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.
Ask Chalkline about this →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.
| # | Category | Residential example |
|---|---|---|
| 1 | Risk of a person falling more than 2 m | Roof framing, fascia, eaves, scaffolding, upper floors |
| 2 | Work on a telecommunication tower | Antenna installation on a building |
| 3 | Demolition of a load-bearing or structurally integral element | Removing a loadbearing wall, knocking down a brick pier |
| 4 | Work likely to disturb asbestos | Cutting into pre-1990 eaves, removing fibro sheeting |
| 5 | Structural alterations requiring temporary support to prevent collapse | Opening up a wall, underpinning, removing a ridge beam |
| 6 | Work in or near a confined space | Entering a subfloor void, crawl space below 900 mm clearance |
| 7 | Work in or near a shaft or trench deeper than 1.5 m | Deep service trenches, pad footings, stormwater pits |
| 8 | Work in or near a tunnel | Cut-and-cover drainage, underboring works |
| 9 | Work involving explosives | Rock breaking on constrained sites |
| 10 | Work near pressurised gas distribution mains or piping | Excavation near gas mains, gas rough-in |
| 11 | Work near chemical, fuel or refrigerant lines | AC refrigerant lines, fuel lines at garages |
| 12 | Work near energised electrical installations or services | Working near live switchboards, overhead lines |
| 13 | Work in a contaminated or flammable atmosphere | Painting in a poorly ventilated enclosed space, fuel tank areas |
| 14 | Tilt-up or precast concrete work | Precast panels, tilt-up slab walls |
| 15 | Work adjacent to a road, railway, shipping lane or traffic corridor | Driveway and footpath works, fence lines on busy streets |
| 16 | Work in an area with movement of powered mobile plant | Excavator, bobcat, crane or forklift operating nearby |
| 17 | Work in artificial extremes of temperature | Cold-room construction, furnace installation |
| 18 | Work in or near water or liquid with a drowning risk | Pool 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”.
Source link
- Safe Work Australia: High risk construction work requiring a SWMS (verified 2026-05-07)
- Model WHS Regulations reg 291, Federal Register of Legislation (verified 2026-05-07)
- Occupational Health and Safety Regulations 2017 (Vic) reg 322, AustLII (verified 2026-05-07)
References
- Safe Work Australia, High risk construction work requiring a SWMS, safeworkaustralia.gov.au (verified 2026-05-07)
- Work Health and Safety Regulations 2011 (Cth), reg 291, Federal Register of Legislation, legislation.gov.au (verified 2026-05-07)
- Occupational Health and Safety Regulations 2017 (Vic), reg 322 and 327, AustLII, austlii.edu.au (verified 2026-05-07)
- WHS (High Risk Construction Work) Amendment Regulations 2025 (SA), SafeWork SA (verified 2026-05-07)
- Spire Safety Consultants, 18 High-Risk Construction Work Activities, spiresafety.com.au (verified 2026-05-07)
Related
- SWMS: When it’s required and how to write one
- Asbestos removal pathways
- Asbestos identification
- Notifiable incidents
- PPE for residential construction
See also
- HRCW (glossary)
- SWMS (glossary)
- PCBU (glossary)
- WHS Act overview
- Construction induction training
- Site safety basics
Last updated: 2026-05-07. Verified: 2026-05-07. Quarterly review for currency.