WAH โ Roof Repair & Replacement SWMS
Localised roof repairs and full replacement of damaged roof sections on existing buildings.
SWMS variants reference your state's WHS legislation. Instant download after payment.
This SWMS covers localised roof repair and full roof replacement on existing residential and commercial buildings โ patching leaks, replacing corroded flashings, re-laying storm-damaged sheets, and full strip-and-replace of deteriorated roofing systems. It is scoped for roofing contractors, insurance-repair crews, maintenance plumbers, and their supervised apprentices. Roof-repair work differs materially from new-roof installation because the work is performed on an existing, often unknown-condition, roof structure. The age of the roof, the corrosion state of the substrate, the presence of legacy materials like fibre-cement sheeting or bitumen-impregnated sarking, and the often-unrecorded past modifications all combine to make the roof surface itself an unpredictable hazard. The dominant fatality mode in repair work is fall-through of an aged roof surface that the worker believed was load-bearing. All work above 2 m triggers HRCW Category 3 under Schedule 1 of the WHS Regulation 2025; where asbestos is disturbed, the work additionally engages the asbestos regulations under Part 8.7 of the Regulation. Section 299 requires this SWMS before work commences. The document is CIH-authored against the current WHS Regulation 2025 baseline.
Hazards identified
11 hazards covered, sorted by priority.
Fatal fall through an apparently solid roof surface where underlying corrosion has eaten through the sheet; painted topcoat masks the perforation until foot contact.
Inhalation of friable chrysotile and amosite fibres during cutting, breaking, or walking on fibre-cement sheets; Group 1 carcinogen with latent mesothelioma and lung cancer.
Rot-weakened batten failing under worker weight; fall into roof cavity with secondary fall through ceiling or injury from truss strike.
Polycarbonate skylight aged by UV failing under foot; fall to floor below, typical drop of 3-6 m in commercial repair scope.
Slip on wet bird droppings or lichen-covered tile; uncontrolled slide to eave in pitched-roof repair; psittacosis and histoplasmosis exposure risk.
Electrocution from contact with solar DC lead, aerial wire, or service drop buried in the roof structure near the repair area.
Failure of an existing anchor never re-certified during a fall event; harness attached to an anchor with no annual inspection record.
Cut and puncture injury from corroded sheet edges during strip-out; lumbar and shoulder strain from single-worker carry of waterlogged debris.
Respirable crystalline silica exposure above the 0.05 mg/mยณ WES during dry cut of terracotta or concrete tiles and ridge mortar removal.
Heat exhaustion and heat stroke; surface temperatures exceeding 65ยฐC on dark Colorbond or bitumen roofs during February repair work.
Roof debris, broken tiles, or dropped tools striking occupants, neighbours, or ground-level trades during the strip-out phase.
Control measures
Hierarchy-of-controls order: elimination โ substitution โ isolation โ engineering โ administrative โ PPE.
- 1Before access, commission a roof-condition assessment by a competent person โ visual inspection of sheet corrosion, batten integrity, skylight condition, and fixing decay. Classify the roof surface as load-bearing, fragile, or unknown per the Code of Practice: Managing the Risk of Falls at Workplaces (SafeWork Australia, 2011).
- 2For all pre-1990 buildings, commission an asbestos identification survey per the Code of Practice: How to Manage and Control Asbestos in the Workplace (SafeWork Australia, 2020) before any disturbance โ walk-on inspection of fibre-cement sheet is itself a disturbance event.
- 3Where asbestos is confirmed, arrange licensed Class B removal for non-friable sheet exceeding 10 mยฒ and licensed Class A removal for any friable material per WHS Regulation 2025 r. 485; removalists produce a Clearance Certificate before repair work resumes.
- 4Eliminate fall-through risk on fragile sheeting by installing a crawl-board or fall-through cover system (AS/NZS 5532) across the work area โ no foot load is applied directly to aged fibre-cement or translucent sheet.
