In August 2025, the Australian Government recalibrated its English language requirements for certain visa categories. While presented as a technical alignment across testing systems, there was a practical impact for “functional English” thresholds, that is, the English proficiency, of the pool of international workers entering Australia.

From a WHS perspective, the potential for ‘culturally and linguistically diverse’ (CALD) workers or work groups having more limited English language proficiency inadvertently heightens the challenge of communicating with staff onsite, and has the potential to expose several critical vulnerabilities, such as the potential for:

  • Reduced effectiveness of traditional training and induction processes.
  • Reduced effectiveness of formalised WHS communication processes such as toolbox talks, prestart discussions and written safety notices.
  • Reduced effectiveness of the informal communications with colleagues & HSRs.
  • Reduced confidence in the level of understanding in relation to safety instructions, JSA or SWMS (this is also accounting for the scenario where a worker may sign off the SWMS but without fully understanding the detail within).
  • Increased workload on the supervisory personnel to compensate for communication gaps by spending more time repeating instructions, demonstrating instructions and verifying the workers understanding of these instructions.
  • Reduced confidence in the hazard reporting and incident reporting processes, not only from a possible failure to understand, but also from cultural differences such as a deference to authority and a hesitation to speak up.

Australian industry statistics indicate that the more at-risk industries (for WHS incidents) include Construction, Manufacturing, Agriculture & Logistics. These sectors typically involve hazardous, complex, and fast-paced work. WHS Legislation requires that PCBUs must ensure (so far as is reasonably practicable), that workers understand safety information and instructions, and comply with them. Therefore, the burden for addressing any potential communication gaps rests squarely on employers.

Where this risk is identified, organisations should review and adapt their induction, training, and communication processes, implement appropriate language support measures, and strengthen verification activities to confirm that the controls implemented are effectively managing the risk.

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