WAH — Roof Cleaning SWMS
Pressure cleaning, moss treatment, and gutter cleaning on residential and commercial roofs.
SWMS variants reference your state's WHS legislation. Instant download after payment.
This SWMS covers pressure washing, moss and lichen treatment, gutter clearing, and non-structural roof cleaning on residential and commercial buildings. It is scoped for roof-cleaning contractors, high-pressure washing operators, and maintenance crews engaged for seasonal clean-down or pre-paint preparation. Roof cleaning is unique among working-at-height scopes because the worker is generating the slip hazard in real time — the water they apply to the roof surface is the same water making the surface unsafe to stand on. The pressure washer wand adds a further dimension: a 3000-psi lance delivers a reaction force that can destabilise a worker standing at the edge of a pitched roof, and the high-pressure jet itself is capable of penetrating skin at close range. The combination of height, wet surface, electrical water spray, and reaction force means roof-cleaning fatalities are consistently over-represented in Australian fall statistics relative to other roof trades. All work above 2 m triggers HRCW Category 3 under Schedule 1 of the WHS Regulation 2025; Section 299 requires this SWMS. The document is CIH-authored against the WHS Regulation 2025 baseline.
Hazards identified
10 hazards covered, sorted by priority.
Uncontrolled slide to unprotected edge while the cleaner is moving across the already-washed area; fatal fall from pitched roof.
Loss of balance from 3000-psi lance kick; worker tips forward over edge during aggressive trigger pull.
Laceration and tissue damage from close-range jet contact with hand or leg; infection from high-pressure embedded material.
Slip on green growth that appears superficial but extends under the surface; foothold failure at eave.
Electrocution from water spray on service drop, rooftop solar wiring, or AC aerial cabling; conductive path through worker to ground.
Skin corrosion, respiratory irritation, and eye injury from direct spray-back or wand-delivered chemical; mixing incompatible cleaners creating chlorine gas.
Skylight condition hidden by leaf litter and algae; worker steps through during cleaning pass.
Gutter collapse under worker weight during clean-out; dropped hand tool entangling worker at edge.
Electrocution from wand contact with LV service drop; water column itself can be conductive under spray conditions.
Environmental offence from uncontrolled discharge of cleaning chemicals and organic debris to stormwater; POEO Act liability.
Control measures
Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.
- 1Eliminate the fall-on-wet-surface risk by specifying ground-level cleaning methods where practicable — telescopic soft-wash pole systems, low-pressure foam wash, or drone-mounted soft wash allow cleaning from ground level or from a stable EWP basket without walking the wet roof.
- 2Where roof access is unavoidable, edge protection scaffold per AS/NZS 1576.1 is installed before cleaning commences — the wet-surface hazard is inherent to the task and cannot be eliminated by work sequence alone.
- 3Travel-restraint with AS/NZS 1891.1 harness and AS/NZS 1891.4-certified anchor is the minimum control where edge protection is not reasonably practicable on short-duration residential jobs; lanyard length physically prevents reach to the edge.
- 4Pressure washer reaction force control — maximum 3000 psi for residential surfaces, wand is held with both hands in a stable stance, no trigger-pull while leaning; lance tip is kept 300-600 mm from the roof surface to diffuse reaction force.
- 5Soft-wash chemistry preferred over high pressure for moss and lichen — a dilute sodium hypochlorite or quaternary ammonia solution applied at low pressure is effective and avoids the destabilising reaction force entirely.
- 6Chemical controls per the Code of Practice: Managing Risks of Hazardous Chemicals in the Workplace (SafeWork Australia, 2020) — SDS on site, chemical-resistant gloves (nitrile under outer glove), face shield, chemical-resistant coveralls, and the sodium hypochlorite never mixed with ammonia-based cleaner.
- 7Electrical isolation — all rooftop solar arrays opened at the rooftop DC isolator per AS/NZS 5033 before cleaning; AC aerial or service drop de-energised via the network operator where spray path cannot maintain 3 m clearance from LV or 6.4 m from transmission.
- 8Fragility mapping before cleaning — skylights and polycarbonate sheets are located, debris is cleared by hand (not by washing), and fall-through covers are installed across fragile areas within the work path.
- 9Gutter clearance controlled from a ladder or EWP basket rather than from the roof plane where reasonably practicable; where gutter clearance must be done from roof, worker is in harness with restraint lanyard anchored above gutter.
- 10Runoff capture — tarps or temporary bunding at downpipe outlets during chemical cleaning; chemical-free rinse collected via downpipe interceptor and disposed of per Environment Protection licence requirements.
- 11PPE baseline: waterproof grip-rated footwear with deep sole tread (AS/NZS 2210.3), cut-resistant gloves under chemical outer glove, face shield over Grade II eyewear (AS/NZS 1337.1), chemical-resistant long-sleeve coveralls, hard hat with chin strap.
- 12Weather window — work stop at sustained wind above 30 km/h (lower than other roof tasks due to chemical drift), full stop during or immediately after rain until roof is assessed dry or treated with a rinse cycle.
- 13All cleaners hold a valid White Card (CPCCWHS1001); the chemical handler holds current chemical-safety awareness training and the SDS folder is on site.
- 14Rescue plan and trained rescuer named on the SWMS before harness-based cleaning commences; suspension-trauma window tracked at 5-minute radio checks.
- 15Daily pre-start reviews the weather window, chemical stocktake, fragility map, and isolation status; recorded on the worker sign-on register.
