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Work on Roofs NSW: 11 Critical Safety Rules

Roof safety in NSW is a legal requirement that protects workers from serious, preventable harm. Commercial roof safety applies to office buildings, shopping centres, and warehouses, while industrial roof safety applies to factories, processing plants, and large storage facilities. These workplaces often require regular roof access for tasks such as installing solar panels, servicing air conditioning units, cleaning, and repairs. That access brings real risks, including falls over edges, falls through weak or fragile roof surfaces, falling objects, and electrical hazards. Whether you are a business owner, a contractor, a person conducting a business or undertaking (PCBU), or a worker stepping onto one of these roofs for the first time, here is what you need to know before anyone sets foot on site.

What Is the Work on Roofs Code of Practice?

The Work on Roofs Code of Practice is an approved guide made by SafeWork NSW under section 274 of the Work Health and Safety Act 2011. It explains how to manage safety risks for anyone working on commercial and industrial roofs in NSW, supporting safe working at heights NSW, including tasks like installing solar panels, servicing HVAC systems, inspecting safety equipment, cleaning, and repairs.

It helps duty holders understand and follow the Work Health and Safety Regulation. It does not replace the law but helps you comply with it.

It applies to businesses, contractors, designers, suppliers, installers, and supervisors who work on these sites. It does not apply to residential roofs, demolition work, or roof support construction.

Who Has Responsibilities Under the Code?

Roof safety on commercial and industrial sites is not the responsibility of one person alone. The Work on Roofs Code of Practice outlines specific duties for everyone involved. Here is a breakdown of who is responsible and what that means in practice.

Person Conducting a Business or Undertaking (PCBU)

The PCBU carries the heaviest responsibility. This means keeping the work environment safe, maintaining equipment, providing proper training and supervision, managing fall risks, and looking after the overall wellbeing of everyone on site.

PCBU with Management or Control of a Workplace

Entering and exiting the workplace would not risk the health and safety of a person.

Designers, Manufacturers, Importers, Installers and Suppliers

Anyone who designs, makes, imports, or supplies equipment or structures used on roofs must ensure those products are safe to use.

Persons with Management or Control of Fixtures, Fittings and Plant

Anyone who is responsible for the physical assets on a worksite must ensure tools do not pose risk at the workplace.

Officers

Company officers must exercise due diligence to make sure the business is meeting its WHS obligations. Meaning, they are involved with keeping up with the updated safety laws and processes are in place.

Workers

Must be responsible for their own safety and comply with what PCBU instructs them to do.

Principal Contractors

Responsible for the written WHS management plan, making sure all workers are aware of it before starting, ensuring Safe Work Method Statements (SWMS) are prepared for high-risk work, and coordinating safety across all workers on site.

PCBUs working on construction projects, including principal contractors and subcontractors

Responsible for working within the WHS management plan, preparing their own SWMS for any high-risk work they control, and making sure their workers are properly trained and informed before starting.

Other Persons at the Workplace

People who are present in site must be responsible for their own safety, avoid putting others at risk, and follow reasonable instructions from the PCBU.

Common Roof Work Hazards

Working on a commercial or industrial roof comes with risks and understanding what those hazards are before stepping on site is the first step to staying safe and managing roof safety requirements.

Falls Over Edges

Most common and deadly risk on any roof. Without barriers or proper roof fall protection, workers can easily fall from the sides of a roof.

Falls Through Roofs

Happens when old or weakened roofing materials give way under a worker’s weight without any warning.

Skylights

Many are not built to hold a person’s weight and covers can become brittle or shift out of place over time. Proper roof safety requirements must treat skylights as fragile areas.

Falling Objects

Tools, materials, and loose debris can fall from a roof and seriously injure people working or passing below.

Electrical Hazards

This includes overhead power lines, solar panels, and air conditioning systems on rooftops can cause serious electric shock or death if contacted.

Weather Conditions

Strong wind, rain, heat, ice, and wet surfaces make it much easier to slip, lose balance, or drop tools while on a roof.

Remote or Isolated Work

Worker on a roof who cannot be seen or heard by others. If something goes wrong, help may take too long to arrive.

Asbestos Roof Risks

Present in many older commercial and industrial buildings. Asbestos cement sheeting was commonly used on roofs before the 1990s. Without the right controls, it releases tiny fibres into the air that can cause serious and permanent lung disease.

