Asphalt Shingle Roofing SWMS
NSW — Asphalt Shingle Roofing. Full task scope, hazards and controls to be authored to Phase 1 standard.
SWMS variants reference your state’s WHS legislation. Instant download after payment.
Asphalt shingle roofing involves the installation, replacement or repair of bitumen-based shingle systems over pitched timber or engineered roof decks. The work sequence — stripping existing coverings, laying underlayment, nailing courses of shingles, cutting hips, valleys and ridge caps, and installing flashings — is performed at height on sloped, often slippery surfaces. Workers are exposed to falls from eaves, ridges and penetrations, heat radiating from dark shingle surfaces during summer, sharp roofing tools, hot bitumen adhesives, and manual handling of heavy bundles carried up ladders.
Under the Work Health and Safety Regulation 2025 (NSW), any work where a person could fall more than 2 metres is high risk construction work under section 291(a), and work in artificial extremes of temperature is captured under section 291(p). Section 299 requires a Safe Work Method Statement to be prepared before the work commences, kept available for inspection, and complied with on site. Controls must follow the hierarchy under section 36 — eliminate the fall risk where reasonably practicable, then substitute, engineer, administer, and finally rely on PPE.
Hazards identified
12 hazards covered, sorted by priority.
Fatal or catastrophic multi-system trauma; spinal and head injuries
Fatal fall to floor below; internal injuries
Uncontrolled slide over eave leading to fall
Heat exhaustion, heat stroke, dehydration, long-term skin cancer
Fall from height; crush injuries
Full-thickness burns; respiratory injury from bitumen fumes
Lumbar strain, disc injury, shoulder and knee damage
Electrocution, arc flash, fall triggered by shock
Silicosis, lung cancer, chronic obstructive pulmonary disease
Mesothelioma, asbestosis, lung cancer
Penetrating wounds, lacerations, head injury to ground workers
Fall from height; materials becoming projectiles
Control measures
Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.
- 1Eliminate at-height work where feasible by pre-fabricating flashings, valleys and ridge assemblies at ground level and lifting only completed sections
- 2Substitute torch-applied adhesives with self-adhesive underlayments and cold-applied shingle cements to eliminate LPG open flame and reduce bitumen fume exposure
- 3Install perimeter guardrails or edge protection to all fall exposures greater than 2 m in accordance with AS/NZS 4994.1:2009 Temporary edge protection — this is the primary fall control under section 79 of the WHS Regulation 2025
- 4Where edge protection is not reasonably practicable, deploy travel-restraint systems anchored to certified roof anchors complying with AS/NZS 5532:2013, with harnesses and lanyards to AS/NZS 1891.1:2020 and rescue plan documented
- 5Cover or barricade all skylights, penetrations and brittle areas with load-rated mesh or timber before work commences; do not rely on visual warnings alone
- 6Use single or extension ladders compliant with AS/NZS 1892.1:2018 secured top and bottom, extending 1 m above landing; use mechanical hoists or telehandlers for shingle bundle delivery to eliminate ladder carrying
- 7Implement a documented heat stress management plan under section 291(p): scheduled work during cooler parts of the day, mandatory rest cycles in shaded areas, electrolyte hydration every 20 minutes, and cessation triggers based on WBGT or ambient temperature and roof surface temperature
- 8Maintain minimum approach distances from overhead powerlines per the SafeWork NSW Code of Practice: Work near overhead power lines; arrange isolation, tiger-tails or spotters through the network operator where distances cannot be maintained
- 9Control silica dust using on-tool water suppression or H-class HEPA extraction when cutting tiles, fibre-cement or masonry, with air monitoring against the 0.05 mg/m³ WES; identify and manage asbestos under a licensed removalist per the Regulation Chapter 8
- 10Provide and enforce PPE to AS/NZS 1801 (hard hat), AS/NZS 1337.1 (eye protection), AS/NZS 2210.3 (safety footwear with heat-resistant, non-slip soles), AS/NZS 1715/1716 P2 respirators, cut-resistant gloves, long-sleeved sun-protective clothing and SPF 50+ sunscreen
- 11Establish exclusion zones below the work area with hard barricades and signage; tether all hand tools and prevent material fall via kickboards and mesh at edge protection
- 12Verify all workers hold CPCCWHS1001 (White Card) and current working-at-heights training; consult the SWMS with the crew under section 47 of the WHS Act and review under section 302 of the WHS Regulation 2025 whenever the method, weather, or personnel change
Applicable Codes of Practice
Primary Code for eliminating and minimising fall risk on pitched roofs including hierarchy of fall controls, edge protection and fall-arrest systems
Governs SWMS content and review, HRCW identification, site induction and consultation requirements for the roofing task
Applies to bitumen adhesives, primers and solvents used in shingle installation — SDS management, storage and exposure control
Technical basis for selection, inspection, anchor testing and rescue planning where fall-arrest is deployed on shingle roofs
High-Risk Construction Work triggered
Asphalt shingle roofing is performed on pitched surfaces where fall exposures at eaves, ridges, valleys and during ladder access routinely exceed 2 m, including on single-storey pitched dwellings where eave heights typically sit at 2.4–3.0 m
Dark asphalt shingles absorb solar radiation and reach surface temperatures of 60–80°C in NSW summer conditions, creating a radiant heat environment on and immediately above the roof deck that constitutes an artificial extreme of temperature
Because the work is HRCW under section 291, section 299 of the WHS Regulation 2025 (NSW) requires a compliant SWMS to be prepared before work starts, complied with during the work, and made available for inspection. Section 302 requires the SWMS to be reviewed and if necessary revised whenever controls are found inadequate, the method changes, or a notifiable incident occurs. Failure to prepare, comply with or review a SWMS, or a breach of the primary duty of care under section 19 of the WHS Act 2011 (NSW), may be prosecuted as a Category 1 offence (section 31 — reckless conduct), Category 2 (section 32 — exposure to risk of death or serious injury), or Category 3 (section 33). Penalties for individuals, officers and body corporates are set under Part 2 of the Act and are indexed by SafeWork NSW; refer to the current SafeWork NSW penalty schedule for applicable amounts.
