Painted Lines Do Not Stop Forklifts

A $200,000 reminder that traffic management must physically control the risk

On 17 Dec 25, D’Orsogna Limited was convicted and fined $200,000 after a reversing forklift struck a worker and pinned her legs to the ground at its Mickleham warehouse in Victoria. The prosecution is another reminder that instructions, eye contact, painted lines and high-visibility clothing do not physically prevent mobile plant from colliding with a person.

The incident occurred in April 2023 while a team leader was unloading pallets using a pallet jack. A forklift reversed in an arc across the warehouse dispatch chiller area, struck the worker and caused serious injuries, including a complex comminuted fracture to her foot.

WorkSafe investigators found there were no physical barriers, bollards or marked walkways separating pedestrians from powered mobile plant in the dispatch chiller area. There was also no traffic management plan, with the work system instead relying on forklift operators and pedestrians making eye contact and using ad hoc communication to decide who would give way.

The Melbourne County Court heard that it was reasonably practicable for D’Orsogna to design, implement and regularly review a traffic management plan. Available controls included physical barriers, clearly marked walkways and designated driver safety zones in areas where pedestrians and forklifts could interact.

The company also admitted that it had not provided all workers with adequate instruction and training concerning safe interaction with mobile plant. Forklift operators had not been adequately instructed about the importance of conducting head checks before reversing.

The full prosecution summary is available from WorkSafe Victoria.

Back when I was behind the badge

Back when I was behind the badge, I lost count of how many improvement notices were written by me or my teammates concerning the risk of mobile plant colliding with pedestrians or other mobile plant. The workplaces changed, but the underlying problem was remarkably consistent, forklifts, trucks, loaders or other plant operated in areas also occupied by workers, contractors and visitors, while the controls depended almost entirely on everybody remaining alert.

A painted pedestrian line was regularly presented as segregation. A sign saying “Pedestrians Give Way” was treated as though it created an invisible barrier, while high-visibility clothing was expected to perform the work of fixed guardrails, exclusion zones and properly designed traffic flows.

It does not.

A line of paint does not stop a forklift, a sign does not prevent a reversing movement, and a high-visibility vest does not protect a person from several tonnes of moving plant.

A common compliance pathway was the formation of a traffic management planning committee. That committee typically included management, supervisors, forklift or plant operators, pedestrians who worked in the affected areas, health and safety representatives and other workers with practical knowledge of how the workplace actually operated.

The purpose was not to establish another committee that met twice, produced minutes and then quietly expired. Its purpose was to provide a structured mechanism for consultation, examine actual plant and pedestrian movements, identify conflict points and develop a traffic management plan that could be implemented and tested.

Workers were essential to that process because the site map rarely told the whole story. Workers knew where vehicles queued, which shortcuts people took, where loads obstructed visibility, when production pressures changed traffic flows and where drivers were forced to reverse because the workplace had been poorly designed.

A traffic management plan is a system, not merely a document

WorkSafe describes a traffic management plan as a system for protecting people at a workplace from powered mobile plant. A suitable plan should identify plant movements, pedestrian routes, loading and unloading areas, exclusion zones, driver safety zones, blind spots, reversing areas, crossings and the controls used at each potential interaction point.

The plan should include an accurate site diagram showing forklift operating areas, plant travel paths, pedestrian-only areas and physical separation arrangements. It should also address temporary work, changing layouts, contractor activities, unusual loads and other conditions that may alter normal traffic movements.

The document itself remains an administrative control. Its value comes from the physical and operational changes it requires, the allocation of responsibilities, the implementation of those controls and verification that the arrangements work under actual operating conditions.

A traffic management plan that shows barriers which have not been installed is not an implemented plan. A plan that bears no resemblance to how the site currently operates is wall decoration with a revision number.

WorkSafe’s current forklift hazards and risk controls guidance requires traffic plans to be reviewed when incidents occur, tasks or layouts change, pedestrian protection arrangements change, other mobile plant is introduced or an HSR requests a review. Consultation must include affected employees, contractors, labour hire workers and HSRs.

Start at the top of the hierarchy

The central control question is not whether the workplace has signs, lines, procedures and high-visibility clothing. The question is whether the risk has first been eliminated or minimised through substitution, isolation or engineering controls, so far as is reasonably practicable.

Elimination may involve removing forklifts from a work area, relocating pedestrian tasks, changing the loading process or designing the workplace so pedestrians never need to enter plant operating zones.

