Quick answer: A roofing business in Australia generally needs a WHS policy, SWMS for all working-at-heights and other high risk construction work activities, a fall protection equipment inspection register, a worker licences and competencies register, a plant and equipment register, site induction records, a height rescue plan, an incident register, evidence of current insurances, and toolbox talk records. The exact documents required depend on your state or territory, the nature of the work, and your role on site.
Last reviewed: 12 June 2026
WHS documentation for roofing businesses is shaped by one overriding fact: roofing is among the highest-risk trades in Australia. Falls from heights are a leading cause of fatalities and serious injuries in the construction industry, and roofing work — by its very nature — takes place at elevation. Getting your WHS documents right is not just a compliance exercise; it is a practical safeguard for your workers and your business.
This guide sets out the core WHS documents that roofing businesses commonly need, explains what each document must cover, and highlights the particular importance of working-at-heights documentation.
Note: WHS legislation in Australia is based on the model Work Health and Safety Act 2011 developed by Safe Work Australia, but each state and territory has its own laws and regulators. Always check the requirements in your jurisdiction.
At a glance
| Your role | Key obligations |
|---|---|
| Any roofing business | WHS policy, SWMS for HRCW, fall protection records, registers, induction records, incident register |
| Principal contractor | WHS management plan (notifiable construction work), site safety file, subcontractor coordination |
| Subcontractor roofer | SWMS for your activities, compliance with principal contractor's site rules, current licences |
| Employer (with workers) | Training register, return-to-work program, toolbox talk records |
Core WHS documents required
The following table summarises the documents most commonly required or expected for a roofing business operating in Australia.
| Document | Why it is needed |
|---|---|
| WHS Policy | Demonstrates leadership commitment to health and safety; required under the WHS Act for businesses with workers |
| SWMS — Working at Heights / Roofing | Required for all HRCW activities; working at heights greater than 2 metres is HRCW and must have a SWMS before work commences |
| Fall Protection Equipment Inspection Records | Documents pre-use and periodic inspections of harnesses, lanyards, anchor points, guardrails, and other fall arrest or restraint equipment |
| Height Rescue Plan | Sets out how an injured or incapacitated worker will be safely rescued from an elevated position; required wherever fall protection systems are in use |
| Site Induction Records | Demonstrates all workers and visitors have received site-specific safety information, including height hazards |
| Worker Licences and Competencies Register | Records current licences (white cards, EWP tickets, roofing contractor licences) and competencies for each worker |
| Plant and Equipment Register | Tracks ladders, EWPs, scaffolding, nail guns, and other plant — including inspection dates and operator qualifications |
| Incident Register | Records all incidents, near misses, and injuries; supports investigation and regulatory reporting |
| Hazard / Risk Register | Documents identified hazards, risk ratings, and controls across your roofing activities |
| Emergency Plan | Sets out emergency response procedures, including fall rescue and first aid response |
| Toolbox Talk Records | Documents safety briefings conducted with workers, including height-specific topics |
| Insurances Register | Maintains evidence of current public liability and workers compensation insurance policies |
| Contractor / Subcontractor Register | Documents any businesses or trades engaged, their licences, insurance certificates, and submitted SWMS |
| First Aid Register | Records first aid treatment provided on site |
| Return-to-Work Program | Required for employers in most states; supports injured workers back into the workplace |
SWMS and working at heights — the #1 priority
Working at heights is the single most critical WHS issue for roofing businesses in Australia. Under the model WHS Regulations, a Safe Work Method Statement is required before commencing any high risk construction work, and work at heights greater than 2 metres is explicitly listed as HRCW. This means that virtually every roofing job — from a domestic re-roof to a large commercial installation — requires a SWMS in place before work begins.
Your roofing SWMS must:
- Identify the specific HRCW activity (e.g. installation of metal roof sheeting at heights greater than 2 metres)
- Identify all hazards associated with the activity, including fall hazards, fragile surfaces, roof edges, skylights, and unstable substrates
- Set out the risk controls that will be applied — for example, edge protection, safety mesh, personal fall arrest systems, or restricted access zones
- Be reviewed and signed by workers before they commence the activity
- Be kept on site and readily accessible throughout the works
Where a job involves multiple HRCW activities — for example, working at heights and working near energised electrical services or in a roof void that may constitute a confined space — each activity must be addressed in the SWMS.
