Safety Communication Duties for CALD and Migrant Workers in Victoria

A factory in Dandenong or Laverton North runs a five-minute site induction, hands over a PPE booklet in English, and gets a signature. If a third of the shift floor speaks Vietnamese, Punjabi or Dinka as a first language and the induction wasn't delivered in a way they could actually follow, that signature doesn't mean what the employer thinks it means — and it won't hold up if WorkSafe ever asks how that worker was trained.

Victorian manufacturing employs a lot of migrant and culturally and linguistically diverse (CALD) workers, particularly in food processing, metal fabrication and warehousing. That's not a diversity talking point — it's a live compliance question, because Victoria's core safety duty is written around whether a worker actually understands what they're told, not whether the paperwork exists.

There's no separate "CALD worker" law — it flows from the general duty

There is no standalone Victorian regulation titled "safety communication for migrant workers." The duty comes straight out of the Occupational Health and Safety Act 2004 (Vic), section 21(2)(e), which requires an employer to:

"provide such information, instruction, training or supervision to employees of the employer as is necessary to enable those persons to perform their work in a way that is safe and without risks to health."

The word doing the work here is "necessary to enable." Handing an English-only SDS or induction booklet to someone who reads Tagalog and speaks basic workplace English isn't information that enables safe work — it's information that exists. If that worker is injured using a machine they were never trained on in a language they understood, the employer's s.21(2)(e) duty is exposed regardless of what was signed.

This matters for how you frame it internally: this isn't a "nice to have" cultural inclusion initiative. It's the same general duty that underpins every other induction, training record and toolbox talk your business already runs — see our guides on the safety induction checklist and training records requirements. Language competency is just the point at which that duty is tested hardest.

What WorkSafe Victoria has actually published on this

WorkSafe Victoria has real, Victoria-specific material here — it's worth being precise about what exists and what doesn't.

The compliance code. WorkSafe's Compliance Code: Communicating Occupational Health and Safety Across Languages (updated 2022, replacing a 2008 edition) is the most directly relevant document. A compliance code isn't a new law — it has evidentiary status under the OHS Act: a duty holder who follows it is taken to have complied with the underlying duty it addresses. It covers building a "language profile" of your workforce, techniques for communicating for understanding (not just translating), using interpreters, translators and multilingual staff as facilitators (and the limits of relying on a bilingual colleague instead of a qualified interpreter), and running effective training for employees, supervisors and managers across languages.

The WorkWell Toolkit. WorkSafe's toolkit for supporting a culturally and linguistically diverse workforce sets out a practical sequence: understand your workforce's language mix, adapt resources (translated materials plus pictograms and demonstrations, not translation alone), and apply a consult-find-fix-review approach to checking comprehension, not just delivery.

Translated resources. WorkSafe maintains a languages page with safety information in more than 20 languages, and has run targeted campaigns — for example, seasonal worker safety material in Bislama, Fijian, Samoan and Tongan covering machinery, vehicle and ladder hazards.

Where the material runs thin. WorkSafe's 2025 priority-industries announcement confirms manufacturing as one of five focus sectors — those five account for almost 60% of Victorian work-related deaths — but that release doesn't break the data down by language proficiency or migration status, and we could not find a published WorkSafe Victoria statistic quantifying CALD or limited-English-proficiency worker injury rates specifically within manufacturing. If you see that figure quoted elsewhere, treat it with caution unless it's traceable to a WorkSafe or Safe Work Australia source — the honest position is that the duty is clearly established and well-documented, but a Victoria-specific, manufacturing-specific injury statistic for this cohort isn't something WorkSafe has published.

Understanding, not literacy, is the legal test

The compliance code's framing is useful because it separates two things employers often conflate:

Approach	What it actually tests	Problem
English literacy test before machine sign-off	Whether the worker can read English	Fails competent, safe workers who just don't read English well
Competency-based, demonstrated assessment	Whether the worker can safely operate the plant	Matches what s.21(2)(e) actually requires
Translated document handed over, no follow-up	Whether a document exists in another language	Doesn't confirm comprehension
Translated material + demonstration + verbal check + interpreter for high-risk steps	Whether the worker understood and can apply it	Matches the compliance code's guidance

Practical steps that align with WorkSafe's published guidance:

• Language-profile your workforce at induction — ask what language a worker is most comfortable receiving safety information in, not just what English level they claim.
• Translate the induction and high-risk SWMS/JSEA content, not just the handbook — pair with our JSEA vs SWMS guide when deciding what needs translating first.
• Use qualified interpreters for formal training and consultation, especially anything tied to high-risk work licensing — our forklift licence guide covers where licensing already assumes comprehension of written test material.
• Back up text with pictorial and demonstrated signage on machine guarding, isolation points and PPE requirements — visual controls don't replace training but they reduce reliance on reading English under pressure.
• Use buddy or mentor systems for the first weeks, pairing a new CALD worker with a bilingual, safety-competent colleague — but the compliance code is explicit that a workmate filling in as an informal translator is not a substitute for a qualified interpreter on anything safety-critical.
• Check comprehension, don't just deliver information — ask the worker to demonstrate the task or explain it back, rather than relying on a signature.

Why this belongs in your safety system, not a one-off memo

None of this needs a separate policy titled "CALD worker safety." It needs to be built into the induction process, training records and toolbox talks you already run, with a language-needs field added at the point of hire. If your current induction checklist has no field for "language needs assessed" and no record of how a non-English-speaking worker's training was delivered, that's a gap an inspector can find as easily as a missing guard.

FAQ

Is there a Victorian law specifically about training workers with limited English? No. There's no standalone regulation. The obligation flows from the general duty in the Occupational Health and Safety Act 2004 s.21(2)(e), which requires employers to provide information, instruction, training and supervision "necessary to enable" employees to work safely — and that necessarily includes doing it in a language and form the worker understands.

What is WorkSafe Victoria's compliance code on this and does it change my legal obligations? The Compliance Code: Communicating Occupational Health and Safety Across Languages doesn't create a new duty — it explains how to meet existing OHS Act duties when language is a barrier. Following it gives you evidentiary protection: a duty holder who complies with the code is taken to have complied with the duties it addresses.

Can a bilingual coworker act as our interpreter for inductions and training? WorkSafe's compliance code addresses this directly, noting the role and limitations of employees acting as multilingual facilitators. A bilingual colleague can help with day-to-day communication, but for formal training, consultation and safety-critical instruction, a qualified interpreter or translator is the safer and more defensible approach.

Does WorkSafe publish injury statistics for migrant or CALD workers in manufacturing specifically? Not that we could locate. WorkSafe's 2025 priority-industries release confirms manufacturing as a focus sector (the top five sectors account for almost 60% of work-related deaths in Victoria) but doesn't break this down by language proficiency or migration status. Be wary of any CALD-specific manufacturing injury figure that isn't sourced to WorkSafe or Safe Work Australia directly.

What's the first practical step for a manufacturer with a language-diverse workforce? Add a language-needs field to your induction and training records so you can show, worker by worker, how safety-critical information was actually delivered and understood, not just distributed.

If you're not sure your induction and training records would hold up to that question, book a site assessment and we'll go through your current process against what WorkSafe Victoria actually expects.

This article is general information for Victorian manufacturers, not legal advice. Last updated: 20 September 2026.