Who this is for
- →Licensed roofing contractors and subcontractors installing or replacing asphalt shingle systems in NSW
- →Principal contractors coordinating re-roofing works on residential and light-commercial projects
- →Roof plumbers and carpenters transitioning between metal, tile and shingle systems on tie-in works
- →Roofing labourers and apprentices working under direct supervision at height
- →WHS managers and site supervisors responsible for HRCW documentation and consultation across pitched-roof trades
What you receive
- ✓Fully editable Microsoft Word SWMS mapped to the NSW WHS Regulation 2025 sections 291 and 299
- ✓Pre-populated hazard register covering falls, heat stress, manual handling, silica, asbestos, electrical and chemical exposures
- ✓Hierarchy-of-control matrix aligned to AS/NZS 4994.1, 1891.1 and 1892.1 with control selection guidance
- ✓HRCW category identification page citing section 291(a) and 291(p) with worker sign-off block
- ✓Heat stress management appendix with WBGT triggers, hydration schedule and cessation criteria
- ✓Emergency response and roof rescue plan template compatible with fall-arrest system requirements
- ✓Section 47 consultation record and daily pre-start briefing sheet
- ✓Section 302 SWMS review log with revision triggers and version control
- ✓PPE schedule, plant and equipment register, and licence/competency verification register including CPCCWHS1001
Worked example
A two-storey residential re-roof in Baulkham Hills in the Sydney Hills district requires stripping of ageing concrete tiles and installation of a new asphalt shingle system over structural plywood. Ridge height is 7.8 m with an 8.4 m eave at the rear elevation over a paved courtyard. The principal contractor determines HRCW under section 291(a) (fall > 2 m) and section 291(p) (roof surface temperatures forecast at 65°C+ during the January install window). Perimeter scaffold with a working platform 900 mm below eave and mid-rail edge protection is erected to AS/NZS 4994.1. Skylights are mesh-covered before tile strip commences. Bundle delivery is by telehandler to eliminate ladder carrying. A heat plan mandates a 5:30 am start, 30-minute rest cycles from 11:00 am, and cessation above 36°C ambient. The SWMS is walked through with the crew under section 47, signed, posted in the site shed, and reviewed under section 302 when a mid-project storm damages the scaffold handrail.
Related legislation
- Work Health and Safety Act 2011 (NSW) — sections 19, 31, 32, 33, 47
- Work Health and Safety Regulation 2025 (NSW) — sections 78–80 (falls), 291 (HRCW), 299 (SWMS), 302 (review)
- Work Health and Safety Regulation 2025 (NSW) Chapter 8 — Asbestos
- Work Health and Safety Regulation 2025 (NSW) Chapter 7 — Hazardous chemicals (bitumen products and solvents)
- Electricity Supply (Safety and Network Management) Regulation 2014 (NSW) — work near overhead powerlines
- Building and Construction Industry (Portable Long Service Leave) Act 1986 (NSW) — worker registration for construction work
Frequently asked questions
Is asphalt shingle roofing always HRCW in NSW?
Yes, in practically all cases. Section 291(a) of the WHS Regulation 2025 (NSW) captures any work with a fall risk greater than 2 metres. Even single-storey pitched roofs have eave heights above 2 m, so a SWMS under section 299 is required before work starts. Section 291(p) may also apply during hot-weather installation.
Can a harness alone satisfy the fall control requirement?
No. Section 79 of the WHS Regulation 2025 requires the hierarchy of fall controls to be followed — elimination first, then passive systems such as edge protection or scaffolds, then work-positioning, and only then fall-arrest. A harness in fall-arrest mode is the last option and requires certified anchors to AS/NZS 5532, a rescue plan and trained personnel.
How do we manage roof surface temperature under section 291(p)?
The SWMS includes a documented heat stress program: measurement of ambient and roof-surface temperature at pre-start, scheduled work during cooler parts of the day, mandatory rest and hydration cycles, shaded rest areas, buddy monitoring for heat illness symptoms, and defined cessation triggers. This satisfies both section 291(p) SWMS requirements and the primary duty under section 19 of the WHS Act.
How often must this SWMS be reviewed?
Section 302 of the WHS Regulation 2025 (NSW) requires review whenever controls are found inadequate, the work method changes, new hazards are introduced, or a notifiable incident occurs. For shingle roofing this typically means review at each new site, after significant weather events, and whenever crew composition or plant changes materially.
Document details
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