A practical guide for Queensland workplaces on high risk work licensing, documented lifting procedures, and staying compliant.
One of the most common questions we get at TrainX Solutions is: “Does everyone who slings a load need a dogging licence?” It’s a fair question — and the answer surprises a lot of employers. For many routine, repetitive lifts — the kind you see every day in warehousing, manufacturing and production environments — the answer can be no, provided the work is set up and documented correctly.
Here’s what the legislation actually says, and how a properly documented lifting procedure (and the right training) can let your team lift safely and legally without every person holding a high risk work licence.
What “dogging” actually means
Under Queensland’s Work Health and Safety laws, dogging (DG) is a class of high risk work. According to WorkSafe Queensland, dogging work means:
- the application of slinging techniques — including the selection and inspection of lifting gear — to safely sling a load; or
- directing a plant operator in the movement of a load when the load is out of the operator’s view.
The critical word in that first point is judgement. Slinging techniques become “dogging” when the person has to exercise judgement about the suitability of the lifting gear and the method of slinging — weighing up the nature of the load, its mass and its centre of gravity, on the spot. When a task genuinely requires that judgement, a licensed dogger must perform it.
The key insight: remove the judgement, and it may not be “dogging”
This is where many workplaces are carrying more licensing overhead than they need. If the lift is the same every time — the same load, the same rigging, the same lifting points — then the judgement has already been made. It doesn’t need to be re-made by a licensed dogger on every lift.
WorkSafe Queensland says so directly. A competent person may sling loads without a dogging licence when all of the following are predetermined:
- the load weight is predetermined;
- the sling selection and slinging techniques are predetermined;
- the condition of the lifting gear is predetermined;
- the lifting points are predetermined by a competent person and marked on the load;
- the load remains in view throughout the lift; and
- standard lifting procedures have been documented and signed off by a competent person.
Add one more practical requirement: the workers doing the lift must be trained in those specific procedures and able to follow them.
When all of those boxes are ticked, the “judgement” that defines dogging has been done up-front by a competent person and captured in a documented procedure. The operator on the floor is following a proven, signed-off method — not exercising independent slinging judgement — so a full DG licence isn’t triggered for that task.
What this looks like in a warehouse or production line
Picture a warehouse that repeatedly lifts the same palletised product, engine, coil or sub-assembly with a gantry or jib crane, using the same dedicated lifting attachment every time. If a competent person has assessed the load and its centre of gravity, specified and marked the lifting points, selected the correct inspected lifting gear, and written a clear signed-off lifting procedure for that exact task — and the load stays in the operator’s view — then trained operators can carry out that repetitive lift under the documented procedure without each of them holding a dogging licence. It’s the same principle behind engineered lifting jigs and below-the-hook devices designed for a specific, repeated task.
Important: this is not a loophole to avoid safety
Lifting without a dogging licence is only legitimate when it’s done properly. It does not remove your broader duties under the WHS Act. In particular:
- The person conducting the business or undertaking (PCBU) must still ensure a safe system of work, safe plant, and that workers are trained, competent and supervised.
- The documented procedures must be prepared and signed off by a genuinely competent person — typically a licensed dogger or rigger, or a suitably qualified engineer.
- If anything changes — a different load, damaged gear, new lifting points, or the load going out of sight — the predetermined conditions no longer hold, and licensed dogging (or a fresh assessment) is required.
- This is general information based on WorkSafe Queensland guidance. WHS laws are harmonised across most of Australia but administered by each regulator, so confirm your specific situation with WorkSafe Queensland or a WHS professional before relying on it.
Where TrainX Solutions comes in
Getting this right is exactly the kind of practical compliance work we help Queensland businesses with. TrainX Solutions can:
- Develop and review your documented lifting procedures through competent, licensed personnel — so your repetitive lifts are properly assessed, signed off and audit-ready.
- Deliver task-specific lifting and slinging training and verification of competency for your team.
- Advise on the right approach — a full Dogging (DG) licence, a documented-procedure model, or a mix.
- Provide nationally recognised dogging (CPCCLDG3001) training when a licence is the right call.
If you’re carrying more licensing overhead than you need — or you’re not sure whether your current lifting practices are compliant — talk to our team. We’ll help you build a lifting setup that’s safe, legal and efficient.
Call 1300 595 924 or contact TrainX Solutions (RTO 45601) to discuss your workplace lifting and compliance needs.
Disclaimer: This article provides general information only and is not legal advice. It is based on WorkSafe Queensland guidance current at the time of writing. High risk work licensing requirements are set under the Work Health and Safety Regulation and administered by state and territory regulators. Always confirm your specific circumstances with WorkSafe Queensland or a qualified WHS professional.
