Do I need a SWMS for work above two metres now?

Do I need a SWMS for work above two metres now? That is the question we have been asked most often since 1 July, and the answer in South Australia is yes.

Work at height was high risk construction work above three metres. It is now above two metres. The change came in through the Work Health and Safety (High Risk Construction Work) Amendment Regulations 2025, which amend the Work Health and Safety Regulations 2012 (SA). SafeWork SA has published its own explanation on safework.sa.gov.au, under the page titled WHS (High Risk Construction Work) Amendment Regulations 2025. It is worth reading directly rather than taking anyone's summary of it, including ours.

The practical effect is simple. Work that sat below the old line and needed no safe work method statement may now sit above the new one. If a job involves a person working more than two metres above the ground, it is high risk construction work, and a SWMS has to be prepared before the work starts.

The risk is not that people do not know. Most builders and subcontractors in South Australia have heard about this by now. The risk is that the paperwork has not caught up. SWMS templates get copied forward from job to job for years. If yours was written before July, there is a reasonable chance it still says three metres somewhere, and a document that states the wrong threshold is worse than no document, because it looks like a considered decision.

Three things worth doing this month

Open your SWMS templates and search them for the word "three" and the figure "3". Fix every height reference. Then look at your induction material, your site rules and any toolbox talk notes, because the old number tends to be in more places than you remember.

Look at the jobs you priced before July that have not started yet. If any of them involve work between two and three metres, they now need a SWMS that they did not need when you quoted. That is time, and it is better found now than on the morning the work starts.

If you engage subcontractors, ask what they have updated. A head contractor who accepts a subbie's SWMS with the old threshold in it has a problem too.

While you are in the folder

One other thing catches people out. Safety data sheets have to be reviewed and reissued every five years, but that duty sits with the manufacturer or importer of the chemical, not with you. Your duty is to hold the current sheet. The five year figure is useful to you as a date check: every sheet carries an issue or revision date, so if the one in your folder is more than five years old, it has almost certainly been superseded and what you are holding is no longer current.

This sits inside a wider question, which is what a builder actually asks a subcontractor for before letting you on site, and why some of that paperwork is required by the WHS Regulations while the rest is the builder's own commercial requirement. Those are two different lists and it is worth knowing which is which before you argue about any of it. We have written that up separately, under the title What WHS documents does a builder ask a subcontractor for.

P&P Consulting prepares SWMS and WHS document packs for trade and construction businesses in South Australia. If your templates were written against the old threshold and you would rather someone went through them properly, get in touch.

This article is general information about South Australian work health and safety law and is current as at the date of publication. It is not legal advice for your circumstances.