Working at Heights SWMS Guide — Templates & Compliance | SafeSWMS

When is a Working at Heights SWMS Required?

A SWMS is required under the WHS Regulation 2025 Schedule 1 for any construction work involving a risk of a person falling more than 2 metres. This includes but is not limited to:

Work on roofs (all types — tiled, metal, flat, pitched) where there is a risk of falling from the roof edge or through fragile roof surfaces such as skylights, fibre cement sheeting, or corroded metal.

Work on scaffolding, including the erection, alteration, and dismantling of scaffold, and any trade work carried out from scaffold platforms above 2 metres.

Work using elevated work platforms (EWPs) including scissor lifts, boom lifts (articulating and telescopic), cherry pickers, and truck-mounted platforms.

Work on ladders where the worker could fall more than 2 metres (noting that ladders should be the last resort for height access, not the first choice).

Work near open edges, floor penetrations, voids, lift wells, stairwell openings, or unprotected perimeters at any level above 2 metres.

Work in ceiling spaces and roof voids where there is a risk of falling through the ceiling to the level below.

The risk of falling more than 2 metres is assessed from the point where the worker is standing, sitting, or working to the point where they would land if they fell. For work on a pitched roof, this is typically measured from the roof edge to the ground, not from the ridge. For work near a floor opening, it is measured from the opening to the next level below.

Key Hazards in Working at Heights

The primary hazards associated with working at heights in construction include:

Falls from edges — falling from roof edges, scaffold platforms, EWP baskets, open-sided floors, loading docks, and any unprotected perimeter above 2 metres. Falls from edges are the most common mechanism of fatal falls in construction.

Falls through surfaces — falling through fragile or deteriorated roof sheeting (particularly asbestos cement sheeting), skylights, ceiling tiles, insulation, or plasterboard in ceiling spaces. Workers stepping off structural members (joists, purlins) onto non-structural surfaces is a frequently reported mechanism of serious injury.

Falls from plant and equipment — falling from ladders (the most common source of non-fatal fall injuries), mobile scaffolds, trestle platforms, and during access to and egress from EWPs and fixed scaffolding.

Falling objects — tools, materials, and debris falling from elevated work areas onto workers or the public below. A dropped hammer from 10 metres can generate an impact force equivalent to approximately 100 times its static weight.

Scaffold collapse — structural failure of scaffolding due to inadequate design, non-compliant erection, overloading, removal of ties or bracing, or foundation failure. Scaffold collapse incidents frequently result in multiple casualties.

EWP tip-over or structural failure — overturning of scissor lifts and boom lifts due to uneven ground, overloading, wind forces, or operating on slopes exceeding the machine's rated gradient. Boom lift catapult effect (whip) from sudden boom movements can eject workers from the basket.

Wind — gusts can destabilise EWPs, dislodge unsecured materials and sheeting, push workers off balance on exposed platforms, and create sail effects on large sheet materials being handled at height.

Suspension trauma — a harness-suspended worker who cannot self-rescue after a fall is at risk of orthostatic intolerance (suspension trauma), which can cause unconsciousness and death within 15 to 30 minutes. Rescue planning is therefore a mandatory component of any fall arrest system.

Lightning — workers at height on scaffolding, roofs, cranes, and EWPs are at extreme risk during electrical storms. Metal scaffolding and crane structures are effective lightning conductors.

Hierarchy of Controls for Falls from Height

The Code of Practice: Managing the Risk of Falls at Workplaces (2011) prescribes the following hierarchy of controls for managing fall risks, which must be applied in order:

1. Eliminate the risk of a fall — wherever reasonably practicable, the work should be carried out at ground level or from a solid construction. Examples include: assembling roof trusses at ground level then craning them into position; using prefabricated wall panels that are tilted up rather than framed in place; and designing buildings to allow maximum work to be completed before height access is required.

2. Prevent falls — if the risk of falling cannot be eliminated, falls must be prevented using passive fall prevention devices that do not require the worker to do anything. The primary control is edge protection (guardrails complying with AS/NZS 4994). Guardrails must include a top rail at 900mm minimum above the working surface, a mid-rail, and a toeboard. Other passive controls include scaffold platforms with guardrails, EWP baskets with guardrails, and full decking/covering of floor penetrations and openings.

3. Minimise the distance of a fall — where falls cannot be prevented, systems that limit the fall distance must be used. Travel restraint systems (where the lanyard length prevents the worker from reaching the fall edge) are preferred over fall arrest systems (which allow a fall but arrest it). Industrial safety nets positioned close to the work surface reduce fall distance and arrest the fall without requiring worker action.

4. Arrest falls — fall arrest systems (full-body harness, shock-absorbing lanyard, and rated anchor point) are used as a last resort when higher-order controls cannot adequately manage the risk. Fall arrest systems require: trained workers (Working at Heights — RIIWHS204E); daily inspection of equipment; a rescue plan that can be executed within 20 minutes; adequate clearance below the anchor point for the fall distance plus shock absorber deployment plus worker height; and anchor points rated to 15kN for fall arrest.

