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Steeplejack & High Structure Work SWMS

NSW β€” Steeplejack & High Structure Work. Full task scope, hazards and controls to be authored to Phase 1 standard.

βš–οΈWHS Regulation 2025 & Codes of Practice β€” legally binding from 1 July 2026 (s26A)
πŸ‘·Reviewed by certified occupational health and safety professionals
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Steeplejack and high structure work covers the inspection, maintenance, repair, painting, rigging and demolition of tall structures β€” chimneys, spires, church steeples, silos, industrial stacks, water towers, communication and broadcast towers, flagpoles and monuments. Workers ascend and descend using fixed ladders, permanent anchorages, rope access techniques or purpose-built scaffolds, often at heights exceeding 30 metres and frequently on ageing or corroded structures with unknown residual strength. The hazards are severe and cumulative: falls from extreme height, structural collapse, exposure to weathered lead-based paint and crystalline silica dust from masonry preparation, RF radiation on live telecommunications towers, falling tools and debris, lightning, and rapid onset of wind, heat and fatigue.

Under the Work Health and Safety Regulation 2025 (NSW), section 291 defines high risk construction work to include any work with a risk of a person falling more than 2 metres (paragraph (a)) and work on or near a telecommunications tower (paragraph (b)). Section 299 requires a Safe Work Method Statement be prepared before this work commences. Controls follow the hierarchy in section 36 β€” eliminate the fall where practicable, then substitute, engineer, administer and finally rely on PPE such as fall-arrest harnesses and rope access systems.

Hazards identified

12 hazards covered, sorted by priority.

Fall from height exceeding 2 m (often 20–100 m) during ascent, descent or work positioning on the structureHIGH

Fatal impact injuries; suspension trauma if fall-arrest activates without prompt rescue

Structural failure of corroded steelwork, deteriorated masonry, rotten timber or fatigued anchorage points on aged structuresHIGH

Collapse causing fatal fall or crush injury to workers and persons below

Radiofrequency (RF) electromagnetic radiation exposure on active telecommunications and broadcast towersHIGH

Tissue heating, burns, cataracts, acute RF sickness; exceeds ARPANSA general public and occupational limits

Failure of personal fall-arrest, rope access or work-positioning systems (anchor pull-out, rope cut over sharp edge, incorrect connector loading)HIGH

Uncontrolled fall to ground level; fatal outcome

Exposure to lead-based paint dust and residues during surface preparation on heritage steeples, stacks and water towersHIGH

Elevated blood lead levels, neurological and reproductive harm; contamination of surrounding area

Respirable crystalline silica generated when grinding, cutting or repointing masonry chimneys, spires and monumentsHIGH

Silicosis, lung cancer, chronic obstructive pulmonary disease

Falling objects β€” tools, fasteners, debris, rigging components β€” striking workers or public belowHIGH

Fatal or serious head and crush injuries at ground level; property damage

Lightning strike and static discharge on exposed elevated metal structuresHIGH

Electrocution, cardiac arrest, burns, secondary fall

High winds, gusts and wind loading on rigging, ropes and workers on slender structuresMEDIUM

Loss of balance, uncontrolled swing, dropped loads, rope entanglement

Suspension intolerance (orthostatic shock) following an arrested fall while awaiting rescueHIGH

Loss of consciousness and death within minutes if suspended motionless

Heat stress, cold exposure, dehydration and fatigue during prolonged periods on the structureMEDIUM

Impaired judgement, heat stroke, hypothermia, increased fall risk

Public and traffic exposure below the structure in occupied precinctsMEDIUM

Struck-by injury to third parties from dropped objects or displaced masonry

Control measures

Hierarchy-of-controls order: elimination β†’ substitution β†’ isolation β†’ engineering β†’ administrative β†’ PPE.