Applicable Codes of Practice
Binding fall-protection hierarchy applied throughout the wet-surface cleaning task.
Governs sodium hypochlorite, biocide, and cleaning-agent use during roof cleaning.
Applies to rooftop solar and AC service isolation before wet cleaning commences.
Establishes HRCW SWMS duties where roof cleaning is part of construction or pre-paint preparation.
Standard for harness and anchor used in the wet-roof fall control.
Technical reference for pressure washer operation and reaction-force management.
Environmental compliance for runoff management during chemical cleaning.
High-Risk Construction Work triggered
Roof cleaning is performed across the full roof plane above 2 m eave height; the work is extended in duration and combines height with a self-generated wet-surface slip hazard.
High-pressure washers, pump-driven soft-wash systems, and associated powered equipment are in continuous use during the clean.
Because roof cleaning triggers HRCW Categories 3 and 13, Section 299 of the WHS Regulation 2025 requires this SWMS before work commences. Section 300 maximum penalty for failure to prepare or maintain a current SWMS is $36,000 for a body corporate and $7,200 for an individual. Where cleaning chemicals are released to stormwater without control, additional offences arise under the Protection of the Environment Operations Act 1997 (NSW) with penalties to $1 million for a body corporate. A fatality from a wet-roof slip attracts Category 1 or 2 prosecution under Sections 31-32 of the WHS Act.
Who this is for
- →Roof-cleaning contractors and high-pressure washing operators.
- →Maintenance crews engaged for seasonal roof clean-down.
- →Painters performing pre-paint surface preparation on roofs.
- →Facility managers coordinating commercial or strata roof-cleaning contracts.
- →Self-employed cleaners operating as a PCBU with their own HRCW SWMS obligation.
What you receive
- ✓Editable Microsoft Word document (.docx, Word 2016 or newer compatible).
- ✓Title page with PCBU, ABN, property address, and revision date fields.
- ✓Signed approval block for PCBU, property owner or Principal Contractor, and supervisor.
- ✓Hazard register with the 10 roof-cleaning hazards above, each with inherent risk, controls, and residual risk on a 5x5 matrix.
- ✓Chemical-register template for sodium hypochlorite, biocide, and surfactant inventory.
- ✓Pre-clean checklist covering electrical isolation, fragility mapping, weather, and runoff capture.
- ✓Worker sign-on register, consultation record, and state-variance schedule.
- ✓Fall-arrest rescue plan template with suspension-time monitoring.
- ✓Environmental runoff-management plan aligned to POEO Act requirements.
Worked example
A two-person cleaning crew is engaged to perform a full soft-wash moss treatment on the Colorbond roof of a 1996-built Class 1a dwelling in Hornsby. Eave height is 5.2 m, pitch 22°. Before work commences the lead cleaner completes this SWMS: a soft-wash pole system is selected in preference to high-pressure to eliminate the reaction-force risk; the 5 kW rooftop solar array is opened at the rooftop DC isolator by the client's electrician; two downpipe interceptors are installed to capture runoff; tarps are laid at the eave. Chemical mix is 3% sodium hypochlorite with surfactant, applied via telescopic pole from a low-height mobile scaffold at the eave. A harness and anchor are used as backup control. The job completes in 6 hours with no foot contact on the pitched roof plane; runoff is transferred to a licensed liquid-waste disposer.
Related legislation
- Work Health and Safety Act 2011 (NSW) — Section 19 primary duty of care; Section 27 officer due diligence.
- WHS Regulation 2025 (NSW) — r. 78-80 (falls), r. 298-300 (SWMS for HRCW), Part 7.1 (hazardous chemicals).
- Protection of the Environment Operations Act 1997 (NSW) — Sections 120-121 prohibition on pollution of waters.
- Electricity Supply Act 1995 (NSW) — Section 44 approach distances; Electrical Safety Act provisions.
- Home Building Act 1989 (NSW) — where cleaning is part of a licensed building renovation.
Frequently asked questions
Is high-pressure washing always more effective than soft wash?
No. For moss, lichen, and organic growth, a dilute sodium hypochlorite soft wash at low pressure is as effective and avoids both the reaction-force hazard and the risk of driving water under flashings. The SWMS prefers soft wash as a control, not a commercial compromise.
Does the SWMS cover interior cleaning of gutters from the ground?
Yes — gutter-vacuum work performed from ground level with a telescopic wand is covered as a sub-task. Where the work is entirely ground-based and no roof access occurs, the fall-protection hazards de-escalate but the chemical, electrical, and environmental hazards still apply and the SWMS remains appropriate.
What chemical-safety training is required?
At minimum the chemical handler should have completed general chemical-safety awareness training covering SDS interpretation, chemical compatibility, and emergency response to chemical exposure. Where the cleaner holds a Chemical Certification Scheme qualification (AgVet or similar), this satisfies the training requirement. SDS for each product is retained on site.
Can the rooftop solar array stay on during cleaning?
No — the rooftop DC isolator must be opened before any water contact with the array. Solar PV remains self-energised in daylight regardless of inverter status, and wet cleaning creates a conductive path to ground through the water column. The isolation is a non-negotiable control in the SWMS.
How is runoff managed on a residential driveway?
Downpipe interceptors collect the initial high-load runoff into a bund; final rinse water with diluted chemical can be discharged to the sanitary sewer only with prior approval from the water-utility's trade-waste team. Direct discharge to stormwater is a POEO Act offence. The SWMS documents the selected disposal route.
Document details
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