A forklift may have a reversing alarm. The operator may hold the correct licence. Workers may know that forklifts regularly travel through the area.
But could someone still step through a doorway, walk around a pallet or take an informal shortcut directly into the forklift’s path?
That is the practical question raised by a recent NSW prosecution involving a worker who was struck by a reversing forklift at a food manufacturing workplace.
The main lesson is that forklift pedestrian separation must be designed into normal operations. Businesses cannot rely mainly on operators seeing pedestrians, pedestrians hearing alarms or workers remembering general instructions to stay clear.
A safe system should prevent people and forklifts from coming together wherever reasonably practicable. Where their paths must cross, the interaction needs to be deliberately controlled.
What happened in the NSW forklift prosecution?
The prosecution followed an incident in November 2022 in which a worker entered a production area and was struck by a reversing forklift.
The company and one of its officers were later convicted of work health and safety offences. The NSW Industrial Court proceedings were finalised in June 2026.
The court’s findings focused on the absence of an effective system for managing the interaction between forklifts and pedestrians. The official case summary described a total absence of procedures for using forklifts around pedestrians, resulting in a high likelihood that workers would be exposed to the risk.
The important point for other businesses is not the identity of the workplace. It is how familiar operating conditions were allowed to continue without adequate separation, procedures, training and verification.
A forklift licence, reversing alarm or instruction to “watch out” may form part of the overall system. None of them physically prevents a person from entering the path of moving plant.
Why forklift pedestrian separation comes before warnings
The NSW Work Health and Safety Regulation requires businesses to manage risks associated with powered mobile plant colliding with people or other plant. So far as reasonably practicable, powered mobile plant must not collide with pedestrians.
The Regulation also requires a warning device where there is a possibility of collision. That does not mean a warning device is the main control. The obligation to prevent the collision comes first.
A reversing beeper tells people that a forklift is moving. It does not stop someone from walking through a doorway into its path.
Similarly, painted lines can show people where they are expected to walk, but a line on the floor cannot prevent an unexpected step into an operating zone.
The hierarchy of controls provides a more reliable order for managing the risk:
- Eliminate the need for forklifts and pedestrians to use the same area.
- Physically separate their routes with barriers, guardrails or other fixed controls.
- Control the limited locations where their paths must cross.
- Support those controls with procedures, signs, alarms, training, supervision and personal protective equipment.
SafeWork NSW and Safe Work Australia guidance both prioritise physical separation. Examples include separate walkways, barriers, pedestrian doors, controlled crossings, bollards, gates and designated exclusion areas.
This does not make signs, line marking or high-visibility clothing unnecessary. It means they should support stronger controls rather than carry most of the responsibility.
Since 1 July 2026, approved codes of practice in NSW operate as minimum performance standards. A business must follow an applicable code or use another method that provides an equivalent or higher standard of safety.
Could someone enter the forklift’s path during normal work?
A forklift risk assessment should not be limited to a quiet walk through the warehouse when production has stopped.
The most useful review happens while the area is operating normally. That is when pallets are being moved, deliveries are arriving, workers are changing tasks and temporary storage begins to affect visibility.
Walk the busiest route with the forklift operators and the people who work nearby. Look for the points where their movements could unexpectedly overlap.
Check every pedestrian entry point
Pedestrian exposure does not only occur on marked walkways.
Look at every place someone can enter a forklift area, including:
- Pedestrian doors
- Production lines and workstations
- Offices and amenities
- Cool rooms and storage areas
- Loading docks
- Maintenance access points
- Emergency exits
- Informal shortcuts
- Visitor entrances
At each location, consider what a person sees as they enter the area.
Can they clearly see an approaching forklift? Can the operator see them? Could pallets, racking, machinery or stored materials block the view?
A pedestrian door that opens directly into a forklift route is a clear warning sign. A barrier, railing or offset entrance may be needed to stop someone walking straight into the operating zone.
Design routes that do not depend on attention
People become familiar with their workplace. Operators repeat the same movements, while pedestrians become used to hearing alarms and seeing forklifts nearby.
That familiarity makes controls based only on attention less reliable.
