Refer to our general information on volunteers if you are still unsure whether the model WHS laws apply to your volunteer organisation.
The information on this page is intended to help volunteer organisations and volunteers understand their work health and safety (WHS) duties in relation to COVID-19.
For comprehensive general information on the how the model WHS laws apply to volunteers and volunteer organisations, you can refer to our:
The model WHS laws have been implemented in all Australian jurisdictions except Victoria and Western Australia. For detailed advice in relation to volunteers and WHS you should contact the WHS regulator in your jurisdiction.
You can also seek further information on volunteers from a volunteer peak body in your state or territory.
Are volunteers covered by the model WHS laws?
Yes, unless they are volunteering on behalf of a ‘volunteer association.’ A volunteer association is a group of volunteers working together for one or more community purposes and none of the volunteers or the association itself employs a person to carry out any work for the association. Volunteer associations are not covered by the model WHS Act.
However, if a volunteer organisation (or the organisation’s members either separately or jointly) employs one or more paid workers to carry out work for the organisation (for example, a book keeper), the organisation will be a person conducting a business or undertaking (PCBU) under the model WHS Act.
As a PCBU the volunteer organisation will owe a duty to both paid workers and volunteers.
Refer to our guide on work health and safety for volunteer organisations if you are still unsure whether the model WHS laws apply to a volunteer organisation. Even if an organisation is a volunteer association and does not fall under the model WHS Act, it is a good idea to comply with general work health and safety duties as general and common law duties of organisations who engage volunteers are well established.
What is a PCBU’s WHS duty to volunteers in relation to COVID-19?
A PCBU’s duties to volunteers are the same as their duties towards paid workers. PCBUs must eliminate the risk of a volunteer being exposed to COVID-19 if reasonably practicable. If a PCBU is not able to eliminate the risk of exposure to COVID-19, they must minimise that risk, as far as is reasonably practicable.
Read more information on WHS duties.
Can volunteers continue to perform work during the COVID-19 pandemic?
Volunteer organisations must follow the public health directions in the relevant state or territory. Organisations should check whether the specific task or activities their volunteers perform are allowed under the public health directions and make sure that these activities can continue to be carried out safely. Volunteer organisations should also check whether they must prepare a COVIDSafe Plan (or similar).
Where a volunteer organisation is covered by the model WHS Act it owes specific duties to volunteers, just as it does to paid workers. The information on this page will help organisations that engage volunteers determine whether they are covered by the model WHS Act and if they are, how they can meet their duties.
However, regardless of whether volunteers are covered by the model WHS Act, when carrying out volunteer work they should comply with physical distancing requirements, practice good hygiene and follow any other measures being taken in the broader community to reduce the risks of contracting and spreading COVID-19.
In some cases, this may require changes to the arrangements for volunteer work. For example, working remotely or from home if possible.
For more information see our COVID-19 Information for workplaces.
How can a PCBU meet their WHS duty to volunteers in relation to COVID-19?
PCBUs will need to identify all activities or situations where volunteers are at risk of contracting or spreading COVID-19 while performing their volunteer work. They must then assess the level of risk that people carrying out these activities or in these situations may contract and spread COVID-19 in the workplace. PCBUs must then determine control measures that will minimise the risk of a volunteer contracting and spreading COVID-19 so far as is reasonably practicable.
PCBUs must also take into account any other new or changed risks arising from COVID-19, such as risks to mental health, including those that may arise from working in isolation due to the pandemic (for example, if working from home arrangements are put into place for volunteers as a control measure to minimise the risk of COVID-19). PCBUs may also need to address the risk of work-related violence that can arise, such as from increased customer stress, frustration and anxiety in a retail store from having to comply with measures put into place to comply with physical distancing requirements.
Remember, PCBUs must consult with workers, including volunteers, and any health and safety representatives when identifying risks and control measures for their workplace. Refer to our web page on consultation and our model Code of Practice: Work health and safety consultation, cooperation and coordination for further information.
