WAH — Roof Tiling SWMS
Concrete and terracotta roof tile installation, repair, and replacement on pitched residential roofs.
SWMS variants reference your state's WHS legislation. Instant download after payment.
This SWMS covers working-at-height roof tiling on Australian residential and commercial projects — the laying of concrete and terracotta tiles on battens across pitched roof structures, loading of tile pallets to the roof, hand placement and fixing of tiles, ridge and hip capping, and on-roof cutting of tiles for hips, valleys, and penetrations. It is written for licensed roof tilers, tile apprentices under direct supervision, and subcontractors engaged on new-build and re-roofing packages.
Roof tiling is high-risk construction work under Schedule 1 of the WHS Regulation 2025 (NSW). Category 3 — work at a height greater than 2 metres — is triggered across every activity because tile roofs are always above the fall threshold and the work must be performed on the pitched surface. Category 17 — work in an atmosphere with a contaminant exceeding the Workplace Exposure Standard — is triggered by respirable crystalline silica generation during concrete tile cutting. Falls from roofs are consistently among the top three fatal mechanisms in Australian construction; tile-roof falls are over-represented in residential-construction fatalities. Section 299 of the WHS Regulation requires a SWMS before HRCW commences.
Hazards identified
11 hazards covered, sorted by priority.
Fatal or permanent injury from falls exceeding 2 metres off the eave line, gable, or ridge during tile laying, capping, or walking between work areas.
Fatal slide-off from standing on a loose tile that dislodges from the batten, or from walking across stacks placed on the working surface.
Severe musculoskeletal injury from handling 4-5 kg tiles at repetition across a shift, and from carrying tile pallets (hundreds of kilograms) onto the working surface.
Roof structure failure and collapse under the point load of concentrated tile pallets placed on battens or rafters not designed for the local point load.
Silicosis, lung cancer, and autoimmune disease from inhalation of RCS generated during cutting of concrete tiles for hips, valleys, and penetrations without water suppression.
Heat exhaustion, heat stroke, and accelerated skin cancer risk from extended work on dark tile surfaces reaching 60-70°C in Australian summer conditions.
Loss of balance and fall from gust-induced sway of tiles, body, or equipment during carrying, lifting, or placing on exposed ridge and gable positions.
Fatal fall through a skylight, polycarbonate insert, or aged fibre-cement sheet during re-roof work or access across a partially tiled roof field.
Fatal or serious injury to workers or public below from unsecured tiles, cappings, or tools falling off an unbarricaded perimeter.
Permanent hearing loss and hand-arm vibration syndrome from sustained use of tile saws during hip, valley, and penetration cutting.
Fatigue, shortcutting of edge protection, and cumulative musculoskeletal harm from bonus-driven daily tile targets under heat and programme pressure.
Control measures
Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.
- 1Eliminate at-roof-edge exposure by completing as much assembly at ground level as practicable — pre-cut hip and valley tiles below using a wet saw; pre-bundle tiles for specific roof positions.
- 2Edge protection is the primary fall control per the Code of Practice: Managing the Risk of Falls at Workplaces and the Code of Practice: Managing the Risk of Falls in Housing Construction. Perimeter scaffold with catch platform along the eave line, installed before tiling commences.
- 3Where perimeter scaffold is not reasonably practicable (and only then), a catch platform below the eave plus fall-arrest harness to an engineer-designated anchor per AS/NZS 1891.1 and AS 1891.4. Rescue plan in place before harness-based work begins.
- 4Tile distribution across the roof: tiles distributed in single rows along battens to spread the load evenly. No concentrated stacks. Pallet loading per the truss engineer's or roof designer's load diagram.
- 5Mechanical loading of tiles to the roof — crane, conveyor, or telehandler — rather than manual carrying up ladders. Ground crew brief on exclusion zones during every load.
- 6Silica dust controls: wet cutting with a water-fed saw for every concrete tile cut; cuts made at ground level wherever practicable; respiratory protection (P2 minimum, P3 PAPR for extended cutting) per AS/NZS 1715 and AS/NZS 1716. Reviewed against the 1 December 2026 WEL transition for RCS.