The Roof Work Risk Management Process

Effective fall prevention roof work starts with a structured risk management process. The Code outlines four stages:

1. Identify Hazards

Review the workplace and how the work will be carried out. Talk to workers and review incident records, safety data sheets, and relevant standards. Consider all physical and psychosocial hazards, including risks related to commercial roofing compliance and industrial roofing safety, where roof work is involved.

2. Assess the Risks

For each hazard, evaluate:

The severity of potential outcomes
How frequently workers are exposed
Current work practices and procedures including SWMS roof work documentation
Competency of workers and effectiveness of existing controls

3. Control the Risks

Apply the Hierarchy of Controls. In most cases, a combination of measures delivers the best outcome.

Control measures may include:

Edge protection to prevent workers falling from roof edges
Skylight covers to protect against falls through fragile roofing surfaces
SWMS roof work procedures to ensure safe methods of work are followed
Specific controls for asbestos roof safety where asbestos-containing materials are present

4. Review Control Measures

Control measures must be reviewed regularly, particularly when the work environment changes, after any incident, or when new work techniques are introduced. Involve workers and Health & Safety Representatives (HSRs) in all reviews.

Understanding the Hierarchy of Controls

When managing the risks of working at heights in NSW, the law requires duty holders to work through a set of controls in a specific order. The strongest and most reliable options must always be considered first before moving to weaker ones.

Level	Control Type	Examples
1	Elimination	Eliminate the need for workers to go onto the roof.
2	Substitution	Replace fragile roofing material with trafficable alternatives
3	Engineering Controls	Guardrails, scaffolding, roof safety mesh, permanent walkways
4	Administrative Controls	Safe work procedures, training, SWMS, exclusion zones
5	PPE	Harnesses, hard hats, non-slip footwear

Why Guardrails and Scaffolding Are Preferred Over Harnesses

Guardrails system and scaffolding help stop falls from happening in the first place. A harness does not stop the fall, it only helps protect the worker after they have already fallen.

Planning Roof Work Before It Starts

Commercial roofing compliance starts with careful planning. Before work begins, the site should be inspected to identify hazards and determine the safest way to carry out the job.

Site Assessment Checklist

Roof condition: Is the structure capable of supporting workers and equipment? and the necessary Roof Access Systems used to access the roof?
Hazardous materials: Is asbestos present?
Access routes: Are safe access points available?
Electrical hazards: Are overhead power lines or live electrical systems present?
Weather conditions: What are the forecast conditions? Roof work should not proceed in high winds, rain, or extreme heat without appropriate controls.
Worker competency: Have all workers been trained and do they hold relevant competencies for the work?

SWMS Requirements for Roof Work

A Safe Work Method Statement (SWMS) is a written document that identifies the high-risk construction work to be carried out, the hazards associated with that work, the control measures to be put in place, and how those controls will be implemented, monitored, and by whom.

When Is a SWMS Required?

In NSW, a SWMS is legally required for any construction work where a person could fall 2 metres or more. This is called high-risk construction work under NSW law.

What Must a SWMS Include?

A compliant SWMS for roof work must cover:

The specific work activities to be performed
Hazards associated with each activity
The control measures to be applied
How each control measure will be implemented
Who is responsible for implementing and monitoring controls

Common SWMS Mistakes to Avoid

Generic, one-size-fits-all documents. A SWMS must be specific to the job and site.
Not consulting workers. Workers who perform the work must be involved in developing the SWMS.
Listing PPE as the primary control. Higher-order controls must be identified and implemented first.

Hierarchy of Control

Need help developing compliant SWMS documentation? Contact our team for a roof safety compliance consultation.

Fall Prevention Measures

Choosing the right roof fall protection system is important for keeping workers safe and meeting safety requirements.

Fall Prevention Systems Comparison Table

System	Type	Best For	Key Advantages	Limitations
Scaffolding	Engineering	Major works, perimeter access	Provides full work platform and edge protection	Cost and time to erect
Temporary Edge Protection	Engineering	Shorter-term works	Quick to install, reusable	Must meet AS/NZS standards
Guardrail Systems	Engineering	Flat roofs, ongoing access	Passive protection	Requires structural assessment
Roof Safety Mesh	Engineering	Under fragile roofs	Catches falls through fragile materials	Installation requires access
Walkways	Engineering	Regular maintenance routes	Defined safe path of travel	Limited to fixed routes
Work Platforms	Engineering	Elevated plant access	Stable, load-rated surface	Access to platform required
Harness Systems / Static Lines	PPE	Use harnesses safer physical controls cannot be used	Flexible, can cover large areas	Requires training, behaviour-dependent
Fall Arrest Systems	PPE	Last-resort backup	Limits fall distance	Does not prevent the fall

Scaffolding

Scaffolding is a safe platform with barriers around the edges so workers do not fall. It must be designed by a qualified person and built and removed by licensed scaffolders.

