Delving into a more comprehensive approach to differentiating work at height systems, in the following article Mark Da Silva explores Gallagher’s classification of systems type (Gallagher, 2000:79-83).

Theoretically, the types identified all meet the basic requirements of an OHSMS – a formalised management system to improve OHS comprising a complex set of inter-related programme elements. However, the four are distinguished first by different OHS control strategies and second by different management structures and styles. OHS control strategies are categorised as either ‘safe person’ or ‘safe place’. Management structures and styles are either ‘traditional’ or ‘innovative’. These are explained below.

The four approaches to health and safety management are identified from the findings of the literature on health and safety management systems and types of systems, and from the emerging case evidence. The four approaches and their characteristics are identified below:

  1. Traditional management, where health and safety is integrated into the supervisory role and the ‘key persons’ are the supervisor and/or any health and safety specialist; employees may be involved, but their involvement is not viewed as critical for the operation of the health and safety management system, or alternatively a traditional health and committee is in place.
  2. Innovative management, where management have a key role in the health and safety effort; there is a high level of integration of health and safety into broader management systems and practices; and employee involvement is viewed as critical to system operation, with mechanisms in place to give effect to a high level of involvement.
  3. A ‘safe place’ control strategy, which is focused on the control of hazards at source through attention at the design stage and application of hazard identification, risk assessment and risk control principles.
  4. A ‘safe person’ control strategy, which is focused on the control of employee behaviour.

These approaches are combined into the following four types of health and safety management system.

Managing the risk of falls at workplaces where there is a risk of a fall by a person from one level to another that is reasonably likely to cause injury is the description or determination of a fall. This can occur from the perspective of the innovative/safe place approach, rather than traditional/ safe person based.

Safe design

The best part of ensuring elimination of a potential hazard is at the initial design stage (project development-strategic, concept or detailed design) process of the asset or project lifecycle examining areas within the innovative safe place-adaptive hazard managers. This is where anything that has been pencilled in can be literally rubbed out and erased on paper; while there is still an opportunity to apply practical solutions to manage the risks of falls in the workplace. Conversely, it’s too late to change and at a considerable cost when progressing each lifecycle stage in the project delivery of construction, operation or maintenance.

Health and safety in design is paramount for not only good design, but parallel to good safety business outcomes within all workplaces. Design considerations for the potential risk of falls early on in the piece when designing plant or structures can result in the elimination of such risks. Conversely, where elimination is not possible, one way to minimise risks at the design stage is to integrate fall prevention systems into the design.

Safety considerations at the design stage should include areas such as:

  • Safe entry to and exit from any work area
  • Designing permanent guard rails or other forms of edge protection (for example, parapet walls) for permanent fall prevention on roofs
  • Future maintenance requirements, especially in relation to sloping building exteriors and windows, to ensure maintenance can be carried out safely
  • Specifying the strength of roof members and other points to which guard rail, or anchor points for work positioning systems will be fixed
  • Safer building design generally, with, for example:
  • Low-level mounting of roof vents
  • The location of air conditioning units and other roof-mounted plant, such as satellite dishes, away from edges
  • The location of air conditioning and similar plant at ground level
  • The specification of non-fragile material for the roof
  • The use of permanent safety mesh
  • Safer gutters, for example, installing large volume gutters and down pipes to minimise the need to access the roof for cleaning, locating the gutters at ground level or away from edges, or the removal of gutters altogether, with a smooth transition from the roof to the walls with the gutters at ground level
  • Specific safety requirements for particular workers doing subsequent installation, maintenance or repair work

These groups include:

  • People installing and maintaining antennae and satellite dishes
  • Contractors servicing air conditioning equipment on the roof
  • Window and gutter cleaners and repairers
  • Designing the pre-fabrication of structures on the ground before they are lifted into position

Whereas plant health and safety in design may include areas such as:

  • Providing adequate steps and hand rails on vehicles
  • Incorporating a fall prevention system in silos and overhead conveyors
  • Ensuring workers who will be maintaining or cleaning the plant are able to do so safely
  • Considering the safety of public users and/or passengers

Whereas health and safety in design for buildings and structures must ensure, so far as is reasonably practicable areas such include:

  • Workers involved with the construction, use or subsequent maintenance are not exposed to the risks associated with work at height. Therefore, at the design and planning stage, it is important to consider providing fall prevention systems as part of the building or structure
  • It may be considered unlikely that all design work on larger projects will be carried out by one individual designer, consultation, co-operation and co-ordination should occur between the builder and other designers to ensure the safe interaction of the different design aspects
  • When risks remain in the design work, information must be included with the design to alert others to the risks. Providing information about safety issues is a key component to ensure proper, adequate and suitable design and installation

The design and planning for the construction stage should include:

  • Reducing the risk for those working at heights, such as the installation of guard rails to perimeter structural members prior to erection
  • Reducing the time spent working at heights by pre-fabricating modules on the ground, before lifting them into position
  • Sequencing of the work to be performed at heights
  • The location and condition of access roads, for example to enable a crane to place building materials in the most appropriate and accessible location, rather than the materials being moved manually
  • Preparation of the ground or floor below the work area. It should be compacted and level
  • To support plant or equipment, such as cranes and scissor lifts
  • Identification of underground services including drainage, for example for the safe setting up of cranes
  • Provision of permanent safety mesh

Planning for building maintenance

During the planning stage, consideration should also be given to the methods by which maintenance, repairs or cleaning will be undertaken on a building or structure, for example:

