The Health and Safety at Work Act 2015 (HSWA) is New Zealand's main workplace health and safety law, administered by WorkSafe New Zealand. It places duties on every business, sole traders and large corporations included, to manage risks to people in their workplace.
This guide sets out in plain English what the HSWA 2015 requires on site access. It covers who is allowed on your site, what records to keep, and what you owe contractors and visitors.
Who is responsible under the HSWA 2015
The Act uses the term PCBU, short for Person Conducting a Business or Undertaking. If you operate a business that has a workplace with other people in it, you are a PCBU. PCBUs have a primary duty of care to ensure the health and safety of their workers and others who may be affected by their work, so far as is reasonably practicable.
"Others" includes visitors, contractors, subcontractors, labour hire workers, customers, members of the public who might be affected by your work, and anyone else who enters your site.
Your duty of care covers everyone on your site, including people employed by other companies, if they are on your premises or affected by your operations.
What the HSWA says about site access records
The HSWA 2015 does not prescribe a specific format or system for site access records. It does require businesses to identify hazards, assess risks and put controls in place, and knowing who is on your site at any time is a core part of that.
Under WorkSafe New Zealand's guidance, effective risk management includes:
- Knowing who is on site and what work they're doing
- Being able to account for all people in an emergency
- Making sure contractors have received relevant information about site hazards
- Verifying that workers have completed required inductions before starting work
A paper sign-in book can meet some of these requirements if it is used consistently, kept current and accessible in an emergency. Paper systems often fall short on all three.
Main contractors and shared duties on construction sites
The HSWA 2015 does not define a principal contractor role. On a building site the main contractor and each subcontractor are all PCBUs, and they often share duties for the same workers and the same risks. Under section 34, each PCBU that shares a duty must consult, cooperate and coordinate with the others, so far as is reasonably practicable. Under section 33, a PCBU cannot transfer its duty to another PCBU.
The Health and Safety at Work Amendment Act 2026 replaces section 34 from 1 April 2027. PCBUs that share a duty must still consult, co-operate and co-ordinate with each other. A large PCBU must do this for every risk. A small PCBU, one with fewer than 20 workers, only has to do it for critical risks, such as working at height, excavations and hazardous substances. The PCBUs can agree in a contract that a small PCBU will co-operate on other risks as well.
The main contractor usually runs the site and does most of the coordinating, often because the contract says so. That work commonly includes:
- Making sure all workers receive a site-specific induction before starting work
- Coordinating emergency procedures and maintaining an up-to-date evacuation list
- Managing the overlap between different trades working at the same time
- Keeping records that show compliance for a WorkSafe audit or incident investigation
If a subcontractor's worker is injured, WorkSafe can look at how each PCBU on the site met its duty, including how site access and inductions were managed. Records showing who was on site, when they arrived and which inductions they had completed are part of that evidence.
How the Act treats visitors and contractors
Under the HSWA 2015, contractors are treated as workers and fall under your duty of care the same as employees. Visitors such as delivery drivers, clients and inspectors are "others". You still owe them a duty of care, but the obligations are slightly different.
For contractors and subcontractors, you need to:
- Check they have had a site induction
- Verify they hold any required certifications or licences
- Include them in your emergency procedures
- Coordinate their work to minimise risks from overlapping activities
For visitors, the minimum is:
- Notifying them of relevant hazards on site
- Knowing who is on site in case of emergency
- Supervising or escorting them through hazardous areas
Emergency evacuation requirements
The Health and Safety at Work (General Risk and Workplace Management) Regulations 2016 require businesses to have emergency procedures in place, including procedures for evacuating the workplace. An evacuation procedure needs a way of knowing who is on site.
An evacuation list that is incomplete, out of date or locked inside the building being evacuated does not work as an evacuation procedure. WorkSafe expects your evacuation list to show who is on site at the time of the emergency.
How SiteKey supports HSWA compliance
SiteKey does not replace your health and safety programme. It automates the site access record-keeping that HSWA compliance depends on. With SiteKey:
- Every check-in is time-stamped and logged automatically
- Compliance gates prevent non-inducted workers from checking in
- Your evacuation list is always current and accessible from any device
- Historic records are stored and exportable for WorkSafe audits
- Automatic sign-out keeps records accurate without manual intervention
Get your site access records in order
Most SiteKey customers are set up within a few days, with no IT project needed.
Talk to us about your siteFrequently asked questions
Does the HSWA 2015 require businesses to keep site access records? +
The HSWA does not prescribe a specific format. It requires businesses to manage risks to everyone on site, and knowing who is on site is a basic part of that. WorkSafe may ask to see evidence of your site access records during an audit or after an incident.
Is a principal contractor a role under HSWA 2015? +
No. The Act does not define a principal contractor. The main contractor and each subcontractor are PCBUs with their own duties, and where those duties overlap each one must consult, cooperate and coordinate with the others under section 34. On most sites the main contractor does the coordinating, including site inductions, emergency procedures and keeping a current record of who is on site. From 1 April 2027 a subcontractor with fewer than 20 workers only has to co-operate on critical risks, unless the subcontract requires more.
Are contractors considered workers under the HSWA 2015? +
Yes. The HSWA defines 'worker' broadly to include contractors, subcontractors, labour hire workers, apprentices, trainees and some volunteers. Your duty of care applies to them the same as to your direct employees, if they are working under your management or on your site.
What records do I need to keep for a WorkSafe audit? +
WorkSafe may ask for evidence of who was on site, when they arrived and departed, what inductions they completed, and how you manage hazard identification. A digital system such as SiteKey can produce these records quickly. Paper systems often cannot.