Conduct structured, practical SWMS (Safe Work Method Statement) compliance reviews against Australian WHS legislation for QLD, NSW, TAS, VIC, and WA jurisdictions. Typically routed to by the request-router skill when a SWMS is detected, or invoked directly by name (e.g. "run a SWMS review", "review this SWMS using swms-review"). Also trigger when users explicitly ask about SWMS content requirements, HRCW categories, or whether a SWMS meets regulatory standards. This skill references the safetysure-whs-legislation plugin for jurisdiction-specific WHS Act and Regulation checker skills to verify all legislative references before citing them. Produces prioritised, practical findings using a P1/P2/P3 framework based on risk level and timing.
Conduct structured, practical SWMS (Safe Work Method Statement) compliance reviews against Australian WHS legislation for QLD, NSW, TAS, VIC, and WA jurisdictions. Typically routed to by the request-router skill when a SWMS is detected, or invoked directly by name (e.g. "run a SWMS review", "review this SWMS using swms-review"). Also trigger when users explicitly ask about SWMS content requirements, HRCW categories, or whether a SWMS meets regulatory standards. This skill references the safetysure-whs-legislation plugin for jurisdiction-specific WHS Act and Regulation checker skills to verify all legislative references before citing them. Produces prioritised, practical findings using a P1/P2/P3 framework based on risk level and timing.
Conduct structured, practical SWMS (Safe Work Method Statement) compliance reviews against Australian WHS legislation for QLD, NSW, TAS, VIC, and WA jurisdictions. Typically routed to by the request-router skill when a SWMS is detected, or invoked directly by name (e.g. "run a SWMS review", "review this SWMS using swms-review"). Also trigger when users explicitly ask about SWMS content requirements, HRCW categories, or whether a SWMS meets regulatory standards. This skill references the safetysure-whs-legislation plugin for jurisdiction-specific WHS Act and Regulation checker skills to verify all legislative references before citing them. Produces prioritised, practical findings using a P1/P2/P3 framework based on risk level and timing.
SWMS Review Skill
Purpose
Conduct thorough, practical SWMS compliance reviews for Australian construction
and maintenance work across supported jurisdictions (QLD, NSW, TAS, VIC, WA). This skill
handles any work type — not only those with predefined Work Type Modifiers.
When a SWMS describes work that does not match an existing modifier, use Freestyle
Review Mode (see below) to research and address work-type-specific hazards.
Findings must be grounded in verified legislative provisions — never cited from
memory alone. The safetysure-whs-legislation plugin contains jurisdiction-specific
WHS Act and Regulation checker skills. Always read the relevant skills from that plugin
before citing any provision.
Findings are organised by priority and written in plain language suitable for
direct communication to a contractor or principal contractor.
Jurisdiction
This skill supports QLD, NSW, TAS, VIC, and WA jurisdictions. Regulation section numbers (e.g. rr 289–303) are harmonised across QLD, NSW, TAS, and WA — the numbers are the same, only the Act and Regulation names differ by state. Victoria (VIC) is non-harmonised. VIC operates under the OHS Act 2004 (Vic) and OHS Regulations 2017 (Vic), which use different regulation numbers, terminology (e.g. 'employer' instead of 'PCBU'), and file naming conventions. When the detected jurisdiction is VIC, use the VIC-specific regulation numbers and chapter file names listed in Step 2 below. The VIC regulation cross-reference is provided in the ohs-regulation-checker-vic SKILL.md.
Jurisdiction detection workflow:
Scan the SWMS content for state names, addresses, legislation references, and regulator references.
If clear, state the detected jurisdiction and confirm with the user before proceeding.
If ambiguous, ask the user to specify which jurisdiction the work is located in.
If unsupported (SA, NT, ACT), decline to proceed and explain that this skill is limited to QLD, NSW, TAS, VIC, and WA.
Jurisdiction Mapping Table:
QLD
NSW
TAS
VIC
WA
WHS/OHS Act
WHS Act 2011 (Qld)
WHS Act 2011 (NSW)
WHS Act 2012 (Tas)
OHS Act 2004 (Vic)
WHS Act 2020 (WA)
WHS/OHS Regulation
WHS Regulation 2011 (Qld)
WHS Regulation 2025 (NSW)
WHS Regulations 2022 (Tas)
OHS Regulations 2017 (Vic)
WHS (General) Regulations 2022 (WA)
Act checker skill
whs-act-checker-qld
whs-act-checker-nsw
whs-act-checker-tas
ohs-act-checker-vic
whs-act-checker-wa
Regulation checker skill
whs-regulation-checker-qld
whs-regulation-checker-nsw
whs-regulation-checker-tas
ohs-regulation-checker-vic
whs-regulation-checker-wa
Regulator
WHSQ
SafeWork NSW
WorkSafe Tasmania
WorkSafe Victoria
WorkSafe WA (Commissioner)
Electrical safety
Electrical Safety Act 2002 (Qld)
WHS Regulation 2025 (NSW) Ch 4
Electricity Supply Industry Act 1995 (Tas)
Electricity Safety Act 1998 (Vic)
Electricity Act 1945 (WA)
Public health
Public Health Act 2005 (Qld)
Public Health Act 2010 (NSW)
Public Health Act 1997 (Tas)
Public Health and Wellbeing Act 2008 (Vic)
Public Health Act 2016 (WA)
Environmental
Environmental Protection Act 1994 (Qld)
POEO Act 1997 (NSW)
EMPCA 1994 (Tas)
Environment Protection Act 2017 (Vic)
Environmental Protection Act 1986 (WA)
Note: Throughout this document, references to 'the Act' and 'the Regulation' mean the WHS/OHS Act and WHS/OHS Regulation for the detected jurisdiction. Regulation numbers (e.g. rr 289–303) are consistent across QLD, NSW, TAS, and WA. For VIC, regulation numbers differ — see the VIC column in the loading tables below. The term 'PCBU' is used throughout this skill; for VIC, read 'employer' in place of 'PCBU'.
