Pre-ticked for falls, asbestos and the traffic corridor limb, with three rows written. Roofing is the trade where the hazard nobody plans for is usually on the ground rather than the roof.
The fragile surface is not a separate category, and that is the problem
There is no high risk construction work limb called fragile roof. Falls through rooflights, fibre cement and corroded metal sheet land under the ordinary fall limb, so the SWMS ticks the same box whether the risk is walking off the edge or through the middle.
Which means the document has to carry the distinction that the category does not. Cover every rooflight before the first shift rather than as they are found, mark them, and treat any sheet whose condition you cannot see the underside of as fragile. Falls through a surface kill about as often as falls from an edge and they are far less anticipated.
What is under you decides more than what is on the roof
The traffic corridor limb covers work on, in or next to a road, railway, shipping lane or other traffic corridor in use. A roof over a live footpath is next to one. A shop frontage on a high street is next to one. It reads like a roadworks rule, which is why roofers skip it, and it is the limb that decides whether you need a footway closure from the council rather than a line of cones.
Get that wrong and the problem is not the paperwork, it is that the exclusion zone you have drawn on the plan does not exist on the pavement, because the public has right of way through it until somebody formally closes it.
Asbestos on a roof is usually cement, and usually whole
Asbestos cement sheet is a lower risk product than sprayed coating or insulating board, and it stays lower risk for exactly as long as it stays intact. Broken, cut, or dropped from a roof onto a hard surface, it stops being the low risk one immediately.
So the control is the handling, not just the licence question. Sheets come off whole, get lowered rather than dropped, and stay damp. And where the register is silent or there is no register, the material is treated as asbestos until somebody samples it, because an absent register is not evidence of absence.
Wind is a stop, not a variable
Sheet material is a sail. The point at which roofing becomes unsafe in wind arrives well before the point at which working at height in general does, and it arrives quickly, so a SWMS that says work will be managed in high winds is describing an intention rather than a control.
A useful one names a figure and names who calls it. Somebody has to be able to stop the job without ringing the office, or the decision gets made by whoever is holding the sheet.
The scaffold is somebody else structure
Almost every roofing job works from an access scaffold erected by another contractor, and the statement should say plainly that you are relying on it, that you will check the tag before every use, and that you will not alter it.
That last part is where the arguments come from. A tie in the way of a verge detail, a board that needs lifting to get a sheet through, a lift that is 300mm too low: each one is a small practical problem with a scaffolder-shaped answer, and each one gets solved by a roofer with a spanner if the statement has not said otherwise. Writing it down does not stop it happening, and it does decide who is standing where when somebody asks.
Common questions
Is a SWMS required for all roof work?
Where there is a risk of a person falling more than 2 metres, yes, and that covers almost all of it. Queensland uses 3 metres for housing construction and 2 for everything else, and South Australia moved from 3 to 2 on 1 July 2026, so check which figure applies where you are working before you decide a low roof is outside it.
Does harness and lanyard satisfy the fall control?
It is the last option rather than the answer. The order is eliminate the need to be at height, then prevent the fall with edge protection or a scaffold, then arrest it. A SWMS that goes straight to harnesses without saying why edge protection was not reasonably practicable is the version that comes back. And fall arrest brings its own requirement, which is a rescue plan that does not consist of ringing 000 and waiting.
What if the asbestos register does not mention the roof?
Treat the material as asbestos until it is sampled. A register that is silent is not a register that says no, and refurbishment and demolition work needs a survey of that type rather than a management survey. Stopping to sample costs a day. Getting it wrong contaminates the site, the crew and everybody downwind.
Do I need a separate SWMS for the scaffold?
The scaffolder does, for their own work. Yours covers your work on the completed scaffold, and it should say plainly that you are relying on somebody else’s structure, that you will check the tag before every use, and that you will not alter it. Most disputes on a roof job are about who moved a board.
How long does the SWMS have to be kept?
It has to be available at the workplace for as long as the high risk construction work is going on, and kept until the work is finished. If a notifiable incident happens that relates to it, it is kept for at least two years after that. Storing it in a van that leaves at four does not satisfy available at the workplace.