Temporary Edge Protection

Temporary Edge Protection must meet the requirements of AS/NZS 4994.1 and be installed, inspected, and maintained by a qualified person.

Guardrail Systems

Guardrail systems are one of the most effective ways to prevent falls on commercial and industrial rooftops.

Roof Safety Mesh

Roof safety mesh is installed underneath fragile or see-through roofing materials to catch workers if they fall through during the construction of the building only. It must be installed correctly by a qualified person and routinely inspected.

Harness-Based Systems

Harness systems, including static line systems and anchor points, should only be used when stronger controls are not possible. The system must be designed by a qualified person, and all workers must be trained on how to use it correctly, including how to inspect it before use and what to do in a rescue situation.

Safe Roof Access Systems

Having a safe, clearly designated way to get onto and off a roof is not optional. It is a legal requirement. The Code states that proper access systems must be provided and kept in good condition at all times.

Fixed ladders include rest platforms where required and provide controlled, safe access for entering and exiting.

Roof must be large enough for workers carrying tools and PPE, and lockable from both sides where possible.

Walkways provide a safe, slip-resistant path from the access point to the work area

Book a roof access assessment to determine what permanent systems your building requires.

Working Around Fragile Roofs and Skylights

Falls through fragile roofs and skylights are one of the most common causes of serious and fatal injuries in commercial roof work.

Identifying Fragile Roofing Materials

A competent person must inspect the roof and identify all fragile surfaces before anyone starts work. This includes fibreglass sheeting, deteriorated metal, asbestos cement, and skylights. A proper Height Safety Audits process can help ensure all hazards are correctly identified before work begins.

Exclusion Zones

Fragile areas that cannot be made safe must be physically barricaded. Signs and tape alone do not meet the requirement. Where exclusion zones are required, proper Guardrail Systems or other physical barriers must be used to prevent access.

Covers

All skylights and roof openings must have rigid covers that can hold the weight of a person and their equipment. Covers must be permanently labelled so workers can identify them instantly. In some cases, roof walkways and roof access systems are used to redirect foot traffic away from fragile areas.

Asbestos Roof Safety Requirements

Asbestos cement sheeting was widely used in commercial and industrial roofing across Australia until the 1980s. If your building was built before 1990, there is a good chance it contains asbestos somewhere, including on the roof.

Identifying Asbestos Roofs

Do not assume a roof is asbestos-free just because it looks modern or seems old enough to have been replaced. Asbestos cement sheeting can look exactly like products used today.

Legal Requirements

If asbestos is found or suspected, strict rules apply under NSW law, including SWMS requirements and asbestos management plans. In these situations, Asbestos Roof Safety procedures must be followed, along with appropriate Safety Compliance Services to ensure legal compliance.

Safe Work Procedures for Asbestos Roofs

Even basic maintenance on an asbestos cement roof can release dangerous fibres into the air. Safe procedures include:

Avoiding walking directly on the sheeting where possible
Using water to keep dust down if any cutting or drilling is needed
Wearing the right respiratory protection at a minimum
Disposing of all asbestos waste in line with requirements

Electrical Hazards on Roofs

Electrical safety is one of the most serious and underestimated risks in commercial roof work.

Overhead Power Lines

Overhead power lines are the biggest electrical hazard on any roof. Workers, metal materials, and equipment must always stay a safe distance away from them. If work needs to happen within that exclusion zone, the relevant network operator must be contacted first to arrange isolation before anyone goes near it.

Solar Installations

Solar panels produce electricity whenever there is light and cannot be fully switched off. Work on or near them requires isolation procedures and licensed electrical work. In these environments, Anchor Points and Fall Arrest Systems are often required to ensure worker safety while accessing roof-mounted systems.

