regulation Health and safety (WHS) 8 min read

HRCW: The 18 High-Risk Construction Work categories

The complete list of 18 High-Risk Construction Work categories under WHS Regulation 291. Know which activities require a SWMS before work starts in Australia.

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In plain English

High-Risk Construction Work (HRCW) is a defined legal category under Australian WHS law. If your construction work falls into any one of the 18 HRCW categories, you must have a Safe Work Method Statement (SWMS) in place before the work starts. No SWMS, no legal right to do the work.

The list is set out in reg 291 of the model WHS Regulations, adopted by all states and territories except Victoria. Victoria runs its own equivalent list under reg 322 of the Occupational Health and Safety Regulations 2017, which has 19 categories with similar but not identical wording. South Australia currently uses a 3 m fall threshold instead of 2 m (drops to 2 m on 1 July 2026).

On a typical residential build, the trigger you’ll hit first is item 1: any work where a person can fall more than 2 m. Roof framing, fascia and eaves, upper floor slabs, scaffolding: all HRCW from the moment a worker is at height.

What it requires

A PCBU (person conducting a business or undertaking, i.e. the builder or subcontractor doing the work) must:

  • Prepare a SWMS before HRCW starts
  • Ensure workers comply with the SWMS while the work is being carried out
  • Review and revise the SWMS if the work changes or a new risk emerges
  • Keep the SWMS for at least 2 years after a notifiable incident, or until the work is complete (whichever is longer)

Source: model WHS Regulations regs 293 to 300 (verified 2026-05-07).

The 18 HRCW categories (model WHS Regulation 291)

These categories apply in NSW, QLD, WA, SA, TAS, ACT, and NT. Check state-specific regulations for variations.

#CategoryResidential example
1Risk of a person falling more than 2 mRoof framing, fascia, eaves, scaffolding, upper floors
2Work on a telecommunication towerAntenna installation on a building
3Demolition of a load-bearing or structurally integral elementRemoving a loadbearing wall, knocking down a brick pier
4Work likely to disturb asbestosCutting into pre-1990 eaves, removing fibro sheeting
5Structural alterations requiring temporary support to prevent collapseOpening up a wall, underpinning, removing a ridge beam
6Work in or near a confined spaceEntering a subfloor void, crawl space below 900 mm clearance
7Work in or near a shaft or trench deeper than 1.5 mDeep service trenches, pad footings, stormwater pits
8Work in or near a tunnelCut-and-cover drainage, underboring works
9Work involving explosivesRock breaking on constrained sites
10Work near pressurised gas distribution mains or pipingExcavation near gas mains, gas rough-in
11Work near chemical, fuel or refrigerant linesAC refrigerant lines, fuel lines at garages
12Work near energised electrical installations or servicesWorking near live switchboards, overhead lines
13Work in a contaminated or flammable atmospherePainting in a poorly ventilated enclosed space, fuel tank areas
14Tilt-up or precast concrete workPrecast panels, tilt-up slab walls
15Work adjacent to a road, railway, shipping lane or traffic corridorDriveway and footpath works, fence lines on busy streets
16Work in an area with movement of powered mobile plantExcavator, bobcat, crane or forklift operating nearby
17Work in artificial extremes of temperatureCold-room construction, furnace installation
18Work in or near water or liquid with a drowning riskPool construction, waterfront sites, flooded excavations

Source: Safe Work Australia, model WHS Regulations reg 291 (verified 2026-05-07).

Victoria: regulation 322 (19 categories)

Victoria is the only jurisdiction that did not adopt the model WHS laws. It operates under the Occupational Health and Safety Act 2004 (Vic) and the Occupational Health and Safety Regulations 2017 (Vic). High-risk construction work in Victoria is defined in reg 322, which contains 19 categories. The practical coverage is very similar to the model list, but the precise wording differs. SWMS obligations in Victoria sit under reg 327.

If you work in Victoria, verify against reg 322 directly rather than relying on the model list above.

Source: Occupational Health and Safety Regulations 2017 (Vic) reg 322 and 327 (verified 2026-05-07).

South Australia: 3 m fall threshold (until 1 July 2026)

SA currently uses a fall threshold of 3 m, not 2 m, for item 1 (falling). A SWMS for fall risk in SA is required when a person can fall more than 3 m. From 1 July 2026, SA aligns with the national model and the threshold drops to 2 m.

Source: WHS (High Risk Construction Work) Amendment Regulations 2025 (SA) (verified 2026-05-07).

What it doesn’t cover

  • Non-HRCW site hazards: working with hazardous substances, manual handling, or noise exposure are general WHS duties, not HRCW triggers. They require risk management and controls but not a SWMS specifically.
  • High-risk work licences: HRCW is a different concept to High-Risk Work (HRW), which covers licensed activities like dogging, rigging, scaffolding, pressure equipment, and forklift operation. HRCW triggers a SWMS; HRW triggers a licence. Some activities overlap (e.g. scaffold over 2 m is both HRCW item 1 and may require a HRW scaffold licence).
  • Domestic owner-builders: owner-builders doing their own work may have reduced obligations in some states, but most HRCW obligations still apply where workers are engaged.

Practical implications

The fall-over-2-m category (item 1) is the one that catches nearly every residential builder. Gutter work, roof framing, fascia and eaves, second-storey floor edges, scaffold: if a worker can fall more than 2 m, the HRCW trigger is live and a SWMS must exist before anyone starts.

The asbestos category (item 4) is the second most common on residential renovation and knockdown-rebuild work. Any pre-1990 structure warrants an asbestos identification check before disturbing anything. You don’t need to know it contains asbestos: it only needs to be “likely to involve disturbance”. When in doubt, assume it’s there and treat accordingly.

Trenches over 1.5 m (item 7) catch builders on deep service connections, stormwater detention tanks, and slab edge footings on sloping sites. A standard 450 mm strip footing does not trigger HRCW; a 1.8 m deep drainage trench does.

Structural alterations (item 5) catch renovation work: removing walls, adding openings, underpinning. The test is whether temporary support is required to prevent collapse, not whether the element is “major”.

References

  1. Safe Work Australia, High risk construction work requiring a SWMS, safeworkaustralia.gov.au (verified 2026-05-07)
  2. Work Health and Safety Regulations 2011 (Cth), reg 291, Federal Register of Legislation, legislation.gov.au (verified 2026-05-07)
  3. Occupational Health and Safety Regulations 2017 (Vic), reg 322 and 327, AustLII, austlii.edu.au (verified 2026-05-07)
  4. WHS (High Risk Construction Work) Amendment Regulations 2025 (SA), SafeWork SA (verified 2026-05-07)
  5. Spire Safety Consultants, 18 High-Risk Construction Work Activities, spiresafety.com.au (verified 2026-05-07)

See also


Last updated: 2026-05-07. Verified: 2026-05-07. Quarterly review for currency.