AMCA has lodged a formal submission to the Victorian Government’s Independent Review of Employee Representatives – Interim Report, responding to proposed changes to the operation of Health and Safety Representatives (HSRs) and Authorised Representatives of Registered Employee Organisations (ARREOs).

The Review is considering a range of potential reforms, including expanded ARREO powers such as broader right-of-entry provisions, access to digital systems, and — most significantly — the ability to issue Provisional Improvement Notices (PINs) or direct cease-work actions in certain circumstances.

Strong Position on ARREO Power Expansion

AMCA has taken a firm position opposing any expansion of ARREO powers in the construction and mechanical services context.

Our submission makes clear that:

• Existing ARREO powers have, in some cases, resulted in site-wide disruption and productivity impacts that extend beyond the original safety issue.
• Expanding statutory powers without first addressing known deficiencies in oversight, accountability, and dispute resolution would compound existing challenges.
• Increased powers would inevitably lead to more disputes, investigations and regulatory intervention — placing additional strain on WorkSafe and government systems unless accompanied by significant additional resourcing.
• There must remain a clear separation between legitimate safety regulation and industrial leverage.

AMCA has emphasised that any consideration of expanded authority must be accompanied by robust checks and balances, real-time reporting to the regulator, and transparent audit mechanisms — none of which currently operate at a level that would justify broader powers.

Recognising Construction Realities

The submission also highlights that mechanical services contractors operate in complex, multi-employer construction environments. Consultation and representation frameworks designed for single-employer workplaces do not always translate effectively to specialist subcontractor arrangements.

AMCA supports practical improvements to consultation, transparency, and dispute resolution. However, reforms must be proportionate and reflect how construction sites actually function — particularly in relation to sequencing, trade-specific risk ownership, and subcontractor exposure.

Focus on Oversight Before Expansion

Before any expansion of powers is considered, AMCA has recommended:

• Improved baseline data collection on ARREO entries, PINs and dispute outcomes.
• Mandatory reporting of entry notices and PINs to WorkSafe.
• Faster and clearer dispute resolution pathways.
• Greater transparency in WorkSafe investigations and decisions.

AMCA will continue to engage constructively with the Victorian Government to ensure that any reforms strengthen safety outcomes while maintaining productivity, certainty and fairness for contractors and workers alike.

If you would like a copy of the submission or wish to provide feedback on how ARREO activity has impacted your business, please contact [email protected]