The pre-start inspection requirements mining operators must meet are set out as outcomes, not forms. Queensland coal mines must have a standard operating procedure requiring the operator, as soon as practicable after taking control of mobile plant, to check that the brakes, steering, lights and other safety features work. New South Wales and Western Australia require the mine operator to manage mobile plant risk having regard to the maintenance, testing and inspection of those same features. None of the instruments prescribes a particular pre-start form or pre-start checklist.
This guide explains the pre-start checks law in Australia actually imposes, separates it from site convention, sets out what a good pre-start covers, and explains how a defect should travel from the cab to someone who can act on it.
Why the pre-start is worth getting right
The pre-start is the last check between a machine with a fault and a road full of other machines and people. It is also the inspection almost everyone on site does every shift, so it sets the tone for how seriously inspections are taken.
When it degrades, it degrades quietly: the same answers ticked every day, a weeping hose noted three shifts running, a form in a tray nobody reads. Pre-starts sit inside the wider system covered in our guide to mine site inspections in Australia, but they differ in volume: every machine, every shift, done by the operator.
Pre-start inspection requirements in mining: what the law says
Queensland coal: a procedure for checking mobile plant
The Coal Mining Safety and Health Regulation 2017 is the most specific of the three states. Section 73 requires a coal mine to have a standard operating procedure for checking mobile plant used at the mine. The procedure must provide for the operator of the plant, as soon as practicable after taking control of it, to check that the brakes, steering, lights and any other safety features are functioning properly.
Section 71 adds checks for hazards by a competent person, periodically and before plant stopped for at least 24 hours is restarted. Section 72 requires a procedure for tyres and rims, and section 78 one for taking plant out of service and returning it, which is where a failed pre-start should lead.
Queensland metalliferous mines and quarries: do not operate unfit plant
The Mining and Quarrying Safety and Health Regulation 2017 is framed differently. Section 106 says plant must not be operated if inspections, tests or monitoring show it is unfit for use, or if it is locked out and tagged. Sections 107 and 108 cover taking plant out of service and monitoring its condition.
Section 113 is the one to note for records. Where it is necessary for managing the risk, the site senior executive must ensure a record is kept of the plant’s inspection, testing and monitoring and any action taken as a result. The record is kept for the life of the plant, or until it is permanently decommissioned or disposed of, and must be readily accessible to each worker who uses the plant.
New South Wales: movement of mobile plant and the mechanical engineering control plan
Section 32 of the Work Health and Safety (Mines and Petroleum Sites) Regulation 2022 requires the mine operator to manage risks from the movement of mobile plant, having regard to matters including pre-movement warnings and the maintenance, testing and inspection of brakes, steering, lights and other safety features. Where there is risk from the mechanical aspects of plant, section 30 and Schedule 2 require a mechanical engineering control plan that takes into account inspection and testing of plant, including braking, steering and warning systems, and the identification, assessment, management and rectification of defects.
The regulator’s technical reference guide for roads and other vehicle operating areas (July 2025) goes further in practical terms. It suggests operator prestart inspections based on manufacturer or approved engineering advice, pre-use inspections that highlight specific machine down items, and a method of notifying and managing equipment failures during operations. It is guidance, not law, but it signals what an inspector will expect.
Western Australia: the same themes, plus competence
Regulation 631 of the Work Health and Safety (Mines) Regulations 2022 mirrors the NSW wording on the maintenance, testing and inspection of brakes, steering, lights and other safety features, and adds the competence of operators and maintenance personnel. Regulation 213 separately requires the person with management or control of plant to ensure maintenance, inspection and, if necessary, testing is done by a competent person in line with the manufacturer’s recommendations where there are any.
Law versus site convention
Much of what people call “the pre-start requirements” is site practice hardened into habit. It helps to know which parts are law and which parts you chose.
