SWMS for working at heights
If there's a risk of someone falling more than 2 metres, it's high risk construction work under regulation 291 of the Work Health and Safety Regulation 2011 (Qld). That means a SWMS (Safe Work Method Statement) before anyone climbs, every time. Below 2 metres you still have to manage the fall risk under regulation 78, you just don't need the SWMS paperwork for it. Falls are still one of the biggest killers on Australian building sites, so this is the one document an inspector will ask for first.
Where the 2 metre line comes from
Regulation 291 lists the kinds of work that count as high risk construction work. First on the list: work that "involves a risk of a person falling more than 2 metres". Not "work done above 2 metres". The test is the risk of the fall, so working on a 1.8 metre platform next to a 3 metre drop into an excavation still counts.
Once you're in that category, regulation 299 says the PCBU (Person Conducting a Business or Undertaking) must prepare a SWMS before the work starts. Not after the first day. Not when the inspector turns up. Before.
What the SWMS has to say
Regulation 299 is short and it's not complicated. Your SWMS must:
- identify the high risk construction work (in plain terms: what you're doing and where)
- spell out the hazards and the risks to health and safety
- describe the control measures you'll use
- say how those controls will be implemented, monitored and reviewed.
WorkSafe Queensland's guide adds the practical bits: the PCBU's name, address and ABN (Australian Business Number), who is responsible for making sure the SWMS is followed, and for a construction project the principal contractor's name, the site address and the date it was prepared and reviewed. It also says controls should be specific. "Use appropriate PPE (Personal Protective Equipment)" is not a control. "Full body harness to AS/NZS 1891, connected to the rated anchor at grid line C, lanyard with shock absorber" is a control.
The hierarchy: it's in the regulation, not just the code
This is where a lot of generic SWMS fall over. Regulations 78 and 79 don't let you jump straight to a harness. The order is fixed:
- Do the work on the ground or on a solid construction if reasonably practicable (regulation 78). Solid construction means a surface that can take the load, barriers around the edges and any openings, an even surface and a safe way on and off.
- If you can't, use a fall prevention device: guardrails, edge protection, scaffold, a fully decked platform, covers over penetrations (regulation 79).
- If that's not reasonably practicable, a work positioning system, such as a restraint line set so the worker physically can't reach the edge.
- If that's not reasonably practicable either, a fall arrest system: harness, lanyard, rated anchors, and a rescue plan for the bloke who's now hanging in it.
- Administrative controls (signs, exclusion zones, training) only to mop up what's left. They are not a substitute for the physical stuff.
Your SWMS should show the thinking. If you've gone to harnesses, write down why guardrails or a scaffold weren't reasonably practicable. An inspector will ask.
The jobs that catch people out
Thirty-five years on the Gold Coast and the same jobs keep hurting people:
- Roof work on housing: trusses, sarking, tiling, gutters, solar. Queensland has extra rules in the WHS Regulation specifically for falls in housing construction on top of the general provisions. Edge protection before the roof goes on, not after.
- Stair voids and floor penetrations. Cover it or rail it the day it's cut. A sheet of ply with "HOLE" written on it and screwed down beats a broken back and an improvement notice.
- Ladders. A ladder is for getting up and down, and for short light work with three points of contact. It's not a work platform for a day of fascia fixing.
- Elevating work platforms (EWPs). Boom lifts need a harness clipped on inside the basket. Scissor lifts on uneven ground tip.
- Scaffold. Only a licensed scaffolder erects or alters it above 4 metres, and it needs a handover certificate and regular inspections. Don't pull a plank out because it's in the way.
A SWMS that actually works on site
The regulation doesn't care about formatting. It cares that the document matches the job and the crew follows it.
Consult. Talk to the workers doing the job before you finalise it. They know the roof is steeper than the plans say. WorkSafe Queensland expects consultation before work starts, at induction or a toolbox talk if not earlier.
Keep it on site. Readily available for inspection, kept until the high risk work is finished, or two years if there's a notifiable incident.
Stop if it's not being followed. If the work isn't going the way the SWMS says, stop immediately or as soon as it's safe, fix the SWMS or the work, then restart. That's the bit the crew needs to hear at the toolbox.
Below 2 metres
No SWMS needed, but regulation 78 still applies. A fall off a 1.5 metre trestle onto a slab can still kill you. Solid platforms, guardrails on trestles, floor kept clear. Just don't let anyone tell you a SWMS is a legal requirement for a step ladder.
Sources
- Managing the risk of falls at workplaces Code of Practice 2021 (Qld)
- WorkSafe Queensland – Work at heights
- WorkSafe Queensland – Safe work method statements
- Work Health and Safety Regulation 2011 (Qld) – regs 78, 79, 291, 299
- Safe Work Australia – Model Code of Practice: Managing the risk of falls in housing construction
General information only — not legal advice. Laws and codes change; check the current legislation or get advice for your own situation.