Working at Heights Risk Assessment for Australian Workplaces

A working at heights risk assessment is a structured evaluation of the hazards and risks associated with work performed at an elevation where a fall could result in injury — broadly, any work above ground level where uncontrolled descent is possible. It identifies the specific fall hazards present, evaluates the likelihood and consequence of a fall, and determines the controls necessary to eliminate or minimise the risk of falling to workers and others in the vicinity.

Falls from heights are the leading cause of workplace fatalities in Australian construction and the second most common cause across all industries. According to Safe Work Australia data, falls from heights account for approximately 12–15% of all worker fatalities annually, and the fatality rate for construction falls is substantially higher than the average across all industries. Non-fatal fall injuries — fractures, spinal injuries, traumatic brain injuries — cause permanent disability in a significant proportion of cases and are among the most costly workers' compensation claims.

The definition of 'working at heights' for regulatory purposes in Australia is broader than many workplaces appreciate. The WHS Regulation 2025 imposes specific requirements for falls risk management when there is a risk of a person falling more than 2 metres. For construction work, the threshold for 'high-risk construction work' requiring a SWMS is a fall risk of more than 3 metres. However, the obligation to assess and control fall risks applies to any height — a fall from a standing platform, a ladder, or a structure at any height that could cause injury. A fall from 1 metre onto a hard surface can cause serious injury; a fall from 3 metres is commonly fatal.

The working at heights risk assessment is required before any elevated work commences, and the controls identified in the assessment must be in place before workers access the elevated work area. Unlike a generic risk assessment, a falls risk assessment must specifically evaluate the fall arrest and fall restraint systems to be used, the inspection and maintenance status of those systems, and the rescue procedure in the event of a fall.

The legal framework governing working at heights in Australian workplaces combines general WHS obligations with specific regulatory requirements for falls prevention, high-risk construction work, and fall-related plant.

**WHS Regulation 2025 — Managing falls risk.** The Regulation requires PCBUs to eliminate the risk of falls where reasonably practicable. Where elimination is not reasonably practicable, the PCBU must minimise the risk by providing a fall prevention device (physical barrier that prevents a fall — guardrails, edge protection, covers over openings); a work positioning system (keeping the worker in a position where a fall cannot occur — work platforms, scaffolding); a fall-arrest system (arresting a fall that has occurred — personal fall-arrest systems including full-body harnesses and energy-absorbing lanyards); and as a last resort, administrative controls (restricted access, spotter, work practice procedures).

**SWMS for high-risk construction work.** Under the WHS Regulation, a Safe Work Method Statement (SWMS) is mandatory for any construction work where there is a risk of a person falling more than 3 metres. This includes work on roofs, scaffolding, elevated platforms, and any other work location at height. The SWMS must be prepared before the work commences, reviewed and signed by each worker performing the work, and retained for five years after the work is completed.

**High-risk work licences.** Scaffolding work requires a high-risk work licence in the relevant scaffolding category under the WHS Regulation. Basic scaffolding licence covers most general construction scaffolding. Intermediate and advanced licences cover more complex scaffolding configurations. The risk assessment must verify that all scaffolders hold the appropriate licence category for the scaffold being erected or dismantled.

**AS/NZS 1891 — Industrial fall-arrest systems:** The applicable standard for personal fall-arrest systems used at Australian workplaces is the AS/NZS 1891 series. The series covers full-body harnesses, energy-absorbing lanyards, self-retracting lifelines, rope access systems, and anchor devices. The risk assessment must confirm that all personal fall-arrest equipment complies with AS/NZS 1891 and has been inspected by a competent person before use.

**AS 1576 — Scaffolding.** AS 1576 specifies the requirements for the design, construction, maintenance, inspection, and dismantling of scaffolding. The risk assessment for any scaffolding work must reference AS 1576 and confirm that the scaffold design, materials, and erection comply with the standard.

A comprehensive working at heights risk assessment must identify and evaluate all relevant fall hazard categories. The principal categories are as follows.

**Falls from edges and openings.** Unprotected edges — of roofs, elevated platforms, mezzanine floors, loading docks, excavations, and open floor openings — are the most common sources of fatal construction falls. The assessment must identify every unprotected edge in the elevated work area, the height of the potential fall, and the nature of the surface below (hard, with projections, with water, other workers below). Temporary and permanent edge protection measures must be specified.

**Falls from ladders.** Ladder falls account for a significant proportion of fall injuries in maintenance and trade work. The assessment must evaluate the type of ladder to be used, the specific hazards of ladder use for this task (reaching, working with both hands, carrying materials), and whether a safer alternative work platform is available and practicable.