- Required: a check of brakes, steering, lights and other safety features (Queensland coal by procedure; NSW and WA as a matter the mine operator must address), not operating plant that inspections show is unfit (stated expressly in the Queensland metalliferous and quarry regulation), and a procedure for taking plant out of service and returning it (both Queensland regulations).
- Convention: a specific paper or electronic form, a fixed list of 40 items, a signature box, a colour-coded fault category, a walk-around in a set direction, a rule that the form lives in the cab.
- Somewhere in between: keeping the record. Queensland metalliferous and quarry sites must keep plant inspection records where needed to manage the risk. Elsewhere, the record is how you prove your procedure is actually being followed, which is hard to do without one.
Fault categories are a good example. Many sites grade defects as category A, B or C, with A meaning the machine does not move. That is a sensible convention, explained in our article on light vehicle pre-start fault categories A, B and C, but no instrument we reviewed prescribes it. What the law cares about is that unfit plant is not operated and that defects are managed.
What a good pre-start covers
A useful mobile plant pre-start starts from the manufacturer’s operator checks, then adds what your risk assessment says matters for that machine. A haul truck and a light vehicle share a structure but not a length, which is why the haul truck pre-start checklist is a separate page.
- Walk-around: leaks, damage, loose or missing guards, fire suppression condition, tyres and rims, lights and reflectors, access ladders and handrails.
- Fluids: oil, coolant, hydraulic and fuel levels where the operator is expected to check them.
- In-cab: service and park brake tests, steering, horn and reversing alarm, lights, mirrors and cameras, seat belt, gauges and warning lamps, radio.
- Systems: proximity detection, collision avoidance or fatigue technology where fitted, and any machine-specific safety interlocks.
- Context: who did it, on which machine, at what time, with what result, and what happened to every fault found.
Tyres deserve particular care in any equipment pre-start on a mine; the tyre and rim inspection checklist covers what an operator can see and when a tyre fitter takes over.
How defects should escalate
A pre-start that finds a fault and stops there has done half its job. The defect has to reach someone who can decide whether the machine is fit, and that decision has to be recorded.
- Safety-critical fault (brakes, steering, fire suppression, a tyre issue): the machine does not move. It is tagged out of service under the site’s isolation and out-of-service procedure and the supervisor and maintenance are told immediately.
- Operational fault that does not affect safe operation today: recorded with a photo, reported to maintenance before the end of shift, and given a clear date by which it must be fixed.
- Repeat fault: the same defect reported on consecutive shifts is itself a finding. It usually means the report is not reaching anyone, or is reaching someone who cannot act.
- Return to service: a named, competent person confirms the repair before the tag comes off, and that confirmation is recorded against the original fault.
The link between fault and return to service is what most systems lose: nobody can later show that the fault found at 6.10 am was the one fixed at 2 pm.
Where pre-starts go wrong
- Pencil whipping. Every box ticked in 40 seconds. Long generic forms make it worse; see why general checklists create a false sense of safety.
- One form for every machine. A dozer operator answering questions about a tray lock means the form was built for convenience.
- Defects that go nowhere. The operator learns that reporting changes nothing and stops reporting.
- No record of the decision. The machine went out with a known fault and nobody can show who accepted it.
- The shift change gap. Plant handed over mid-shift goes unchecked because the pre-start was “done this morning”. The Queensland coal wording attaches the check to each operator taking control.
Making pre-starts a control rather than a ritual
The operational problem is rarely that operators skip pre-starts. It is that results sit in paper books in cabs, this morning’s fault is invisible to the supervisor until the book is collected, and repeat defects only surface when someone goes looking. The check is done; the information dies in the cab.
HazView treats a pre-start as a checklist built to the site’s own form and the specific machine type, not a generic template. It can be completed fully offline in the cab and syncs when the device is back in reception. Conditional logic means a failed brake test opens the follow-up questions that matter, such as photo, tag-out and who was told, instead of letting the operator carry on ticking. Every answer can carry a photo and comment, a supervisor countersignature can be required by role, and a PDF record can be emailed to nominated recipients such as the maintenance planner as soon as it is submitted.
