The definition of 'manual handling' in regulation 1.1.5 of the Occupational Health and Safety Regulations 2007 (Vic) requires the use of 'force' in its ordinary meaning of physical effort or exertion; the carrying of small, light objects does not necessarily involve the application of 'force' sufficient to constitute 'manual handling'. Whether a load is 'unstable or unbalanced' or 'difficult to grasp or hold' for the purposes of the definition of 'hazardous manual handling' must be assessed by reference to the inherent characteristics of the load, not the circumstances in which it is being handled (such as being on a ladder). The question remains contested, as the dissent took a broader purposive approach.
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