Working at Heights SWMS for Painting Work
When fall risk over 2 metres turns a painting job into high-risk construction work, and what belongs in the SWMS.
A working at heights SWMS is required when painting work carries a risk of a person falling more than 2 metres. That is common on exterior, eaves and multi-storey jobs. Prepare the SWMS before work starts, with site-specific hazards and controls, not generic boilerplate.
General information for Australian painting businesses, not legal, financial, tax or safety advice. Rules change and vary by state or territory. Confirm anything you rely on with the relevant regulator (Safe Work Australia and your state or territory WHS regulator) before acting.
When heights work needs a SWMS
Under the model WHS Regulations, construction work with a risk of a person falling more than 2 metres is high-risk construction work. When that applies, the business doing the work must have a SWMS in place before starting. Victoria has not adopted the model WHS laws in the same way; check WorkSafe Victoria if that is your jurisdiction.
Source: Safe Work Australia — HRCWPainter-specific height scenarios
- Two-storey eaves, fascias and barge boards
- Exterior walls from scaffold or elevated work platforms
- Stair voids and void-edge cutting-in
- Roof-edge or high-ceiling commercial interiors
If the only access creates a fall risk over 2 metres, write the SWMS for that access method and the people below, not a generic “painting” paragraph.
Controls that belong in the SWMS
| Hazard | Typical controls (job-dependent) |
|---|---|
| Fall from ladder / scaffold / roof edge | Prefer scaffold or EWP; secure ladders; edge protection; exclusion zone below |
| Falling tools or materials | Tool lanyards; toe boards; keep floor clear under work |
| Uneven or soft ground under access equipment | Check ground; sole boards; do not use damaged gear |
| Overhead or nearby electrical services | Identify services before setup; maintain safe approach distances |
| Weather (wind, wet surfaces) | Stop work when conditions make height work unsafe |
Controls must fit the hierarchy: eliminate or substitute first, then engineering, then administrative controls, then PPE. A harness alone is not a complete heights plan.
How to fill it in
- Confirm the height trigger. If there is a risk of a person falling more than 2 metres, treat the work as high-risk construction work and prepare a SWMS before starting.
- List the real site hazards. Access method, ground conditions, people below, electrical services, weather and the surfaces you will paint.
- Choose controls in hierarchy order. Eliminate or substitute where you can, then engineering (scaffold/EWP), then admin, then PPE. Do not jump straight to a harness as the only control.
- Brief the crew and keep the SWMS available. Everyone on the high-risk work must understand the controls. Keep the SWMS available until the work finishes.
Full painting SWMS guide
Heights is one trigger among several for painters. See the painting SWMS guide → For a filled-in layout, read the SWMS example →
Frequently asked questions
What height triggers a SWMS in Australia?
A risk of a person falling more than 2 metres is high-risk construction work under the model WHS Regulations. When that risk is present on a painting job, a SWMS is required before work starts. Victoria uses its own OHS framework; confirm the local rule if you work there.
Do ladder jobs need a SWMS?
If using the ladder creates a risk of falling more than 2 metres, yes. Many exterior and two-storey painting tasks hit that threshold. Ground-level interior work on a short step stool usually does not.
Who prepares a working-at-heights SWMS on a painting site?
The business carrying out the high-risk construction work (the PCBU doing that work) must ensure a SWMS is prepared before the work starts. On multi-contractor sites, coordinate so responsibilities are clear.
Is a SWMS the same as a working-at-heights permit?
No. A SWMS is the WHS document for high-risk construction work. Some sites also require a separate permit-to-work system. Follow both when the client or principal contractor requires a permit.