Existing paper pre-starts are converted like for like first, then improved, so operators start on a familiar form. More on how this works for crews is on the HazView page for frontline workers. To see a pre-start built for your plant, book a HazView demo.
Summary: pre-start requirements by state
| Jurisdiction | Instrument | What it requires |
|---|---|---|
| Queensland coal | CMSHR 2017 s.71, s.73, s.78 | Operator checks brakes, steering, lights and safety features on taking control; competent-person checks; out-of-service procedure |
| Queensland metalliferous and quarries | MQSHR 2017 s.106 to s.108, s.113 | Unfit plant not operated; out-of-service system; monitoring; inspection records where needed |
| New South Wales | WHS (MPS) Regulation 2022 s.30, s.32, Sch 2 | Regard to inspection of brakes, steering, lights and safety features; control plan covers testing and defect rectification |
| Western Australia | WHS (Mines) Regulations 2022 r.213, r.631 | Same mobile plant matters plus competence; competent-person inspection per manufacturer |
A quick test of any pre-start system:
| Check | What good looks like | Escalate if |
|---|---|---|
| Form content | Built from the manufacturer’s checks and the site risk assessment for that machine type | One generic form is used for every machine |
| Timing | Done by each operator on taking control, including mid-shift handovers | Plant is handed over without a new check |
| Safety-critical faults | Machine stays parked and is tagged out of service | Plant moves with a known brake, steering or fire suppression fault |
| Fault reporting | Supervisor and maintenance know within the shift, with a photo | Faults are only found when the book is collected |
| Return to service | Named competent person signs off the repair against the original fault | Tags removed with no record of who cleared the fault |
| Repeat defects | Visible across shifts and reviewed | The same fault appears three shifts running with no action |
| Records | Retrievable by machine and date | Nobody can produce last month’s pre-starts for a given unit |
Pre-start records feed the inspections and incident reports that end up in the statutory record. See mine record requirements in Queensland for where that line sits, and vehicle interaction as a principal hazard for the wider mobile plant picture.
Related guides
- Mine Site Inspections in Australia: What the Law Requires, What to Check and What a Defensible Record Looks Like
- Light Vehicle Pre-start Checklist for Mine Sites, and How Faults Are Graded
- Haul Road Inspection Checklist for Mines and Quarries
- Isolation Verification Checklist for Mines and Quarries
- All Inspections & Checklists guides
Frequently asked questions
Is a pre-start inspection a legal requirement on Australian mines?
In Queensland coal, yes in substance: section 73 of the Coal Mining Safety and Health Regulation 2017 requires a procedure for the operator to check brakes, steering, lights and other safety features as soon as practicable after taking control of mobile plant. In NSW and WA the regulations require the operator to manage mobile plant risk having regard to inspection of those features, which in practice is met through a pre-start.
Does the law prescribe a pre-start checklist for mining equipment?
No. None of the Queensland, NSW or WA mining regulations reviewed here prescribes a form, item list or layout. Build the content from the manufacturer’s recommendations and your risk assessment for each machine type.
Do pre-starts have to be done every shift?
The Queensland coal regulation ties the check to the operator taking control, not to a shift, so a mid-shift change of operator triggers a new check. Most sites also set a once-per-shift minimum as policy.
Are category A, B and C faults defined in legislation?
Not in any of the instruments reviewed here. Fault categories are a site convention for deciding whether a machine can operate. They are useful, but the legal tests are framed differently: in Queensland metalliferous mines and quarries, plant that inspections show is unfit must not be operated, and in NSW the mechanical engineering control plan must take into account the identification, management and rectification of defects.
How long should pre-start records be kept?
For Queensland metalliferous mines and quarries, where a record of plant inspection is necessary to manage the risk, section 113 requires it to be kept for the life of the plant. Elsewhere, set retention in your safety management system, long enough to investigate incidents and show repeat defects.