High Risk Construction Work: The Full List of 18 HRCW Activities

What counts as high risk construction work?

High risk construction work (HRCW) is construction work that involves any of the 18 activities listed in s.291 of the model Work Health and Safety Regulations. The list is exhaustive and specific: it runs from s.291(a) through s.291(r), and each paragraph describes one activity or work environment that lawmakers consider dangerous enough to require extra planning.

The definition matters because it is the trigger for the Safe Work Method Statement duty. Under s.299 of the WHS Regulations, a PCBU (person conducting a business or undertaking) must prepare a SWMS before high risk construction work starts. No HRCW activity means no legal SWMS requirement; one or more HRCW activities means a SWMS is mandatory. There is no discretion, no small-job exemption and no threshold based on crew size or contract value.

This version of the list applies in NSW, Queensland, South Australia, Tasmania and the ACT under their harmonised WHS Regulations, where the provision is cited as s.291. The Northern Territory applies the same 18-activity list, cited as Reg 291 of the Work Health and Safety (National Uniform Legislation) Regulations 2011 (NT), and Western Australia adopted it in 2022 as Reg 291 of its WHS (General) Regulations 2022. Victoria runs its own scheme, covered further down.

The 18 HRCW activities under s.291

Here is the full list. Read it against your actual scope of work, not your trade label. A painter on a two-storey house triggers paragraph (a); a plumber cutting into a live gas main triggers paragraph (i); a landscaper working beside a road triggers paragraph (n).

One activity is enough to trigger the SWMS duty

You do not need to tick multiple boxes. If your job involves a single s.291 activity, the full SWMS regime in Part 6.4 of the WHS Regulations applies. That means a SWMS must be prepared before the HRCW starts (s.299), the work must actually be carried out in accordance with the SWMS or stop until it can be (s.300), the principal contractor must be given a copy before the HRCW commences (s.301), the SWMS must be reviewed and revised whenever circumstances change (s.302), and it must be kept and remain readily available while the work is done (s.303).

Most real jobs trigger more than one paragraph. A roof replacement typically involves falls over 2 metres (a), possibly asbestos disturbance on older homes (d), and powered mobile plant if a crane or telehandler delivers materials (o). Your SWMS must identify every HRCW activity that applies, not just the most obvious one.

The duty sits with the PCBU carrying out the work. If you are a subcontractor, that is you, not the builder. The builder, as principal contractor, has a separate duty to obtain your SWMS before you start.

Triggers tradies commonly miss

Some paragraphs of s.291 are about the environment you work in, not the task you perform, and these are the ones that catch people out. Paragraph (o) applies whenever your work area has powered mobile plant moving through it, even if you never touch the machine yourself. Paragraph (n) covers work on or adjacent to a road or railway, which pulls in fencing crews, line markers and landscapers working off the kerb. Paragraph (k) covers work near energised electrical installations, not just electrical work itself, so an excavator operator digging near live underground cables is doing HRCW.

Height and depth thresholds are precise. The fall trigger in paragraph (a) is a risk of a person falling more than 2 metres, which captures most single-storey roof work and a lot of scaffold and ladder work. The excavation trigger in paragraph (g) is a shaft or trench deeper than 1.5 metres, or any tunnel regardless of depth.

South Australia was historically the outlier on the fall threshold. SA used a 3 metre trigger for fall-related HRCW while the model law used 2 metres, but on 1 July 2026 it harmonised with the model 2 metre threshold. That change is now in force, so in SA a risk of a person falling more than 2 metres is now HRCW, the same as the rest of the harmonised jurisdictions.

Victoria is different: 19 classes, not 18 activities

Victoria never joined the harmonised WHS scheme. It runs the Occupational Health and Safety Act 2004 (Vic) and the OHS Regulations 2017 (Vic), and it defines 19 classes of high risk construction work under Reg 322 rather than the 18 activities in the model s.291. The lists cover similar ground but they are not identical, and the Victorian SWMS duty sits in Reg 327, with the duty holder described as the employer rather than the PCBU. WorkSafe Victoria is the regulator.

If you work in Victoria or take jobs across the border, do not assume a SWMS scoped against the model list automatically matches Victorian requirements. See our guide to SWMS requirements in Victoria for the detail.

What happens if you skip the SWMS

The SWMS provisions carry direct penalties. Failing to comply with a SWMS (s.300), failing to review it (s.302) and failing to keep it available (s.303) are each separate offences that attract fines, and regulators in most jurisdictions can also issue on-the-spot penalty notices for SWMS breaches. The exact amounts vary by state, so check your regulator's current penalty schedule. Inspectors routinely ask for the SWMS first when they walk onto a site where HRCW is under way, and no document usually means work stops on the spot.

The practical fix is straightforward: identify which s.291 activities your job involves, then prepare a SWMS that covers each one before work starts. If you would rather not build one from a blank page, GSR sells 753 editable Word safety documents across 22 trades, including trade-specific SWMS templates from $79.95, each citing the relevant WHS provisions and AS/NZS standards so the HRCW identification is already mapped for your trade.

Related guides

• What Is a SWMS? Safe Work Method Statements Explained
• SWMS Legal Requirements: Sections 299 to 303 Explained
• SWMS Requirements in Victoria: OHS Act 2004 and Regulation 327
• Do I Need a SWMS for Working at Heights?