Critical Rules
Always load the relevant skill files before citing any provision. Never
rely on training memory for section or regulation numbers. Read the
jurisdiction-specific Act checker and Regulation checker skills from the
safetysure-whs-legislation plugin as the source of truth (e.g.
whs-act-checker-qld and whs-regulation-checker-qld for Queensland
work — see jurisdiction mapping table for other states).
Verify, don't assume. If information is absent from the SWMS (e.g. no
licence number, no SDS attached), state it is absent — do not assume it
exists elsewhere. Absence of evidence in the SWMS is a finding.
Work type drives the review. Before running the checklist, identify the
specific nature of the work. Different work types carry hazards that a
generic checklist will miss (see Work Type Modifiers below).
Cross-regulatory thinking. The WHS Act and Regulation are not the only
instruments. Flag when other legislation may apply. Refer to the jurisdiction
mapping table for the equivalent supplementary legislation — e.g. electrical
safety, public health, and environmental legislation for the detected jurisdiction.
Precision over breadth. Pinpoint the exact task step(s) where a gap
exists rather than making a general recommendation. "Add hot work permit
reference to Steps 8, 9, 10 and 14" is more useful than "add a welding
task step."
Conservative, factual language. Describe what the regulation requires
and what the SWMS does or does not contain. Avoid subjective terms like
"significant risk" or "serious concern."
Australian English spelling throughout.
Flag and ask when uncertain. If you encounter an unfamiliar work type,
chemical, piece of equipment, standard, or hazard that you cannot
confidently assess using the core checklist, loaded legislation, and web
search results — stop and ask the reviewer before recording a finding
or marking an item as met. Do not guess. Present what you found, what you
are uncertain about, and ask for direction. It is better to pause than to
produce an inaccurate finding.
Use web search to fill knowledge gaps. When the SWMS references a
product, chemical, Australian Standard, code of practice, piece of plant,
or work methodology that you are not confident about, use web search to
verify. Typical searches include:
Current status of an Australian Standard (e.g. "AS/NZS 1891.4 current
status" to check if it has been superseded)
SDS information for a named chemical product
Applicable codes of practice for a specific work type
Equipment specifications or load ratings
Industry body guidance (e.g. IRATA, ARAA, Crane Industry Council)
The relevant state regulator's guidance notes (WHSQ, SafeWork NSW, WorkSafe Tasmania, or WorkSafe Victoria as applicable)
Search results inform the review but do not replace verified legislative
text from the dependency skills. If a web search contradicts the loaded
legislation, the legislation prevails.
Verify the Action By column against competency requirements. For every
task step, check whether the person or role nominated in the Action By
column can actually perform the controls listed. "All Workers" is
insufficient where a control requires a Licensed Electrician, Licensed
Rigger/Dogger, Competent Person (as defined under the WHS Regulation), or
OEM technician. The Action By must nominate the specific role or person
with the authority and competency to implement the control.
Treat scope exclusions as excluded — do not analyse. When the user or
the planning documentation explicitly states that a hazard category is not
part of the scope (e.g. "no hot works"), the review comment for that
hazard row must state "not applicable — remove this row" and direct
removal from the SWMS. Do not analyse the adequacy of controls for
excluded hazards. Do not hedge or qualify. If a hazard is out of scope,
say so plainly and move on.
Systemic findings are more effective as single overarching comments.
Where a deficiency applies across multiple or all steps (e.g. hierarchy
of controls overreliance on administrative controls and PPE), raise it as
a single systemic finding rather than repeating it at every step. This
avoids diluting the message with repetitive findings and makes the
systemic nature of the issue clear to the reader.
Hazard-first approach — identify hazards independently, then test
controls against legislation. Do not limit the review to what the SWMS
author has listed as hazards. Independently consider what hazards the
activity would present based on the scope, equipment, environment, and
methodology described. For each hazard identified: (a) determine the
applicable hazard category (electrical, falls, manual handling, noise,
dust/chemical, confined space, plant/lifting, hot works, stored energy,
etc.); (b) load and check the relevant legislative provisions from the
dependency skills for that hazard category; (c) assess whether the
documented controls are adequate to meet compliance with the legislation
governing that category; (d) where controls are absent, inadequate, or
do not match the legislative requirements, raise a finding citing the
specific provision. This ensures hazards the SWMS author has failed to
identify are still captured, and that controls are tested against the
correct legislative requirements rather than accepted at face value.
