Working at Heights Permit

What Is a Working at Heights Permit?

A Working at Heights Permit is a formal document used to control high-risk work where a person could fall and suffer an injury. In Australian workplaces, it acts as a final safety check. It confirms that a Person Conducting a Business or Undertaking (PCBU) has assessed the risks and that all necessary safety controls are in place before anyone steps off the ground.

This document is not just paperwork. It is a legal tool that bridges the gap between planning and action. While a Safe Work Method Statement (SWMS) outlines how the job should be done safely over the course of a project, the permit verifies that those specific conditions are met on that specific day. It confirms that the weather is suitable, the equipment is inspected, and the workers are competent.

Under the model Work Health and Safety (WHS) laws adopted across most of Australia, this permit is crucial for satisfying the primary duty of care. It provides evidence that a PCBU has taken all reasonably practicable steps to manage the risk of a fall.

When to Use This Document

You must use a Working at Heights Permit whenever a worker is required to perform a task where a fall could result in death or serious injury. The regulations set specific triggers that require this level of administrative control.

High Risk Construction Work

Under the WHS Regulations, "High Risk Construction Work" includes work that involves a risk of a person falling more than 2 metres. If you are undertaking this type of work, the law requires a SWMS. The permit serves as the operational authorization that verifies the controls listed in that SWMS are actually active on site.

General Industry and Maintenance

For general industry or maintenance outside of construction, the 2-metre rule is not the only trigger. You must use a permit whenever there is a risk of a fall, regardless of the height. This includes working:

• Near fragile surfaces (such as skylights or fibreglass roofing).
• On steep roofs where a person could slide to the edge.
• Over pits, open shafts, or water.

Specific Risk Factors

Certain situations demand a permit even at lower heights if the risk is severe. This includes working near traffic, using mobile plant while at heights, or working in extreme weather conditions where stability might be compromised. If the risk cannot be eliminated at the design stage, a permit ensures that the remaining risks are managed through strict engineering and administrative controls.

Key Sections and Required Elements

A robust permit does more than list names. It forces the user to walk through the hierarchy of controls physically. Here are the essential sections every Australian Working at Heights Permit must contain to be legally compliant and practically useful.

Job Details and Scope

The document must clearly identify the specific task. General descriptions like "roof work" are insufficient. You need the exact location, the height involved, and the duration of the task. This section should also reference the specific Risk Assessment conducted for the job. The Safe Work Australia Code of Practice stresses that the risk must be quantified before work starts, so including a risk matrix score here is best practice.

Hierarchy of Controls Confirmation

This is the most legally critical section. Under WHS Regulation 79, you must manage risks in a specific order: eliminate the hazard first, then use engineering controls, then administrative controls, and finally Personal Protective Equipment (PPE). The permit must explicitly ask the user to confirm why higher-level controls are not being used. For example, if a worker is using a harness (PPE), the form must require a justification for why scaffolding (Engineering) was not used. This prevents the lazy defaulting to PPE, which is a common compliance failure.

Equipment Inspection Register

You cannot use height safety equipment without proof it is safe. This section must record the tag numbers of all harnesses, lanyards, and anchors. It must confirm compliance with AS/NZS 1891.4:2020 regarding equipment selection and maintenance. You need to see the inspection date and confirm the equipment has a current "Green Tag" or similar visual inspection marker. Without this, you are likely breaching the standards for fall-arrest systems.

Emergency and Rescue Procedures

A common misconception is that calling 000 constitutes a rescue plan. If a worker is suspended in a harness, they can suffer suspension trauma within minutes. The permit must verify that a specific rescue plan is in place and that rescue equipment is physically present on the site. It should detail the retrieval method, whether it is a self-rescue or a man-basket retrieval, and confirm that emergency services have been notified if the risk is high.

How to Write a Working at Heights Permit (Step by Step)

Creating a permit is a process of verification. Follow these steps to ensure the document is valid and the work site is safe.

Step 1: Define the Work and Hazards

Start by filling out the job details. Be specific about the height. Is it 2.5 metres on a double-storey house, or 10 metres on a commercial roof? Identify the specific hazards. Is there a risk of falling through a brittle roof? Are there power lines overhead? This information sets the context for the controls you will select.

Step 2: Select Controls According to the Hierarchy

Do not jump straight to harnesses. Look at the work environment. Can you use a scaffold or an elevating work platform (EWP)? If you are using ladders, justify why in the permit. If you are using a harness, you must record the type of harness and the anchor point. You must verify that the anchor point can withstand the required force, usually referencing AS 1657:2018 for fixed structures.

Step 3: Verify Worker Competency

Check the licences and training of the workers. Best practice requires the permit to state the specific competency class of the worker, such as the unit "RIIWHS204D Work safely at heights". You must sight the actual physical cards or verify them digitally. Signing off a worker who is not trained is a direct breach of WHS Regulation 39 regarding the provision of training.

Step 4: Inspect and Record Equipment

Before the permit is signed, inspect the gear. Check the webbing on harnesses for fraying. Check the lanyards for wear. Write down the serial or tag numbers on the permit. This creates a traceable audit trail. If a piece of equipment fails later, you have proof that it was passed as safe at the start of the shift.

