Internal Window Cleaning SWMS
Internal window and glass surface cleaning in occupied commercial premises using stepladders, poles, and squeegees. Covers slip/wet floor hazards, chemical exposure, and working around public.
SWMS variants reference your state’s WHS legislation. Instant download after payment.
Internal window cleaning in occupied commercial premises involves cleaning glass partitions, internal windows, glazed doors, and reflective surfaces using stepladders, extension poles, microfibre cloths, squeegees, and detergent-based cleaning chemicals. While often perceived as low-risk, the work environment introduces significant hazards including slip risks from wet floors, falls from height when using stepladders, chemical exposure to skin and eyes, manual handling of equipment and water buckets, and the constant presence of members of the public, staff, and visitors moving through the work area.
Under the model Work Health and Safety Act 2011 and WHS Regulation 2025, Part 4.1 (Managing Risks of Work), a Person Conducting a Business or Undertaking (PCBU) must identify hazards, eliminate risks so far as is reasonably practicable, and where that is not possible, minimise risks through the hierarchy of controls (regulation 36). The PCBU must also consult workers (section 47 of the WHS Act) and document the risk management process.
A Safe Work Method Statement is required for this work to demonstrate compliance with the PCBU's primary duty of care under section 19 of the WHS Act, to satisfy client and facility manager prequalification requirements, and to provide documented evidence of hazard identification, control measures, and worker consultation. Although internal window cleaning typically does not trigger High Risk Construction Work provisions, a documented SWMS remains the industry-standard control document for cleaning contractors operating in occupied premises.
Hazards identified
6 hazards covered, sorted by priority.
Fractures, sprains, head injuries to workers or members of the public; potential public liability claim
Serious injury including fractures, spinal injury, or fatality from falls above 2 metres
Skin dermatitis, eye irritation, respiratory irritation, chemical burns
Lower back strain, shoulder injuries, repetitive strain injuries
Impact injuries to workers and third parties; pole strike injuries from extension equipment
Electric shock, electrocution, equipment damage from water ingress
Control measures
Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.
- 1Erect compliant warning signage (yellow A-frame 'Wet Floor / Caution Cleaning' signs) at all approaches to the work area before commencing and remove only when floors are dry
- 2Use industrial-grade Type 1 (Industrial) stepladders compliant with AS/NZS 1892.1 with a maximum working height of 2 metres; for higher glazing use extension poles from ground level rather than ladders
- 3Maintain three points of contact when ascending/descending stepladders; never stand on the top two rungs; ensure ladder is on level, dry, non-slip surface with all four feet stable
- 4Select low-hazard cleaning chemicals (pH-neutral or low-VOC glass cleaners) and obtain current Safety Data Sheets; store SDS on site and brief workers on chemical hazards per WHS Regulation 2025 Chapter 7
- 5Issue and require use of nitrile chemical-resistant gloves, safety glasses to AS/NZS 1337.1, non-slip enclosed footwear, and high-visibility vests when working in occupied premises
- 6Use microfibre application and minimise spray volume; spray cloth rather than glass to reduce overspray, drips, and aerosol inhalation
- 7Schedule cleaning outside peak occupancy where possible; where not possible, establish a 2-metre exclusion zone with bollards or warning tape and have a spotter when using extension poles in public areas
- 8De-energise or maintain a minimum 500mm clearance from electrical fittings, switchboards, and live equipment; never spray cleaning fluid directly onto or near electrical components
- 9Implement two-person team where loads exceed 16kg or where ladder work is conducted in trafficked areas (one cleaner, one spotter)
- 10Conduct daily pre-start inspection of ladders, poles, and PPE; tag out and remove any damaged equipment from service immediately
- 11Provide first aid kit, eye-wash station access, and ensure all workers know the location of nearest emergency exits and incident reporting procedure
Applicable Codes of Practice
Establishes the systematic risk management process required under WHS Regulation 2025 Part 4.1, including hazard identification, risk assessment, and the hierarchy of controls applicable to all cleaning tasks
Provides guidance on stepladder selection, safe use, and fall prevention applicable when accessing high internal windows and glazing
Governs the use, labelling, storage, and SDS requirements for glass cleaning chemicals and detergents
Applies to repetitive overhead reaching, carrying buckets and ladders, and pole-cleaning postures
Specifies industrial-grade stepladder design and load rating requirements for ladders used in commercial cleaning
Applies if cleaning extends into service corridors, riser cupboards, or behind fixed glazing assemblies
Who this is for