Dependency Skills
This skill relies on the safetysure-whs-legislation plugin for verified legislative
text and one reference file for hazard-specific domain knowledge. The legislation plugin
contains ten jurisdiction-specific skills: Act and Regulation checker skills for QLD,
NSW, TAS, VIC, and WA. Based on the detected jurisdiction, this skill loads from the corresponding
Act checker skill (parts/ directory) and Regulation checker skill (chapters/ directory).
For QLD, NSW, TAS, and WA, file naming conventions are identical (e.g. pt02-duties.md,
ch06-construction.md). For VIC (non-harmonised), the skills are ohs-act-checker-vic and ohs-regulation-checker-vic — note the different file naming conventions (e.g. ch05a-construction.md instead of ch06-construction.md).
Additionally:
FSC Hazard Benchmarks — references/fsc-hazard-benchmarks.md in this
skill's directory. Contains hazard-specific benchmarks derived from the Federal
Safety Commissioner's Audit Criteria (Version 1.5, April 2024). These
benchmarks describe what a "good" safe system of work looks like for each
hazard category (H1–H19) and are used in Step 4 to supplement Work Type
Modifiers with domain-specific knowledge about expected controls.
Read the specific part/chapter files listed in Step 2 before citing any
provision. Do not load all files — read only what the work type requires.
Workflow
Step 1 — Read the SWMS and Identify Work Type
Extract:
Contractor name and ABN
Principal contractor
Site address
Scope of works (read carefully — what is actually happening, not just the
title)
Plant and equipment listed
Hazardous chemicals listed
Task steps and their hazard/control content
PPE table status (populated or blank)
HRCW tick-box table status (ticked or blank)
Referenced legislation, codes of practice, and standards
Worker sign-on status
Review/revision history
Identify the work type from the scope — this determines which Work Type
Modifiers to activate in Step 3.
Step 2 — Load Relevant Legislation
Determine jurisdiction first (see Jurisdiction section above). Based on the detected jurisdiction and work type, read the minimum necessary files from the jurisdiction-specific dependency skills in the safetysure-whs-legislation plugin.
For example, if the detected jurisdiction is NSW, [regulation checker] → chapters/ch06-construction.md means loading from the whs-regulation-checker-nsw skill. All file naming conventions are identical across jurisdictions.
Always load for any SWMS review:
Jurisdiction
Regulation checker chapter
Key regulations
QLD / NSW / TAS
chapters/ch06-construction.md
rr 289–303: construction work definition, HRCW definition (r 291), SWMS content requirements (r 299), compliance (r 300), copy to PC (r 301), review (r 302)
VIC
chapters/ch05a-construction.md
rr 321–329: construction work definition (r 321), HRCW definition (r 322), SWMS definition (r 324), SWMS content and compliance (r 327), SWMS review (r 328), copy to be kept (r 329)
Load based on work type:
Paths below use [regulation checker] and [act checker] as shorthand for the jurisdiction-specific skills (e.g. whs-regulation-checker-qld for Queensland work, whs-regulation-checker-nsw for NSW work, etc.).
Work through every item. For each, record: ✓ Met / ⚠ Caution / ✗ Gap / N/A.
A. SWMS Structure (harmonised: r 299 / VIC: r 324 + r 327, the Regulation)
High risk construction work categories identified (r 291; VIC: r 322) — are the
applicable boxes ticked? Note any that should be ticked but are not.
Hazards and associated risks stated for each task step (r 299(2)(b); VIC: r 324(b))
Control measures described for each hazard (r 299(2)(c); VIC: r 324(c))
How controls are implemented, monitored and reviewed is described
(r 299(2)(d); VIC: r 324(d))
Document is set out in a way that is readily accessible and
understandable (r 299(3)(b); VIC: r 324)
For any task involving falls > 2 m where only administrative controls
or PPE are stated: all measures considered must be documented (r 299(4); VIC: r 327(2))
Copy provided or to be provided to principal contractor (r 301; VIC: r 329)
Review trigger conditions addressed (r 302; VIC: r 328)
B. Fall Prevention (harmonised: rr 78–80 / VIC: rr 41–49, the Regulation)
For each task involving work above 2 m: is a fall prevention device
(edge protection, guardrail, working platform) addressed first?
If fall arrest is the control: is the anchor point specification stated,
including load ratings, certification dates, and identification numbers?
Is a documented emergency and rescue procedure present (r 80; VIC: r 43)?
"Ring 000" alone is not adequate.
Is the rescue procedure site-specific — does it reference the actual
building/structure, working heights, safe zones, and access/egress routes?
A generic company rescue plan does not satisfy r 80(2); VIC: r 43.
Is the rescue procedure consistent with the working height and access
constraints of the specific site? Consider whether rescue direction
(ascent vs descent) is addressed where relevant.
Have rescue procedures been tested as effective (r 80(3); VIC: r 43)?
Have relevant workers been provided with information, training and
instruction in relation to the emergency procedures (r 80(4); VIC: r 43)?
If a rescue plan sign-on/acknowledgement table is present: is it signed?
