Safety AI in manufacturing: the certification requirement
Manufacturing operations that deploy AI in safety-critical contexts — AI that controls machinery that can cause injury, AI that detects hazardous conditions in real time, AI that makes decisions about whether equipment is safe to operate — face specific obligations under Work Health and Safety legislation. Safe Work Australia's model WHS Act and state equivalents require that plant and machinery be designed and constructed to be safe — AI control systems are part of the plant, and their safety must be demonstrated.
For AI systems in safety-critical manufacturing roles, the safety demonstration typically requires: a risk assessment that identifies the AI system's failure modes and their safety consequences, validation testing that demonstrates the AI system performs safely under the conditions it will encounter in operation, fail-safe design that ensures failures are detected and appropriate responses are triggered, and ongoing monitoring that verifies safety performance in production. The safety case methodology — structured arguments supported by evidence that a system is acceptably safe — is the appropriate framework for AI in safety-critical manufacturing applications.
Supply chain AI and modern slavery due diligence
AI-driven supply chain management creates specific modern slavery due diligence considerations. Australian organisations subject to the Modern Slavery Act 2018 (those with consolidated annual revenue above $100 million) must report on their actions to address modern slavery risks in their operations and supply chains. AI systems used in supplier selection, risk scoring, or supply chain monitoring must be designed and implemented in ways consistent with this due diligence obligation — not as a substitute for it. An AI supplier risk model that systematically scores suppliers from certain geographic regions or sectors as low-risk without adequate investigation does not satisfy the due diligence obligation; it automates a superficial risk management process that the Act requires be genuine and substantive.
