Do I need a SWMS? The 18 high-risk activities explained
Australian WHS Regulations mandate a SWMS for 18 specific categories of construction work. Here's the full list in plain English, so you can tell in 60 seconds whether your job needs one.
Nobody wants to produce paperwork they don't legally need. Nobody wants to arrive at a principal-contractor site without the paperwork they do need. This guide cuts through: here are the 18 categories of high-risk construction work that require a Safe Work Method Statement under Australian WHS Regulations, in plain English, with real-world examples.
Short version: if your work is on this list, you need a SWMS before work starts. If it's not on this list, a SWMS isn't legally required, but a principal contractor may still require one, and a good risk assessment is still best practice.
The legal source
The 18 categories are defined in Schedule 3 (or the equivalent clause) of each Australian state's WHS Regulation. In New South Wales, the current reference is clause 312 of the WHS Regulation 2025 (NSW). The categories are harmonised across jurisdictions. What applies in Queensland also applies in Victoria and WA, with minor wording differences.
A SWMS is required whenever the work involves one or more of these categories. It doesn't matter if the work is a single task inside a larger job; the SWMS covers that specific high-risk task.
The 18 categories
1. Work at heights where a person could fall more than 2 metres
Any elevated work platform, scaffold, roof, ladder work where a fall from above 2 metres is possible. Includes work on frames, formwork, and suspended structures.
Examples: roof tiling, solar panel installation, guttering, scaffold erection, working from an EWP, window cleaning above ground floor.
2. Telecommunication tower work
Any work on a telecommunication tower. This is a dedicated category separate from general working at heights because of the specific hazards (RF exposure, confined climbing space).
3. Demolition of load-bearing structural elements
Demolishing any element that supports the load of a structure : columns, beams, load-bearing walls, slabs. Non-load-bearing partition demolition is not automatically in this category.
4. Disturbance or removal of asbestos
Any work that disturbs asbestos-containing material, including removal, encapsulation, or work adjacent to ACM where it could be disturbed. Licensed asbestos removal work is mandatory for friable asbestos and more than 10m² of non-friable ACM.
5. Alteration to a structure that may affect physical integrity
Structural alterations where the alteration itself could cause the structure to collapse or become unstable. Load path modifications, temporary propping during renovation, etc.
6. Confined space work
Any work in an enclosed or partially enclosed space not designed for continuous occupancy, with limited means of entry/exit, and potential for dangerous atmosphere or engulfment. Tanks, pits, pipes, silos, ducts.
7. Work in or near a shaft or trench deeper than 1.5 metres
Excavation work where the trench or shaft exceeds 1.5 metres deep. Shoring, benching or battering requirements apply; SWMS must address collapse risk and access/egress.
8. Work involving tilt-up or precast concrete
Any use of tilt-up panels or precast concrete elements, including lifting, bracing, positioning and connecting. This covers the high-risk moment when a panel is suspended or temporarily braced.
9. Work on, in, or adjacent to a road, railway, shipping lane or traffic corridor
Roadworks, rail corridor work, and any construction adjacent to live traffic. Traffic management plans are typically required alongside the SWMS.
10. Work on or near energised mobile plant
Work in proximity to plant that is operating or could be operated unexpectedly: forklifts, cranes, excavators, mobile elevating work platforms. Exclusion zones, spotters, and separation of workers from plant paths apply.
11. Work involving tilt-up or precast concrete erection (structural)
Dedicated category for the structural erection phase of tilt-up and precast systems. Covers the sequence of panel lift, brace and connect.
12. Work in areas with artificial extremes of temperature
Work in cold-storage facilities, commercial freezers, foundries, boiler rooms, or any environment where artificial temperature extremes create health risk.
13. Work in or near water where drowning is a risk
Bridge work, dam work, pier construction, marine work, and any trench or pit that could contain water. PFDs, rescue plans and edge protection apply.
14. Diving work
Commercial diving as part of construction work. Compressed-air diving, surface-supplied diving, and SCUBA work for construction purposes all fall under this category with additional AS/NZS 2299 requirements.
15. Work on or near a chemical, fuel or refrigerant line
Any work on or near live piping carrying hazardous chemicals, fuel, or refrigerants. Includes disconnection, tapping, isolation and work in proximity.
16. Work on or near energised electrical installations
Live electrical work. Testing, fault-finding, and commissioning on energised installations. De-energised work does not automatically trigger this category but is good practice to include.
17. Work in areas with explosive or flammable atmospheres
Hazardous-area work (Zone 0, 1, 2 classifications), petrochemical sites, grain silos, painting with flammable solvents. AS/NZS 60079 compliance for equipment used in these areas.
18. Work involving powered mobile plant
The use of powered mobile plant as part of construction work , including forklifts, skid-steers, excavators, rollers, and so on. Operator licensing and exclusion zones apply.
What if I'm not sure?
If the work is borderline, produce a SWMS. The cost of the paperwork is trivial compared to the cost of:
- Being turned away from a principal-contractor site
- An improvement or prohibition notice from the regulator
- An infringement notice under WHS Regulations
- A prosecution if something goes wrong and there was no SWMS
RAE IQ's guided intake automatically flags which of the 18 categories apply based on your description of the work. If the description matches one or more categories, the system produces a SWMS with those categories identified and the correct controls structured. If none apply, it will still produce a risk assessment (JSA/SWP format) that meets best practice.
State-specific additions
A few jurisdictions add local extensions:
- Queensland: the Construction Work Code of Practice adds procedural requirements on top of the 18 categories.
- Victoria: OHS Regulations use slightly different category wording but align with the national harmonised set.
- Western Australia: harmonised to the model from the 2022 reform; the 18 categories apply directly.
- New South Wales: from 1 July 2026, the s26A change makes approved Codes of Practice enforceable duties, which tightens the requirement to follow (or justify departure from) the Construction Work Code.
The fast path
If you're here because a principal contractor has asked for a SWMS and you don't have one ready, start free and generate a compliant SWMS in under 60 seconds. The generator classifies the high-risk categories for you, cites the right legislation for your state, and produces a signature-ready PDF with worker sign-on and supervisor sign-off built in.