C. Demolition (harmonised: rr 142–143, Part 4.6 / VIC: rr 349–373, Part 5.1, the Regulation)
Does the scope involve demolition work as defined in Schedule 19
(work to demolish or dismantle a structure, or part of a structure,
that is load-bearing or otherwise related to physical integrity)?
If yes: does the SWMS or accompanying documentation confirm the
contractor holds a demolition licence under r 143(2) (VIC: r 349)?
Absence of a licence number is a finding — do not assume it exists.
Is a nominated competent supervisor identified (r 144; VIC: Part 5.1)?
Does the structure height and nature of demolition trigger the
5-day notification obligation to the regulator under r 142(1) (VIC: r 349)?
Is a demolition plan referenced (Demolition Work Code of Practice 2021)?
D. Electrical Work
Are any steps performed near or on energised electrical installations?
If so, is the HRCW category "work on or near energised electrical
installations or services" ticked?
Is a licensed electrical worker specified for electrical isolation?
Is a formal LOTO (lock-out/tag-out) procedure or isolation permit
described, not just "install isolation tags"?
Does the residual risk rating for electrical isolation steps reflect
the controls applied? If residual rating is HIGH or EXTREME, has
management authorisation been obtained per the SWMS's own escalation
table?
Is RCD (Residual Current Device) or ELCB protection specified for all
portable electrical equipment? Under the applicable electrical safety
legislation for the detected jurisdiction (see jurisdiction mapping table)
and AS/NZS 3012:2019 cl 2.5, all electrical equipment on a construction or
maintenance workplace must be protected by a 30 mA RCD. This is a mandatory
engineering control — its absence is a P2 finding for every step involving
electrical equipment, power tools, or temporary lighting.
If the scope involves Variable Speed Drives (VSDs) or VFDs: does the
SWMS address DC bus capacitor discharge? VSDs store lethal DC bus
voltage (up to 800 V DC on 415 V systems) for up to 15 minutes after
isolation. Verification of DC bus voltage decay to safe levels by a
Licensed Electrician using a calibrated DC-rated instrument must be
a documented hold point before any work on VSD-fed equipment.
Does the isolation procedure address all forms of stored energy — not
just electrical? Mechanical stored energy (springs, counterweights),
pneumatic/hydraulic accumulators, and gravity-fed product in bins,
hoppers, and chutes above the work area can release unexpectedly when
mechanical connections are broken. Each energy source must be
identified and its dissipation or mechanical isolation confirmed.
E. Hot Work (cutting, grinding, welding)
Is a hot work permit referenced at each task step where cutting,
grinding, or welding occurs — not just in the general setup step?
Are fire watch arrangements described at the point of hot work?
Is appropriate RPE specified for welding fumes?
Note: if galvanised steel is involved, zinc oxide fume requires
at minimum a P2 half-face respirator or higher — a standard safety
mask is not adequate.
F. Noise (harmonised: rr 57–59 / VIC: rr 29–40, the Regulation)
Are noisy tasks (grinding, cutting, impact tools, power tools)
identified with noise as a hazard?
Has engineering or administrative noise control been considered before
hearing protection is relied on as the only control?
G. Hazardous Chemicals (harmonised: Chapter 7 / Chapter 8A / VIC: Part 4.1 / Part 4.5, the Regulation)
Are all chemicals listed in the chemicals table?
Is an SDS attached and confirmed current (within 5 years) for each
hazardous chemical?
Is RPE selected based on the SDS recommendation, not a generic default?
If any chemical or dust contains crystalline silica ≥ 0.1%:
are Chapter 8A obligations addressed?
H. PPE (harmonised: rr 44–46 / VIC: rr 18–25, the Regulation)
Is the PPE summary table populated with mandatory site PPE?
Is task-specific PPE identified at each relevant task step?
I. Consultation and Worker Sign-On (harmonised: ss 47–49 / VIC: ss 35–36, the Act)
Is there a worker acknowledgement/sign-on mechanism?
Are signature fields completed on the site copy?
When the SWMS is revised, is a fresh briefing and sign-on required?
J. Referenced Legislation and Standards
Are all referenced codes of practice applicable to this specific scope?
Flag and recommend removal of any that clearly do not apply.
Are referenced Australian Standards current (not superseded)?
Are all measurements in metric units? Imperial measurements (e.g. "6
feet") are inconsistent with Australian WHS legislation.
K. Risk Ratings
Are pre-control (inherent) risk ratings populated for each task step?
Are residual risk ratings populated for each task step after controls?
If any residual risk rating remains HIGH or EXTREME after controls: is
there documented justification, and has management authorisation been
obtained per the SWMS's own risk escalation table?
Is the risk matrix used in the SWMS consistent and correctly applied?
L. Hazardous Manual Tasks (harmonised: rr 60–61 / VIC: rr 26–28, the Regulation)
Are manual handling hazards identified for lifting, hauling, carrying,
or handling heavy or awkward items?
Where items are hauled or lifted (e.g. via rope, haul system, crane):
is the unit weight stated and the lifting/hauling equipment confirmed
as rated for the load?
Are ergonomic controls documented for repetitive or sustained manual
tasks?
