Paddy,
It seems that teh UK & US have a more defined requiredment for employers to "qualifiy or certify" forklfit operators than those from Australia. Maybe it is because of our "lawyers".

Have you made a comparison of what the UK's, Health & Safety at Work Act and the US, Occumational Safety & Health Acts state vs what Australia has published? That might help you.
With the internet you should be able to find this. From the US stand point "Clark" Material Handling Company makes a nice publication for Employers on this subject - I'll try to find the exact name and publication number for you.