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If you work in construction, you've probably heard the term "high risk construction work" thrown around on site, in tender documents, or by a principal contractor asking "where's your SWMS?" But what actually counts as high risk, and when does the law say you need a Safe Work Method Statement in place before you pick up a tool?
The good news is the answer isn't a matter of opinion. Under Australia's WHS Regulations, there are exactly 18 defined categories of high risk construction work (HRCW). If your job falls into one (or more) of these categories, a SWMS is a legal requirement, not an optional extra. If it doesn't, you're not legally obligated to prepare one, although a principal contractor or client may still ask for your SWMS before you start work anyway.
This article walks through all 18 activities in plain English, explains what triggers each one, and clears up some of the confusion around when a SWMS is actually needed.
HRCW is a legal category set out in the model WHS Regulations, most commonly referenced as Regulation 291 (Victoria uses its own equivalent under the Occupational Health and Safety Regulations 2017). The categories were chosen because they cover activities with a genuinely high potential for serious injury or death — falls, collapses, explosions, electrocution, and similar hazards.
Where a job involves HRCW, the person conducting a business or undertaking (PCBU) responsible for that work must prepare a SWMS before work begins. The SWMS needs to identify the hazards, describe the risks, and set out the control measures that will be used to manage them. It's a working document too — it must be followed on site, and reviewed and revised if the work or the risks change.
One thing worth clearing up: you don't need a separate SWMS for every single HRCW activity on a job. If your work involves several categories at once — say, working at height while also using powered mobile plant near a public road — one comprehensive SWMS covering all relevant risks is generally the better approach.
Here's the full list, as defined under the model WHS Regulations.
1. Risk of a person falling more than 2 metres This is the one that catches almost every residential build. Roof work, scaffolding, working near unprotected edges, ladder work above the threshold — all of it. Note that fall thresholds can vary slightly between states, so it's worth checking your local regulator's current position.
2. Work on a telecommunication tower Any work carried out on a telecommunication tower, due to the height and structural risks involved.
3. Demolition of load-bearing structural elements Demolishing any part of a structure that's load-bearing, or otherwise critical to the structure's physical integrity, carries a real risk of unplanned collapse.
4. Disturbance of asbestos Any work that involves, or is likely to involve, disturbing asbestos. This applies broadly — not just formal asbestos removal work, but any activity where asbestos-containing material might be disturbed, such as drilling, cutting, or demolition in older buildings.
5. Structural alterations or repairs requiring temporary support Work that involves structural changes needing temporary propping or bracing to prevent collapse while the work is underway.
6. Work in or near a confined space Confined spaces present multiple hazards at once — poor ventilation, restricted entry and exit, and the potential for hazardous atmospheres.
7. Excavation, shafts, trenches, or tunnels Work carried out in or near a shaft or trench with an excavated depth greater than 1.5 metres, or in a tunnel. Trench collapse is one of the more common and preventable causes of serious injury in construction.
8. Use of explosives Any use of explosives on a construction site, which brings its own set of licensing and control requirements beyond the SWMS itself.
9. Work on or near pressurised gas mains or piping Work near pressurised gas distribution infrastructure, where a strike or leak could have serious consequences.
10. Work on or near chemical, fuel, or refrigerant lines Similar logic to the gas mains category — a strike or failure of these lines can create fire, explosion, or toxic exposure risks.
11. Work on or near energised electrical installations or services This includes work near live electrical infrastructure, whether that's an installation, a service line, or in-wall wiring that hasn't been isolated. Electrical work of this kind carries an obvious and serious risk of electrocution and arc flash.
12. Work in an area with a contaminated or flammable atmosphere Where the work area may contain contaminated air or a flammable atmosphere, such as near old fuel storage, landfill sites, or certain industrial areas.
13. Tilt-up or precast concrete work Handling, lifting, or installing tilt-up panels or precast concrete elements, where uncontrolled movement or a lifting failure can be catastrophic.
14. Work on, in, or adjacent to a road, railway, shipping lane, or traffic corridor Any work carried out where traffic other than pedestrians is present — think roadworks, rail corridor work, or building sites adjacent to active roads.
15. Areas with movement of powered mobile plant Any work carried out in an area where powered mobile plant (excavators, forklifts, cranes, etc.) is moving. This is one of the most common HRCW triggers on active construction sites, given how much plant is typically in motion.
16. Areas with artificial extremes of temperature Work carried out in artificially created extreme heat or cold, such as cold storage construction or work near industrial heat sources.
17. Work in or near water with a drowning risk Any work carried out in or near water, or another liquid, that involves a genuine risk of drowning.
18. Diving work Any construction-related diving work, given the specialised hazards involved in underwater work.
A common question we get is whether each HRCW activity needs its own document. The short answer: no, not necessarily. One SWMS can cover multiple HRCW activities if the work is closely related — for example, a job involving working at height, using powered mobile plant, and working next to an active road can often be captured in a single, well-structured SWMS. Alternatively, you can prepare separate SWMS for each activity if that suits your business better. What matters is that every relevant hazard is properly identified and controlled, and that the document is genuinely usable by the workers doing the job.
Every SWMS template we produce includes a built-in HRCW table, listing all 18 categories so you can see at a glance which ones apply to the job.
Some activities are a given for that type of work — a roofing SWMS will always involve a fall risk above 2 metres, for example — so those boxes come pre-ticked for you. Others depend on the specific site or the day's conditions — powered mobile plant might be on site for one job and not the next, or you might be working near an active road on some sites but not others. For those, we leave the box blank so you can tick it on or off depending on what's actually happening on that particular worksite.
This means you're not stuck re-writing the HRCW section from scratch every time, but you're also not stuck with a document that claims risks that don't actually exist on your job. It keeps the SWMS accurate to the work in front of you, which matters both for your crew's safety and if the document is ever reviewed after an incident or during an audit.
If your work involves HRCW and you don't have a SWMS in place, you're in breach of your WHS obligations — regardless of the size or value of the project. A two-storey residential job carries the same SWMS obligation as a major commercial build if HRCW is involved. Regulators can, and do, stop work on sites where a required SWMS isn't in place, and penalties for non-compliance can be significant.
Beyond the legal side, a properly prepared SWMS genuinely protects your workers, and it protects your business if something does go wrong. It's evidence that you identified the risks and took reasonable steps to control them.
A pre-written SWMS template is a great starting point — it saves you the time of building a document from scratch and gives you a compliant structure to work from. But a generic SWMS isn't legally sufficient on its own. It needs to be reviewed and adjusted so it reflects the actual site, the actual hazards present, and the actual controls you'll use. That's the difference between a document that ticks a box and one that actually holds up if it's ever reviewed by an inspector or relied on after an incident.
If you've worked through this list and realised your next job involves one or more of these 18 activities, the next step is making sure you've got a SWMS that's fit for purpose. At Occupational Safety Solutions, we've spent 15 years building practical, plain-language SWMS templates for Australian tradespeople and small construction businesses — covering the full range of HRCW activities, from working at heights to trenching to work near energised electrical services.
Our templates are fully editable in Microsoft Word, so you can tailor them to your specific site and job in minutes, not hours. And if you're not sure which document you need, our team is on hand for free phone and email support — no pressure, no upselling, just help getting the right paperwork sorted so you can get on with the job.
Browse our individual SWMS templates and discounted SWMS Industry Packs, or get in touch if you'd like help figuring out exactly what your next job requires.
This article provides general information about high risk construction work under Australia's model WHS Regulations. Requirements can vary slightly between states and territories, so always check with your relevant work health and safety regulator for jurisdiction-specific detail.