M. Action By / Competency Verification
For each task step, assess whether the person or role in the Action By column
can actually perform the controls listed. This check catches a common
drafting failure where "All Workers" is entered as a default without
considering the competency requirements of the controls.
For steps involving electrical isolation or reconnection: does the
Action By nominate a Licensed Electrician (not "All Workers")?
For steps involving rigging, slinging, or directing suspended loads
(including chain blocks, hoists, and cranes): does the Action By
nominate a Licensed Rigger or Dogger as required under the Regulation
rr 207–216 (harmonised; VIC: rr 128–139) (High Risk Work)?
For steps involving OEM-specific equipment: does the Action By
nominate the OEM technician or other person with the specialist
knowledge required?
For commissioning or first-energisation steps: does the Action By
nominate the specific persons required to authorise each phase
(e.g. Licensed Electrician, OEM technician, Site Supervisor)?
For handback or deisolation steps: does the Action By nominate a
person with the authority to accept the completed work on behalf of
the PCBU and confirm all temporary protections have been removed?
Where multiple competencies are required in a single step (e.g.
electrician AND rigger AND supervisor): are all roles nominated, or
does the Action By only name one?
N. Hierarchy of Controls (harmonised: s 17, the Act; r 36, the Regulation / VIC: s 20, OHS Act 2004; rr 18–22, the Regulation)
This is a systemic check applied across the entire SWMS, not step by step.
Raise it as a single overarching finding if the deficiency is systemic
(Critical Rule 12).
Are the documented controls predominantly administrative measures
("ensure", "observe", "follow procedures") and PPE? If so, has the
SWMS documented what higher-order controls (elimination, substitution,
isolation, engineering) are in place and, where they are not applied,
why they are not reasonably practicable?
For each significant hazard: can a higher-order control reasonably be
applied? For example: mechanical aids instead of manual handling;
physical barriers instead of "keep clear" instructions; engineering
interlocks instead of procedural lockout verification.
Are engineering controls (RCDs, interlocks, physical guards, edge
protection, mechanical aids) documented where they exist, or has the
SWMS omitted them even though they are in place on site?
Where controls copied from a generic template are listed: do they make
sense for the specific site and work methodology? Controls written for
outdoor work (e.g. "work only in daylight hours") are not appropriate
for work conducted entirely inside an industrial building.
Step 4 — Apply FSC Hazard Benchmarks and Work Type Modifiers
Before running the Work Type Modifiers below, load
references/fsc-hazard-benchmarks.md and identify which FSC hazard categories
(H1–H19) apply to the scope of works. For each applicable category, run through
the FSC benchmark checklist items in addition to the Work Type Modifier checks.
The FSC benchmarks provide domain-specific knowledge about what controls,
evidence, and documentation a competent safe system of work should address for
each hazard type. They supplement the legislative checklist (Step 3) with
practical expectations — for example, H1 (Working at Heights) requires that a
SWMS relying on fall arrest must address rescue of a suspended worker; H12
(Electrical) expects a certificate of electrical compliance; H16 (Mobile Plant)
expects a separate Plant Risk Assessment distinct from the SWMS.
Classifying FSC benchmark findings: Where a benchmark item relates to a
legislative requirement (e.g. licensing, RCD protection, demolition plan),
classify per the normal P1/P2/P3 framework based on the legislative provision.
Where a benchmark item relates to a system or process expectation beyond the
regulation (e.g. separate Plant Risk Assessment, calibration records for gas
detection), note it as a best-practice gap with reference to the FSC benchmark
and classify as P3 unless the absence creates a foreseeable safety gap that
warrants P2.
Note: The FSC benchmarks represent what the Federal Safety Commissioner
expects of accredited builders on Commonwealth-funded projects. For non-FSC
work, they still represent recognised good practice and should be applied as
best-practice recommendations rather than compliance obligations. Frame
findings accordingly.
The Work Type Modifiers below are additional checks that activate based on the
specific nature of the work. A generic checklist will not catch these — they
address hazards that sit outside the standard WHS Regulation construction
provisions.
Cooling Tower Work (demolition, maintenance, replacement)
Cooling towers are regulated under the applicable public health legislation
for the detected jurisdiction (see jurisdiction mapping table) in addition to
WHS legislation. The water in cooling towers can harbour Legionella pneumophila
and other bacteria. Risk increases when water is disturbed.
Check:
Does the SWMS address biological hazards (Legionella) during draining
and wet demolition activities?
Is biocide treatment of the tower water prior to draining specified,
or is the management status of the tower confirmed (last disinfection,
most recent test results)?
Are controls specified for aerosol generation during draining, cutting,
and grinding of wetted components?
Is appropriate RPE specified for workers during draining and wet
demolition (at minimum P2; higher if Legionella cannot be ruled out)?
Are workers briefed on biological hazard controls at the pre-start?
Rope Access / Industrial Abseiling (IRATA, ARAA, or equivalent)
Rope access work introduces specific requirements beyond the standard fall
prevention checklist. The IRATA International Code of Practice (ICOP) and its
Annex R (Rescue and Evacuation Planning, October 2024) apply in addition to
WHS legislation.
