Lone work & client-site coordination
Protect workers who clean alone or after hours, and coordinate clearly with clients and other businesses where health and safety duties overlap.
Remote or isolated work: regulation 21 of the Health and Safety at Work (General Risk and Workplace Management) Regulations 2016 requires a PCBU to manage risks to workers performing remote or isolated work. To minimise those risks, the PCBU must provide a system of work that includes effective communication with the worker.
For cleaning and property services, this can be relevant where someone works alone after hours, in an isolated part of a building, at an unoccupied property or somewhere assistance may not be readily available. The appropriate system depends on the circumstances; the law does not prescribe one universal check-in app, device or timetable.
Client sites: under the current sections 33 and 34 of HSWA, more than one PCBU may have the same duty. Each retains responsibility to the extent it can influence and control the matter, and PCBUs sharing a duty must, so far as is reasonably practicable, consult, co-operate and co-ordinate activities. A cleaning contract does not by itself transfer away a PCBU's legal duties.
What should a manager have in place?
Manager check
- Do we know which workers and shifts involve remote or isolated work?
- Does our system provide effective communication rather than relying only on a worker being expected to call if something goes wrong?
- Is there a clear response when a worker misses an expected contact or asks for help?
- Have we exchanged relevant health and safety information with the client or property manager before work starts?
- Have we considered other PCBUs, contractors, occupants and activities at the site where duties or risks overlap?
- Are responsibilities based on actual influence and control rather than assuming the service contract transfers all responsibility?
- Do we review the arrangement when shifts, access, occupancy, hazards or other work at the site changes?
2027 legal change
The Health and Safety at Work Amendment Act 2026 contains changes to overlapping-duty requirements that are due to take effect on 1 April 2027. This guide describes the current law and should be reviewed before that commencement date rather than treating the amended framework as already in force.
NZQC provides practical educational information. It is not legal advice and does not certify that a provider is compliant. Check the official source and the requirements that apply to your service, contracts and scope.