By Giles Donovan ·
Safe Work Australia has released a discussion paper titled Options to improve quad bike safety in the workplace, proposing six regulatory and non-regulatory reforms. Public submissions close at 11:59pm AEST on 1 June 2026 and can be lodged via the Safe Work Australia Consultation Hub.
I run Quad Bike King on the NSW Central Coast. We deliver more than 20,000 guided quad bike rides every year with a zero-fatality record. I support Safe Work Australia's underlying objective — reducing deaths and serious injuries on Australian farms is unambiguously worth pursuing. But the case the paper makes for further regulation is weaker than it looks, and if you operate a commercial quad bike fleet — in tourism, in agriculture, or in any supervised setting — you should read it carefully before the consultation closes.
Here is my response, in summary. The full submission is lodged with Safe Work Australia and is available here.

What Safe Work Australia is proposing
The paper puts forward six options:
- Requiring operator protection devices (OPDs) to be fitted on all quad bikes used in the workplace.
- Mandating helmets on all workplace quad bikes.
- Restricting the carrying of passengers on operator-only (type 1) quad bikes.
- Restricting workplace quad bike use to 16 years of age and over.
- Improving quad bike data collection processes.
- Targeted safety communications campaigns.
The first four are proposed amendments to the model WHS Regulations. The last two are non-regulatory.
The number Safe Work Australia doesn't lead with
Here is the figure that should shape this entire consultation — but doesn't appear in the paper:
Approximately 1 quad bike workplace fatality per 24,000 bikes in operation per year, or around 0.0042% per bike per year.
That's calculated from the ACCC's own 2017 estimate of roughly 380,000 quad bikes in operation in Australia, against the paper's figure of 245 workplace fatalities since 2011 (averaging ~16 per year).
For context, Australia's general road death rate works out to about 0.006% per registered vehicle per year. On a per-vehicle basis, workplace quad bikes in Australia are at least as safe as, and probably safer than, the average registered road vehicle. That doesn't mean fatalities are acceptable. It does mean the starting point for a regulator proposing further prescriptive controls should be an honest account of the base rate — and this paper doesn't provide one.
The ACCC Standard has not reduced fatalities
The paper treats the ACCC Quad Bike Safety Standard — phased in from October 2020, fully in force from October 2021 — as a positive foundation to build on. The data tells a different story.
| Period | Years | Fatalities | Annual avg |
|---|---|---|---|
| Pre-Standard | 2011–2019 (9 years) | 138 | 15.3/year |
| Standard phase-in | 2020–2021 (2 years) | 36 | 18.0/year |
| Standard fully in effect | 2022–2025 (4 years) | 61 | 15.25/year |
The pre-Standard and fully-post-Standard averages are statistically indistinguishable. 2024 was in fact the worst year since the Standard took effect, with 20 deaths — a fact the paper acknowledges on page 5 but frames as a case for further regulation rather than as evidence the existing intervention has not worked.
Before layering on new prescriptive rules, Safe Work Australia should be obliged to explain why the ACCC Standard has not produced measurable fatality reduction, and to identify the specific causal pathway by which a new intervention will succeed where the old one has not.
“Workplace” is doing a lot of work in this paper
The paper uses the word “workplace” throughout without drawing distinctions between four very different contexts:
- Workers in primary production — solo operation, remote terrain, utility work involving loads and towing, often older operators, inconsistent helmet use. This drives the fatality statistics.
- Family members, including children, on farms that are also workplaces— not “workers” under the Act but present at a workplace. Contributes to the fatality data: the paper shows 15 fatalities in the under-10 and 10–19 age brackets.
- Paying customers on supervised commercial tours — speed-governed bikes, mandatory helmets, no passengers, no loads, trained guides, pre-scouted trails. Not a material contributor to the fatality statistics.
- Non-worker workplace visitors — highly variable, generally short-duration and supervised.
The proposals apply to all four. But the evidence base applies almost entirely to the first. This is the single most important question the paper leaves unanswered: does a retrofit OPD requirement designed for a solo farm worker carrying a load in remote terrain deliver any safety benefit for a tour operator running governed, single-rider, supervised rides on a known trail network?
In our case, across more than 20,000 rides a year, the answer is no.
The statistical foundation has other gaps
A few further issues worth pointing out:
Side-by-side vehicles (SSVs) are handled inconsistently. The paper presents “quad bike” fatality figures, but cites research from the Centre for Automotive Safety Research that recommends standardised investigation of “all quad bike and SSV fatalities” — research that treats them together. The AIHW hospitalisation data labelled “quad bike related” relies on ICD-10-AM coding that is known to be imprecise for off-road vehicle categorisation. SSVs have ROPS, seatbelts and enclosed cabins — they are widely regarded as materially safer. If the working fleet is shifting toward SSVs and “quad bike” hospitalisations are falling, the question is whether the fall reflects genuinely safer quad bikes or simply the SSV migration masking the underlying trend. The paper doesn't address it.
There's no fleet-size normalisation. Absolute fatality counts are presented without any denominator. If the quad bike fleet is shrinking (plausible, given the SSV shift), flat counts mean per-bike risk is actually rising.
The tractor ROPS comparison is overstated. The paper cites an 87% reduction in tractor rollover fatalities after ROPS adoption as evidence for quad bike OPDs. But ROPS is a full roll cage, generally paired with seatbelts — a fundamentally different engineering solution to a roll hoop OPD on a quad bike. The biomechanical evidence specifically on quad bike OPDs is substantially more contested.
The 86% no-helmet statistic is a national base rate. It reflects the agricultural and recreational population where helmet wearing is inconsistent. It's not a basis from which to infer that mandating helmets will reduce fatalities by 86% in contexts (like commercial tourism) where helmet wearing is already universal.
My position on each option
- Option 1 (OPDs): Oppose as drafted. Support only with carve-outs for commercial tour operators with demonstrated safety records, and with retrofit applied only on change of ownership.
- Option 2 (helmets): Support, unreservedly. Already universal in commercial tourism. Formalising it in regulation costs compliant operators nothing.
- Option 3 (no passengers on type 1 bikes): Support. Already universal in our operation and well supported by evidence.
- Option 4 (16+ age restriction): Support in principle. Clarification needed on how it applies to farm children, tour customers, and youth-size bikes.
- Option 5 (better data):Strongly support. This should be sequenced before Options 1–4, not alongside them. You can't build a defensible impact analysis on data the paper itself acknowledges is incomplete.
- Option 6 (targeted communications): Support. Focus on the demonstrated high-risk population — older male operators, solo utility work with loads — rather than blanket messaging.
The bigger picture
The right way to improve quad bike safety in Australia isn't to keep adding prescriptive rules on top of prescriptive rules. It's to:
- Fix the data first, so we actually know what's driving fatalities.
- Evaluate the ACCC Standard properly, with counterfactuals and fleet normalisation.
- Regulate in proportion to demonstrated risk, recognising that a supervised commercial tour operation is not the same as a solo farm worker in remote terrain.
- Focus intervention on the use case that is actually killing people.
Treating all workplace quad bike use as one homogeneous risk category is administratively convenient. It is not, on the evidence presented, well-supported.
How to have your say
If you operate quad bikes commercially — in tourism, in agriculture, in any supervised context — this consultation matters. Submissions close 11:59pm AEST on 1 June 2026 and can be lodged through the Safe Work Australia Consultation Hub at consult.swa.gov.au.
You can also read our full guide to the safety protocols we run at Quad Bike King.