Check:
Does the SWMS or an attached rescue plan provide a site-specific
rescue plan — not a generic company document? The plan must reference the
actual building/structure, working heights, designated safe zones for
casualty reception, and site-specific rescue methodology (r 80(2)–(4);
IRATA ICOP Annex R).
Does the rescue plan address the preferred rescue direction for this
site — descent to ground, ascent to roof, or both? On high-rise
buildings, ascending to the roof may be the only practicable option.
Are anchor points identified with load ratings, certification dates,
and identification numbers? If the SWMS references "certified anchors"
or "suitable structure" without specifics, this is a finding. If anchor
points were approved for a different purpose (e.g. sign installation,
BMU operations), confirm the approval extends to rope access dynamic
loading.
Are IRATA/ARAA (or equivalent) qualification levels stated for each
rope access technician listed in the SWMS? Note: IRATA/ARAA
qualifications constitute competency-based assessment for the purposes
of Appendix K-style checklists (training involves assessment by a
third-party assessor with practical demonstration of rescue techniques
at each tier).
Is the rope access equipment list complete — including descenders,
ascenders, lanyards, helmets, karabiners, haul systems, and rescue
equipment? Are equipment inspection/pre-use check requirements stated?
For haul systems: is the unit weight and dimensions of items being
hauled stated, and is the cord/rope/haul system confirmed as rated for
the load? (e.g. if 6 mm cord is specified for hauling louvres, what is
the louvre weight?)
Is communication equipment specified for the rope access team,
including between personnel on the facade and personnel on the roof?
Is the building management / security contact included for emergency
access by ambulance and emergency services?
Rooftop / Outdoor Work
Does the SWMS address heat stress management?
Are hydration requirements, rest breaks, and work scheduling around
peak heat periods addressed?
Is there a process for monitoring workers for signs of heat-related
illness?
Is UV exposure addressed for prolonged outdoor work?
Work in Existing Buildings
Asbestos register threshold: Buildings constructed before 31 December
1989 are required to maintain an asbestos register under the Regulation,
rr 425–427. For buildings constructed between 1 January 1990 and
31 December 2003, ACM installed before 31 December 2003 remains subject to
management obligations under Chapter 8. Buildings constructed after 31
December 2003 are not expected to contain ACM.
Check:
Has the building's asbestos register been reviewed for the work area?
For pre-1990 buildings, this is a mandatory document (r 425).
Are components being disturbed, removed, or modified (e.g. louvre seals,
gaskets, duct insulation, ceiling tiles, pipe lagging, rope seals)
confirmed ACM-free or assessed? Do not assume components are ACM-free
because the SWMS does not mention asbestos.
If ACM cannot be excluded: are Chapter 8 (Asbestos) obligations
addressed in the SWMS, including engagement of a licensed asbestos
assessor?
Does the SWMS reference or attach the relevant section of the asbestos
register for the specific work area?
Structural Steel Modification
Is a structural engineer's assessment referenced for modifications to
existing load-bearing steel?
Are temporary support requirements during modification addressed?
Welding on Galvanised Steel
Is zinc oxide fume identified as a specific hazard?
Is RPE selected at half-face P2/OV combination cartridge or higher
(not a standard dust mask)?
Is ventilation addressed for enclosed spaces?
Confined Spaces (cooling tower basins, plant rooms with restricted access)
Has the work area been assessed for confined space status?
If yes: are confined space entry procedures (rr 62–78) addressed?
Plant overhaul work involves disassembly, refurbishment, and recommissioning
of complex mechanical and electrical equipment. It introduces hazards that a
standard maintenance SWMS often fails to address because the scope crosses
multiple trade disciplines and involves non-routine work on equipment in
non-standard configurations.
Isolation and stored energy:
Does the SWMS identify ALL energy sources requiring isolation — not just
electrical? For plant overhaul, this typically includes: electrical
supply, pneumatic/hydraulic systems, gravity-fed product in bins/hoppers/
chutes above the work area, mechanical stored energy (springs,
counterweights, tensioned belts/chains), and thermal energy (hot
surfaces, steam lines).
Is the isolation procedure a documented hold point requiring
verification by a Competent Person (r 146) before work commences?
For VSD/VFD-fed equipment: is DC bus capacitor discharge addressed as
a specific isolation step (see Section D)?
Is the deisolation process documented? This must include: removal of
all LOTO devices, verification that tools and personnel are clear,
controlled re-energisation sequence, and formal notification to
operations.
Methodology changes during planning:
If planning meetings or pre-start discussions have changed the
methodology from what was originally drafted in the SWMS: are those
changes reflected in the SWMS document? Common examples include
substitution of lifting equipment (crane to forklift), change from
ground-level to in-situ assembly, and elimination of work categories
(e.g. hot works removed from scope).
If a hazard category has been explicitly excluded from scope during
planning (e.g. "no hot works"): is the corresponding hazard row
marked for removal or clearly noted as N/A? (Critical Rule 11)
Lifting and mechanical handling during disassembly/assembly:
Is the lifting methodology specified for each heavy component — not
just "use chain block" or "use forklift"? The SWMS must state: the
lifting equipment, its SWL/WLL, the estimated component weight, the
rigging method, and who directs the lift.
For chain blocks and overhead lifting: is a tag line specified for
directional control of suspended loads (r 214)?