A better layout guides people towards the safe route automatically. Depending on the workplace, this may include:
- Guardrails or high-impact barriers
- Bollards beside pedestrian doors
- Separate pedestrian entrances
- Gated crossings
- Traffic-light-controlled crossings
- One-way forklift routes
- Dedicated pedestrian walkways
- Restricted forklift operating areas
- Safe waiting zones for drivers and visitors
Safe Work Australia’s warehousing guidance recommends separating pedestrian and vehicle areas, using barriers or fences, controlling access and protecting blind spots before relying mainly on administrative controls.
Where a physical barrier is not reasonably practicable, the business should be able to explain why and demonstrate how its alternative controls provide an effective level of protection.
Control reversing, speed and visibility
Reversing should be reduced wherever the layout and work process allow it.
This may involve one-way travel routes, drive-through loading arrangements or enough space for a forklift to turn without repeatedly reversing through pedestrian areas.
Where reversing remains necessary, review:
- Operator visibility
- Blind corners and intersections
- Mirrors and cameras
- Proximity detection systems
- Lighting
- Reversing alarms
- Horn-use requirements
- Forklift speed limits
- Speed-limiting devices
- Pedestrian exclusion zones
Technology can improve visibility and provide additional warning, but it should not replace separation.
There should also be a clear rule for what happens when a pedestrian enters the forklift exclusion zone. In most workplaces, the safest rule is simple: the forklift stops and does not move again until the person has left the zone and the operator has confirmed it is safe.
What a forklift traffic management plan should control
A forklift traffic management plan should reflect how the particular workplace operates.
A generic plan copied from another site will not capture your pedestrian doors, loading arrangements, blind corners, production pressures or temporary storage areas.
The plan should clearly address:
- Forklift routes and directions of travel
- Pedestrian walkways
- Controlled crossing points
- Forklift exclusion zones
- Speed limits
- Loading and unloading areas
- Parking and charging locations
- Blind spots and restricted-visibility areas
- Visitor and delivery-driver access
- Responsibilities for monitoring controls
- Emergency arrangements
- How the plan will be reviewed
Safe Work Australia recommends documenting vehicle and pedestrian routes, points of interaction, control measures, responsibilities and arrangements for monitoring and reviewing the traffic system.
A diagram can be useful, particularly on larger sites. It should match the workplace as it currently operates, not the layout that existed when the plan was first written.
Loading areas, visitors and delivery drivers
Delivery drivers, contractors, visitors and office-based employees may not understand the site’s normal traffic movements.
Their access should be planned rather than left to verbal directions given after they arrive.
The traffic system should explain:
- Where drivers report on arrival
- Where they can safely wait
- Whether they may leave their vehicles
- How they reach amenities
- Who controls loading and unloading
- Where visitors may walk
- When forklift work must stop
- What induction or safety information is required
SafeWork NSW specifically includes visitors and delivery drivers when requiring compliance with workplace traffic rules and traffic management plans.
Try following the route of someone visiting for the first time. If that person could easily enter a production or loading area without guidance, the access controls may not be strong enough.
Changes and abnormal operations
Traffic controls often become less effective when the workplace changes.
Common examples include:
- A damaged barrier or gate
- Stock stored over a pedestrian walkway
- Overflow pallets creating a blind corner
- Temporary production equipment
- Maintenance work
- Seasonal increases in deliveries
- A changed loading location
- New plant
- Damaged or faded line marking
Your plan should state what happens when an essential control is unavailable.
For example, if a barrier is damaged or stock blocks a designated walkway, will forklift activity stop? Will the area be isolated? Is there an approved temporary route?
The answer should be decided before the problem occurs, not left to an operator or supervisor to work out during a busy shift.
Competency goes beyond holding a forklift licence
A current high-risk work licence is essential for anyone operating a forklift that requires one.
However, a licence does not confirm that the operator understands every workplace, every forklift model or every local traffic arrangement.
The business still needs to make sure operators are competent in:
- The specific forklift they use
- The workplace layout
- Site speed limits
- Reversing rules
- Pedestrian routes
- Exclusion zones
- Loading and unloading procedures
- The forklift safe operating procedure
- Emergency and stop-work requirements
Site-specific training should include supervised familiarisation and a practical check that the operator can apply the rules during normal work.
SafeWork NSW guidance recommends confirming licence requirements, providing site-specific induction, checking competency on the particular forklift and providing ongoing training, instruction and supervision.
