This paper notes the extent of contractors working in the Central Queensland’s (CQ) coalmines and proposes a different form of managing employment relations in the coal industry, based on Dunlop’s industrial relations (IR) model. The paper argues that due to the complexity of defining ‘employee’ and distinguishing between ‘independent contractors’ and ‘dependent contractors’ within the Australian federal and state IR legislation, the employers and managers in the industry may not have sufficient awareness of their firms’ legal occupational health and safety (OHS) obligations which nevertheless arise under independent contractual arrangements at the workplace. The paper concludes that further investigation is required to verify whether, and how, firms in the coal industry have effectively managed, or are managing, the issue of OHS under the new employment relations framework.