SAFETY SATURDAY: MANUAL HANDLING CASES

Some people say a man is made out of mud

A poor man's made out of muscle and blood

Muscle and blood and skin and bones

A mind that's weak and a back that's strong

- Sixteen Tons, by Tennessee Ernie Ford

Manual Handling is defined by WorkSafe Victoria as any work where a worker needs to lift, lower, push, pull, carry, move, hold or restrain something (WorkSafe Victoria, 2023). Manual handling may be hazardous manual handling if those actions require repeated, sustained or high force; sustained awkward posture; repetitive movements; exposure to sustained vibration; handling people or animals; loads that are unstable, unbalanced or hard to hold; or a combination of the above. Manual handling is a common part of every job and occupation - even office workers need to carry things from point A to point B. Whenever a worker is handling a load, the worker is using force and power generated by their own body to do the work. Manual handling and manual work have been common within occupations from ancient times, and concordantly, the risks from manual handling are well-documented, where these hazards were mitigated by using primitive machines, draft animals, or broader mechanisation (Bronstein, 2008).

In contemporary understanding, a worker's exposure to manual handling tasks results in body stressing. Body stressing is defined by Comcare as a collective term covering a broad range of health problems that may affect a worker's muscles, bones, joints, and which may be affected by or affect their level of stress (ComCare, n.d.). Body stressing does not occur as a consequence of manual handling alone - exposure to vibration, posture, and psychosocial contributing factors can contribute to the total ecosystem of body stress experienced by a worker during the course of their duties, many of which may occur in the absence of manual handling tasks. However, the relationship of physical exertion to the development of strain and stress is well-described in literature and is the subject of investigation, wherein exposure to load and the use of the body to manage loads is proportionally highly represented in the causes of serious and nonserious claims and incidences. Sustained exposure to body stressing factors may cause physical injuries such as sprains and strains of muscles, ligaments and tendons; back injuries; joint and bone injuries or degeneration; nerve injuries or compression (for example carpal tunnel syndrome or spinal radiculopathy); muscular and vascular disorders (such as compartment syndromes); soft tissue injuries such as hernias or haematomas; and which may be persistent. Broadly, these physical injuries are called Musculoskeletal Disorders (Safe Work Australia, 2019), and manual handling may give rise to some or all of these in isolation or in combination. Body Stressing accounts for the highest proportion of serious work-related musculoskeletal disorders in the 2015-2016 reporting period, as well as in earlier reporting periods (safe Work Australia, 2016).

Manual Handling may increase the risk of physical injury through different means.

Movements that require high force, such as arresting a moving object, lifting something relatively heavy off the ground or through a long arc of travel, or pushing or pulling something that is resistive to movement because of inertia, friction, or awkward center of gravity may increase the risk of physical injury (Hume et. al., 2013). In all of these circumstances, the worker's body needs to overcome the weight and awkwardness of the load in order to manipulate it for its designated end. In Sawyer v Steeplechase Pty Ltd [2024] QSC 142, the plaintiff experienced a lower back injury when handling and moving heavy steel mesh sheets (105kg) on a jobsite, where "... The manual handling of heavy items by workers performing duties on a work site poses an obvious risk of physical injury," where the defendant having "organised an activity involving a risk of injury … owed a duty to use reasonable care to avoid or minimise the risk of injury to … workers who would be engaged in that activity." In this case, even though the handling undertaken was being completed by two workers, attendant care to control the systems and duties of work were identified as potential mitigating factors. However, controls applied should be appropriate to the use-case of the work being done, as shown in Welsh v Biggin Pty Ltd (No 2) [2023] QSC 211, where, despite the injured worker using a pallet jack as a manual handling control, the "pulling with significant high force at a stationary laden pallet to initiate its movement" exposed that worker to injury. In this case, the transformation of work owing to the introduction of control resulted in transformation of the force required, thus changing the point at which the worker was exposed to mechanical risk. Instead of lifting using their body, the worker was operating the plant using their body, resulting in risk transduction and an injury arising from failure to control residual risk. This illustrates how control measures may introduce new or alternate risks and should also be accounted for and reassessed.