For further assistance on the risk management process, refer to:
- our COVID-19 risk assessment page
- our information on key considerations for businesses to take into account when assessing the risks associated with COVID-19
- our example risk register
- our model Code of Practice: How to manage work health and safety risks, and
- our guide on How to determine what is reasonably practicable
Do PCBUs have to conduct a risk assessment specifically in relation to volunteers and COVID-19?
No, but all workers, including volunteers, must be taken into account as part of the broader risk assessment carried out in relation to COVID-19 in the workplace.
If volunteers are carrying out specific tasks or activities or performing work at particular locations or workplaces that are different to paid workers, this must be considered when applying the risk management process regarding COVID-19.
What can a PCBU do if volunteers are worried about contracting COVID-19?
PCBUs should talk to their volunteers to understand more about their concerns. Once PCBUs have an understanding of the precise nature and degree of volunteers’ concerns our guidance on mental health may be of assistance.
PCBUs should also remind volunteers of the services that are available to them for support, e.g. the Coronavirus Mental Wellbeing Support Service. It might also be helpful for volunteers to talk to their treating medical practitioners, such as their GP.
Refer to Safe Work Australia's Guide: Work-related psychological health and safety: A systematic approach to meeting your duties for more general information on managing risks to mental health in the workplace.
Is it OK for volunteers who are considered ‘vulnerable’ to COVID-19 to return to volunteering at their usual workplace?
It depends. PCBUs should first undertake a risk assessment, as outlined above, to identify and manage risks to vulnerable volunteers’ health and safety at the workplace, including considering whether the nature of their duties or the workplace increases their risk of exposure to the virus.
It may be that identified risks can be adequately managed by implementing physical distancing requirements and strict hygiene measures to reduce the risks of contracting and spreading COVID-19. Alternatively, you may need to explore options for vulnerable volunteers to work from home, where possible, or arrange for them to move temporarily into different roles. Where it is not possible to effectively manage identified risks, organisations should require vulnerable volunteers to cease their volunteering duties until it is safe for them to resume.
Likewise it is recommended that volunteer associations follow the risk assessment approach before allowing vulnerable people to resume volunteering at the usual workplace.
Public health authorities have identified some people as being at greater risk of more serious illness with COVID-19, including:
Aboriginal and Torres Strait Islander people 50 years and older with one or more chronic medical conditions
people 65 years and older with one or more chronic medical conditions
people 70 years and older, and
people with compromised immune systems.
You can find more information on undertaking risk assessments for vulnerable people in a COVID-19 environment on our website.
What should a PCBU do if a volunteer contracts COVID-19?
If a volunteer has contracted COVID-19 PCBUs will need to follow the health advice provided by the public health authority in their jurisdiction. Contact your state or territory helpline for further information. They may also be required to notify their WHS regulator. For information on when to notify the regulator, see our guidance on Incident Notification.
Our guidance on COVID-19 in your workplace may also help you understand what to do if a volunteer is diagnosed with COVID-19.
A volunteer has been diagnosed with COVID-19. Are they entitled to workers’ compensation?
They may be, however, volunteers are generally not covered by workers’ compensation laws. Workers’ compensation arrangements differ across jurisdictions.
Your workers’ compensation authority will determine whether your volunteer is covered by their scheme and if they are entitled to workers’ compensation. They will consider each claim on its merits, with regard to the individual circumstances and evidence.
As volunteers are generally not covered by workers’ compensation laws, it is important to ensure that your organisation has appropriate insurance that adequately covers its volunteers, and the activities they carry out when volunteering.
Do volunteers have any WHS duties in relation to COVID-19?
If their organisation is covered by the model WHS Act, volunteers have the same duties as all other paid workers. That is, they must:
- take reasonable care for their own health and safety
- take reasonable care that their acts or omissions do not adversely affect the health and safety of other persons
- comply, so far as the worker is reasonably able, with any reasonable instruction that is given by the PCBU to allow the them to comply with the model WHS laws
- cooperate with any reasonable policy or procedure of the PCBU relating to health or safety at the workplace that has been notified to workers
These duties apply in relation to COVID-19 as they do to all other WHS risks. For more information about workers' duties, go to our Duties under WHS laws page.