Perth Metro · South-West · Pilbara · Goldfields
Documentation Gap Analysis
A documented audit of what your records hold against what the applicable Australian standards and WHS Regulations require – then the work to close the gaps. Pressure equipment, valves, fire equipment and electrical test & tag records.
Missing documentation rarely condemns plant. Not knowing what’s missing is the risk.
What this service covers
- Plant registration lodgement and support
- Manufacturer's Data Report retrieval
- Replacement data plates and valve marking
- Asset register in Client Asset Management Portal
- Audit; baseline data established, structured planning provided
- AS3788 Inspection interval compliance and structured scheduling
Documentation Obligations
- Pressure equipment inspected on a regular basis by a competent person. This is the statutory duty, not a recommendation - r. 224 of the WHS Regulations, with a penalty attached. Gas cylinders must also carry a current inspection mark showing the date of the most recent inspection.
- An information file for each item i.e. boilers and pressure vessels at hazard levels A, B and C, piping at hazard levels A and B, and relief devices. Kept current, retained for the life of the item, and transferred with the equipment if it is sold.
- A pressure equipment register listing boilers and pressure vessels at hazard levels A, B, C and D, piping at hazard levels A, B and C, and relief devices. Maintained and current.
- A documentation system that is secure, has its integrity assured, and is accessible at all times to people authorised by the owner. Paper or digital, or both.
- Registration of plant designs and items of plant where the class requires it. Part 5.3 of the WHS (General) Regulations 2022 requires plant designs to be registered (r. 243) and items of plant to be registered (r. 246), with the classes set out in Schedule 5. The registration document must be available for inspection (r. 262, r. 275).
- A unique identification number on every item, displayed prominently on the equipment, used as the prime identifier across all records and cross-referenced to the regulator's registration and design registration numbers.
- On equipment, not just in the file. The plant registration number must be marked on the item itself (r. 273(4)), and the design registration number must be kept readily accessible in the vicinity of the plant at all times (r. 260(5)). Both carry penalties.
- Registration of plant designs and items of plant. Design registration covers pressure equipment other than pressure piping at hazard levels A to D. Item registration covers boilers and pressure vessels at hazard levels A to C, with gas cylinders, LP Gas automotive fuel vessels and serially produced vessels excluded. Part 5.3 of the WHS (General) Regulations 2022 requires plant designs to be registered (r. 243) and items of plant to be registered (r. 246), with the classes set out in Schedule 5. At a mining workplace, Mines Regulations r. 246 requires items of plant to be registered and r. 243 directs design registration back through Part 5.3 of the General Regulations. Under either instrument the registration document must be available for inspection (r. 262, r. 275).
- At a mining workplace, the mine record. Mines Regulations Part 10.7 requires a mine record (r. 675Y) that must be kept and available (r. 675Z) and must contain inspection records (r. 675ZA). Electrical records and log books carry their own duties under r. 641B and r. 641C.
Relevant Standard Applications
| Reference | Title | Documentation it requires |
|---|---|---|
| AS 3788:2024 | Pressure equipment – In-service inspection | Section 8 – equipment files, pressure equipment register, inspection reports, unique identification, marking, missing documentation and equipment history |
| AS 1210:2010 | Pressure vessels | Section 7 – marking and documentation, including the vessel data plate |
| AS 1271:2003 | Safety valves, other valves, liquid level gauges and other fittings | Clause 2.5 – valve marking, serial numbers, certification and manufacturer records |
| AS 1851:2012 | Routine service of fire protection systems and equipment | Logbooks, tags, labels, summary records and baseline data |
| AS/NZS 3760:2022 | In-service safety inspection and testing of electrical equipment | Test records for electrical equipment |
| WHS Act (WA) | Work Health and Safety Act 2020 | Your primary duty of care, and the records that evidence it |
| WHS Regulations (WA) | Work Health and Safety (General) Regulations 2022 | Registered plant, design registration and item registration |
| WHS Regulations (Mines) | Work Health and Safety (Mines) Regulations 2022 | Additional duties on mining operations |
How it Works
- Audit
We compare what you hold against what each standard and regulation requires, asset by asset.
- Gap register
Every gap listed against its asset, with what is missing and which requirement it sits under. You get the register whether or not you engage us to close it.
- Priority List
Gaps that stop equipment being used, or that a regulator would act on, are separated. Not everything is urgent, and treating it as though is not cost-effective.
- Close
Manufacturer’s Data Report retrieval, plant registration lodgement, replacement data plates, and information documented and stored.