  • Designing window cleaning bays or gangways integrated into the structural frame
  • Designing permanent anchorage and hoisting points into structures where maintenance needs to be undertaken at height

Planning the site layout

When planning the site layout, the following factors should be considered:

  • The preparation of firm, level surfaces below work areas for the support of plant and equipment, such as scissor lifts or mobile scaffolds
  • The site and condition of access roads to enable plant to place material in and pick it up from the most favourable positions, thereby reducing, for example, the need for manual handling at height
  • Safe access to and egress from work areas and amenities, including the provision and placement of stairways, ladders, catwalks, guardrails and barriers
  • The need for adequate means of escape and rescue in the event of an emergency

From a legislative viewpoint the definition is considered to include the circumstances by risk of a fall to mean a circumstance which exposes a worker while at work, or other person while at or in the vicinity of a workplace, to a risk of a fall that is reasonably likely to cause injury to the worker or other person.

This includes circumstances in which the worker or other person is:

  • In or on plant or a structure that is at an elevated level
  • In or on plant that is being used to gain access to an elevated level
  • In the vicinity of an opening through which a person could fall
  • In the vicinity of an edge over which a person could fall
  • On or in the vicinity of a surface through which a person could fall
  • On or near the vicinity of a slippery, sloping or unstable surface

This also extends to include persons conducting a business or undertaking, including those persons who design, construct, import, supply or install plant or structures, on how to manage health and safety risks arising from falls.

Designers, manufacturers, suppliers, importers and installers of plant or structures that could be used for work must ensure, so far as is reasonably practicable, that the plant or structure is without risks to health and safety. Designers of plant or structures have an important role in eliminating or minimising the risks of falls in the design stage.

Officers, such as company directors, have a duty to exercise due diligence to ensure that the business or undertaking complies with the WHS Act and Regulations. This includes taking reasonable steps to ensure that the business or undertaking has and uses appropriate resources and processes to eliminate or minimise risks of falls from one level to another that are likely to cause injury.

Workers have a duty to take reasonable care for their own health and safety and that they do not adversely affect the health and safety of other persons. Workers must comply with any reasonable instruction given by the person conducting the business or undertaking (Managing the Risk of Falls at Workplaces – Code of Practice, March 2015).

It also includes information on a range of control measures to eliminate or minimise the risks.

In order to manage risk under the WHS regulations, a duty holder must:

  • Identify reasonably foreseeable hazards that could give rise to the risk
  • Eliminate the risk so far as is reasonably practicable
  • If it is not reasonably practicable to eliminate the risk – minimise the risk so far as is reasonably practicable by implementing control measures in accordance with the hierarchy of control
  • Maintain the implemented control measure so that it remains effective
  • Review, and if necessary revise, risk control measures so as to maintain, so far as is reasonably practicable, a work environment that is without risks to health and safety

Safe Work Method Statement

The primary purpose of a Safe Work Method Statement (SWMS) is to assist supervisors, workers and any other persons at the workplace to understand the requirements that have been established to carry out the high risk construction work in a safe and healthy manner. It sets out the work activities in logical sequences, identifies hazards and describes control measures.

Both simple and complex activities can be broken down into a series of basic steps that will allow for full analysis of each part of the activity for hazards and potential incidents. The description of the process should not be so broad that it leaves out activities with the potential to cause incidents and prevents proper identification of the hazards nor is it necessary to go into fine detail of the tasks.

The aim of a SWMS is to:

  • Describe the activity or task to be undertaken
  • Identify the resources, manpower and skills associated with the task
  • Assess and select control measures (as appropriate)
  • Systematically plan the activity so it can be completed efficiently and effectively

The SWMS must be able to be easily read by those who need to know what has been planned to manage the risks and implement the control measures and ensure the work is being carried out in accordance with the SWMS.

This includes:

  • The supervisor of the high risk construction work
  • The worker carrying out the high risk construction work
  • The principal contractor (if it is a construction project) or the person who has management and control over the high risk construction work

The SWMS should also be aligned to the SWMS Site Register which is then translated at a Project or Site Level to be incorporated in the Site/Divisional Risk Register, aligned to the management of these potential risks governed in the overall WHS Management Plan.

The SWMS must be developed by the people doing the work in order to ensure a correct method has been agreed to by all key stakeholders, as planned. Following this a demonstrated path of communications must also be adhered to verbal/written to ensure everything is understood by all, and therefore signed off by all workers involved in the scope of the work. This form of collaboration must involve cooperation, coordination and consultation at all stages of the work being implemented. The consulting workers involves sharing of information, giving workers a reasonable opportunity to express views and taking those views into account before making decisions on health and safety matters.

You must consult your workers and their health and safety representatives at every step of the risk management process. Furthermore, review available information, including hazard and occurrence reports, records, investigations and lessons learned from earlier records of previous injuries and ‘near miss’ incidents related to falls. The current information and advice about fall hazards and risks relevant to particular industries and work activities is also available from regulators, industry associations, unions, technical specialists and safety professionals/ consultants.


Finally, if necessary revise risk control measures so as to maintain, so far as is reasonably practicable, a work environment that is without risks to health and safety. The review of the process will take into consideration regularly review by all key stakeholders to make sure it remains effective. A SWMS must be reviewed (and revised if necessary) if relevant control measures are revised. By drawing on their experience, knowledge and ideas, you are more likely to identify fall hazards and develop effective control measures.