Why PCBUs should consider a 'for hire' rescue coverage as an option over internal teams:

If you operate a commercial plant, processing facility, workshop, terminal, or industrial site in Western Australia, rescue for confined spaces and work at height are legal and operational requirements from the outset, not afterthoughts.

This requirement is particularly critical for smaller teams.

Many PCBUs operate efficient sites with small teams.

Often, the same staff handle plant operations, isolations, permits, gas testing, supervision, contractor coordination, and production demands. During outages, these pressures increase. Even if your paperwork is perfect, you risk a major gap if rescue duties fall to people already busy with other essential tasks.

Engaging a professional on-call rescue team addresses compliance, practicality, and cost-effectiveness.

Safety Heights & Rescue specialises in training, consultancy, and rescue services for outages, construction, and maintenance safety, with a primary focus on heights, high-risk work, and confined space operations. As a registered training organisation (RTO 52610) delivering nationally recognised training, they provide mobile services across Australia, supply rescue equipment and support outage management and risk consulting.

The legal reality for PCBUs in WA: rescue duties stay with you

Under the Work Health and Safety Act 2020 (WA), the PCBU carries the primary duty of care. Section 19 states that a PCBU must, so far as is reasonably practicable, ensure the health and safety of workers. Section 14 is blunt: “A duty cannot be transferred to another person.”

This point is crucial. This consideration is essential when outsourcing rescue services. Rescue service is a strong control measure, but it does not relieve the PCBU of its duty. What it does is give the PCBU a realistic way to properly discharge that duty—especially when the site lacks the headcount, equipment, or specialist capability to maintain a full-time in-house emergency response team. That is the grown-up version of “outsourcing”: not shifting responsibility, but bringing in competence and capacity.

The WA Act also mandates coordination. Section 46 requires duty holders to consult, cooperate, and coordinate when duties are shared. Section 47 requires consultation with workers affected by WHS matters. In outage work, where roles often overlap, these are legal requirements, not mere formalities.

Officers also have due diligence duties under section 27 to make sure the PCBU meets its WHS obligations. This means having the right resources and processes to reduce risk. Rescue coverage is one of the key resources officers should be able to demonstrate confidently.

Confined space is not just about entry.

In WA, the Work Health and Safety (General) Regulations 2022 set clear rules for confined spaces. For PCBUs, the key point to remember is that compliance is about having a complete system, not just a single document.

What the WA Regulations require (and what that means on-site)

The WA Regulations include explicit requirements for:

• Confined space entry permits and risk assessment (reg 67 and reg 77)

• Communication and safety monitoring (reg 69)

• Emergency procedures (reg 74)

• Personal protective equipment in emergencies (reg 75)

• Information, training and instruction (reg 76)

Many sites underestimate the importance of rescue preparedness.

WA regulation 74 requires PCBUs to establish and test emergency procedures for confined space work, and to provide workers with appropriate information, training, and instruction. This regulation requires proactive preparation, including a standby-and-rescue-ready approach before entry.

Practical guidance is explicit: a standby person, rescue equipment, and regular practice are required. SafeWork Australia’s model code for confined spaces, adopted nationally and supported by WA’s framework, outlines the components of a safe system. The code states:

• Before a worker enters, a standby person must be assigned to continuously monitor well-being, observe the work if practicable, and initiate emergency procedures if needed.

• The standby person should remain outside the space and do no other work that interferes with monitoring.

• Required rescue equipment should be immediately available.

• The standby person should never enter the space to attempt rescue.

This final point is particularly important for plant operators.

Personnel responsible for permits, gas testing, or operations are typically already managing multiple tasks. Even if qualified, they are often unavailable to serve as a dedicated, rescue-ready standby. The code requires the standby role to be continuous and undistracted. Assigning additional duties to the standby person compromises the role before entry begins.

The same code also states that first aid and rescue procedures must be initiated from outside the confined space as soon as practicable, that openings need to allow emergency access, and that rescue equipment and PPE must be maintained in good working order. It also says that rescue procedures must be rehearsed and that, if possible, the rescue should be performed from outside the space by adequately trained workers.

This distinction separates mere documentation from genuine rescue capability. First, you need rescue procedures.

Many sites treat height rescue and confined space rescue as separate, but these often overlap, particularly during shutdowns, tank work, and work on elevated structures, platforms, and access systems.

The WA Regulations (Part 4.4 Falls) set the hierarchy clearly:

1. Work on the ground or on a solid construction where possible (reg 78)

2. If elimination is not reasonably practicable, minimise risk using the hierarchy in reg 79:

   • fall prevention device first

   • Then the work positioning system

   • and only then, a fall arrest system (if higher controls are not reasonably practicable)

Regulation 80 then applies: if a PCBU uses a fall arrest system, they must establish and test emergency procedures, including rescue procedures, and ensure that workers receive appropriate information, training, and instruction. Compliance requires the ability to perform timely, effective rescues, not just the possession of equipment.

The Safe Work Australia falls code is equally direct. It explains suspension intolerance (sometimes called harness suspension trauma), notes that quick rescue of a suspended person is vital, and says workers should be capable of conducting rescue and familiar with site rescue equipment and procedures. It also reiterates that if a PCBU uses a fall arrest system, emergency and rescue procedures must be established and tested so they are effective.

A site may comply with harness requirements on paper but remains at risk if rescue plans are unclear, untested, or depend on unassigned personnel.

Australian Standards are important, but must be applied correctly.

A common misconception is that “the Standard is the law.” SafeWork Australia clarifies that standards are not automatically legal requirements unless referenced in legislation, though they serve as important technical benchmarks and practical guides. While not every standard is mandatory, disregarding them is both risky and difficult to justify.