Repetitive movements are those which may not require high force, but which are done repeatedly. These may be movements of individual body segments such as of the arms when cleaning, sorting, or filing, or may be wholebody repetitive movements such as those which may be required when moving boxes, stacking, shelving, or arranging items at height. Repetitive movements expose body segments to doses of sustained force which, if not mitigated through breaks or work adjustment, may expose a worker to injury and consequent discomfort (Kirkhorn & Earle-Richardson, 2006). The finding in Xu v Diver Foods Pty Ltd [2021] VCC 824, wherein the worker "[moved] approximately 640 boxes, each weighing 15 to 17 kilograms ... [taking] five hours to complete the task … [and] experienced severe pain in the shoulders and neck," determined that the plaintiff's neck injury was causally related to their employment, and while the plaintiff did have a degenerative prior condition, the failure of the defendant to control the ergonomic exposures of the work being done exposed them to liability. Similarly, in Zhai v Victorian WorkCover Authority [2022] VCC 19, the co-occurrence of repetitive movements and exposure to vibration "would likely ... contribute ... by way of acceleration, aggravation and/or exacerbation of the underlying traumatic and inflammatory processes," again even though the plaintiff had predisposing physical conditions. In both of the cited cases, appropriate monitoring and control as well as ergonomic assessment may have mitigated the risks that gave rise to actionable incidents, as well as using worker feedback or task review to ensure that the physical load to which a person was exposed did not exceed their working capacity.

Awkward movements are those where the load may not be particularly heavy and the movement may be done once or twice, but expose workers to potential risk owing to the arrangement of the body (Gallagher, 2005). Combination bending, turning, and twisting of the trunk is a good example of this, especially under load or when pulling. Thee movements position the body in disadvantageous arrangements of limbs with respect to the centers of gravity of those objects and loads being manipulated, which may produce suboptimal, misdirected, or inappropriately compensated movements when undertaking a movement. The pulling of cabling through walls is identified as the first and a recurrent injury factor in Sundar v Watters Electrical (Aust) Pty Ltd; Sundar v Ventilation Australia Pty Ltd [2018] VCC 1242, among a broader ecosystem of hazardous manual tasks. Another example may occur when reaching for something deep in cabinetry or shelving, or performing work while standing on a ladder. The lattermost example of these predisposing activities gave rise to one of three injury claims discussed in Roberson v Icon Distribution Investments Limited and Jemena Networks (ACT) Pty Ltd trading as AGL Distribution [2020] ACTSC 320, wherein expert analysis of the facts of the matter recommended that work could be rearranged "to avoid the need for a person to work awkwardly from a ladder," or "Providing a suitable work platform such as a mobile scaffold or a platform ladder," ostensibly to improve support and balance to minimise the displacement of the movement.

Unstable loads are objects that by virtue of their packing, composition, dimensions or some other property are difficult to handle, move, and balance owing to awkwardly placed centers of gravity (Kjellberg, 2012). Unstable loads require more physical strength to control in order to maintain stability. Half-full buckets and drums, boxes that have space inside them that allow loads to jostle and shift, and objects like frames, long planks, or which have free moving components on them are all examples of unstable loads. Load instability that occurs swiftly can cause injury, as has been seen in Penn v Allied Express Couriers Pty Ltd [2017] VCC 1956, wherein the plaintiff reported their initial mechanism of injury as being instability in a handled load where, on loss of handling of the load, the plaintiff experienced harm. Where loads are packed, boxed, or otherwise arranged so that the constituent materials of that load might not be visibly appreciable, appropriate warning should be given to those workers engaged in manual handling. In Norsgaard v Aldi Stores (A Limited Partnership) [2022] QDC 260, the plaintiff experienced an injury owing to instability in the movement introduced by turning and lifting a load in one compound motion owing to lack of appropriate training. This shows how risk can arise from the concrete properties of the work or be introduced as a vulnerability of deficit.

There are many means by which the risk posed by manual handling practices to overall health may be mitigated. The Primary Duty of Care of a Person Conducting a Business Undertaking, as described by the Work Health and Safety Act 2011 is to ensure, so far as is reasonably practicable, the health and safety of those engaged or caused to be engaged by the Person, and those whose activities in carrying out work are influenced or directed by the Person while at work in the business or undertaking. To this end, a business or employer may engage in a review of the working environment and the tasks done within it, to provide workers with opportunities to move around, stretch, and rest. This engages with those duties an employer is obligated to perform where there is a foreseeable risk of injury consequent to exposure, being the provision and maintenance of a work environment without health and safety risks, the provision and maintenance of safe systems of work, the provision of adequate facilities for the welfare at work of workers, the provision of information, training, instruction and support for workers, as well as monitoring worker health in order to engage with the legal responsibility held by employers to control risks to workers that arise during the course of their work.

