Quick answer: under Australian WHS law, “working at heights” is any work where a person could fall from one level to another and be injured — there’s no magic height. The duty is to work through the hierarchy of controls in order: avoid the height, prevent the fall, then minimise its consequences. An EWP with guardrails is a fall prevention control — which is why hiring the right machine is usually higher up the hierarchy than harnesses and ropes.
Why falls dominate the rules
Falls from height remain one of the biggest killers on Australian worksites, and most fatal falls happen from modest heights — roofs, ladders, vehicles and mezzanines, not towers. That’s why the model Code of Practice for managing falls applies wherever a fall is reasonably likely to cause injury, and why construction work adds hard triggers at 2m.
The hierarchy for height work
Work through these in order, and be able to say why you stopped where you did:
- Avoid the height — do the work from the ground: prefabricate, lower the component, use extendable tools.
- Solid construction — existing safe surfaces with barriers: mezzanines, permanent platforms and walkways.
- Fall prevention devices — the level where most hire equipment lives: EWP guardrails, scaffolds, edge protection, guarded work boxes. The worker physically can’t fall.
- Work positioning systems — restraint that stops you reaching the edge.
- Fall arrest — harnesses, lanyards, anchor points: the fall happens and is caught. Requires anchor engineering and a tested rescue plan.
- Ladders and administrative controls — last resort for short-duration, light, three-points-of-contact tasks.
Skipping from level 1 straight to a harness because it’s cheaper is exactly what the code exists to prevent.
Where EWPs fit
A scissor lift or boom lift puts a guarded platform under the worker — prevention, not arrest. That’s why an EWP is so often the reasonably practicable control for lighting, services, facades, ceilings and roof-edge tasks: it’s faster than scaffold for short works, and safer than ladders for almost everything. Choose the class with Choosing an EWP; note booms add a harness requirement (worn attached to the anchor point) because of catapult risk.
When something else is better
- Long-duration, multi-trade work at one face → scaffold beats a fleet of EWPs.
- Permanent access need → fixed platforms, stairs and walkways, not repeated hires.
- Roof edges on re-roofing → edge protection along the work, EWP for access to it.
- A two-minute inspection → a well-used ladder can be defensible; a day of ladder work is not.
Planning, supervision, SWMS
On construction sites, work with a risk of a fall of more than 2m is high-risk construction work and requires a SWMS before it starts — written for the actual task and site, briefed to the crew, and updated when conditions change. See SWMS Explained for EWP Work. Beyond construction, the falls code still expects planning: assessed ground, weather limits, exclusion zones below, and supervision matching the risk.
Rescue is part of the control
Any plan that can leave a worker stranded aloft or hanging in a harness must include rescue: emergency descent training for ground crew on EWPs, and prompt-recovery arrangements for fall-arrest systems (suspension intolerance is a medical emergency measured in minutes). Details: EWP Rescue Planning.
FAQs
What counts as working at heights? Any work where a person could fall from one level to another and be injured — including near edges, holes and fragile surfaces. There is no minimum height below which the duty disappears.
Is an EWP always the best control? No — it’s often the most practicable fall-prevention control for short and mobile tasks, but scaffolds, edge protection or ground-level methods can rank higher for particular jobs.
Why does the hierarchy of control matter? Because the law requires the highest reasonably practicable control, not the cheapest. Documenting why you chose your level is the core of a defensible plan.
Do I need a SWMS for all height work? Not all — but construction work with a fall risk over 2m is high-risk construction work and must have one.
Can a ladder replace an EWP? For brief, light, three-points-of-contact tasks it can be defensible. For production work at height, a guarded platform is almost always the reasonably practicable control.
Does a harness remove fall risk? No — fall arrest means the fall happens and is caught. It sits low on the hierarchy, needs engineered anchors, and demands a practised rescue plan.
Who decides which control to use? The PCBU, in consultation with workers — guided by the hierarchy and what’s reasonably practicable for that task.
What if the task changes during the day? Re-check the controls. New trades, weather, excavation or a different work face can invalidate the morning’s plan.
Does height work only apply to construction? No — warehousing, retail, facilities and events all involve height work, and the falls code applies to all of it. The 2m SWMS trigger is construction-specific.
What’s the biggest planning mistake? Booking equipment before defining the hazard and method. Define the task, pick the control level, then hire the machine that delivers it.