Roles and responsibilities

While health and safety is everyone’s responsibility, clearly defined roles and responsibilities will help create an effective approach to managing this vital area.

In addition to the legal requirements, this section covers the key operational roles and responsibilities in managing a health and safety system.

Questions to consider

  • Have you clearly identified your responsibilities as they apply to your governance role?
  • Is health and safety a regular agenda item at your meetings and are you asking the right questions under that item?
  • Do you understand the different roles of a person conducting a business or undertaking (PCBU) and an officer?
  • Do you have a plan in place for engaging all workers about the Health and Safety at Work Act 2015 (HSWA) requirements and duties?


Leadership is a critical element of workplace health and safety. Leaders direct culture and lead by example. They also set expectations for management and workers and hold them accountable.

School boards usually delegate the implementation of health and safety policy to the principal, who develops appropriate procedures and practices to ensure obligations and expectations are met.

The board may delegate any of its functions or powers but can never delegate its accountability.

Duty holders

The Health and Safety at Work Act 2015 (HSWA) sets out defined duty holders.

Duty holder


School or early learning role


Person conducting a business or undertaking (PCBU)

The PCBU is usually a legal or corporate entity, including a self-employed person.

Under HSWA, the following are not PCBUs:

volunteer associations (incorporated and unincorporated)

home occupiers, and /or



An early learning service provider and school board (as an entity) are all examples of a PCBU.

The PCBU holds the primary duty of care to ensure the health and safety of everybody involved with the school or early learning service so far as is reasonably practicable.

This means the PCBU must among other things:

provide a safe and healthy environment for workers, including access to facilities

provide the right information and training to all workers and others

provide and allow for worker participation and engagement in health and safety matters

notify all serious illness, injury or near misses

monitor workers’ health and workplace conditions to prevent illness or injury. 


An officer holds a specific role in an organisation that allows them to exercise significant influence over the management of the business or undertaking.

Officers have a due diligence duty under the Health and Safety at Work Act 2015 (HSWA).

Officers are the individual members of a board including principals, elected members, appointed members, staff and student board reps.

A deputy principal in a large school may also be an officer if they have significant influence and control over a large part of school management.

Officers must take reasonable steps to:

know about current work health and safety matters

understand the hazards/risks associated with the workplace operations

make sure there are resources and processes for managing risks

ensure there are processes for receiving and reviewing information on and responding to incidents, hazards/risks

verify workplace health and safety processes and resources are being used. 


Workers work for the PCBU and include:

  • employees
  • contractors or subcontractors and their workers
  • labour hire company employees
  • apprentices or trainees
  • people on work experience or a work trial
  • volunteer workers.


Teachers including relief teachers and trainee teachers, non-teaching staff, the principal, contractors etc.

Workers must:

  • take reasonable care for their own health and safety
  • take reasonable care that their behaviour does not adversely affect the health and safety of others
  • comply with any reasonable instruction from the PCBU to allow the PCBU to comply with the HSWA
  • cooperate with the PCBU’s health and safety policies or procedures.


  • Workers should report any incident, risk or hazard using the schools procedures, and inform visitors of any known hazards or risks in the workplace.
  • A student becomes a worker while on work experience for another PCBU. So when they are on work experience, the host PCBU will have the most influence over their health and safety. 

Health and safety representatives (HSR)

Health and safety representatives are workers who are elected to represent a defined workgroup.

Go to the worker participation page for more information.

Worker participation

Health and safety representatives can:

  • represent workers on health and safety matters
  • investigate complaints from workers about health and safety issues
  • monitor health and safety measures taken by the PCBU
  • provide feedback to the PCBU about health and safety compliance
  • issue provisional improvement notices and direct work group members to cease unsafe work if appropriate. 

Other persons at the workplace (school or early learning service premises)

These are people who are present at a workplace but are not workers. This includes visitors and casual volunteers (volunteer workers have different rules).

It does not include people who unlawfully enter the premises.

Visitors, parents/whānau, other volunteers, and ākonga/tamariki enrolled with the education provider.

Other persons should:

  • take reasonable care for their own health and safety
  • take reasonable care that their behaviour does not adversely affect the health and safety of others
  • comply with any reasonable instruction from the PCBU to allow the PCBU to comply with the HSWA.

The PCBU’s responsibility towards children centres on keeping them safe from risks to their health and safety, and ensuring they are not harmed by the actions of workers. This can largely be addressed by provision of information and promotion of good worker health and safety practices. Ākonga also have their own responsibilities and need to be educated about their role to keep themselves and others safe.