- 5Edge protection per AS/NZS 4994.1 installed at the working eave before crew access โ where scaffold is not reasonably practicable on short-duration repairs, use a travel-restraint system with lanyard length physically preventing reach to the edge.
- 6Fall-arrest harness per AS/NZS 1891.1 is a last-resort control; any existing anchor on the roof must be load-tested by a competent person before use, with certification to AS/NZS 1891.4. Anchors without a current tag are treated as failed.
- 7Isolate all rooftop electrical services before roof contact โ solar DC array isolated at the inverter and via the roof-top DC isolator per AS/NZS 5033; aerials and LV service drops de-energised via the network operator where clearance cannot be maintained.
- 8Silica controls for tile cutting and mortar removal โ wet-cut with water suppression or tool-on-tool LEV (Type H vacuum extraction) per the Code of Practice: Managing Respirable Crystalline Silica Dust Exposure in Construction (SafeWork Australia, 2023); P2 respirator minimum, with RPL 50 for dusty cut-off work.
- 9Fouling and biohazard controls โ bird droppings dampened with a misting sprayer before contact; P2 respirator and disposable coveralls for cleaning of lichen or droppings; hepatitis-A and tetanus vaccination current for the crew.
- 10Drop-zone barricade and signage at ground level beneath the strip-out area; second worker as ground-level spotter where the repair is over a public path or neighbour boundary; debris netting under the eave where dropped material is foreseeable.
- 11Heat-stress controls per the Code of Practice: Managing the Work Environment and Facilities โ 60-minute rotation when ambient exceeds 32ยฐC, shaded rest at ground level, and continuous electrolyte availability at the SWMS water-station location.
- 12PPE baseline: cut-5 gloves (AS/NZS 2161.3), Grade II eyewear (AS/NZS 1337.1), grip-rated safety footwear (AS/NZS 2210.3), P2 respirator for silica and biohazard work (AS/NZS 1716), and long-sleeve UV-rated shirt.
- 13All workers hold a valid White Card (CPCCWHS1001); any asbestos-handling worker holds a current asbestos-awareness training certificate per WHS Regulation 2025 r. 445.
- 14Daily pre-start reviews the roof-condition assessment, weather window, and any change in crew or scope; attendance recorded on the SWMS worker sign-on register.
Applicable Codes of Practice
Binding fall-protection hierarchy for all repair work at or above 2 m, including fragile-surface management.
Governs asbestos identification, removal, and clearance for any pre-1990 roof repair involving fibre-cement sheet.
Sets the licensed-removalist requirements and control-zone specifications engaged by this SWMS.
Applies to tile-cutting and mortar-removal dust controls specified in the SWMS.
Establishes HRCW categorisation and SWMS preparation duties for the repair work.
Standard for fall-through covers and anchor devices used during roof repair.
Governs the inspection and certification of existing anchors encountered during repair.
High-Risk Construction Work triggered
Every roof repair on a residential or commercial building at or above 2 m eave height places the worker in continuous fall-risk exposure, with the added dimension that the surface integrity is unknown until assessed.
Pre-1990 roofs commonly contain fibre-cement sheet, soakers, or flashing components; any repair work on these surfaces is foreseeable asbestos disturbance.
Because this work triggers HRCW Categories 3 and (for pre-1990 buildings) 10, Section 299 of the WHS Regulation 2025 requires the SWMS to be prepared before work commences and provided to the Principal Contractor on request. 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. Asbestos-specific offences under Part 8.7 of the Regulation carry additional penalties; an un-licensed asbestos removal over the threshold volume attracts penalties to $60,000 for a body corporate under r. 485.
Who this is for
- โRoofing contractors engaged on insurance repair, storm damage, or planned maintenance.
- โMaintenance plumbers and handymen handling small-scope roof repairs.
- โFacility-management PCBUs coordinating repairs to tenant or owned commercial roofs.
- โSelf-employed roof-repair operators with their own HRCW SWMS obligation.
- โBody-corporate managers commissioning strata-roof repair work.
