High risk construction work: the 18 activities that require a SWMS

What is high risk construction work (HRCW)?

High risk construction work (HRCW) means construction work involving one of the specific activities or situations listed in regulation 291 of the model WHS Regulations. Examples include work with a risk of falling more than 2 metres, disturbing asbestos or working near energised electrical services. It is the work and its conditions that matter, not whether the project is a large commercial site or a small home renovation.

Under regulation 299, a Safe Work Method Statement (SWMS) must be prepared before any high risk construction work starts. It identifies the high-risk work, hazards and risks, controls, and how those controls will be implemented, monitored and reviewed. Read what a SWMS is and use our SWMS template to understand the layout.

Here's the full list of 18 categories, worded as they appear in the regulation, with a plain-English trade example for each, so you can quickly tell whether your job needs a SWMS.

The 18 high risk construction work activities (model WHS Regulation 291)

1. Work that involves a risk of a person falling more than 2 metres. A roofer on a two-storey re-sheet, a carpenter framing a first-floor wall, or a painter on scaffold at first-floor eaves.
2. Work on a telecommunication tower. A rigger installing antennas or a technician maintaining equipment on a mobile phone tower.
3. Demolition of an element of a structure that is load-bearing or otherwise related to the physical integrity of the structure. A builder removing a load-bearing wall in a renovation to open up a kitchen.
4. Work that is likely to involve disturbing asbestos. A tiler lifting old vinyl and backing in a pre-1990 bathroom, or an electrician drilling through an old fibre-cement eave.
5. Work that involves structural alterations or repairs that require temporary support to prevent collapse. Propping a floor while a bearer is replaced, or installing a beam under acrow props.
6. Work that is carried out in or near a confined space. A plumber entering a grease arrestor pit or a tradesperson working in a water tank.
7. Work that is carried out in or near a shaft or trench with an excavated depth greater than 1.5 metres, or a tunnel. A drainer laying a sewer connection in a 2 m trench, or work in a service tunnel.
8. Work that involves the use of explosives. Rock breaking with explosives on a civil site, or powder-actuated work where explosives are involved.
9. Work that is carried out on or near pressurised gas distribution mains or piping. A gasfitter connecting to a live gas main, or an excavator operator digging beside one.
10. Work that is carried out on or near chemical, fuel or refrigerant lines. A refrigeration mechanic working on refrigerant pipework, or welding near a fuel line at a depot.
11. Work that is carried out on or near energised electrical installations or services. An electrician testing a live switchboard, or a crew working close to overhead power lines.
12. Work that is carried out in an area that may have a contaminated or flammable atmosphere. Hot works in a fuel storage area, or painting with solvents in a poorly ventilated plant room.
13. Work that involves tilting, jacking or placing tilt-up or precast concrete elements. Standing up tilt panels for a warehouse, or placing precast stair flights.
14. Work that is carried out on, in or adjacent to a road, railway, shipping lane or other traffic corridor that is in use by traffic other than pedestrians. Roadside driveway works, kerb and channel replacement, or work beside an active rail line.
15. Work that is carried out in an area at a workplace in which there is any movement of powered mobile plant. A tiler on a commercial site where forklifts and telehandlers move, or a concreter working around reversing agitator trucks.
16. Work that is carried out in an area in which there are artificial extremes of temperature. Installing shelving or services in cool rooms and freezers, or work near industrial furnaces.
17. Work that is carried out in or near water or other liquid that involves a risk of drowning. Jetty or marina work, seawall repairs, or work beside a deep open tank.
18. Work that involves diving work. Underwater inspection or construction on a marine structure.

Victoria's OHS Regulations 2017 (reg 322) list 19 categories: tunnels are a separate item and the traffic category covers roadways and railways. See SWMS requirements by state.

High risk construction work by state

The model WHS Regulations provide the national model, but the applicable law is your state or territory's legislation. See our guide to SWMS requirements by state for more detail.

High risk construction work QLD (SWMS Queensland)

Law and regulator. Queensland uses the Work Health and Safety Act 2011 (Qld) and the Work Health and Safety Regulation 2011 (Qld). The regulator is Workplace Health and Safety Queensland, which publishes its guidance on worksafe.qld.gov.au (the "WorkSafe" site most Queenslanders search for). Section 291 lists the same 18 HRCW activities as the model regulations, including a risk of a person falling more than 2 metres, a shaft or trench deeper than 1.5 m, disturbing asbestos, tilt-up or precast concrete, work near traffic corridors and work near powered mobile plant.

What a Queensland SWMS must do (s299). It must:

• identify the high risk construction work;
• state the hazards and risks;
• describe the control measures;
• describe how the controls will be implemented, monitored and reviewed;
• take into account the workplace circumstances and, on a construction project, the principal contractor's WHS management plan; and
• be readily accessible and understandable to the people using it.

If a SWMS for work with a risk of falling more than 2 m relies only on administrative controls or PPE, it must describe all the control measures that were considered (s299(4)).

