How to write a SWMS, step by step

This guide follows one real job from start to finish: replacing about 40 cracked concrete roof tiles on a two storey house. The eaves are around 6 m above a concrete driveway, the roof pitch is 25 degrees, and an overhead service line runs to the front of the house. Two roofers and a leading hand will do the work over two days.

The law does not set a SWMS form. It sets what the SWMS must do (r.299). Any template with the right content works.

A SWMS must take account of the circumstances at the workplace (r.299(3)(a)(i)). WorkSafe Victoria recommends bringing the workers, their HSRs and supervisors together at the location if possible. WorkSafe WA lists what to look for: the design of the structure, access and transport, essential services on or near the site, and the safe work methods and plant to be used. On a construction project, also read the principal contractor's WHS management plan, because your SWMS must take it into account (r.299(3)(a)(ii)).

For the roof job, the site walk records: eaves height, roof pitch, tile type and condition, any skylights, where a ladder can be secured, the service line, the driveway below, and the forecast for wind and heat.

Go through the r.291 list and tick every category the job involves. For the roof job, two apply: a risk of a person falling more than 2 m, and work near energised electrical installations or services because of the overhead service line. WorkSafe WA's own completed example ticks the electrical category for overhead lines near scaffolding.

If none of the categories apply, a SWMS is not required, but you still have to manage the risks.

List the tasks in the order they will happen. For the roof job:

• Check the weather, look for power lines and barricade the area below.
• Set up scaffold edge protection and a secured ladder for roof access.
• Check for brittle tiles and skylights from the access point and plan a walking route.
• Walk on the tile laps only, clipped to an anchor where there is no edge protection.
• Lift out broken tiles and lower them down; never throw them off the roof.
• Cut new tiles with a grinder fitted with water or dust extraction.
• Fit new tiles, re-bed and re-point the ridge capping.
• Clear offcuts from the roof and gutters, then take down access equipment last.

For each task, say what could hurt someone and how (r.299(2)(b)). Be specific to this site. WorkSafe Victoria notes that only hazards directly related to the HRCW need to be in the SWMS, although you can add others if it helps, as long as the focus on the HRCW is not lost.

The WHS Regulations set the order you must work through. First eliminate the risk if that is reasonably practicable. If not, minimise it by substitution, isolation or engineering controls. If risk remains, add administrative controls. Then, for whatever risk is left, provide PPE (r.36). For falls there is a specific order: a fall prevention device such as edge protection first, then a work positioning system, then a fall arrest system (r.79(3)).

Applied to the roof job, from most to least effective:

• Eliminate: do any measuring and tile sorting on the ground, not on the roof.
• Isolate and engineer: scaffold edge protection along the full eaves before anyone goes on the roof; ask the network operator to sleeve or isolate the service line; barricade the driveway.
• Engineer: cut tiles with water suppression or on-tool extraction rather than dry.
• Administrative: walk on the tile laps only, cover the skylight, stop work in high wind, rotate tasks in heat.
• PPE: harness and lanyard to a rated ridge anchor where edge protection does not cover the work, P2 respirator while cutting, safety glasses, gloves, sun protection.

If anyone will rely on a harness to stop a fall, you must set up emergency and rescue procedures, test them, and train the workers involved (r.80). Write the rescue plan into the SWMS.

In Queensland, if the only controls for falls over 2 m are administrative controls or PPE, the SWMS must describe all the controls you considered and why (r.299(4)).

Cutting concrete tiles produces crystalline silica dust. If the processing is high risk under Chapter 8A, a silica risk control plan must be prepared before it starts (r.529CB).

A risk rating is not required by the regulations, and WorkSafe Victoria says risk matrices and risk scores are not legally required. Many principal contractors still ask for a before and after rating. If you use one, score likelihood (1 to 5) times consequence (1 to 5) and show the key.

For the roof edge: before controls, a fall is Likely (4) and the consequence Catastrophic (5), a score of 20, Extreme. With full edge protection the likelihood drops to Rare (1), a score of 5, Medium. The consequence does not change, because the drop is still there.

Regulation 299(2)(d) requires this, and it is the part most often missing. Name who sets up each control and how it is checked. For the roof job: the scaffold supplier erects and hands over the edge protection; the leading hand checks it, the anchor and the ladder at every pre-start; the SWMS is reviewed if the scope, crew or weather changes, after any incident, or if a control is not working. Name the person responsible for compliance and the reviewer.

Go through the SWMS with the crew, change anything they spot, and get each worker to sign and date it. On a construction project, give a copy to the principal contractor before the HRCW starts (r.301). Keep it on site where workers can read it until the work is finished, and for 2 years after any notifiable incident (r.303).

Principal contractors and inspectors usually look for these points first.

• The HRCW is identified and matches the tasks.
• Hazards and controls are specific to the site, not copied from another job.
• Fall controls follow the hierarchy, with edge protection or scaffold before harnesses.
• A rescue plan exists wherever fall arrest is used.
• The how, who and when of monitoring and review is written down.
• Workers have signed, and the SWMS is easy to read.