Duty of care to volunteers

PCBUs have the same duty of care to volunteer workers as you do to every other worker. PCBUs need to ensure volunteer workers understand the hazards and risks of their work and are competent to work safely. That means they need appropriate training and information.

While the HSWA distinguishes between volunteer workers and other volunteers, it is good practice for the board to ensure the same duty of care is applied to all volunteers. Other volunteers fall in to the category of ‘others’ in the workplace. 

The legislation introduces 2 categories of volunteer.

Volunteer workers

People who regularly do voluntary work for a school on an ongoing basis, are integral to the school’s operations and with consent and knowledge of the school.

Examples include mentors/coaches of at risk children, breakfast club helpers, classroom parent helpers.

Parent volunteers, attending with their children at Playcentre.

Other volunteers

Volunteers doing the following activities are not volunteer workers:

  • participating in a fundraising activity for a school or early learning service
  • assisting with sports or recreation for a school or early learning service (eg, sports day, school fair)
  • assisting with activities for a school outside the premises or grounds of the school or early learning service (eg Education Outside the Classroom EOTC, early learning excursion).

Find out more about how the Health and Safety Work Act applies to volunteers and officers who are volunteers:

Volunteers – WorkSafe(external link)

Police vetting for schools and kura Māori

Safety checking: general guidance

Police vetting for early learning services

Multiple PCBUs

Many work situations involve multiple PCBUs that have overlapping duties. For example, there may be a number of different businesses working together or alongside each other on a single worksite, such as on a construction site, and through contracting activities or supply chains such as education outside the classroom.

PCBUs will need to consult, cooperate and coordinate activities to meet their shared responsibilities.

They should make reasonable arrangements and coordinate responsibilities with the other PCBUs to fulfil their duties and they should also monitor each other to ensure everyone is doing what they agreed.

For more information about contractors:

Managing contractor health and safety

Police vetting for school property contractors

External agencies

PCBUs will engage with external agencies about health and safety management. These agencies have varying support and compliance roles. PCBUs are encouraged to seek advice from these agencies.



Ministry of Education

The role of the Ministry of Education is one of stewardship for the whole education system. The Ministry provides support and guidance to the education sector.

New Zealand School Trustees Association (NZSTA)

NZSTA is the national organisation which represents school boards’ views and provides boards with advice.

Through an agreement with the Ministry of Education, NZSTA is responsible for delivering an integrated range of services designed to support and enhance board capability in their governance and employer role. This includes health and safety and these services are available free to all boards.

Education Review Office (ERO)

As part of an ERO review, which takes place on average every 3 years, school boards or early learning service providers attest that they take all reasonable steps to meet their statutory obligations. School boards are provided with a self-audit checklist to help them in this process.


A section of the checklist covers the management of health and safety with respect to the following:

  • emotional safety of students (including prevention of bullying and sexual harassment)
  • physical safety of students
  • teacher registration
  • processes for appointing staff
  • stand-downs, suspensions, expulsions and exclusions
  • attendance
  • and where relevant school hostels and provision for international students. 

Early learning services:

Early learning service providers also complete a self-audit checklist.

Self-audit checklists – ERO(external link) [PDF, 797KB]

Worker’s unions:
NZEI Te Riu Roa and PPTA Te Wehengarua


The unions have a role in promoting good workplace health and safety processes. This includes: encouraging worker participation in workplace health and safety, providing access to appropriate health and safety training for elected health and safety representatives and committees and working proactively with PCBUs to engender a positive school-wide health and safety culture. 

WorkSafe New Zealand (the regulator)

WorkSafe NZ is the health and safety regulator. Its focus is to embed and promote good workplace health and safety. This aligns with their vision: That everyone who goes to work comes home healthy and safe.

WorkSafe carry out workplace assessments, receive and respond to notifications and reported risk or harm, conduct investigations and prosecutes. WorkSafe also provides a wide range of information and guidance about health and safety in the workplace.

Under the HSWA, PCBUs have a legal duty to notify WorkSafe of any notifiable event arising from work.

They can be contacted on 0800 030 040 or at Worksafe website.

Health and safety at work – WorkSafe(external link)

Tools and resources

Early learning resources

The types of positions considered to be duty holders vary depending on the service type. The following information sheets help identify which positions have duties in your early learning service.

The 'health and safety in early childhood education' table below sets out the definitions and responsibilities of the duty holders and has space for you to fill in the positions at your early learning service.

We recommend that you print this document and write in your service’s positions.

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