For this topic, the key standards and standard references commonly used include:

• AS 2865:2009 – Confined spaces (the core Australian Standard for confined spaces)

• AS/NZS 1891.4:2009 – Industrial fall-arrest systems and devices – Selection, use and maintenance (referenced repeatedly in the falls code)

• AS/NZS 1715 – Selection, use and maintenance of respiratory protective devices (explicitly referenced in the confined spaces code for further guidance)

For PCBUs, the key point is that your plant’s rescue arrangements must comply with legal requirements and recognised standards, particularly for fall arrest systems, respiratory protection, and confined space rescue equipment.

Why on-call rescue makes sense for lean plants and outage-heavy operations

This highlights the business case for on-call rescue services.

1) You stop pulling critical people away from plant operations

On many sites, the people most likely to be nominated as standby/rescue support are the same people needed for:

• permit issuing

• gas testing

• isolations

• operations monitoring

• contractor coordination

• shutdown planning and sequencing

During outages, these roles are already under significant pressure. Assigning rescue standby duties creates a conflict, as rescue requires full attention while outage work is demanding.

A dedicated on-call rescue team resolves this issue by allowing operators to focus on their primary responsibilities, maintaining permit office operations, and ensuring gas testers can perform their duties, while the rescue team remains prepared for emergencies.

2) You avoid the expense of training large numbers of staff for infrequent rescue scenarios.

Developing in-house rescue capability requires more than sending a few staff to training.

To keep it credible, you need:

• initial training

• refresher training

• scenario drills

• competency maintenance

• supervision

• documentation

• roster depth (because leave, fatigue, and attrition happen)

If rescue events and confined space shutdowns are infrequent, maintaining in-house capability can be costly and underutilised.

Safety Heights & Rescue’s combined model of rescue services and RTO capability enables PCBUs to scale effectively by outsourcing specialist rescue coverage and training only those internal roles that require in-house competence, such as permit holders, spotters, gas testers, supervisors, and selected responders. The company is positioned as both a specialist rescue provider and a training organisation, offering services in confined spaces and working at heights.

3) You avoid the costs and responsibilities of owning and maintaining rescue equipment that is seldom used.

Specialist rescue equipment is not “buy once and forget.”

Equipment for confined space and height rescue requires:

• scheduled inspection

• service records

• testing and tagging (where applicable)

• calibration (for gas detection)

• replacement of time-expired components

• storage and transport controls

• competence in setup and use
  

For plants requiring rescue coverage only during shutdowns, campaigns, or vessel entries, purchasing and maintaining all equipment in-house is often not cost-effective. The Safety Heights & Rescue website states that they can provide on-site rescue equipment, converting significant capital and maintenance costs into a manageable service expense.

This is the part that auditors, officers, and incident investigators care about.

A dedicated rescue team is there to:

• monitor

• remain available

• Maintain rescue gear readiness

• rehearse response

• integrate with permits and task controls

• Act immediately if something goes wrong.

This approach aligns more closely with WA regulations and codes than arrangements where standby staff have additional duties. The confined space code requires that the standby person must not perform any other work that would distract from monitoring. PCBUs: resilience, not just compliance

Many companies still regard rescue as merely a compliance requirement. This perspective is too narrow. Rescue capability is fundamentally a resilience function:

• It stabilises for

• For PCBUs and facility operators, rescue capability is about maintaining operational resilience under pressure,

• and it gives officers a defensible WHS position.

That is especially important in outages, where multiple simultaneous tasks create exactly the conditions that expose weak systems: fatigue, handovers, contractor mix, production pressure, and competing priorities.

An on-call rescue model can be tailored to meet peak demand periods. A full-time internal emergency response team is not necessary if your plant profile does not require it. However, a real, practised, and available rescue plan is essential whenever high-risk work is underway. For sites with lean staffing or where a permanent emergency response team is not justified, the message is clear: you remain responsible for WHS duties, but do not need to manage all rescue capability internally. Business is framed around both:

• specialist rescue/safety services for outages, maintenance, and high-risk work, and

• training capability through an RTO for the internal competencies your site still needs.

This combination is practical for commercial plants:

• outsource the specialist response capability

• keep internal roles focused on operations and peThis

• tion works well for commercial plants:d over-investing in rarely used rescue equipment

• maintain a safer, more defensible shutdown system

This is not a shortcut; it is a mature operating model.

Final takeaway for PCBUs and plant operators

If your site regularly conducts confined space entry, this is not a shortcut.

It is a mature and effective operating approach. Once campaigns or high-risk tasks begin, rescue preparedness is integral to the job, not an optional add-on after the SWMS is signed.

WA WHS law and regulations require planning, coordination, communication, emergency procedures, testing, and training. Codes of practice specify that standby and rescue roles must be genuine, dedicated, and ready. For many sites with small teams, engaging a specialist on-call rescue service is more practical than maintaining a full in-house team. 

The key message for PCBUs is to protect people, meet obligations, and manage outages without diverting essential staff from their primary roles. References:

• Work Health and Safety (General) Regulations 2022 (WA) — confined space and falls requirements, including emergency/rescue procedures and training.

• Safe Work Australia, Model Code of Practice: Confined spaces — standby person, communication, rescue initiation, rehearsals, and rescue-from-outside guidance.

• Safe Work Australia, Model Code of Practice: Managing the risk of falls at workplaces — legal effect notes, fall arrest rescue procedures, suspension intolerance, and AS/NZS 1891 references.

• Safe Work Australia, Standards and standardisation — standards are not automatically mandatory unless referenced in law.

• Standards Australia Store — AS 2865:2009 Confined spaces (standard title reference).

• Safety Heights & Rescue / Safety Heights & Rescue Training website content — company positioning, services, training scope, outage and risk services, and mobile equipment/service capability.