The Machinery Report
Independent machinery safety assessment

Machinery safety assessment for agricultural equipment

Assessment of agricultural machinery against the safety standards that apply in Australia and New Zealand. Imported or locally built, new or thirty years old. Every assessment is carried out on the machine itself by a Certified Machinery Safety Expert with close to twenty years in agricultural operations.

CMSE, Certified Machinery Safety Expert, certified by TÜV NORD Fixed fee, quoted before work begins
$2,373,000
Maximum penalty for a company under a Category 2 WHS offence. For a sole trader or partner it is $475,000.
Any origin
Machinery built in Europe, North America, Asia or Australia, and machinery of any age.
On site
Findings are measured on the machine. Nothing is assessed from the manual alone.
Why it applies

Overseas safety approval does not discharge Australian duties.

A CE mark, an ANSI or ASABE conformance statement, a GB certificate or a factory sign off is a declaration made by the manufacturer against the law of another country. None of them satisfy the obligations that Australian and New Zealand law place on the importer, the supplier, or the business that controls the plant.

Overseas approval does not transfer

An importer or supplier must obtain the manufacturer's safety information, inspect the plant, test it where that information requires testing, and then either eliminate an identified risk before supply or advise the receiver of it in writing. A mark applied in another country does not satisfy any of those requirements.

WHS Act 2011. OHS Act 2004 (Vic).

No machine specific standard applies

With the exception of telehandlers, there is no AS/NZS machine specific standard for agricultural machinery. The horizontal AS/NZS 4024 series applies instead, which means each clause has to be assessed against the machine in front of you rather than resolved by reference to a single standard.

AS/NZS 4024 series. AS 10896.1.

Age does not reduce the duty

A machine built in 2004 must still be safe to operate, maintain and clean today. The duty rests with the business that has management or control of the plant now. It does not remain with the manufacturer, and it does not stay with a previous owner.

Duties of a PCBU with management or control of plant.

Cost is considered last

Reasonably practicable requires the likelihood of harm, the degree of harm, what the business knew or ought reasonably to have known, and the availability and suitability of controls to be weighed first. Cost is considered only after those matters, and it must be grossly disproportionate to the risk before it carries weight.

WHS Act s.18.
Services

Services by duty holder

Engagements are scoped to the machine and to the duty being discharged. Some are a single day on one machine. Others establish a program that your own team continues to run afterwards.

Importers and distributors

Importer and supplier duties apply from the point the machinery arrives.

  • Gap assessment of imported machinery against the standards that apply in Australia and New Zealand, regardless of country of origin or the marks the machine carries. Every stricter or unmapped requirement is assessed on the machine.
  • Pre-supply inspection and test procedures that your pre-delivery or warehouse team can run repeatably, with records that evidence the duty has been discharged.
  • Written risk advice for receivers where a hazard cannot be eliminated before supply.
  • Safety bulletins, field notices and recall documentation prepared for dealers and operators.
  • Escalation documentation for the manufacturer, written against the standards the factory already works to.

Manufacturers, fabricators and designers

Local manufacture, local modification, or an overseas product entering this market.

  • Risk assessment through the design cycle, with hazard identification, risk estimation and risk reduction applied in the correct order and documented as the design progresses.
  • Verification of guarding, openings, access and safety distances by measurement.
  • Functional safety assessment, including determination of the required performance level, validation of the design, and the supporting evidence.
  • Review of operator manuals, decals and residual risk information against the machine as built.
  • Market entry review before the first shipment, while design changes remain inexpensive.

Dealers and workshops

The last party to handle the machine before it enters service.

  • Pre-delivery safety inspection procedures written for workshop use.
  • Risk assessment of modifications, retrofits and non-OEM attachments, which alter the risk profile of the machine and can move the duty to the dealer.
  • Briefings for technicians and sales staff on the scope of a dealer's duty of care.
  • Independent second opinion where a customer, an insurer or an inspector has raised a concern about a machine.

Farms and contractors

Mixed fleets, older equipment, and machinery maintained on site.

  • Plant risk assessments across owned and hired machinery, scored and ranked so that remediation can be prioritised.
  • Guarding, access and isolation specifications for older machines built to earlier expectations.
  • Safe operating and maintenance procedures written for the people who use the equipment.
  • Assistance following an incident or an inspector's visit, including investigation and corrective action.

Insurers, brokers and legal

Independent technical assessment where the machine is the question.

  • Incident investigation and root cause analysis on agricultural plant.
  • Independent technical opinion on guarding, control systems, safety distances and standards compliance.
  • Pre-cover risk survey of a fleet, a workshop or a site.
Process

How an engagement runs

Findings without a close-out do not reduce risk, and a close-out based on a desk review will not withstand scrutiny. The following sequence is applied on every engagement.

STEP 01

Scope

A discussion to establish which machines are in scope, which duty is being discharged, and what the assessment needs to support. A fixed price is agreed in writing before work begins.

STEP 02

On site

Assessment carried out on the machine, including measurements, photographs, control system checks, and review of the manufacturer's documentation against the machine as supplied.

STEP 03

Report

Findings referenced to the applicable clauses, risk scored before and after control, and controls recommended in order of precedence: elimination, then safeguarding, then information for use.