Step 5: Emergency Rescue Plan Verification

Confirm the rescue plan. Ask the supervisor: "If a worker falls now, exactly how do we get them down?" If the answer involves waiting for the fire brigade without an interim plan to relieve suspension trauma, the permit is not valid. You must detail the rescue equipment available on site.

Step 6: Sign-off and Time Limit

The supervisor must sign the document to authorize the work. Remember, a permit is usually valid for a maximum of 12 hours or one shift. If the job runs longer or if there is a significant break, you must complete a new permit. This forces a re-assessment of the environment, particularly the weather, which is vital for outdoor work in Australia.

Common Mistakes to Avoid

Many businesses treat permits as a bureaucratic tick-box exercise rather than a live safety document. Avoiding these mistakes will protect your workers and your business from prosecution.

Treating the Permit as a "License to Work"

A permit does not authorize unsafe work. If conditions change, the permit becomes void immediately. For example, if a storm rolls in and wind speeds exceed the safety limits of your EWP or scaffolding, work must stop. Failing to include a "Stop Work" condition creates liability if a worker continues in bad weather. In Victoria, under the Occupational Health and Safety Act 2004, employers must maintain a safe environment, which includes monitoring changing conditions.

Generic Rescue Plans

Writing "Call 000" in the emergency section is a major error. While calling emergency services is necessary, it is not a rescue strategy for a suspended worker. Regulators and insurers view this as a failure to manage the risk. You need a specific plan that addresses the immediate hazards of the specific site.

Ignoring State Variations

While the WHS Act is national, Victoria uses its own OHS Act 2004. The principles are similar, but the terminology differs. Furthermore, some codes of practice vary by state. Ensure your WHS Policy reflects the specific legislation of the state or territory you are working in. Do not assume a NSW compliant permit will satisfy a VIC inspector without checking the specific local requirements.

Skipping the Supervisor Sign-off

Sometimes, in the rush to start a job, a worker might sign the permit themselves. This is a non-compliance. The law requires authorization from a supervisor or PCBU representative who has the authority to stop the work. This ensures an independent set of eyes checks the controls before the work begins.

Legal Considerations (AU)

Compliance with height safety requirements is non-negotiable in Australia. The penalties for getting it wrong are severe, including heavy fines and potential imprisonment.

Primary Duty of Care (Section 19)

Under Section 19 of the Work Health and Safety Act 2011 (Cth), a PCBU must ensure, so far as is reasonably practicable, the health and safety of workers. This is the overarching legal obligation. A permit is evidence that you have actively discharged this duty. It demonstrates that you have identified the risk and implemented controls. Without this document, it is very difficult to prove you took "reasonably practicable" steps if an incident occurs.

Managing Risks of Falls (Regulation 78-80)

The WHS Regulations provide specific instructions on managing fall risks. Regulation 78 requires a PCBU to manage the risk of a fall. Regulation 79 mandates the specific hierarchy of controls mentioned earlier. Regulation 80 deals with the specific control measures themselves. Your permit must map directly to these regulations. If an inspector looks at your permit and sees you have skipped a control level without justification, you will be breaching Regulation 79.

Safe Work Method Statements (Regulation 291)

For "High Risk Construction Work," Regulation 291 mandates a SWMS. The permit does not replace the SWMS. It works with it. The SWMS is the planning document; the permit is the go-ahead document. You cannot legally commence high-risk construction work without both. The permit references the SWMS to ensure the worker on the ground is following the plan written by management.

Duty to Consult

The permit process is also a mechanism to meet your duty to consult workers under Section 48 of the WHS Act. By filling out the permit with the workers on site, you are consulting them about the hazards and the controls. This collaborative approach is often looked upon favourably by regulators and leads to safer outcomes.

Victorian Specifics

If you are working in Victoria, the Occupational Health and Safety Act 2004 applies. Section 21 imposes the duty of care on employers. The principles of risk management are identical to the WHS framework. However, compliance with the relevant Compliance Codes for Falls is essential in Victoria to demonstrate you have met your duties.

Frequently Asked Questions (preview)

Do I need a permit for working on a ladder? Not always. If the ladder is being for a short duration and the risk is low, a risk assessment might suffice. However, if the work is complex, involves two-handed work at height, or is near an edge, a permit should be used to ensure the ladder is secured and the work is authorized.

Who can sign a Working at Heights Permit? A competent person, usually a supervisor, site foreman, or the PCBU. This person must have the authority to stop the work and the knowledge to verify that the controls listed in the permit are adequate.

How long is the permit valid for? Typically, a permit is valid for one shift or 12 hours. This is industry best practice because site conditions, particularly weather, can change quickly. You should not use a permit issued on Monday for work done on Wednesday.

Is a digital permit valid? Yes. Digital permitting systems are becoming the standard in Australia. They offer advantages like geo-tagging and time-stamping. Insurers and regulators accept digital records as long as they capture the same information and require the same level of authentication as a paper document.

Can a permit be transferred between workers? No. A permit is usually issued to a specific team or individual for a specific task. If the crew changes or the task scope changes, a new permit or a variation to the existing permit is required to ensure the new workers are briefed on the risks.