Substitution may include using an overhead crane, conveyor, hand stacker or other handling system that creates less interaction between workers and powered mobile plant.

Isolation and engineering controls can include fixed high-impact barriers, separate pedestrian entrances, self-closing pedestrian gates, raised walkways, forklift exclusion zones, pedestrian exclusion zones and physically protected driver safety zones.

Other measures may include one-way traffic flows, redesigning loading areas to eliminate reversing, pedestrian-detection systems, traffic lights, speed limiters and removing blind corners through workplace redesign.

These controls act on the hazard or physically restrict access to it. They do not depend entirely on a worker noticing a moving forklift, correctly interpreting an operator’s intentions and moving out of the way in the few seconds available.

WorkSafe’s hierarchy of control guidance expressly identifies concrete barriers separating pedestrians from powered mobile plant as an isolation control. Pedestrian-sensing systems and speed-governing mechanisms are identified as engineering controls.

Lower-order controls have a supporting role

Administrative controls include procedures, instructions, training, traffic rules, speed limits, signs, floor markings and scheduled movement times.

PPE includes high-visibility clothing and safety footwear.

These measures still have a role, but they should support higher-order controls rather than replace them. WorkSafe states that administrative controls and PPE do not control the hazard at its source, rely on human behaviour and supervision, and tend to be the least effective controls when used alone.

A painted pedestrian path may help people identify the correct route, but it should lead to and operate within a physically protected pedestrian system. A speed-limit sign may support a forklift speed limiter, while a site induction may explain exclusion zones, crossings, driver safety zones and communication requirements established through the site design.

Warning lights, reversing alarms, horns, mirrors and eye contact may improve awareness, but awareness is not separation. The D’Orsogna prosecution demonstrates the weakness of a system that relied on eye contact and informal communication where people and forklifts could occupy the same space.

Higher and lower-order controls should therefore operate together. The physical controls prevent or restrict the interaction, while procedures, training, signs and supervision tell people how to use and maintain that controlled system.

Consultation must influence the result

Consultation is not satisfied by showing workers a completed traffic management plan and asking them to sign an attendance sheet. Workers and HSRs must be given a genuine opportunity to contribute while hazards are being identified and controls are being selected.

A functional traffic management planning committee should walk the site during operating conditions and observe actual movements. It should speak with forklift operators, truck drivers, pedestrians, contractors and supervisors, then compare the documented system with what occurs during busy periods, shift changes, loading activities and abnormal work.

The committee should identify every location where a person can enter a mobile plant operating area and determine whether that interaction can be eliminated. Where elimination is not reasonably practicable, it should determine what physical separation, engineering controls and access arrangements are required before relying on rules or individual behaviour.

Actions should be assigned, funded and tracked to completion. The committee should then verify the controls in operation, because closing an action in a spreadsheet does not establish that the risk has been controlled.

Questions every workplace using mobile plant should answer

A workplace should be able to demonstrate where pedestrians and mobile plant are physically separated, including during loading, unloading, maintenance, cleaning and non-routine work. It should also be able to explain how truck drivers, contractors and visitors reach offices, amenities and waiting areas without entering mobile plant operating zones.

The traffic management plan should reflect the current workplace layout and identify reversing areas, blind spots, crossings, exclusion zones and protected driver safety zones. The controls shown in the plan should exist on the ground and remain effective during ordinary production, not only during an audit or regulator visit.

The workplace should also be able to show how workers and HSRs were consulted, why the selected controls were considered reasonably practicable and why any higher-order options were rejected. If the answer is simply that workers have been instructed to be careful, the risk assessment has stopped well before the hierarchy did.

The practical lesson

The hazard of powered mobile plant colliding with people is well known, foreseeable and capable of causing fatal or permanently disabling injuries. Employers also have specific duties to control, so far as is reasonably practicable, the risk of powered mobile plant colliding with pedestrians or other powered mobile plant.

A traffic management committee provides the consultation and operational knowledge needed to understand the risk. A traffic management plan records the agreed system, but neither will protect anybody unless the identified controls are implemented, maintained, enforced and reviewed.

The test is brutally straightforward. If a pedestrian and a forklift can still enter the same space without a physical control preventing or tightly controlling that interaction, the workplace has not achieved effective separation.

Painted lines, signs, instructions, horns and high-visibility clothing may support the system. They cannot be the system.