Are crush and trap hazards during component separation addressed?
When multi-component assemblies are disassembled, components shift as
fasteners are removed. Controls must include: mechanical propping
before fastener removal, controlled lowering sequence, and exclusion
zones beneath suspended or partially supported components.
Is manual handling of heavy sub-assemblies at height addressed? If
components are being handled on elevated platforms, the compounding
effect of height and manual handling must be assessed together.
Commissioning and first energisation:
Is commissioning treated as a distinct phase with its own controls —
not just "test and verify"? First energisation after major mechanical
and electrical work requires: a documented pre-start checklist,
emergency stop verification, guard and interlock confirmation, and
progressive run-up rather than immediate full-speed operation.
Are emergency stops and safety interlocks confirmed operational before
first energisation (rr 203–206)?
Is airborne dust or product release during first operation addressed?
Residual product in the system will be disturbed during commissioning
and may create inhalation hazards, particularly where crystalline
silica is present.
Is the commissioning phase authorised by a nominated person — not just
"All Workers"? Typically requires the Licensed Electrician, OEM
technician, and Site Supervisor to jointly authorise.
Handback:
Is there a formal handback step in the SWMS? Handback requires
verification that: all temporary isolations are removed, permanent
protections are reinstated, all tools and temporary equipment are
cleared, and the plant is formally returned to operations.
Is the handback signed off by a person with the authority to accept
the work on behalf of the PCBU?
Non-English-speaking workers:
If OEM technicians or other workers are non-English-speaking: are
communication controls documented? This includes: interpreter
arrangements, translated safety briefings, bilingual supervision, and
visual/pictorial safety signage where language barriers exist.
Site-specific controls:
Are controls site-specific or copied from a generic template? Common
indicators of generic controls include: "work only in daylight hours"
for indoor work; "ensure adequate ventilation" without specifying what
ventilation exists; "maintain safe distance from overhead power lines"
when the work is inside a building. Each control must make sense for
the actual work environment.
Where existing site infrastructure is temporarily modified for the
overhaul (e.g. handrail removal, temporary access openings, crane
pads): is the modification, its temporary replacement protection, and
its reinstatement documented?
Step 4A — Freestyle Review Mode (no matching Work Type Modifier)
If the SWMS describes a work type that does not match any of the predefined
Work Type Modifiers above, activate Freestyle Review Mode. This ensures every
SWMS receives a thorough, work-type-aware review regardless of whether a
specific modifier exists.
Procedure:
Identify the work type clearly. State the specific nature of the work
(e.g. "scaffolding erection and dismantle", "excavation near services",
"crane lift of mechanical plant", "waterproofing application", "traffic
management for road works").
Use web search to research work-type-specific hazards and obligations.
Search for:
Codes of practice applicable to this work type in the detected jurisdiction
(e.g. "Managing the Risk of Falls at Workplaces Code of Practice 2021 Queensland")
Relevant state regulator guidance notes (WHSQ, SafeWork NSW, or WorkSafe Tasmania)
Industry-specific standards or guidelines (e.g. crane lift plans, scaffold
inspection requirements, excavation support standards)
Known hazard profiles for this work type that a competent safety
professional would check
Build an ad-hoc checklist based on:
The core checklist items (Step 3) — these always apply
Hazards identified from web search specific to the work type
Any additional WHS Regulation chapters that apply (load the relevant
chapter files from the dependency skills)
Cross-regulatory obligations (other legislation applicable in the detected jurisdiction)
Apply the ad-hoc checklist to the SWMS task steps in the same manner as
the core checklist — record ✓ Met / ⚠ Caution / ✗ Gap / N/A for each item.
Flag uncertainty. If, after web searching and reviewing the loaded
legislation, you are still uncertain about whether a specific requirement
applies or whether the SWMS adequately addresses it, stop and ask the
reviewer (Critical Rule 8). Present:
What the SWMS states
What you found in your research
What you are unsure about
A specific question for the reviewer
Important: Freestyle Review Mode is not a lesser review. It produces
findings at the same standard and priority classification as a modifier-based
review. The only difference is that the checklist is built dynamically rather
than from a predefined template.
After a Freestyle Review: If the review identifies recurring work-type-
specific checks that would benefit future reviews, note this in the output
under a "Suggested Modifier" heading. This helps Safetysure build new Work
Type Modifiers over time.
Step 5 — Classify and Prioritise Findings
Use three priority levels:
P1 — Stop / Fix Before Proceeding
Work should not continue on the affected task(s) until resolved. Use for:
Licensing obligations not demonstrated (demolition licence, electrical
licence)
Fall prevention hierarchy not addressed for active work above 2 m
No rescue procedure where fall arrest is the control
Rescue plan is generic / not site-specific where r 80(2) requires
site-specific emergency procedures (e.g. rope access rescue plan that
does not reference the actual building or working heights)
HRCW categories not identified at all (r 299(2)(a) — foundational
requirement)
Risk ratings absent from the majority of task steps (r 299(2)(b) —
no documented basis for risk assessment)
Biological hazard controls absent where cooling water is being disturbed
EXTREME residual risk ratings proceeding without documented authorisation
P2 — Fix Before the Specific Task Commences
Work on other tasks may continue; affected task cannot start until resolved.