**Falls from scaffolding.** Scaffolding failures — planks moving or tipping, improperly secured scaffold boards, scaffold structure instability — cause fall injuries and falls from height. The assessment must verify the scaffold design, erection, and inspection records and confirm that the scaffold is fit for the purpose and load for which it will be used.

**Falls through fragile surfaces.** Falls through skylights, roof sheets, ceiling tiles, and other fragile surfaces are responsible for a disproportionate number of serious fall injuries because they occur without warning and without the opportunity for a worker to grab a support. The assessment must identify all fragile surfaces in or near the work area and specify the controls — walkways, rated protection covers, and exclusion zones — for each.

**Falling objects.** Work at heights creates the risk of falling objects — tools, materials, and debris — falling onto workers at lower levels. The assessment must evaluate the risk of falling objects and specify controls including tool lanyards, exclusion zones below elevated work areas, toe boards on scaffolding, and material storage at height.

**Environmental conditions.** Wind, wet surfaces, and reduced lighting significantly increase fall risk. The assessment must specify the conditions under which elevated work must be suspended — typically sustained winds above 40 km/h for scaffolding, or when lightning is within 10 km for tower crane or antenna work — and the procedure for securing the work area when work is suspended.

The WHS Regulation establishes a specific hierarchy of controls for falls risk that differs from the general hierarchy in that it prioritises collective protection (measures that protect all workers without individual action) over personal protection (measures that require individual workers to act correctly every time).

**Level 1 — Eliminate the fall risk.** Work at height should be eliminated wherever reasonably practicable. Can the task be performed at ground level and the finished component lifted into position? Can prefabrication or pre-assembly at ground level reduce the time required at height? Can robotic or remote systems perform the elevated task without human entry? Elimination is the safest and most effective control, and the risk assessment must demonstrate that it was considered before proceeding to lower-order controls.

**Level 2 — Fall prevention devices.** If the fall risk cannot be eliminated, the first control priority is a fall prevention device — a physical barrier that prevents a person from reaching the fall hazard. This includes: permanent handrails and guardrails on elevated platforms and walkways; temporary edge protection systems on roofs and elevated slabs; covers over floor penetrations; and barricades around excavations. Fall prevention devices protect all workers in the area without requiring any action by the individual worker.

**Level 3 — Work positioning systems.** A work positioning system keeps the worker in a position where a fall cannot occur. This includes elevated work platforms (scissor lifts, boom lifts, elevated work platforms), scaffolding, and work restraint systems (where a lanyard is short enough that the worker physically cannot reach the fall edge). Work positioning systems are highly effective when the platform or scaffold is designed, erected, and maintained correctly.

**Level 4 — Fall-arrest systems.** A fall-arrest system does not prevent a fall from occurring — it arrests the fall after it has occurred, preventing the worker from hitting the ground. A personal fall-arrest system consists of a full-body harness, a connecting lanyard (energy-absorbing or self-retracting), and an anchor point. The system must be designed to arrest the fall within a total fall distance — including the lanyard length, energy absorber deployment, and harness stretch — that does not allow the worker to contact the next lower level or any projection.

**Fall-arrest system requirements under AS/NZS 1891:** The anchor point must be designed and certified to resist the arrest load — a minimum of 15 kN for a single anchor. The full-body harness must fit the worker correctly, be inspected before each use, and be replaced after any significant loading event. Self-retracting lifelines are preferred over energy-absorbing lanyards where the work area allows, as they minimise fall distance.

**Level 5 — Administrative controls.** Restricting access to elevated areas (exclusion zones, access permits), safety observers, and safe work procedures are administrative controls that rely on individual behaviour and therefore provide less reliable protection than engineering controls. They are appropriate as supplements to higher-order controls, not as primary fall protection.

A working at heights risk assessment is incomplete without a rescue plan. In the event of a fall arrest — where a worker's harness has arrested their fall and they are suspended — the worker is in immediate danger of suspension trauma (positional asphyxia), which can cause death within 10–15 minutes if the worker cannot be retrieved. The rescue plan must be prepared before work commences and the means to execute it must be in place before any worker is at height.

**Suspension trauma.** Suspension trauma occurs when a conscious or unconscious person hangs passively in a harness with their legs dangling, restricting blood return from the lower limbs and causing progressive shock and cardiac arrest. The risk increases significantly after a fall arrest if the worker is unconscious or unable to move their legs. This physiological hazard means that rescue from a fall-arrest situation is a time-critical emergency, not a routine recovery.

