Do I Need a SWMS for Working at Heights?
If there is a risk of a person falling more than 2 metres, the work is high risk construction work under WHS Regulations s.291(a) and a SWMS is mandatory before it starts. The test is the fall risk, not the job title, so roofers, scaffolders, carpenters and painters trigger it routinely. Here is how the 2 metre rule works in every state.
Last updated 2026-07-02
The short answer: yes, if someone could fall more than 2 metres
Under the model WHS Regulations, construction work that involves a risk of a person falling more than 2 metres is high risk construction work (HRCW) under s.291(a). Section 299 then requires a safe work method statement to be prepared before that work starts. This applies in NSW, Queensland, South Australia, Tasmania, the ACT and the Northern Territory under the harmonised WHS laws, with equivalent provisions in Western Australia and Victoria covered below.
Two things trip people up. First, the duty sits on the person conducting the business or undertaking (PCBU) carrying out the work, which usually means the subcontractor, not just the builder. If you are a sole trader roofer, you are the PCBU and the SWMS duty is yours. Second, the principal contractor must obtain a copy of your SWMS before the high risk work starts (s.301), which is why builders ask for it at induction.
The 2 metre test is about fall risk, not the task label
s.291(a) does not say roof work or ladder work. It asks one question: is there a risk of a person falling more than 2 metres? That includes falls from a structure, falls through fragile surfaces such as brittle roofing or formwork, and falls into openings, voids and penetrations. If the answer is yes, the work is HRCW regardless of what the job is called. Common situations that trigger it include:
- Any work on a roof, since the roof surface of a standard single-storey home already sits above 2 metres
- Erecting, altering or dismantling scaffolding
- Working from ladders, trestles or elevating work platforms where the potential fall exceeds 2 metres
- Installing frames, trusses, cladding, fascia or guttering above ground-floor level
- Working near an unprotected edge, stairwell void, penetration or skylight
- Painting, rendering or glazing on upper storeys
What if the fall is under 2 metres?
If the maximum possible fall is 2 metres or less, s.291(a) is not triggered and a SWMS is not legally required on that basis alone. The same job may still be HRCW under another s.291 activity, such as work near energised electrical installations or in an area with powered mobile plant, so check the full list before deciding no SWMS is needed.
Even below 2 metres you still have a general duty to manage fall risks, and the Code of Practice: Managing the Risk of Falls at Workplaces sets out how regulators expect that to be done. Many principal contractors also require a SWMS for all height work as a contract condition, whatever the legal threshold says.
Trades that trigger s.291(a) routinely
The 2 metre trigger is the most common reason a SWMS is required on residential and commercial sites. These trades hit it week in, week out:
| Trade | Typical fall-risk work |
|---|---|
| Roofing | Re-roofs, roof repairs, gutter and fascia, skylight installs |
| Scaffolding | Erecting, altering and dismantling scaffolds |
| Carpentry | Frames, trusses, formwork and cladding above ground level |
| Painting | Exterior work on upper storeys from ladders, scaffolds or EWPs |
| Electrical, HVAC and solar | Rooftop solar panels, aerials and plant installs |
| Plumbing | Roof plumbing, flashings and downpipes |
The special rule for height SWMS: justify your controls
Every SWMS must do four things under s.299: identify the work that is high risk construction work, specify the hazards and risks, describe the control measures, and describe how those controls will be implemented, monitored and reviewed.
Fall work carries an extra requirement many tradies have never heard of. If a SWMS for work involving a risk of falling more than 2 metres relies only on administrative controls or PPE, for example a rule to stay away from the edge plus a harness, the SWMS must describe all the control measures that were considered, in effect justifying why higher-order controls were not used. A one-line wear-a-harness SWMS fails this test on its face.
That justification follows the hierarchy of control, which must be worked through in order:
- Elimination: remove the hazard entirely, such as doing the work at ground level
- Substitution: replace the hazardous method with a less hazardous one
- Isolation: separate people from the hazard
- Engineering: physical controls such as edge protection, scaffolds or elevating work platforms
- Administrative: procedures, training and signage
- PPE: harnesses and other personal equipment, as a last resort
State differences: Victoria, WA and SA
Victoria never joined the national WHS scheme. Its OHS Regulations 2017 (Vic) define 19 classes of high risk construction work under Reg 322, including work where there is a risk of a person falling more than 2 metres, and require a SWMS under Reg 327. The duty holder is the employer rather than the PCBU, and the regulator is WorkSafe Victoria. For height work the practical outcome is the same: a fall risk over 2 metres means a SWMS.