A SWMS that specifies only PPE (harness) as the fall control without justifying why higher-order controls (guardrails, EWP, scaffold) are not reasonably practicable will not satisfy the requirements of the WHS Regulation and the Code of Practice.

Australian Standards for Working at Heights

The following Australian Standards are directly relevant to working at heights and should be referenced in a working at heights SWMS:

AS/NZS 1891.1 — Industrial fall-arrest systems and devices — Harnesses and ancillary equipment. Specifies requirements for full-body harnesses, lanyards, energy absorbers, and connectors.

AS/NZS 1891.4 — Industrial fall-arrest systems and devices — Selection, use and maintenance. Provides guidance on the selection of fall-arrest equipment, inspection procedures, service life, and competency requirements.

AS/NZS 4488 — Industrial rope access systems. Covers rope access techniques for work at height where scaffolding and EWPs are not practicable.

AS/NZS 1576.1 to 1576.6 — Scaffolding. The comprehensive series covering design and construction of scaffolding including general requirements (Part 1), couplers (Part 2), prefabricated and tube-and-coupler scaffolding (Part 3 and 4), and suspended scaffolding (Part 5).

AS/NZS 4576 — Guidelines for scaffolding safety. Provides practical guidance on scaffold erection, inspection, use, and dismantling.

AS/NZS 4994.1 — Temporary edge protection. Specifies requirements for temporary guardrail systems used as edge protection during construction.

AS/NZS 1657 — Fixed platforms, walkways, stairways, and ladders — Design, construction, and installation. Applies to permanent access equipment in buildings and structures.

AS 2550 — Cranes, hoists, and winches — Safe use (relevant series). Applies to the use of cranes for material handling at height and man-cage operations.

Workers using fall-arrest equipment must hold the unit of competency RIIWHS204E (Work Safely at Heights) or equivalent. Scaffold erectors must hold the relevant High Risk Work Licence: SB (basic scaffolding — up to 4 metres), SI (intermediate — up to 15 metres), or SA (advanced — over 15 metres and suspended scaffolding).

Working at Heights Training and Licensing

The following training and licensing requirements apply to working at heights on construction sites in Australia:

General Construction Induction (White Card) — CPCCWHS1001 — mandatory for all workers on construction sites. This is a prerequisite for any height work.

Work Safely at Heights — RIIWHS204E — nationally accredited training covering fall prevention, fall arrest systems, rescue planning, and equipment inspection. Required for any worker who uses a fall-arrest harness or works in a position where they could fall more than 2 metres.

Scaffolding licences (High Risk Work Licences): - SB (Basic Scaffolding) — erection and dismantling of modular or prefabricated scaffolding up to 4 metres in height - SI (Intermediate Scaffolding) — scaffolding from 4 metres up to 15 metres, including hung and cantilevered scaffolding - SA (Advanced Scaffolding) — scaffolding over 15 metres, suspended scaffolding, and all other types

EWP licences (High Risk Work Licences): - WP (Boom-type EWP over 11 metres) — required for operating boom lifts with a platform height exceeding 11 metres. Scissor lifts do not require a WP licence but operators must be trained and assessed as competent.

Rigging licences: - RB (Basic Rigging) — rigging work including erection of mast climbers, personnel and material hoists - RI (Intermediate Rigging) — structural steel erection, gin poles, flying foxes - RA (Advanced Rigging) — all rigging work including complex multi-crane lifts

Dogman licence — DG — required for any worker who directs crane movements and slings loads.

First aid — a current first aid certificate is recommended for at least one worker in every height work team. First aid must include treatment for fall injuries including spinal immobilisation.

Rescue Planning for Work at Heights

A rescue plan is a mandatory component of any work at heights SWMS where fall-arrest systems are used. The rescue plan must address how an injured or suspended worker will be retrieved from their fall-arrest equipment and lowered to ground level for medical treatment.

Suspension trauma (also known as harness-induced pathology or orthostatic intolerance) is a life-threatening condition that can develop within 15 to 30 minutes when a worker is suspended motionless in a harness after a fall. Blood pools in the legs, reducing cardiac output and causing unconsciousness and death if the worker is not rescued promptly. The rescue plan must therefore be capable of execution within 20 minutes of the fall event.

Rescue planning requirements include: identification of the rescue method (self-rescue, assisted rescue by co-workers, or technical rescue by emergency services); availability of rescue equipment at the work location (rescue descent device, rescue pole, retrieval system, stretcher); training of at least two workers per team in the rescue method and equipment; practice of the rescue procedure before work commences (particularly for complex scenarios such as tower crane rescue, communications tower rescue, or rope access rescue); and communication protocols including how the fall will be detected, how the rescue team will be alerted, and how emergency services (000) will be contacted.

A SWMS that specifies fall-arrest harnesses without a corresponding rescue plan does not comply with the Code of Practice: Managing the Risk of Falls at Workplaces. The rescue plan must be tested and workable, not merely a statement that emergency services will be called.