- Maintain
Everything loaded to your Client Asset Management Portal with due dates and reminders, so the gap does not quietly reopen. DGE assigns an Asset Manager to monitor your file and organise inspection requirements and mobilisation at an agreed schedule.
Where Fines Apply
| Duty | Reg. | MAX penalty |
|---|---|---|
| Pressure equipment inspected regularly by a competent person | r. 224 | $4,200 / $21,000 |
| Plant maintained, inspected and tested by a competent person | r. 213 | $4,200 / $21,000 |
| Supplying plant without a registered design | r. 231–233 | $7,000 / $35,000 |
| Commissioning an item that is not registered | r. 234 | $7,000 / $35,000 |
| Plant not in use left in a state that creates a risk | r. 207 | $7,000 / $35,000 |
| Records of tests and inspections for registered plant | r. 237 | $1,450 / $7,000 |
| Design records kept for the design life of the plant | r. 228–230 | $1,450 / $7,000 |
| Registration document available for inspection | r. 262, r. 275 | $1,450 / $7,000 |
| Design registration number accessible in the vicinity of the plant | r. 260(5) | $1,450 / $7,000 |
| Plant registration number marked on the item | r. 273(4) | $1,450 / $7,000 |
| Regulator notified within 14 days where details change or control passes on | r. 282 | $1,450 / $7,000 |
Every Certificate. Every Due Date. Tracked 24/7.
A live asset register, not a document file.
- Dashboard access across every asset and certificate. Search, filter and auto-generate spreadsheets for reporting and audit. Reminders at 90 days, 30 days, and when a certificate is overdue. Accessible 24/7, current at all times.
Audit-ready. Complete compliance register exports in one step – no reconstructing it from certificates in a drawer.
Frequently Asked Questions
Whatever asset list or plant register you have, even if it is incomplete, plus the site and the equipment classes involved. If you have nothing at all, tell us that – it changes the scope but not the answer. The gap register is yours either way; you are not obliged to engage us to close what we find.
It is common, and it can be workable. Where documentation and name plates are missing, AS 3788 provides for equipment data to be developed and validated by a competent person following suitable inspection. You end up with a compliant equipment file rather than unusable plant. This can be managed.
Several of these duties do. Failing to have pressure equipment inspected on a regular basis by a competent person carries a maximum of $4,200 for an individual and $21,000 for a body corporate under r. 224. Commissioning an item that should be registered but isn’t, or supplying plant without a registered design, runs to $7,000 and $35,000. Record-keeping failures sit at $1,450 and $7,000 i.e. no records of tests and inspections, design records not kept, registration document not available, the registration number not marked on the plant, or the design registration number not kept accessible near it. They are maximums, and they apply per contravention.
We can retrieve MDRs where they still exist. Where they do not, the equipment data can be developed and validated instead. Either route gets you to a defensible file. We also handle plant registration lodgement and support, including the design and item registration records that belong in the equipment file. Note the duty to hold records is itself penalised, so an absent file is not a neutral position.
Design registration covers pressure equipment other than pressure piping at hazard levels A to D. Item registration covers boilers and pressure vessels at hazard levels A to C, and excludes gas cylinders, LP Gas fuel vessels for automotive use, and serially produced vessels. Hazard levels are classified under Section 2.1 of AS 4343:2014. Heritage boilers are out, as is any pressure equipment other than a gas cylinder falling outside the scope of AS/NZS 1200:2015. Send your asset register and we’ll tell you which of your items sit where.
No. AS 3788 sets out a path for inadequate marking to be reinstated, and we supply replacement data plates marked to the requirements of AS 1210 Section 7. For valves, the equivalent marking and certification requirements sit in AS 1271 Clause 2.5.
Yes. At a mining workplace the WHS (Mines) Regulations 2022 apply and the General Regulations do not, except where the Mines Regulations provide otherwise – design registration, for instance, is directed back through Part 5.3 of the General Regulations by Mines Regulations r. 243. There is also a mine record obligation under Part 10.7 that has no equivalent off a mine site. It is a different set of duties rather than an extra layer, so the audit scope changes. Tell us if the site is a mining operation when you enquire.
Everything goes into your Client Asset Management Portal against each asset, with its due date. The register exports in one step for audit, and reminders go out at 90 days, at 30 days, and again once something is overdue. Your dedicated DGE Asset Manager will liaise with you for compliance due date requirements at an agreed interval.
Related Services
Set Pressure Testing and Certification to AS1271.
In-service inspection of pressure vessels to AS 3788.
Search, filter, export. Automatic certification reminders at 90 and 30 days.
Unsure where you sit with documentation compliance?
Send whatever asset list you have. We’ll audit it against what the standards require and develop a register and compliance schedule proposal.