To this end, simple consultation with workers regarding duties of work, assessment by an ergonomist or physiotherapist in safe work practices, the provision of lifting equipment, and the arrangement of the workspace may be effective means in managing those risks and exposures that arise from manual handling practices. The relationship between the biomechanics of load management and consequent injury may be plausibly illustrated in these cases. Consequently, where those relationships may exist, appropriate control of the system of work is needed to ensure that uncontrolled biomechanical and occupational factors do not result in unmitigated risk to the worker through aggravation, acceleration, or exacerbation of pre-existing factors which may otherwise be asymptomatic. Further to this, organisational and psychosocial factors arising from the design of work can predispose workers to increased risk owing to intensification of work resulting in unsustainable load that cannot be mitigated with controls or recuperation, or extensification of work where workers are engaged in duties that are outside of their normal spectrum of occupational obligations. Assessment and adjustment of the arrangement of job tasks and the manner in which they are carried out, as well as the individual susceptibility and characteristics of the workers undertaking those tasks, may consequently have a protective effect when considering the risks posed by manual handling exposures. Mindfulness regarding the systemic contexts that arrange forces, postures, repetitions, and durations involved in a task that re capable of stressing human tissues owing to their load magnitude, direction, frequency, posture, and recovery time which create stresses that may exceed tolerance, be repetitive or sustained above adaptive capacity, or reasonably contribute to the likelihood of injury is important to proactively ensure risk control.

Management of risks and exposures arising from manual handling requires consideration of workers' needs and tolerances, the work being done, and the resources available to the workplace, considering the legal, medical, and biomechanical perspectives and interpretations of facts that may inform appreciation and control of risks depending on the conservatism of the decided approach. Every workplace and workforce is different, and so no two problems are ever the same or require precisely the same solution. Effective management of workplace health and safety risks requires appraisal and assessment, planning, and review. This review should also be undertaken being mindful that solutions applied at one time may not be appropriate at another time or for another problem. Managing risks through the framework presented in the Hierarchy of Controls requires elimination of the risk as the most effective means of control, and engineering, isolation or substitution where that is not possible. Given the ubiquity of manual handling in certain job tasks, breaks, safety checks, and spotchecks may be needed to ensure minimisation of stress exposure, and continued sustainability at work.

None of this information constitutes medical, legal, occupational health and safety, best guidance, standard, or other guidance, instruction, or prescription.

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References

Bronstein, J. L. (2008). Caught in the machinery: Workplace accidents and injured workers in nineteenth-century Britain. Stanford University Press.

ComCare. (n.d.). Body Stressing: A Risk Management Snapshot. Retrieved 22 January 2026 from https://www.comcare.gov.au/about/forms-pubs/docs/pubs/safety/body-stressing-risk-management-snapshot.pdf

Gallagher, S. (2005). Physical limitations and musculoskeletal complaints associated with work in unusual or restricted postures: a literature review. Journal of Safety Research, 36(1), 51-61.

Hume, P. A., Bradshaw, E. J., & Brueggemann, G. P. (2013). Biomechanics: injury mechanisms and risk factors. Gymnastics, 75-84.

Kirkhorn, S. R., & Earle-Richardson, G. (2006). Repetitive motion injuries. In Agricultural Medicine: A practical guide (pp. 324-338). New York, NY: Springer New York.

Kjellberg, K. (2012). Work requiring considerable muscle force. Occupational Physiology, 59-97.

Norsgaard v Aldi Stores (A Limited Partnership) [2022] QDC 260

Penn v Allied Express Couriers Pty Ltd [2017] VCC 1956

Roberson v Icon Distribution Investments Limited and Jemena Networks (ACT) Pty Ltd trading as AGL Distribution [2020] ACTSC 320

Safe Work Australia. (2016). Statistics on Work-Related Musculoskeletal Disorders. Retrieved 22 January 2026 from https://www.safeworkaustralia.gov.au/system/files/documents/1702/statistics_on_work-related_musculoskeletal_disorders.pdf

Safe Work Australia. (2019). Work-related Musculoskeletal Disorders in Australia. Retrieved 22 January 2026 from https://www.safeworkaustralia.gov.au/system/files/documents/1912/work-related_musculoskeletal_disorders_in_australia_0.pdf

Sawyer v Steeplechase Pty Ltd [2024] QSC 142

Sundar v Ventilation Australia Pty Ltd [2018] VCC 1242

Welsh v Biggin Pty Ltd (No 2) [2023] QSC 211

WorkSafe Victoria. (2023). Hazardous manual handling: Safety basics. Retrieved 22 January 2026 from https://www.worksafe.vic.gov.au/hazardous-manual-handling-safety-basics

Xu v Diver Foods Pty Ltd [2021] VCC 824

Zhai v Victorian WorkCover Authority [2022] VCC 19

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Declaration: No artificial intelligence or assistive intelligence was used in the creation of this work.