HVAC and Air Conditioning Systems

Roof-mounted HVAC units contain high-voltage electrical components. Before any mechanical work is carried out on or near them, a licensed electrician must confirm the system has been properly isolated. Lockout and tagout procedures must also be in place to make sure the system cannot be accidentally switched back on while work is happening.

General Electrical Isolation

Any electrical system on or near the roof that workers could come into contact with must be:

Identified during the pre-work assessment before anyone goes up
Isolated and tested by a licensed electrician before work begins
Kept isolated until every worker has safely left the work area

Emergency Rescue Planning

Have a rescue plan ready and actually test it works
Train all workers on what to do in an emergency
Never let someone work alone with this equipment. There must always be someone else on site who can rescue them
Rescue quickly if someone is left hanging in a harness, as it can cause serious health issues even without injury

Contact our team to develop a site-specific roof rescue plan.

Roof Safety Compliance Checklist

Use this checklist before starting any work on a commercial or industrial roof.

Pre-Work Planning

Roof inspection completed by a qualified person
Hazardous materials such as asbestos identified and assessed
Electrical hazards identified and an isolation plan confirmed
Weather conditions checked and work postponed if conditions are not safe

Documentation

SWMS prepared and specific to this job and this site
SWMS reviewed with all workers before work starts
WHS Management Plan in place for construction projects
Asbestos Register reviewed where applicable

Fall Protection

Strongest practicable level of fall protection installed
Guardrail systems or temporary edge protection in place at all roof edges
Fragile areas and skylights identified, covered, or barricaded

Access Systems

Safe way onto the roof confirmed through a fixed ladder, hatch, or scaffold
Access walkways in place for the route to the work area
Anchor points or static line system inspected and certified if harnesses are being used

Workers

All workers trained and capable of doing the work safely
PPE inspected and in good condition
Workers briefed on the SWMS and emergency procedures

Emergency Preparedness

Rescue procedures tested and confirmed effective
Rescue to be completed within 5 minutes where possible
At least one other person on site at all times when harnesses are in use

Download our free Commercial Roof Safety Compliance Checklist PDF. Ready-to-use tool for facility managers and WHS officers.

Frequently Asked Questions

1. Who is required to prepare a SWMS for roof work? The business or contractor doing the work is responsible. On construction projects, the principal contractor must also make sure one is in place. Workers must be involved in preparing it and sign off that they understand it.

2. When is a SWMS legally required for roof work? Any roof work at 2 metres or more where there is a risk of falling requires a SWMS.

3. Can I use a harness as my primary fall protection measure? Only if stronger controls like guardrails, scaffolding, or roof safety mesh are genuinely not possible. Harnesses are the lowest level of protection and should never be the default. You must document why higher-order controls cannot be used.

4. How do I know if my roof contains asbestos? You cannot tell by looking at it. If your building was built or renovated before 1990, engage a licensed asbestos assessor to inspect and test suspect materials. All asbestos found must be recorded in an Asbestos Register.

5. What are my obligations as a building owner when contractors work on my roof? You must make sure the site is safe and give contractors information about known hazards before work begins, including asbestos, structural issues, and electrical systems.

6. What is suspension trauma and how do I protect workers from it? Suspension trauma occurs when a worker is left hanging in a harness after a fall. Blood pools in the legs and can cause unconsciousness and death within minutes. A rescue plan must be ready before work starts so workers can be brought down quickly and assessed by a medical professional.

7. Do I need a rescue plan if workers are using harnesses on the roof? Yes. It must be site-specific, include all rescue equipment and procedures, and be explained to every worker before they start.

8. What happens if you don’t follow the Work on Roofs Code of Practice NSW?

If you don’t manage risks properly, safety inspectors can take action such as issuing improvement notices, prohibition notices, or starting legal proceedings. In serious cases, this can lead to significant penalties.

Following the Code is the easiest way to show you are meeting your legal safety responsibilities.

Conclusion

The Work on Roofs Code of Practice NSW sets out clear rules for keeping workers safe on commercial and industrial rooftops. Every business with workers accessing roofs must have a proper risk management plan, the strongest fall protection possible, a compliant SWMS, and a rescue plan ready before anyone goes up.

Falls from roofs continue to kill and seriously injure workers in NSW every year. The risks are real but they are manageable. With the right planning, the right roof fall protection systems, trained workers, and clear procedures in place, roof work can be done safely and within the law.

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From site assessments and system design to testing, inspections and certifications, we’re here to provide expert advice to keep your business protected and workplace safe.

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