Forklift refresher training should not become a calendar exercise completed only because a set period has passed.
Consider refresher training when:
- The workplace layout changes
- A new forklift is introduced
- Traffic arrangements change
- A near miss occurs
- An incident occurs
- Unsafe behaviour is observed
- A supervisor identifies a knowledge gap
- An operator returns after an extended absence
Pedestrians also need training. They should understand where they may walk, how crossings work, what exclusion zones mean and what to do when a forklift approaches.
How managers and officers verify that controls are working
Having a traffic management plan does not prove that the traffic system is effective.
Managers need to check what is happening on the floor.
Useful verification activities include:
- Walking active forklift areas during normal production
- Observing operators and pedestrians
- Inspecting barriers, gates and crossings
- Checking whether walkways are clear
- Reviewing near misses and access breaches
- Speaking with workers and delivery drivers
- Checking training and competency records
- Assigning corrective actions
- Reinspecting completed actions
- Reviewing controls after workplace changes
Supervisors should respond when workers stop using the designated walkway, when forklifts regularly travel outside the planned route or when pallets repeatedly block visibility.
These behaviours often indicate a problem with the design of the system. The walkway may be inconvenient, the loading area may be too small or production requirements may conflict with the documented procedure.
For officers, verification is part of due diligence. Officers may delegate safety tasks, but they cannot delegate their personal duty. They need suitable processes for obtaining information, providing resources and checking that controls are both available and being used.
Verification does not require an officer to personally watch every forklift movement. It does require more than assuming that a policy is being followed because it has been approved.
Useful questions include:
- When was the traffic plan last reviewed?
- What forklift near misses have been reported?
- Are pedestrian barriers inspected?
- Who checks that corrective actions are completed?
- How are changes to the layout assessed?
- What happens when a separation control is damaged?
- How do we know workers and visitors follow the system?
The more significant the forklift activity and pedestrian exposure, the more structured the verification process should be.
Ten-point forklift-and-pedestrian walkthrough
Use this walkthrough with the managers, supervisors, forklift operators and workers who use the area.
1. Walk the busiest forklift route
Complete the walkthrough during normal operations rather than when the area is empty. Observe actual production, picking, loading and delivery movements.
2. Mark every pedestrian entry point
Include doors, offices, amenities, production areas, loading docks, workstations and informal shortcuts.
3. Identify reversing and blind-spot locations
Check corners, intersections, racking, stacked goods and areas where the layout or storage conditions regularly change.
4. Test the physical separation
Confirm that barriers and guardrails genuinely prevent pedestrians from entering the forklift route. Do not assume painted lines provide the same protection.
5. Review every pedestrian crossing
Check that crossings are clearly visible, deliberately positioned and controlled. Avoid placing them close to reversing, turning or loading movements.
6. Confirm the exclusion and stop-work rules
Operators and pedestrians should understand where people must not enter and when a forklift must stop.
7. Verify speed and visibility controls
Check speed limits, lighting, mirrors, cameras, proximity devices, reversing alarms and horn requirements. Confirm these controls work in the actual operating environment.
8. Sample operator competency records
Review licences, site induction, training in the forklift safe operating procedure, practical competency checks and relevant refresher training.
9. Follow the visitor and delivery-driver route
Start at the site entrance and follow the route a new visitor would take. Confirm that reporting points, waiting areas and amenities can be reached safely.
10. Record findings and verify close-out
Assign each action to a responsible person with a completion date. Revisit the area after completion and confirm the control has solved the problem.
The key question for your workplace
The central question is straightforward:
Could a worker, visitor or delivery driver still enter the path of one of your forklifts during normal operations?
The answer should not depend mainly on whether a pedestrian hears an alarm, notices a painted line or remembers a general instruction to be careful.
Effective forklift pedestrian separation combines workplace design, physical barriers, controlled crossings, site-specific procedures, training, supervision and ongoing verification.
Walk your busiest forklift route with the people who use the area. At every entry point, identify where a pedestrian could enter, which control should prevent it and what evidence shows that control is working.
The Safety Dept. helps businesses keep traffic management plans, operating procedures, training records and corrective actions current, so the system on paper continues to reflect what is happening in the workplace.