STEP 04

Close-out

Verification that the recommended controls have been implemented and are effective, with a register suitable for an inspector, an insurer or a customer.

Deliverable

What the report contains

  • Machine identification and documentation registerSection 1
  • Manufacturer's declaration and documentation reviewSection 2
  • Clause by clause findings against the applicable standardsSection 3
  • Photographic evidence with measurementsSection 4
  • Risk scored before and after controlSection 5
  • Recommended controls in order of precedenceSection 6
  • Justification where a risk is accepted rather than removedSection 7
  • Close-out and re-verification registerSection 8

Adverse findings are recorded, not softened.

An assessment that resolves difficult clauses to compliant without justification produces a document that establishes knowledge of a hazard without any corresponding action. Unmapped and stricter requirements are assessed individually. Where a risk is accepted rather than removed, the justification is recorded and dated so that it can be reviewed at the next assessment.

Reports are written to be used by engineering staff, by management, and by a regulator if that becomes necessary.

Extract from an assessment register Example only
Reach over a protective structure Safety distance calculated from ground level rather than from the operator's actual standing position on the machine. Non-conformance
Interlocking device associated with a guard Guard interlock defeatable with a commonly available tool. No fault exclusion documented by the manufacturer. Risk accepted, justified
Emergency stop Actuator reachable from both operating positions. Stop function verified on the machine under load. Verified
Pricing

Fixed fees, agreed before work begins

If the scope changes, a revised price is issued for approval before any additional work is carried out. All prices are in Australian dollars and are GST free.

Most common

Machine Safety Assessment

$1,450One machine. Plus travel outside Geelong.

For a dealer, a farm or an importer requiring one machine assessed in full.

  • On-site assessment of one machine
  • Findings referenced to the applicable standards
  • Risk scored before and after control
  • Photographic evidence with measurements
  • Recommended controls in order of precedence
  • Close-out register and one follow-up review
Before market release

Model Compliance Assessment

$2,900Per model. Plus travel.

For importers and manufacturers releasing a model into Australia or New Zealand.

  • All items in a Machine Safety Assessment
  • Review of the manufacturer's documentation and declarations
  • Escalation documentation prepared for the factory
  • Written risk advice for receivers, ready to issue
  • Pre-delivery inspection procedure for your network
  • Findings applicable to every unit of that model
Fleets and sites

Fleet Safety Program

From $4,800Per-machine rate reduces with volume.

For farms, contractors and workshops assessing multiple machines.

  • Every machine assessed and ranked by risk
  • A single prioritised action plan across the fleet
  • Safe operating and maintenance procedures
  • Guarding and isolation specifications for older machines
  • A register your team maintains afterwards
  • Annual review at a reduced rate
Incident investigation $1,600 per day Root cause analysis and technical opinion for insurers, brokers and legal. Plus travel.
Training and toolbox day $2,400 per day On site for up to 12 people. Duty of care, guarding, isolation and inspection.
Initial discussion No charge Describe the machine and the concern. If an assessment is not required, you will be told so.

What an assessment costs against what it prevents

Maximum penalty, Category 2 WHS offence, company (body corporate) $2,373,000
The same offence where the business is an individual, being a sole trader, partner or officer $475,000
Maximum penalty, Category 1 offence involving reckless conduct, company $11,839,000
Cost of a field safety campaign across a dealer network $50,000+
Your own staff assessing one machine to the same standard 2 to 3 days
Machine Safety Assessment from The Machinery Report $1,450
Penalty figures are the model WHS Act maximums applying from 1 July 2025 and are indexed annually. Victoria and other jurisdictions set their own amounts under the OHS Act 2004. Source: Safe Work Australia.
About

Experience with the machinery, not only the standards

My name is Ben Gillett. I work as a national technical specialist supporting agricultural machinery dealer networks across Australia and New Zealand, and I hold the CMSE qualification, certified by TÜV NORD.

Before the compliance work I spent close to twenty years in large scale cropping, feedlot and broadacre operations. The seeding bars, spreaders, harvesters, balers and tillage equipment covered by this service are machines I have operated, serviced, repaired and sold.

My current work includes importer duty assessments on machinery entering these markets, standards gap assessments, safety bulletins prepared following field incidents, and technical guidance to dealers. The assessment framework used in this service was developed for that work and has been applied to machines in service. It is not a purchased template.

Agricultural machinery carrying complete documentation has still killed people. That is the reason this work is done properly or not at all.

Qualification CMSE, Certified Machinery Safety Expert, certified by TÜV NORD
Standards applied Whichever standards apply to the machine. Australian and New Zealand standards, the international standards behind them, the manufacturer's own design standards, and the overseas standard the machine was built to. Where one sets a higher requirement, that is the one used.
Machinery Broadacre and mixed farming equipment. Seeding, spreading, spraying, tillage, harvest, handling and materials transfer.
Location Geelong, Victoria. Available across Australia and New Zealand.
Contact

Discuss an assessment

Describe the machine and the concern. The initial discussion is free, and it will usually establish whether a full assessment, a second opinion, or a straight answer is what is required.

ben@themachineryreport.com.au Response within one business day