Window Cleaning SWMS

Window cleaning at ground level and up to first-storey height presents a deceptive risk profile — workers routinely combine ladder work, extension pole manipulation, chemical handling, and operation near pedestrian or vehicular traffic. Under WHS Regulation 2025, any task involving a foreseeable fall of more than two metres is classified as High Risk Construction Work (a high risk construction work category) and triggers a mandatory Safe Work Method Statement before work commences. Even sub-2m work attracts the PCBU's primary duty under section 19 of the WHS Act to eliminate or minimise risks so far as is reasonably practicable. This SWMS addresses the specific hazard cocktail of fall-from-height, glycol-ether and ammonia exposure, ladder instability on uneven surfaces, public interface, and ergonomic loading from overhead pole work. It is purpose-built for commercial and residential cleaners working from poles, A-frame and extension ladders, and small EWPs — and excludes rope access or building maintenance unit work which require a separate height-specific SWMS.

Hazards identified

7 hazards covered, sorted by priority.

Control measures

Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.

1. 1Elimination — Use water-fed carbon-fibre pole systems from ground level wherever first-storey glass is reachable, eliminating ladder use and removing the fall-from-height hazard entirely.
2. 2Elimination — Decline scope items requiring access above 2m unless an EWP or rope access SWMS is in place; document refusal in pre-job risk assessment.
3. 3Substitution — Replace ammonia and glycol-ether cleaners with low-toxicity surfactant or pure deionised water systems, reducing inhalation and dermal exposure per HSIS exposure standards.
4. 4Substitution — Use non-conductive fibreglass or carbon-fibre poles in place of aluminium where any overhead electrical infrastructure is present within 3m of the work zone.
5. 5Engineering — Deploy industrial-rated ladder stabilisers, anti-slip feet, and ground mats (AS/NZS 1892.5) on all ladder setups; isolate work area with bollards or A-frame barriers.
6. 6Engineering — Install drip trays and absorbent runoff mats beneath wash zones on smooth flooring to prevent slip hazards in public thoroughfares.
7. 7Administrative — Conduct documented pre-start briefing using this SWMS, confirm sign-on by every worker, and complete a site-specific ladder/EWP setup checklist before each access cycle.
8. 8Administrative — Schedule shopfront cleaning outside peak pedestrian and vehicle hours; deploy a dedicated spotter when working within 2m of any active trafficked area.
9. 9PPE — Wear ANSI/AS-rated chemical splash safety goggles (AS/NZS 1337.1), nitrile chemical gloves, and slip-resistant footwear (AS/NZS 2210.3) throughout all cleaning operations.
10. 10PPE — Don high-visibility vest (AS/NZS 4602.1 Class D/N) for any work within 5m of vehicle movement areas, and use forearm-supported pole harness for sustained overhead pole work exceeding 30 minutes.

Applicable Codes of Practice

High-Risk Construction Work triggered

Worked example

A two-person window cleaning crew arrives at a suburban medical centre to clean ground-floor and first-storey external glazing. Before unloading equipment, the lead cleaner opens this SWMS on a tablet at the rear of the van and walks through it as the pre-start brief. They identify three site-specific hazards: a sloped concrete apron at the entry (slip and ladder slip-out risk), an overhead 240V service drop running parallel to the eastern wall (electrical contact risk via metal pole), and a busy carpark aisle within 3m of the shopfront (struck-by risk). Referencing the controls register, they swap the aluminium pole for a carbon-fibre water-fed pole on the eastern elevation, deploy bollards and an A-frame sign in the carpark aisle, and lay an absorbent runoff mat at the sloped entry. Both workers sign on to the SWMS, confirming PPE — splash goggles, nitrile gloves, hi-vis vest, slip-resistant boots. Midway through the job, a delivery vehicle attempts to reverse into the work zone; the spotter halts work, the crew steps back, and the lead cleaner notes the near-miss on the SWMS review section, upgrading the traffic control to require a second physical barrier for the remainder of the shift. The completed SWMS is uploaded to the contractor's compliance folder and retained for two years.

Related legislation

• WHS Act 2011 (model)
• WHS Regulation 2025
• Managing the Risk of Falls at Workplaces CoP

Frequently asked questions