- →Commercial cleaning contractors servicing offices, retail, and shopping centres
- →Facility management companies with in-house cleaning teams
- →Sole trader window cleaners tendering for commercial contracts
- →Building managers and strata managers engaging cleaning contractors
- →Cleaning supervisors responsible for inducting new staff onto sites
- →Contractors required to upload SWMS documentation to Rapid Induct, Cm3, Avetta, or similar prequalification platforms
What you receive
- ✓Fully editable Microsoft Word (DOCX) SWMS template branded to your company
- ✓State and territory-specific legislation schedule covering all eight Australian jurisdictions
- ✓Comprehensive hazard register with risk matrix and residual risk scoring
- ✓Worker sign-on register with consultation acknowledgement fields
- ✓Pre-start daily checklist for ladders, PPE, and chemical equipment
- ✓Safety Data Sheet register template for cleaning chemicals
- ✓Emergency response and incident reporting procedure
- ✓Free lifetime updates when WHS Regulations or Codes of Practice are amended
Worked example
Sarah is a contract cleaner engaged by a Sydney CBD facility manager to clean internal glass partitions and atrium windows in a 12-storey commercial tower. Before commencing, she reviews the Internal Window Cleaning SWMS with her offsider, signs the worker consultation register, and briefs the building concierge on the work zones for the shift. She places A-frame wet floor signs at each lift lobby entry, sets up bollards around her stepladder zone in the ground-floor foyer, and confirms her nitrile gloves and safety glasses are worn before decanting the pH-neutral glass cleaner. Mid-shift, a building tenant attempts to walk through the bollarded zone while Sarah is on the second step of her ladder. Because the SWMS requires a spotter in trafficked areas, her offsider intercepts the tenant and redirects them safely. After the shift, Sarah signs off the daily pre-start checklist, notes a minor ladder foot wear issue in the equipment register, and tags the ladder for replacement. The completed SWMS, sign-on register, and checklist are uploaded to the facility manager's Cm3 portal as evidence of compliance with WHS Regulation 2025.
Related legislation
- Work Health and Safety Act 2011 (Cth model) — sections 19, 20, 27, 47
- Work Health and Safety Regulation 2025 — Part 4.1 Managing Risks of Work
- Work Health and Safety Regulation 2025 — Part 4.4 Falls
- Work Health and Safety Regulation 2025 — Chapter 7 Hazardous Chemicals
- Work Health and Safety Regulation 2025 — Part 3.2 General Workplace Management
- Workers Compensation Act 1987 (NSW) and equivalent state-based workers compensation legislation
- Australian Consumer Law — public liability obligations for contractors operating in occupied premises
Frequently asked questions
Is internal window cleaning classified as High Risk Construction Work?
No. Internal window cleaning in occupied commercial premises does not trigger any of the 18 High Risk Construction Work categories listed in WHS Regulation 2025 regulation 291, as it is not construction work and typically does not involve work at heights above 2 metres. However, a SWMS remains best practice and is almost always required by facility managers and prequalification platforms as a condition of site access.
Do I legally need a SWMS for internal window cleaning?
While a SWMS is only legally mandated for High Risk Construction Work, a documented safe work procedure is required under WHS Regulation 2025 Part 4.1 to demonstrate the PCBU has met its duty to manage risks. In practice, virtually all commercial clients, facility managers, and contractor prequalification systems (Cm3, Avetta, Rapid Induct) require a SWMS before granting site access.
Can I use this SWMS in any Australian state or territory?
Yes. The document includes a state-specific legislation schedule covering NSW, VIC, QLD, WA, SA, TAS, ACT, and NT. Note that Victoria operates under the OHS Act 2004 and OHS Regulations 2017, and Western Australia under the WHS Act 2020 (WA), both of which are addressed in the schedule.
How often should this SWMS be reviewed?
Per WHS Regulation 2025, a SWMS must be reviewed whenever the work method changes, an incident occurs, a new hazard is identified, or a worker raises a concern. As a minimum, we recommend an annual review and a fresh site-specific review for each new commercial premises before commencing work.
Does the SWMS cover external or high-rise window cleaning?
No. This SWMS is scoped specifically to internal window and glass surface cleaning using stepladders and extension poles up to 2 metres. External facade cleaning, rope access, boom lift work, or building maintenance unit (BMU) operation require separate SWMS documents addressing working at heights, fall arrest systems, and HRCW category 1 (risk of fall more than 2 metres).
Can I edit the document with my company logo and details?
Yes. The SWMS is supplied as a fully editable Microsoft Word (DOCX) file. You can insert your company logo, ABN, insurance details, site-specific information, and adjust controls to match your specific equipment and chemicals while retaining the underlying compliance framework.