For detailed guidance on preparing a compliant roofing SWMS, see:
Fall protection equipment inspection records
Fall protection equipment is only effective if it is in good working order. A harness with a damaged stitching, a lanyard past its service life, or an anchor point that has never been load-tested provides little real protection. WHS regulators and principal contractors increasingly expect documented evidence that fall protection equipment is being inspected and maintained properly.
Fall protection inspection records should capture:
- Each item of equipment (harness, lanyard, self-retracting lifeline, anchor sling, karabiner, etc.) with a unique identifier
- The date and result of each pre-use inspection
- The date and result of periodic detailed inspections (typically at least six-monthly, or per the manufacturer's instructions)
- The name of the person who carried out each inspection
- Any defects found and the action taken (repaired, removed from service, replaced)
- The date of manufacture and next scheduled retirement or replacement
Equipment that fails inspection or has reached the end of its service life must be removed from service immediately and destroyed or clearly marked to prevent re-use.
Height rescue plan
A height rescue plan is a document that often goes missing from roofing WHS systems, yet it is one of the most important. Suspension trauma — also known as harness hang syndrome — can become life-threatening within minutes of a worker being suspended in a harness after a fall. The ability to perform a prompt, safe rescue is not optional.
A height rescue plan for a roofing business should:
- Be specific to the site or work type
- Identify the rescue method (self-rescue, assisted rescue, or emergency services rescue)
- Set out the equipment and procedures required to effect a rescue
- Identify who is responsible for rescue and what training or competency they hold
- Include the relevant emergency services contact numbers
- Be communicated to all workers before work at heights commences
Where the nature of the work makes self-rescue or assisted rescue impractical, the rescue plan must account for this and ensure emergency services can access the site promptly.
WHS policy and procedures
A WHS policy is a statement of commitment from the person conducting a business or undertaking (PCBU). It sets out the organisation's obligations, who is responsible for what, and how WHS is managed. A written WHS policy is broadly expected for any business with workers and is routinely requested by clients, principal contractors, and insurers.
Supporting WHS procedures provide the detail behind the policy. Common WHS procedures for roofing businesses include:
- Hazard identification and risk assessment procedure
- Working at heights procedure (including edge protection selection, harness use, and ladder safety)
- Fall protection equipment inspection procedure
- Incident reporting and investigation procedure
- Emergency response procedure (including height rescue)
- Contractor and subcontractor management procedure
- Plant and equipment inspection procedure
Worker licences and competencies register
Roofing businesses must ensure that workers hold the right licences and competencies for the work they perform. A licences and competencies register provides an up-to-date record that is easy to check before mobilising workers to a site.
The register should include, for each worker:
- General construction induction (white card) number and date of issue
- Any high risk work licences held — particularly EWP tickets for workers operating elevated work platforms with a boom length greater than 11 metres
- Any trade certificates or roofing contractor licence numbers required in your jurisdiction
- Expiry dates for any time-limited licences or tickets
- First aid certificates and expiry dates
A well-maintained licences register protects your business by demonstrating due diligence, and helps you quickly identify when renewals are needed.
Plant and equipment register
Roofing work involves a range of plant and equipment that carries its own risks — ladders, scaffolding, nail guns, tile cutters, EWPs, and lifting equipment. A plant and equipment register provides a systematic record of what equipment is in use, its inspection history, and whether operators hold the required competencies.
The register should track:
- A description and unique identifier for each item of plant
- The date of the most recent inspection and the result
- The next scheduled inspection date
- Any defects found and corrective action taken
- For plant requiring a licensed operator, the names of licensed workers authorised to use it
Pre-start inspections for plant items such as EWPs and scaffolding should be documented and retained.
Insurances register
Maintaining evidence of current insurances is important both as a regulatory matter and as a practical business requirement. Principal contractors routinely require subcontractors to provide certificates of currency before mobilising to site. An insurances register or file should hold:
- Current certificate of currency for public liability insurance (typically $20 million minimum, though clients and principal contractors may require more)
- Current workers compensation insurance policy details (required if you employ workers)
- Any other relevant policies (e.g. tools of trade, management liability)
Certificates of currency should be checked for renewal dates and updated as a matter of routine.