  1. 1Eliminate the fall risk where reasonably practicable by carrying out inspections and works from the ground using drones, telescopic cameras or elevating work platforms before committing personnel to the structure.
  2. 2Substitute climbing with a mobile or tower crane suspended work platform (crane-lifted personnel box) engineered to AS 1418.17 where structural access from within is unsafe, with a Safe Work Method Statement and lift study prepared by a competent rigger.
  3. 3Engineer collective fall protection by installing engineered platforms, edge protection and catch fans wherever the structure geometry permits, before defaulting to personal fall-arrest systems.
  4. 4Design and certify all anchorages, tie-back points and rigging by a competent structural engineer prior to loading; anchorages used with personal fall protection to comply with AS/NZS 5532 and be identified, tagged and load-tested.
  5. 5Deploy dual rope access systems in accordance with AS/NZS 4488 (industrial rope access) using IRATA/ARAA-qualified operators with a working line and independent safety line, edge protectors, and a documented rescue plan capable of retrieving a suspended worker within minutes to control suspension intolerance.
  6. 6Personal fall-arrest equipment (harnesses, lanyards, energy absorbers, connectors, self-retracting devices) to comply with AS/NZS 1891 series; inspected before each use and recertified at intervals specified by the manufacturer.
  7. 7For telecommunications tower work, obtain written RF hazard information and switch-off/power-down permits from carriers; measure RF fields using calibrated meters, apply the ARPANSA RPS S-1 exposure limits, and use RF personal monitors and shielded PPE where residual exposure remains.
  8. 8Manage lead-based paint in accordance with AS 4361.1: assume pre-1970 coatings are leaded until sampled; use wet methods or HEPA-shrouded tools, containment sheeting, P3 respiratory protection, decontamination facilities and biological monitoring under Regulation 2025 sections 394–401.
  9. 9Control respirable crystalline silica in accordance with the SafeWork NSW Code of Practice β€” Managing the risks of respirable crystalline silica from engineered and natural stone: use water suppression or on-tool HEPA extraction, air monitoring, and P2/P3 respiratory protection; comply with the 0.05 mg/mΒ³ workplace exposure standard.
  10. 10Establish exclusion zones at ground level with hard barricades, spotters, signage and traffic control per AS 1742.3; suspend work when wind speed exceeds engineered limits (typically 36 km/h at working height) or when electrical storms are within 10 km; monitor via BoM alerts.
  11. 11Conduct daily pre-start structural inspections and toolbox talks; implement a documented emergency and rescue plan rehearsed on site, with a dedicated rescue operator and equipment on standby throughout the work.
  12. 12All workers to hold White Card (CPCCWHS1001), rope access or working-at-height competencies, and where applicable rigging/dogging licences; consult workers under section 47 and review the SWMS under section 302 whenever a control fails, an incident occurs, wind or structural conditions change, or a new hazard is identified.

Applicable Codes of Practice

SafeWork NSW Code of Practice β€” Managing the risk of falls at workplacesβš– Legally binding Β· 1 Jul 2026

Approved code establishing the hierarchy of fall controls, anchorage design, edge protection and administrative controls directly applicable to steeplejack access.

SafeWork NSW Code of Practice β€” Managing the risks of respirable crystalline silica from engineered and natural stoneβš– Legally binding Β· 1 Jul 2026

Governs silica dust controls when grinding, cutting or repointing masonry chimneys, spires and monuments.

AS/NZS 1891 (set) β€” Industrial fall-arrest systems and devices

Specifies performance and inspection requirements for harnesses, lanyards, energy absorbers and horizontal lifelines used by steeplejacks.

AS/NZS 4488 β€” Industrial rope access systems

Specifies equipment and operational requirements for dual-rope access techniques commonly used on spires, stacks and towers.

High-Risk Construction Work triggered

s291(a)
Involves a risk of a person falling more than 2 metres

Steeplejack activity is performed on chimneys, spires, stacks and towers routinely 20–100 metres above ground; any loss of positioning, anchor failure or structural collapse would result in a fall well beyond the 2-metre threshold.

s291(b)
Is carried out on a telecommunication tower

Inspection, painting, antenna installation and structural repair on carrier and broadcast towers falls squarely within paragraph (b), independently of the fall-height trigger, and introduces additional RF radiation hazards.

Legal consequence

Because the work is high risk construction work, section 299 of the Work Health and Safety Regulation 2025 (NSW) requires a SWMS to be prepared before work commences, complied with during the work, and reviewed under section 302 whenever controls are found not to control the risk, an incident occurs, or the work changes. Failure to prepare, comply with or produce a SWMS is an offence. Where the failure exposes a worker to a risk of death or serious injury, prosecution may proceed as a Category 2 offence under section 32 of the Work Health and Safety Act 2011 (NSW), or a Category 1 offence under section 31 where recklessness is established. Current maximum penalties are set out in the SafeWork NSW penalty schedule and are indexed periodically.

