Working at Height

Under Australian Work Health and Safety regulations, 'working at height' is not defined by a specific height measurement. Instead, it is defined as any work where a person could fall a distance that might cause personal injury. This means that work from even modest heights such as step ladders, raised platforms, or working near unprotected edges at any level is considered working at height if a fall could result in injury. The focus is on the potential consequence of a fall rather than the absolute height. Practically, this means that work above ground level, work near edges where persons could fall to a lower level, work above fragile surfaces that could give way, and work from ladders or platforms all constitute working at height regardless of the specific elevation. Safe Work Australia's Code of Practice for Managing the Risk of Falls at Workplaces clarifies that duty holders must identify fall hazards and implement controls following the hierarchy of control. The risk assessment should consider not just the height, but factors including the falling distance, what the person might strike during the fall, the surface they would land on, and the nature of the work being performed. Even falls from less than two metres can result in serious injuries or fatalities depending on these factors, which is why the regulations adopt a consequence-based definition rather than a specific height threshold.

Yes, operating elevated work platforms is classified as high risk work under Australian WHS regulations and requires a current High Risk Work licence. The specific licence class required depends on the type and capacity of the EWP. For boom-type elevated work platforms (including articulating boom lifts, telescopic boom lifts and cherry pickers) over 11 metres platform height, you must hold a WP class licence. For boom-type EWP with platform heights of 11 metres or less, you need a WN class licence. Scissor lifts and vertical lift platforms are also classified as EWP but may fall under different licence requirements or in some cases can be operated without a High Risk Work licence if used only for vertical access within specific parameters. To obtain an EWP licence, you must complete nationally recognised training through a registered training organisation, demonstrate practical competency in operating specific EWP types, and pass both written and practical assessments. Licences are issued by state and territory work health and safety regulators and must be renewed every five years. Even with a licence, operators must be trained in the specific make and model of EWP they are operating, as controls and features vary between manufacturers. Operators must also complete pre-start inspections, conduct site hazard assessments including overhead power line identification and ground stability evaluation, and implement fall protection measures while in the platform. Using unlicensed operators to conduct EWP work can result in significant penalties for both the operator and the business, work stop notices, and invalidated insurance coverage if incidents occur.

When implementing fall arrest systems, comprehensive rescue procedures are mandatory but frequently overlooked. Work health and safety regulations require that where workers use personal fall arrest equipment, you must have documented rescue procedures and immediately available rescue equipment capable of retrieving a suspended worker within minutes. This requirement exists because suspension trauma—a potentially fatal condition caused by blood pooling in the legs when suspended motionless in a harness—can cause unconsciousness within 5-20 minutes and death within 30 minutes, even if the worker was uninjured by the initial fall arrest event. Your rescue plan must document several critical elements: the rescue method appropriate to your specific work location and height (such as self-rescue using descent devices, assisted rescue by ground-based personnel using descent systems, aerial rescue from EWP, or emergency service rescue); rescue equipment immediately accessible to the work area including descent devices, rescue harnesses, additional anchor points, and first aid equipment; personnel trained in rescue procedures who are present while height work occurs and capable of implementing rescue within 5-10 minutes of a fall event; communication systems allowing suspended workers or observers to immediately summon rescue; and emergency procedures including when to activate emergency services and how to manage post-rescue medical care including the risks of rescue syndrome if the suspended worker is returned to horizontal position too rapidly. You must conduct rescue drills to verify procedures can be implemented effectively, and rescue equipment must be inspected before each work period. Many organisations mistakenly believe that calling 000 constitutes adequate rescue planning, but emergency services typically cannot respond within the critical time window, and may lack equipment or trained personnel for technical rope rescue from height. The brutal reality is that a functional fall arrest system that prevents a worker hitting the ground can still result in death if rescue is not implemented within minutes, making rescue planning as important as the fall prevention systems themselves.

Scaffolding inspections and tagging are legally mandated under WHS regulations with specific requirements at different stages of the scaffold's life cycle. All scaffolding must be inspected by a competent person before first use, after any alteration or addition, after any event that could affect structural integrity (such as impact from plant or severe weather), and at intervals not exceeding 30 days if the scaffold remains erected for extended periods. A competent person for scaffold inspection must have appropriate training and experience to identify structural defects, incomplete components, instability hazards, and non-compliance with the scaffold design. Following each inspection, the scaffold must be tagged to indicate its inspection status. The tag system uses colour-coded tags: a red tag means the scaffold is incomplete or unsafe and must not be used; a yellow tag indicates the scaffold is complete for specific trades but restrictions apply that must be clearly stated on the tag; and a green tag confirms the scaffold is complete, inspected, and safe for use. Tags must include the inspection date, the name and signature of the competent person conducting the inspection, the safe working load of the platform, any restrictions on use, and the date when the next inspection is due. Crucially, scaffold tags do not replace the requirement for individual workers to visually inspect scaffolding before use each day, looking for obvious defects, missing components, or damage that may have occurred since formal inspection. Principal contractors are responsible for ensuring inspection and tagging systems are maintained across all scaffolding on site. Scaffold erectors must not permit incomplete scaffolding to be used, and must implement physical barriers or remove access ladders to prevent access to unsafe scaffolds. Working from scaffolding that lacks a current inspection tag or displays a red tag constitutes a serious breach of WHS regulations, exposing both workers and their employers to significant penalties and insurance issues if incidents occur.

Ladders can be used for work at height only in limited circumstances where other methods of access such as scaffolding or elevated work platforms are not reasonably practicable. The Work Health and Safety Act requires applying the hierarchy of control, which means eliminating the need to work at height where possible, or if work at height cannot be eliminated, providing the safest possible access method. Ladders are considered a higher-risk access method than scaffolding, elevated work platforms or permanent stairs, and should only be used for short-duration tasks, tasks that are low-risk, and situations where it is not reasonably practicable to provide safer access methods. Safe Work Australia guidance indicates ladders may be appropriate for brief tasks such as short-duration inspections, access to other work areas where the ladder is only used for access and not as a working platform, tasks where the total time working from the ladder is less than 30 minutes, and situations where the physical work location makes scaffolding or EWP impractical. However, ladders must not be used for tasks requiring both hands for extended periods, tasks requiring workers to carry heavy or bulky materials, work requiring significant force or reaching, or any work extending beyond brief duration. When ladders are used, strict safety requirements apply: ladders must be industrial-grade and in good condition; the ladder must be set up at the correct angle (75 degrees or 1:4 ratio for extension ladders); the ladder must extend at least 900mm above the landing point; the ladder must be secured at the top or bottom to prevent movement; workers must maintain three points of contact while climbing; and for work extending beyond accessing another level, additional fall protection may be required. Step ladders must not be used with workers standing on the top two steps, and workers must not over-reach from ladders. The key principle is that ladders are an access method, not a work platform, and if the work task requires a stable platform or extended duration, scaffolding or EWP must be used instead. Regulators increasingly challenge ladder use during worksite inspections, requiring businesses to justify why safer alternatives were not reasonably practicable.