Writing the SWMS is the second question
The first one is whether you need it at all, and it gets asked far more often than it gets answered properly. A safe work method statement is required only for high risk construction work, which is a closed list of nineteen items. For everything else the duty is the ordinary one: eliminate or minimise the risk so far as is reasonably practicable.
What happens without a clear answer is predictable in both directions. Crews write a SWMS for work that never needed one, which costs time and teaches everybody that the document is a formality. And crews skip one for work that did need it, usually because the trigger was not the obvious hazard on the job.
The one that catches most jobs
Work carried out in an area in which there is any movement of powered mobile plant. Read it again, because it is broader than almost anybody assumes. It is not about operating the plant. It is not about working on it. It is not even about your trade going near it. It is being in an area where any of it moves.
On a live site that is most areas on most days, and it means a crew doing something entirely unrelated in a yard where a telehandler is working is inside the definition. This is the commonest reason a job turns out to be high risk construction work when nobody expected it to be, and it is very easy to miss because there is nothing in it about what you are actually doing.
Two demolition limbs, not one
The list covers demolition of an element that is load-bearing, and separately demolition of an element related to the physical integrity of the structure. Those are different tests and the second is wider. An element can carry no load at all and still be integral: bracing, a diaphragm, a good deal of what a drawing labels non-structural.
The pair almost always gets read as one item about load-bearing walls, which is how a job that is squarely inside the second limb ends up with nobody thinking the list applies.
Two figures worth getting right
Two metres for a fall. Not 1.8, not 3. And it is a riskof a person falling more than two metres, so the question is whether it could happen rather than whether anybody is planning to be up there.
One and a half metres for a trench or shaft. This one is worth separating from the shoring question people are usually thinking about when they hear the number. A trench at 1.6 metres is high risk construction work and needs a SWMS, and that is true whatever else does or does not apply to the excavation.
The limbs about what might be true
Several of the nineteen are written about possibility rather than certainty, and each is broader than the reading it usually gets. Asbestos is work that is likely to involve disturbance, which on pre-1990 fabric is the default position rather than an exception. Atmosphere is an area that may have a contaminated or flammable atmosphere, so a clean reading today does not take the job out of it. Confined space and traffic corridors both include near and adjacent to, so standing at the lid of a chamber or working a footway beside a live carriageway are both inside.
What a SWMS actually is
WorkSafe WA puts it in a sentence that is worth quoting because the opposite belief is so common: a SWMS is classed as an administrative control and is used to support higher order controls, and it is not intended to be a procedure.
So it sits near the bottom of the hierarchy of control, below elimination, substitution and engineering. A job with a signed SWMS and no engineering control is a job with a document about a hazard rather than a controlled hazard. That is precisely the failure that good paperwork is best at disguising, and it is why the document being in order is not the same as the work being safe.
It also has to be site specific and available to the people doing the work. A generic SWMS pulled off a shared drive and signed at induction fails on both counts at once: it does not describe this site, and nobody has read it.
Whether the list catches you is not what to do about it
It tells you whether the list catches your job. It does not write the SWMS, which is what our SWMS builder is for, and it does not tell you what controls to use, because that depends on the site and is the part that needs somebody who has seen it. The list here is WorkSafe WA's, so check your own jurisdiction before quoting a category count or a threshold: a counting difference is harmless, and a threshold difference is not.
Common questions
When do I need a safe work method statement?
Only when the work is high risk construction work, which is a closed list. Any one item on it is enough, and the SWMS has to be prepared before the work starts rather than written up afterwards. For every other construction activity a SWMS is not required, though the ordinary duty to eliminate or minimise risk so far as is reasonably practicable still applies in full.
What counts as high risk construction work?
WorkSafe WA lists nineteen categories under the Work Health and Safety (General) Regulations 2022, and the tool above reproduces every one verbatim. They cover a fall risk over 2 metres, telecommunication towers, two separate demolition limbs, asbestos disturbance, temporary support, confined spaces, trenches and shafts over 1.5 metres, explosives, pressurised gas, chemical and fuel lines, live electrical work, contaminated or flammable atmospheres, tilt-up and precast, live traffic corridors, powered mobile plant movement, artificial temperature extremes, drowning risk, and diving work.
Is it eighteen categories or nineteen?
It depends whose regulations you are reading, which is why quoting a single national number is the easy way to be wrong. This list is WorkSafe WA’s and runs to nineteen. The model WHS Regulations are usually cited as eighteen, because jurisdictions differ on whether the two demolition limbs count as one item or two. A counting difference changes nothing about whether you need a SWMS. A THRESHOLD difference does, and Queensland housing construction is the known example on the fall height.
Does powered mobile plant on site make everything high risk?
More often than people expect, yes. The limb is work carried out in an area in which there is ANY MOVEMENT of powered mobile plant. Not operating it, not working on it, and nothing about whether your trade goes near it: being in the area while any of it moves. On a live site that is most areas on most days, and it is the single commonest reason an ordinary job turns out to be high risk construction work when nobody thought it was.
How deep does a trench have to be before I need a SWMS?
More than 1.5 metres, and the limb also covers work in or near a shaft at that depth, or any tunnel. It is worth separating from the shoring question people are usually thinking of: a trench at 1.6 metres needs a SWMS whatever else is or is not required of it, and the two figures are not the same rule.
We are only taking out a non-load-bearing wall. Is that high risk?
Possibly, because there are two demolition limbs and the second is wider than the first. One covers an element that is load-bearing. The other covers an element related to the physical integrity of the structure, which can carry no load at all and still be within it. Bracing, diaphragms and a good deal of what a drawing calls non-structural sit in the second limb, and people read the pair as a single item about load-bearing walls.
Does having a SWMS make the job safe?
No, and WorkSafe WA is explicit about why. A SWMS is classed as an administrative control, used to support higher order controls rather than to replace them, and it is not a procedure. So it sits near the bottom of the hierarchy. A job with a signed SWMS and no engineering control is a job with a document about a hazard rather than a controlled hazard, and good paperwork is very effective at disguising exactly that.
Is there any exemption?
One, and it is narrow: a SWMS is not required for work of a minor nature. Safe Work Australia publishes a separate information sheet on what that means, which is itself a fair sign it is not the general get-out people hope for. It is not a judgement about how long the job takes.