**Rescue methods.** The rescue plan must specify the method for retrieving a suspended worker — the equipment available, the person responsible for rescue, and the step-by-step procedure. For elevated work platforms, the platform can often be used for retrieval. For rope access and roof work, a specific retrieval procedure using the fall-arrest anchor and a purpose-built retrieval system (recovery strap, rescue kit, or rope access technique) must be planned and practised.

**Emergency services notification.** The rescue plan must specify at what point emergency services (ambulance, fire and rescue) will be contacted and the information to be communicated. For work at heights on construction sites, the principal contractor's emergency management plan should integrate the falls rescue plan.

**Rescue drills.** The rescue plan must be tested at appropriate intervals to verify that the equipment works, that the designated rescue person is competent, and that the retrieval time is within the physiological safety window. A rescue plan that has never been practised provides substantially less assurance of effectiveness than one that has been tested on the specific structure.

A working at heights risk assessment must go beyond a generic hazard checklist and address the specific technical requirements of fall protection systems, equipment inspection, rescue planning, and the applicable Australian standards.

**Site and task description:** The elevated work area (roof, scaffold, elevated platform, ladder), the height of the work, the nature of the surface below, and the specific tasks to be performed.

**Fall hazard identification table:** A systematic identification of all fall hazards in the work area — edges, openings, fragile surfaces, ladder use — with the height of each hazard and the consequence of an uncontrolled fall.

**Control selection in hierarchy order:** Documentation of the evaluation of each level of the hierarchy — from elimination through to administrative controls — with justification for the level selected and the specific control to be implemented.

**Fall-arrest system specification:** Where a personal fall-arrest system is to be used, the document must specify the harness make and model, the lanyard type and length, the anchor point location and capacity, and the total fall clearance distance calculation to confirm the system will arrest the fall before the worker contacts the lower level.

**Equipment inspection record:** Confirmation that all fall protection equipment — harnesses, lanyards, anchor devices — has been inspected by a competent person before the work commences and is within its service life and in serviceable condition.

**Rescue plan summary:** The rescue method, the rescue equipment at the work site, the designated rescue person, and the emergency contact procedure.

**SWMS cross-reference:** Where the work is high-risk construction work requiring a SWMS, a cross-reference to the relevant SWMS section.

Our CIH-reviewed working at heights risk assessment is priced at $49 AUD for the standard document, delivered as a fully editable Microsoft Word file with the sections above and an editable fall clearance calculation worksheet.

**At what height is a risk assessment required for working at heights?** The WHS Act requires risks to be managed for any work where a person could fall and be injured — which includes falls from any height. The WHS Regulation imposes specific requirements for falls risks above 2 metres (general workplaces) and above 3 metres (high-risk construction work requiring a SWMS). However, a fall from even 0.5–1 metres onto a hard surface can cause serious injury, particularly to older workers or those with pre-existing health conditions, so fall hazards at any height warrant at least a basic assessment.

**Do I need a SWMS for roof work?** Yes, if the work is construction work with a risk of falling more than 3 metres. Roof work on residential and commercial buildings typically involves this risk and therefore requires a SWMS under the WHS Regulation. The SWMS must be prepared before work commences, signed by each worker performing the work, and kept for five years.

**Can I use a harness and lanyard instead of edge protection?** Only if it is not reasonably practicable to install edge protection. The hierarchy of controls requires fall prevention devices (edge protection) to be implemented before fall-arrest systems (harnesses). A harness and lanyard is a fall-arrest system — it arrests a fall after it has occurred; it does not prevent the fall. If edge protection cannot be installed, a fall-arrest system is required, but the risk assessment must justify why edge protection was not reasonably practicable.

**How long should a working at heights risk assessment take?** For a simple task — for example, gutter cleaning on a single-storey residential building — a competent person may complete an adequate assessment in 30–60 minutes. For a complex task — roof installation on a multi-storey commercial building, scaffolding erection on a complex facade, or elevated work in a confined or congested area — the assessment may take several hours. The depth of the assessment should be proportionate to the complexity of the hazard and the consequence of a fall.

**Is there a maximum wind speed for working at heights?** AS 1576 specifies maximum wind speed conditions for scaffolding — scaffolding operations must generally be suspended when sustained winds exceed 40 km/h. For work on elevated platforms (scissor lifts, boom lifts), the manufacturer specifies maximum operating wind speeds and these must be observed. For roof work and rope access, the risk assessment must specify the wind conditions under which work will be suspended, based on the stability of the equipment and the safety of the workers.