Details WorkSafe Queensland says to include. The PCBU's name, address and ABN (if any); the person or people responsible for implementing, monitoring and compliance; and, on a construction project, the principal contractor's name, the work address, the date the SWMS was prepared and given to the principal contractor, and any review date.

Your duties.

• Prepare the SWMS (or use one already prepared by another person) before the work starts.
• Give a copy to the principal contractor before work starts. The principal contractor must not let the HRCW start until it has one.
• Make sure the work follows the SWMS. If it doesn't, stop the work immediately, or as soon as it's safe, and only resume in line with the SWMS.
• Review and revise the SWMS when needed.
• Keep a copy until the work is finished, or for at least 2 years after a notifiable incident (s303), readily accessible to the workers doing the work and available for inspection. WorkSafe Queensland suggests keeping all revised versions.

Don't mix up the two Queensland falls numbers. The HRCW (SWMS) trigger is a fall of more than 2 m on any construction work. Separately, Queensland's construction falls provisions (ss306B–306H) set when specific fall controls such as edge protection are required, with different thresholds for housing construction work (3 m) and for other construction work or steeper roofs (2 m, or roofs over 26 degrees). The 3 m housing number does not change when a SWMS is needed.

WorkSafe Queensland has an interactive SWMS tool and guidance: see its safe work method statements guide.

Build a Queensland SWMS in the SWMS generator with QLD selected. Drafting is free with a free account; PDF download is on the $20/month or $200/year plan. For other states, see SWMS requirements by state.

NSW

New South Wales uses the Work Health and Safety Regulation 2025, with the 18 HRCW categories and the requirement to prepare a SWMS before that work starts. Check SafeWork NSW for official guidance.

Victoria

Victoria uses a different law: the Occupational Health and Safety Regulations 2017, Part 5.1. Regulation 322 lists 19 categories of high risk construction work, and the required document is also called a SWMS. See WorkSafe Victoria's SWMS guidance.

WA

Western Australia's Work Health and Safety (General) Regulations 2022 apply the 18 HRCW categories for general industry. Check WorkSafe WA for official guidance.

Hit any of the above? You need a SWMS.

Even one is enough. The SWMS must be prepared before the high-risk work starts, the work must be done in line with it, and it must be kept and available for inspection until that work is finished. It must also be reviewed when the work changes or a control isn't working.

A common mistake: assuming "low-rise" or "domestic" jobs are exempt. They're not. HRCW applies regardless of project size.

One job, several categories

Most real jobs hit more than one category. A residential reno that includes removing a load-bearing wall and working from a ladder with a fall of more than 2 m is two categories. A roof re-sheet on a two-storey house can involve falls, a crane truck delivering sheets, and an overhead service line. One SWMS can cover more than one HRCW activity on the same job, as long as it names each category and sets out the controls for each.

See how that looks in practice in our filled SWMS example for a metal roof re-sheet, and check the content rules in what a SWMS must include.

High risk construction work vs high risk work licences

These two get mixed up all the time, and they are about different things. High risk construction work is about the activity: the categories in regulation 291 of the model WHS Regulations, which trigger the need for a SWMS before the work starts. High risk work (HRW) is about the person: under Part 4.5 and Schedule 3 of the model WHS Regulations, certain plant and work can only be operated or carried out by someone who holds a high risk work licence issued by the state or territory regulator.

Common construction examples of work that needs a high risk work licence:

• Scaffolding work — basic, intermediate and advanced — where a person or object could fall more than 4 metres.
• Dogging and rigging (basic, intermediate and advanced).
• Crane and hoist operation, such as vehicle loading cranes, slewing and non-slewing mobile cranes, tower cranes, and materials and personnel hoists.
• Boom-type elevating work platforms with a boom length of 11 metres or more.
• Concrete placing booms.
• Forklift and order-picking forklift operation.
• Pressure equipment, such as boilers.

One job can need both. A crane lift of roof trusses on a two-storey house is high risk construction work — there is a risk of falling more than 2 metres and powered mobile plant moving in the area — so a SWMS must be prepared before it starts. At the same time, the crane operator and the dogger must hold the right high risk work licences. Record in the SWMS that licensed operators will be used, but remember: a licence never replaces the SWMS, and a SWMS is not a licence.

In Victoria, licences sit under the Occupational Health and Safety Regulations 2017 and are issued by WorkSafe Victoria; other states and territories issue them under their version of the WHS Regulations. See SWMS requirements by state for how the rules differ, and use the AI SWMS generator to draft a SWMS that covers the high risk construction work and notes your licensed plant and operators. Drafting is free with a free account; PDF download is on the $20/month or $200/year plan.

What to do next

• Identify which HRCW categories apply to your job.
• Prepare a SWMS that lists each step, the hazards, the controls, and how the controls will be implemented, monitored and reviewed.
• Consult your workers and have them sign on.
• Keep it on site. Review whenever conditions change.

If the task is not on this list, a JSA may be the right document. It is still not a substitute when HRCW applies. The fastest way to draft a SWMS: use our AI SWMS generator. Tell it the trade, the task and the state, then review and edit the draft for your site before use.

For the difference between the two documents, read SWMS vs JSA.

Frequently asked questions