Records and registers
Good record keeping is a practical and legal necessity for roofing businesses. Key records to maintain include:
- Incident register: All incidents, near misses, dangerous occurrences, and work-related illnesses should be recorded. Falls and near-miss falls should always be recorded and investigated, even where no injury resulted.
- Toolbox talk records: Toolbox talks should be documented, including the date, topic, who conducted the briefing, and who attended. Height safety and fall prevention are appropriate recurring topics.
- First aid register: Records the name of the person treated, the nature of the injury or illness, and the treatment provided.
- Hazard and risk register: Captures ongoing hazard identification, risk ratings, and the controls in place — including height-related hazards specific to particular roof types or substrates.
Example scenario
Consider a roofing contractor in New South Wales operating with a team of six workers carrying out residential re-roofing and new-build roof installation. On a typical residential re-roofing project, the business would typically hold:
- A SWMS for working at heights reviewed and signed by workers before work commences on each site, addressing fall hazards specific to that roof — including pitch, edge conditions, fragile surfaces, and access and egress
- Fall protection equipment inspection records for every harness, lanyard, and anchor sling in use, completed before the equipment is put to work
- A height rescue plan communicated to workers at each site, with rescue equipment accessible on site
- Site induction records signed by each worker before commencing work
- A licences and competencies register confirming current white cards, EWP tickets where applicable, and any required contractor licences
- A plant and equipment register covering scaffolding, EWPs, ladders, nail guns, and other items — with pre-start inspection records
- An incident register maintained in real time, with any notifiable incidents reported to SafeWork NSW
- Current certificates of currency for public liability and workers compensation insurance, available to provide to clients and principal contractors on request
- Toolbox talk records from regular safety briefings, including roof-specific topics such as harness use, edge protection, and rescue procedures
At the business level, this contractor also maintains a WHS policy, core WHS procedures (including a working at heights procedure and height rescue procedure), and a return-to-work program as an employer.
Frequently asked questions
Does a sole trader roofer need WHS documents?
Yes. Sole traders are PCBUs under the WHS Act and carry the same core obligations as any roofing business. If you carry out high risk construction work — which includes all roofing work at heights greater than 2 metres — you must have a SWMS in place before work commences. You also need a WHS policy, an incident register, and records of any licences and competencies. The documents may be simpler than those of a larger business, but the obligation to have them is the same.
When is a SWMS required for roofing work?
A SWMS is required before commencing any high risk construction work (HRCW). Working at heights greater than 2 metres is HRCW, which means virtually all on-roof work requires a SWMS. If your roofing work also involves other HRCW activities — such as work near energised electrical services, work in confined spaces (e.g. roof voids), or use of a crane or EWP — those activities also require their own SWMS coverage. SWMS must be kept on site and readily accessible to workers.
What licences do roofing workers need in Australia?
Roofing workers and businesses may need a range of licences depending on state or territory and the specific work being performed. A general construction induction card (white card) is required for all workers on construction sites. Where an elevated work platform (EWP) is used, an EWP operator ticket (high risk work licence) is required for EWPs with a boom length greater than 11 metres. Some states also require a specific roofing contractor licence. Check with your state or territory WHS regulator and licensing authority for the requirements in your jurisdiction.
How often should a roofing SWMS be reviewed?
A SWMS should be reviewed before each new project or if site conditions, work scope, or the methods of work change. If a notifiable incident occurs, the SWMS should be reviewed immediately. Workers should re-read and re-sign the SWMS whenever it is updated. At minimum, SWMS should be formally reviewed at least annually as part of your broader WHS document review cycle. A documented review date helps demonstrate due diligence if the SWMS is ever examined by a regulator or principal contractor.
Get your roofing WHS documents in order
Blue Safe Online provides ready-to-use WHS document systems for Australian roofing businesses. Whether you are setting up a WHS system from scratch, updating outdated SWMS, or preparing a complete height safety document package, the Blue Safe Online platform gives you access to professionally prepared WHS policies, working-at-heights SWMS, fall protection inspection records, rescue plans, registers, and more — tailored to the roofing industry.
Browse roofing WHS documents on Blue Safe Online
This guide provides general information only and does not replace legal advice or consultation with the relevant WHS regulator. WHS document requirements may vary by state or territory, project type, contract conditions, and the nature of your role on site.