- 7Heat-stress management: early start in hot weather (commence before 6am in extreme-heat forecast), mandatory hydration breaks every 30 minutes, shade at ground level for rest, and cessation when wet-bulb globe temperature exceeds the site threshold (typically 32°C WBGT).
- 8UV exposure controls: long-sleeve UPF-rated shirts and trousers, wide-brim hat under hard hat, SPF 50+ sunscreen applied at start of shift and every two hours, and UV-rated safety glasses.
- 9Wind management: site anemometer reading. Cease tile-handling work at 30 km/h sustained wind or 40 km/h gusts (or at a lower threshold if the specific roof geometry dictates). Ridge and gable work stopped at lower threshold.
- 10Fragile-substrate management on re-roof work: identify and demarcate fragile elements before access. No foot traffic on skylights or polycarbonate. Walk boards or crawl boards for unavoidable crossings.
- 11Drop-zone barricading below every working roof area. Pedestrian hoarding for street frontages. Tile off-cuts collected progressively — not left on the roof or at the edge.
- 12PPE baseline: hard hat with chin strap, UV-rated safety glasses, cut-resistant gloves for tile handling, hearing protection during cutting, high-grip soft-sole safety footwear (AS/NZS 2210.3), and P2 or P3 respirator during cutting.
- 13All roof tilers hold a valid White Card (CPCCWHS1001). Roof plumbers hold plumbing licence. Scaffolders hold the appropriate high-risk work licence. Apprentices work under direct supervision.
- 14Psychosocial controls per WHS Regulation 2025 r55A-55D: manageable daily targets, no bonus incentives tied to rushing, scheduled rotation out of high-heat ridge positions, and a documented stop-work right for unsafe wind, heat, or scaffold conditions.
- 15Health monitoring under WHS Regulation 2025 Part 7.1 for workers with ongoing RCS exposure.
- 16Conduct a daily pre-start toolbox talk covering weather, wind threshold, edge-protection state, and tile-loading sequence. Record attendance.
Applicable Codes of Practice
Primary binding guidance for fall protection during roof tiling — hierarchy of control from edge protection through to harness as last resort.
Specifically applies to residential roof tiling where most of this work occurs.
Baseline for HRCW categorisation, SWMS content, and principal contractor interaction.
The February 2026 Code directly addresses RCS from concrete tile cutting.
Applies to repetitive tile handling across the scope.
Technical standard for fall-arrest harnesses where scaffold is not practicable.
Technical standard for tile fixing, lapping, and weatherproofing.
High-Risk Construction Work triggered
Roof tiling is performed entirely on pitched roof surfaces above 2 metres on residential and commercial buildings — the defining HRCW for the scope.
Cutting of concrete tiles for hips, valleys, and penetrations generates RCS that routinely exceeds the WES without water suppression.
Tile saws, conveyors, and telehandlers for tile loading are used across the scope.
Because roof tiling is always HRCW, Section 299 of the WHS Regulation 2025 (NSW) requires the SWMS to be prepared before work commences, kept available on site for inspection, reviewed and updated if the work changes, and provided to the Principal Contractor on request. Failure by a PCBU to prepare or maintain a current SWMS for HRCW is an offence under Section 300; maximum penalty for a body corporate is $36,000 per offence and $7,200 for an individual. Where a tile-roof fall causes serious injury or death, Sections 31-33 of the WHS Act apply higher-tier prosecutions with substantially greater penalties. RCS exposure above the WES triggers additional health monitoring obligations under Part 7.1.
Who this is for
- →Licensed roof tilers engaged on residential, multi-unit, and commercial projects.
- →Roof-tiling apprentices working under direct supervision of a qualified tradesperson.
- →Roof-tiling subcontractors engaged by a Principal Contractor on new-build and re-roof packages.
- →Self-employed roof tilers operating as a PCBU who require a documented SWMS for their HRCW scope.
- →Site supervisors and WHS leads reviewing roof-tiling subcontractor documentation during pre-start.
What you receive
- ✓Editable Microsoft Word document (.docx, Word 2016 or newer compatible).
- ✓Title page with PCBU name, ABN, site address, project, and revision date fields.
- ✓Signed approval block for PCBU, Principal Contractor, and nominated roof-tiling supervisor.
