.
- Australian and international standards — e.g. AS 2675 — First aid kits, the ANZCOR clinical guidelines. Codes refer to standards; standards refer to clinical evidence.
Western Australia and Victoria have their own equivalent legislation that mirrors the model law with local variations. The substance is the same.
The phrase to remember from this whole stack is "reasonably practicable". A PCBU is not required to make the workplace risk-free — they are required to do everything that is reasonably practicable to control the risks. Reasonable depends on the size of the risk, the available controls, the cost relative to the risk, and the state of knowledge at the time. Codes of Practice are how the regulator publishes its current view of what "reasonable" looks like.
Where ANZCOR sits in this picture
ANZCOR clinical guidelines (the ARC guidelines chapter covers these in detail) are not Codes of Practice. They are clinical consensus documents from a peak body, not regulator-endorsed compliance documents. But they are referenced into the Code of Practice and into the training package: when the Code says a workplace first aider should be trained, the training that satisfies the Code is built on the ANZCOR protocols. So in practice the chain runs:
WHS Act → WHS Regulations → First Aid Code of Practice → HLTAID training package → ANZCOR clinical guidelines
A first aider following ANZCOR protocols is, by construction, doing what the Code expects, and a workplace whose first aiders are HLTAID-trained and ANZCOR-current is meeting the Code's training requirement. The two stacks fit together cleanly.
It's worth keeping the language straight: Codes of Practice are workplace compliance documents from Safe Work Australia and the WHS regulators; guidelines are clinical recommendations from ANZCOR. A Code tells you how many first aiders your workplace should have. A guideline tells you what each of them should do at the side of a casualty. Both matter, and they answer different questions.
Other Codes a first aider may run into
The first-aid Code is the central one, but a workplace first aider sometimes touches the edges of other Codes too:
- Model Code of Practice: How to Manage Work Health and Safety Risks — the general risk-management Code. Sits behind every workplace risk assessment, including the first-aid one.
- Model Code of Practice: Hazardous Manual Tasks — relevant if your workplace has lifting or repetitive-strain injuries you may be called to.
- Model Code of Practice: Managing the Risks of Hazardous Chemicals in the Workplace — relevant if your workplace stores or uses chemicals; the SDS folder and eyewash station live under this Code.
- Model Code of Practice: Confined Spaces — relevant if your workplace has tanks, silos, vaults, sewers, or any other confined-space environment. As the incident hazards chapter notes, confined-space rescue is not a first-aid task and a first aider should never enter one.
- Model Code of Practice: Managing the Work Environment and Facilities — covers basics like lighting, ventilation, drinking water, washroom access — the background conditions that prevent first-aid incidents in the first place.
Each is published by Safe Work Australia and adopted (with minor variations in name and number) by each state and territory regulator.
What a first aider actually needs to know
You will not be tested on the section numbers of any Code. What you should walk away with is:
- A First Aid Code of Practice exists, it's free, it's published by Safe Work Australia, and it's the document your workplace's first-aid arrangements are supposed to comply with.
- Your workplace is supposed to have done a first-aid risk assessment that considers the hazards, the number of workers, the location, the distance from medical help, and the type of work — and to have provisioned kits, facilities, and trained first aiders accordingly.
- The Code is admissible in court. If a workplace incident is investigated, the Code is what the inspector and the coroner read first.
- Your training, your kits, and your protocols all trace back through the Code to the WHS Act. This is not improvised. There is a paper trail behind every part of your role.
If you can see that your workplace is not meeting the Code — no first-aid kit, an empty kit, no trained first aider, no posted procedures, no incident register, no AED where the Code says one should be — that is the kind of thing to raise through your health and safety committee, your HSR, or directly with your manager. You are not personally liable for the gap, but you are a worker with a legal duty to raise it. If it isn't fixed, the next step is the WHS regulator in your state. See the workplace procedures chapter.
How the Code interacts with workplace policy
Most Australian workplaces have their own first-aid policy on top of the Code. Workplace policy can:
- Add detail beyond the Code — extra reporting steps, specific equipment, particular contact numbers, named first aiders, room locations. This is fine and is the normal way a Code is operationalised in a particular workplace.
- Not contradict the Code or the law. A workplace policy that tells you not to call an ambulance, or to perform a procedure outside your training, or to skip incident reporting, is in conflict with the Code and is not lawful. In that situation, the Code wins, the law wins, and you escalate.
The relationship is the same as the one between ANZCOR guidelines and casualty-specific action plans (covered in the peak body guidelines chapter): the more detailed document takes precedence as long as it doesn't contradict the broader one. Workplace policy on top of Code is fine; workplace policy that overrides Code is not.
A person conducting a business or undertaking (PCBU) must ensure, so far as is reasonably practicable, that an adequate number of workers are trained to administer first aid at the workplace, that first aid equipment is provided and maintained, and that access to facilities for the administration of first aid is provided. The number and type of first aid arrangements should be determined by a risk assessment that considers the nature of the work, the hazards present, the size and location of the workplace, and the nature of the workforce.
What not to do
- Do not treat the Code as bureaucratic background noise. It is the document the inspector reads.
- Do not assume your workplace has covered everything because no-one has complained. Codes are how things stay covered between incidents.
- Do not follow a workplace policy that conflicts with the Code or the law. Escalate.
- Do not confuse Codes (workplace compliance) with ANZCOR guidelines (clinical practice). Both matter, and they answer different questions.
- Do not wait for an inspector to fix gaps you can already see. Raise them through your HSR or committee.
You will not be tested on the contents of any Code, but you should be able to name the document (the Model Code of Practice: First Aid in the Workplace), say who publishes it (Safe Work Australia, adopted by state and territory regulators), and explain what it does (sets the workplace first-aid baseline). The instructor will likely walk you through the table of contents on screen so you know what to look for if you ever need to.
The Code of Practice is the bridge between the law and the day-to-day. The law says "do what is reasonably practicable"; the Code says, in concrete terms, what reasonable looks like in a workplace first-aid context. A first aider who knows the Code exists is a first aider whose workplace is harder to embarrass and easier to defend.
— Safe Work Australia, Model Code of Practice: First Aid in the Workplace