What you receive
- โEditable Microsoft Word document (.docx, Word 2016 or newer compatible).
- โTitle page with PCBU, ABN, site address, property age, and revision date fields.
- โSigned approval block for PCBU, Principal Contractor or property owner, and nominated supervisor.
- โHazard register with the 11 repair hazards above, each with inherent risk, controls, and residual risk on a 5x5 matrix.
- โRoof-condition assessment template including asbestos-presumption checklist for pre-1990 buildings.
- โAnchor-point verification log for existing anchors encountered on the roof.
- โWorker sign-on register, consultation record, and state-variance schedule for all jurisdictions.
- โEmergency contacts, fall-arrest rescue plan template, and evacuation procedure.
- โReview-and-update log for tracking revisions across the repair scope.
Worked example
A two-person repair crew is engaged by a strata corporation to replace 18 m of corroded metal valley and re-flash two skylights on a 1987-built Class 2 unit block in Ashfield. Eave height is 5.6 m. Before work commences the lead contractor completes this SWMS and arranges a pre-1990 asbestos identification survey โ the survey finds asbestos-cement soakers at the skylight penetrations. A licensed Class B asbestos removalist is engaged for the soakers; the SWMS is amended to reference the Class B Asbestos Removal Control Plan and the Clearance Certificate is obtained before the repair crew re-accesses the roof. Existing anchors on the roof have no current tag, so the repair crew installs two temporary ridge-strap anchors tested to AS/NZS 1891.4. Work completes in 4 days with no incident; the SWMS is closed out with the final sign-off page attached to the invoice.
Related legislation
- Work Health and Safety Act 2011 (NSW) โ Section 19 primary duty of care; Section 27 officer due diligence.
- WHS Regulation 2025 (NSW) โ Part 4.4 (HRCW and SWMS), Part 8.7 (asbestos), r. 298-300 (SWMS), r. 445 (asbestos awareness training), r. 485 (asbestos licensing).
- Environmental Planning and Assessment Act 1979 (NSW) โ consent requirements for roof work on heritage buildings.
- Protection of the Environment Operations Act 1997 (NSW) โ management of asbestos waste and contaminated runoff.
- Strata Schemes Management Act 2015 (NSW) โ common-property roof repair obligations.
Frequently asked questions
Does every pre-1990 roof require an asbestos survey?
Yes โ the Code of Practice: How to Manage and Control Asbestos in the Workplace requires that any building completed before 31 December 2003 be treated as asbestos-presumed until a competent person confirms otherwise by survey or sampling. Repair work on a roof without the survey is foreseeable asbestos disturbance and exposes the PCBU to Part 8.7 offences.
Can the repair crew use the building's existing anchor points?
Only if the anchors carry a current AS/NZS 1891.4 certification tag from a competent person within the last 12 months. Anchors without a current tag are treated as failed; the SWMS requires installation of a temporary anchor or use of a scaffold/EWP system instead.
What minimum fall-protection applies to a one-hour skylight repair?
Duration does not change the hierarchy โ a one-hour task above 2 m is still HRCW Category 3. The minimum is travel-restraint with anchor; harness-based fall arrest is acceptable only with a documented rescue plan. There is no short-duration exemption in the WHS Regulation 2025 or the Fall Code.
Is this SWMS suitable for a single tradesperson working alone?
A single operator is permitted but the SWMS requires a documented rescue plan with a second rescuer available within the suspension-trauma onset window (5-30 minutes per AS/NZS 1891.4). Most single-operator repair scopes require a second person on site in practice; the SWMS worker sign-on register accommodates the rescuer role.
Can I use this SWMS in Queensland?
Yes โ Queensland operates under the WHS Act 2011 (Qld) and WHS Regulation 2011 (Qld) which are substantially aligned with the NSW 2025 provisions; the Queensland Code of Practice: Managing the Risk of Falls at Workplaces is identical. Update the legislation schedule to the Queensland Act and Regulation citations.
Document details
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