- ✓Hazard register with the 11 hazards above, each with consequence, inherent risk, controls, and residual risk scored on a 5x5 matrix.
- ✓Hierarchy-of-control measures cross-referenced to WHS Regulation sections and applicable Codes of Practice.
- ✓Fall-protection decision tree from edge protection through catch platform to harness as last resort.
- ✓Heat-stress and UV-exposure response protocol.
- ✓Worker sign-on register for daily acknowledgement with space for scaffold and anchor ticket records.
- ✓Legislation schedule pre-populated for NSW with variance table for VIC, QLD, SA, WA, TAS, NT, ACT.
- ✓Emergency contacts, high-angle and heat-illness rescue plan, and review-and-update log.
Worked example
A three-person tiling crew — one roof-tiler in charge and two tradespeople — is subcontracted to re-roof a 1978 single-storey dwelling in Blacktown with 190 square metres of concrete tiles. The existing roof is fibre-cement under old tiles, so a pre-demolition asbestos test is arranged before any strip-back. The tiler completes this SWMS: the elevated work triggers HRCW Category 3 and requires perimeter scaffold with catch platform installed before strip-back; on-roof cutting triggers Category 17 and is eliminated by pre-cutting at ground level with a water-fed saw; tile loading triggers an engineer-approved stack pattern with no concentrated pallets. The SWMS is signed, the asbestos clearance is posted, and the crew acknowledges. A mid-afternoon forecast of 38°C triggers an early-start protocol for the following day; the SWMS review records the heat-adjusted schedule.
Related legislation
- Work Health and Safety Act 2011 (NSW) — Section 19 primary duty; Section 27 officer due diligence; Section 47 worker consultation; Sections 31-33 higher-tier offences.
- WHS Regulation 2025 (NSW) — r. 298-300 (SWMS); r. 78-82 (managing falls); r. 49-51 (WES/WEL); r. 55A-55D (psychosocial); r. 368-381 (health monitoring).
- Home Building Act 1989 (NSW) — licensing of roof tiling work.
- Environmental Planning and Assessment Act 1979 (NSW) — roof tiling as regulated building work.
- Building Code of Australia (National Construction Code, Volume 2) — roof compliance.
Frequently asked questions
Can I use harness alone in place of edge protection?
No. The Code of Practice: Managing the Risk of Falls at Workplaces requires fall protection to follow the hierarchy — elimination, then edge protection, then travel-restraint, with fall-arrest harness only as the last resort. Harness-only is not acceptable where a scaffold or catch platform is reasonably practicable.
Does this SWMS cover re-roofing on pre-2004 homes with asbestos substrate?
It sets the baseline controls and references the asbestos inspection requirement before any strip-back. Confirmed asbestos requires a licensed removalist (Class B for bonded) before tiling work begins. The Asbestos Management and Removal Codes of Practice apply in addition to this SWMS.
Can I use this SWMS in Victoria?
You can use it as a starting point. Victoria operates under the OHS Act 2004 and OHS Regulations 2017 with the fall-protection threshold at 2 metres on construction sites. Update the legislation schedule and cite WorkSafe Victoria Compliance Codes in place of SafeWork Australia Codes of Practice.
How does this SWMS address heat stress?
Early-start protocol in hot weather, mandatory hydration breaks every 30 minutes, ground-level shade for rest, a wet-bulb globe temperature threshold for cessation, and UV-protective clothing are all included. Bonus and piece-rate incentives that drive workers to push through heat are prohibited under the psychosocial controls.
How often does this SWMS need to be reviewed?
Review whenever the work or hazards change materially, after an incident, or when a worker raises a concern. At minimum, every 12 months and at the start of each project. The 1 December 2026 WES-to-WEL transition and the 2026 Silica Code of Practice are mandatory review triggers.
Is this SWMS compliant with the 1 July 2026 Section 26A changes?
Yes. From 1 July 2026, 34 approved Codes of Practice become legally binding under Section 26A of the amended WHS Act. This SWMS cites the currently-approved Codes that will become binding — Managing the Risk of Falls, Managing the Risk of Falls in Housing Construction, Construction Work, RCS, and Hazardous Manual Tasks. No amendment is required for the 2026 transition.
Document details
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