Your ECE service is legally required to run a predictable pattern of health and safety checks, reviews, and drills. When there is no evidence of a systematic schedule – missing monthly hazard checks or overdue evacuation drills – ERO and Ministry auditors treat it as a red flag that broader non-compliance and risk is likely.
Here is the hard truth: Every licensed early learning service in New Zealand must check its equipment, premises, and facilities every single day for hazards. That is not a suggestion. It is a licensing criterion under the Health and Safety (HS) criteria of the Licensing Criteria for Early Childhood Education and Care Services 2008, enforced under the Education and Training Act 2020. Yet, when auditors walk in, they routinely see the same failure: a stack of policies but no operationalised timeline. No calendar. No schedule. Just paperwork theatre.
The Audit Trigger
Auditors are pattern-spotters. They ask one simple question: “Show me your last month of daily hazard checks.” When they see gaps – multiple days missing, or a log that looks “bulk ticked” on a single date – they immediately infer the system is theoretical only. They then go deeper: sleeping checks, supervision, outings, emergency drills. They look for a high number of similar accidents with no documented follow-up. They check if your emergency plan promises termly evacuation drills but your records show nothing for six months. A mismatch between policy and practice is a non-compliance trigger that invites closer scrutiny of your entire risk management system.
The Regulatory Hook
The obligations are not abstract. They sit inside the Education and Training Act 2020, the Licensing Criteria for Early Childhood Education and Care Services 2008, and the Health and Safety at Work Act 2015 (HSWA). Under HSWA, your service as a PCBU can face penalties up to $3 million for Category 1 offences. Ministry-level sanctions include licence suspension or cancellation – which means immediate loss of funding and the inability to operate. The financial impact of a suspension is existential, especially when combined with reputational damage and loss of enrolments. Parents are told by the Ministry to expect robust health and safety; a complaint about missing drills or unsafe conditions can trigger a targeted licensing assessment outside the regular review cycle.
Director Action Point
“Ask your CEO: ‘Show me the month-by-month health and safety calendar for the last three months, with evidence that every daily hazard check, monthly inspection, and termly drill was completed and reviewed.’ If they cannot produce it, you have a governance gap that needs immediate attention.”