Who this is for

  • β†’Steeplejack contractors performing heritage steeple, spire and monument works
  • β†’Industrial rope access companies servicing chimneys, silos and process stacks
  • β†’Telecommunications tower riggers and antenna installers working for carriers
  • β†’Specialist protective coating and painting contractors on tall structures
  • β†’Principal contractors and PCBUs engaging steeplejack subcontractors on NSW projects

What you receive

  • βœ“Fully editable Microsoft Word SWMS aligned to the Work Health and Safety Regulation 2025 (NSW) sections 299–302
  • βœ“Steeplejack-specific hazard register covering fall, RF, lead, silica, structural and environmental risks
  • βœ“Hierarchy-of-control task steps for ascent, positioning, work execution, descent and rescue
  • βœ“Anchorage, rope access and PPE inspection checklists referencing AS/NZS 1891 and AS/NZS 4488
  • βœ“Emergency and suspension-trauma rescue plan template with rehearsal record
  • βœ“Section 47 consultation record and sign-on register for workers and subcontractors
  • βœ“Section 302 review log to document control failures, incidents and change events
  • βœ“Guidance notes cross-referencing NSW approved Codes of Practice and ARPANSA RPS S-1
  • βœ“Free lifetime updates whenever the NSW Regulation, Codes or referenced Standards change

Worked example

A steeplejack contractor is engaged to inspect, repoint and repaint the 42-metre sandstone spire of a heritage church in Goulburn, NSW. Before mobilising, a licensed drone operator conducts a photogrammetric survey to identify loose masonry and corroded ferrous cramps. A structural engineer designs three top-anchor points bolted through the spire cross-section and issues a certificate of load capacity. Two IRATA Level 3 operators establish dual-rope systems complying with AS/NZS 4488, with a third rescue-capable operator on standby at the belfry. Pre-1970 paint samples return positive for lead, so surface preparation is limited to wet scraping under HEPA-shrouded containment, with workers in P3 half-face respirators and disposable coveralls, and biological monitoring arranged through an occupational physician. Repointing dust is controlled by wet methods to comply with the 0.05 mg/mΒ³ silica exposure standard. A 15-metre ground exclusion zone is barricaded, with a traffic controller on Auburn Street. Work is suspended when wind at the top anchor exceeds 36 km/h. The SWMS is signed by all workers under section 47, and reviewed under section 302 after a lightning forecast forces mid-shift descent on day three.

Related legislation

  • Work Health and Safety Act 2011 (NSW) β€” sections 19, 31, 32, 47
  • Work Health and Safety Regulation 2025 (NSW) β€” sections 78–80 (falls), 291, 299, 302, 394–401 (lead)
  • Radiocommunications Act 1992 (Cth) and ARPANSA Radiation Protection Standard RPS S-1 (RF exposure limits)
  • Heritage Act 1977 (NSW) β€” where the structure is a listed heritage item
  • Protection of the Environment Operations Act 1997 (NSW) β€” lead and dust discharge
  • Environmental Planning and Assessment Act 1979 (NSW) β€” approval for scaffolding and hoardings in public precincts

Frequently asked questions

Is steeplejack work always high risk construction work in NSW?

Yes. Any component of the work with a fall risk exceeding 2 metres triggers section 291(a) of the Work Health and Safety Regulation 2025 (NSW), and work on a telecommunications tower independently triggers section 291(b). A SWMS is mandatory under section 299 before work commences.

Can rope access replace scaffolding on a spire or chimney?

Rope access complying with AS/NZS 4488 is an accepted method where scaffolding is not reasonably practicable, but it must use dual independent lines, competent operators, engineered anchorages certified to AS/NZS 5532, and a rehearsed rescue plan capable of retrieving a suspended worker within minutes to prevent suspension intolerance.

What do we do about lead paint on a heritage steeple?

Treat all pre-1970 coatings as lead-containing until sampled to AS 4361.1. Apply wet methods or HEPA-shrouded tools, full containment, P3 respiratory protection and decontamination facilities. Workers must be enrolled in health monitoring, including blood lead measurement, under sections 394–401 of the Regulation 2025.

How often must this SWMS be reviewed?

Section 302 of the Regulation 2025 requires the SWMS to be reviewed and, if necessary, revised whenever a control measure is found not to control the risk, a notifiable incident occurs, a new hazard is identified, or the work changes β€” including anchor changes, weather deterioration, RF status changes on a tower, or personnel changes.

What's in this SWMS

Document details

Regulation
Work Health and Safety Regulation 2025 (NSW), Section 291 β€” High Risk Construction Work
HRCW Category
s. 291(a) β€” Risk of fall greater than 2 metres; s. 291(b) β€” Work on a telecommunications tower
Hazards Identified
12 hazards with controls
Format
Editable DOCX (Microsoft Word)
Author
Certified Industrial Hygienist (CIH)
Delivery
Instant download after payment
CIH-reviewed SWMS Β· from $99 Β· instant download

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