Officer duties & contractor coordination · 12 October 2026
Director Due Diligence and Shared Workplace Risks: What WorkSafe’s 2027 Guidance Means
A director can approve a safety policy and still have little idea whether the controls are working. Two contractors can arrive with their own safety plans and still leave a dangerous gap between their jobs.
WorkSafe New Zealand’s guides on officer duty and working with other PCBUs to manage work risks address these two connected problems: leadership oversight and cooperation where work meets.
Timing matters: both linked guides state that they apply from 1 April 2027. This article was published on 12 October 2026 and explains the guides as preparation for that date. In particular, the small and large PCBU distinctions below must not be used to narrow today’s obligations before the guidance applies.
Officer due diligence: know what is happening in your business
A PCBU is a person conducting a business or undertaking. Officers are people in senior leadership positions who can significantly influence its management. WorkSafe’s examples include company directors, partners and chief executives, including non-active directors and sleeping partners.
The officer duty requires due diligence to ensure the PCBU complies with its duties under the Health and Safety at Work Act 2015. Each officer has their own duty. Having a health and safety adviser or a folder of procedures does not, by itself, demonstrate that the officer has met it.
The guide calls for officers to understand the work, keep up with relevant health and safety matters, and know the business’s hazards and risks. They must ensure appropriate resources and processes are available and used, that information about incidents and hazards receives a timely response, and that compliance processes are implemented. They must also verify those arrangements.
For a construction director, practical questions might be: Are supervisors checking fall protection before roof access? Are workers competent for the tasks assigned to them? When an audit finds a missing control, who fixes it and who checks the fix?
These are useful questions for an officer review:
- What work could seriously harm someone, and what controls prevent it?
- What evidence shows those controls are in place and being used?
- Are time, equipment, training and supervision adequate for the work?
- What have workers and contractors reported, and how have we responded?
- Which corrective actions remain open, and why?
An officer may reasonably rely on information from managers or technical experts. That still requires enough understanding to question the information and follow up where something is unclear.
A director who is also on the tools has more than one role
The officer guide makes a specific distinction: the officer duty applies to actions taken in the officer role. It does not apply to actions taken in a separate, non-officer role.
For example, an owner who operates machinery also has responsibilities as a worker while doing that operational work. Decisions about resourcing safe machinery, arranging appropriate training and verifying the business’s safety processes belong to their leadership role.
This distinction does not remove the duties that apply in the other role. For owner-operated businesses, it helps to keep a record of leadership decisions as well as daily site checks.
Overlapping PCBU duties: agree how the work will fit together
Businesses can have duties relating to the same people, risks or work activities. WorkSafe calls these overlapping duties. Its guide explains cooperation through three actions: consult with each other, cooperate on the shared matter, and coordinate activities.
A signed subcontract is useful, but the work still needs a clear plan. Who provides safe access? Who controls the exclusion area? Who communicates a changed work sequence? Who can stop the job if the agreed protection is missing?
Small and large PCBUs: the guide’s April 2027 distinction
The guide describes different cooperation requirements according to PCBU size and the risks involved. Businesses should use WorkSafe’s companion guidance, Am I a small or large PCBU?, to establish their classification rather than assume it from a label such as “SME”.
- Small PCBUs: from the guide’s application date, they must cooperate so far as reasonably practicable where duties relate to the same critical risk. They may cooperate on other risks and may agree through a contract to participate in managing them.
- Large PCBUs: they must cooperate so far as reasonably practicable on all relevant overlapping risks and prioritise critical risks. The guide says this includes cooperating with small PCBUs on all risks, although the small PCBU’s required cooperation is limited to critical risks unless agreed otherwise.
- All sizes: other overlapping duties, such as shared responsibilities for toilets, drinking water, hand washing, first aid and emergency planning, still require cooperation. Those are basic working conditions, not simply a question of risk level.
The guide also makes clear that businesses can agree to work together beyond the minimum requirements. A contract cannot remove or transfer a PCBU’s HSWA duties.
A roofing and solar job shows why coordination matters
WorkSafe gives an example of a small roofing business and a small solar installation business working on the same commercial roof. Falls and electrocution are critical risks. The businesses need to cooperate on roof access, fall prevention, edge protection and electrical isolation.
In practice, that means agreeing the arrangements before either crew starts and reviewing them when the work changes. If a protective system is removed to allow installation, both crews need to know what replaces it before anyone is exposed.
The director’s due diligence connects directly to this site work. Leadership needs credible evidence that the business has a coordination process and uses it. A supervisor needs clear responsibilities, time and authority to put that process into practice.
How Auditsure can help directors and contractors
Auditsure Ltd is a Māori-owned health and safety consultancy. We help businesses turn health and safety requirements into arrangements that directors can review and crews can use.
- Officer due diligence reviews: identify gaps in reporting, resources, verification and the follow-up of corrective actions.
- Critical risk assessments: identify serious harm scenarios, the controls required and how those controls will be checked.
- Contractor safety management: clarify shared risks, responsibilities, communication and work sequencing.
- Site safety audits: compare the agreed arrangements with what is happening on site and record practical improvements.
- SSSP development and review: bring access, supervision, emergency arrangements and contractor interfaces into a site-specific plan.
- Director and supervisor briefings: explain the two guides and help businesses prepare for their stated application date.
Our approach draws on Te Whare Tapa Whā and recognises that serious harm affects workers and whānau. Listening to workers, acting on their concerns and checking the controls are useful parts of that approach.
Auditsure provides practical support and assurance. Officers and PCBUs retain their own duties; commissioning a review does not transfer them.
Start with one leadership review and one shared-work review
Choose a job involving more than one business. Check whether everyone agrees on the critical risks, controls and responsibilities. Then ask what evidence reaches the directors and whether unresolved issues receive action.
If those two reviews tell different stories, there is a gap to close. Auditsure can help you put a practical plan around it.
Contact Auditsure about director due diligence or contractor safety management, or email safety1stconsultants@gmail.com.
WorkSafe sources
This article draws on the following WorkSafe NZ quick guides. Both are marked “This guidance applies from 1 April 2027”. The practical questions and Auditsure service examples are our commentary.