Western Australia runs the WHS Act 2020 (WA) with the WHS (General) Regulations 2022 (WA); high risk construction work is Reg 291 and the SWMS duty is Reg 299, enforced by WorkSafe WA. The Northern Territory uses the same numbering under its WHS (National Uniform Legislation) Regulations 2011.
South Australia used a 3 metre fall threshold for years, but from 1 July 2026 it harmonised with the national 2 metre threshold. The 2 metre test now applies in every Australian state and territory.
Penalties, and getting a compliant height SWMS
A SWMS is not a set-and-forget document. Once it exists you must comply with it or stop the work (s.300, which carries up to 73 penalty units for an individual), review it when circumstances change (s.302) and keep it until the work is complete (s.303). Failing to review or keep a SWMS attracts on-the-spot fines of $432 for individuals and $2,160 for body corporates in the harmonised jurisdictions.
You can write a height SWMS from scratch, but for common jobs an editable template is faster. GSR sells 753 editable Word safety documents across 22 trades, including working-at-heights SWMS for roofing, scaffolding, carpentry and painting from $79.95. Every document cites the relevant WHS provisions and AS/NZS standards, and you edit it to match your actual site conditions before workers sign on, because s.299 requires the SWMS to reflect the circumstances of your workplace.
Frequently asked questions
Do I need a SWMS for working at heights?
Yes, if there is a risk of a person falling more than 2 metres. That makes the work high risk construction work under s.291(a) of the WHS Regulations, and s.299 requires a SWMS before work starts. Victoria (OHS Regulations 2017 Regs 322 and 327) and WA (WHS (General) Regulations 2022 Regs 291 and 299) have equivalent provisions. Below a 2 metre fall risk, no SWMS is required under this trigger, though the duty to manage fall risks still applies.
Do I need a SWMS for working on a single-storey roof?
Almost always, yes. The roof surface of a standard single-storey home sits above 2 metres, so working on it carries a risk of falling more than 2 metres and is high risk construction work under s.291(a). That covers re-roofing, repairs, gutter and fascia work, skylights and rooftop solar. Prepare the SWMS before starting, and give the principal contractor a copy if you are on a builder's site, as required by s.301.
Does ladder work need a SWMS?
Only if the potential fall is more than 2 metres. The trigger is the fall distance, not the equipment. Working from a step ladder at 1.8 metres does not trigger s.291(a); working from an extension ladder at 3 metres does. Measure the distance a person could actually fall, including through fragile surfaces or into voids and openings, and if it exceeds 2 metres, prepare a SWMS before the work starts.
Can my working at heights SWMS just say wear a harness?
No. For fall work under s.291(a), if the only control measures in the SWMS are administrative controls or PPE, s.299 requires the SWMS to describe all the control measures that were considered, effectively justifying why higher-order controls such as edge protection, scaffolds or elevating work platforms were not used. A PPE-only height SWMS with no such justification does not meet the regulation.
Is the 2 metre rule the same in every state?
Yes, as of 1 July 2026. South Australia was the last jurisdiction using a 3 metre fall threshold, and it moved to 2 metres on that date. NSW, Queensland, Tasmania, the ACT and SA apply the model s.291(a); the NT and WA apply the same test as Reg 291 of their regulations; and Victoria captures work with a risk of falling more than 2 metres as one of its 19 HRCW classes under Reg 322 of the OHS Regulations 2017.
Get the documents
WHS-audited, editable Word documents that cite the exact provisions covered in this guide — pre-filled with your business details.
Not sure what you need? Try the free compliance checker.
Related guides
This guide is general information about work health and safety legislation, not legal advice. Requirements vary by state and by the specifics of your work — check with your regulator or a qualified professional before relying on it. Documents are templates and must be reviewed and adapted to your specific site conditions.