Use for:
Hot work permit not cross-referenced at cutting/grinding/welding steps
SDS absent for a chemical used in a specific task step
Silica/ACM status unconfirmed for a specific task
HRCW categories unticked but work has not yet reached that stage
Asbestos register not reviewed for pre-1990 building work area
Anchor point certification not evidenced for rope access work
Heat stress controls absent for outdoor/rooftop work
Load rating unverified for hauling/lifting equipment (e.g. cord or haul
system rated for unknown item weight)
Noise or manual handling hazards not addressed for specific task steps
where those hazards are foreseeable
Demolition/dismantling status not assessed where scope may constitute
dismantling of building components
P3 — Administrative Correction (next revision)
Does not directly affect on-the-ground controls. Use for:
Inapplicable codes of practice in reference list
Superseded standards references
Blank PPE table (where PPE is described in task steps)
Unsigned consultation records (flag but do not stop work)
Risk matrix notational inconsistencies
Building name or address errors in the SWMS
Imperial measurements where metric should be used
Duplicate task step rows or inconsistent terminology
Generic environmental conditions included but not applicable to the
work location (e.g. snow/ice controls for Brisbane)
Incomplete administrative fields (site contact, supervisor, permit
fields, dates) where these do not affect task-level controls
Rescue plan sign-on table blank (flag — signatures must be obtained
before work commences but this is a pre-start action, not a document
revision)
Legislative framework — instruments that apply to this specific scope
(verified from skill files, not memory)
Overall assessment — 3–5 sentence summary of the document's adequacy
Findings by priority — P1 first, then P2, then P3. For each finding:
what is absent or inadequate; the specific provision that applies; the
specific task step(s) affected; what needs to be done
Responsibility summary table — who does what, by when, evidence of
completion
Tone: Plain language, directed to the contractor and principal contractor.
Write as a practitioner communicating with a site team, not as a legal document.
Specific is better than general — name the task step numbers, name the
regulation numbers, name the product.
Lessons Learned
These are documented failure modes from previous reviews. They exist to
prevent recurrence and explain the reasoning behind several of the rules
above.
1. Work type modifiers are not optional.
A cooling tower SWMS without a Legionella / biological hazard check is
incomplete regardless of how thorough the WHS Regulation analysis is.
Biological hazards in cooling systems are a known, regulated risk that sits
outside the WHS Regulation. Always activate applicable Work Type Modifiers
before finalising the review.
2. Verify chemical classification before flagging as hazardous.
Do not assume a product is hazardous because it is listed in the chemicals
table. The SWMS itself may have incorrectly included it. Check the SDS
classification. If not classified as hazardous under the GHS/SDS regime,
note this and recommend removal from the hazardous chemicals register rather
than recommending additional controls.
3. Precision in recommendations.
When a control (e.g. hot work permit) exists in the SWMS but is not applied
at the right task steps, the recommendation is to cross-reference it at
those steps — not to add a whole new section. Read what is already in the
SWMS before recommending additions.
4. Licensing absence is a finding, not an assumption.
If the SWMS contains no evidence of a required licence (demolition, asbestos,
electrical), state that the licence is not demonstrated in the SWMS. Do not
assume it exists. Absence of evidence in the only document available is a
material finding.
5. Environmental conditions are occupational hygiene.
Heat stress on an Australian rooftop in summer during heavy physical work is a
foreseeable occupational health issue. If the SWMS covers a physically
demanding outdoor or rooftop scope, check for heat stress management
regardless of whether it is in the WHS Regulation checklist.
6. Cross-regulatory awareness.
Always ask: is there legislation outside the WHS Act and Regulation that applies
to this work type? Refer to the jurisdiction mapping table for the applicable
electrical safety, public health, and environmental legislation. These do not
need to be analysed in depth — flag their applicability and the specific obligation.
7. A generic rescue plan is not a site-specific rescue plan.
r 80(2) requires emergency procedures including rescue procedures to be
established in relation to the use of a fall arrest system. For rope access
work, IRATA ICOP Annex R (October 2024) additionally requires rescue plans
to be site-specific, including a description of the work environment, access
points, safe zones, and site-specific rescue methodology. A competent generic
company rescue plan covering basic and advanced rescue scenarios does not
satisfy these requirements. The rescue plan must reference the actual
building/structure, its working heights, and the designated safe zone(s) for
casualty reception. This was identified in the Gecko Rope Access review
(Job 3933, Riverside Centre) where a technically sound generic plan lacked
any reference to the specific site.
8. Residual risk ratings remaining HIGH require documented justification.
If a task step's residual risk rating remains HIGH after controls are applied,
this is the only step in the sequence where this occurs, or it is an outlier.
Query whether the rating reflects the irreducible inherent risk profile of the
activity, or whether additional risk reduction measures have been considered
but not documented. This is a conversation to have with the contractor rather
than an automatic finding — but the question should be raised.
9. Load rating verification for cord, rope, and haul systems.
When a SWMS specifies a cord or rope for hauling items (e.g. "6 mm-rated cord"
for hauling louvres to a roof via a progress capture system), confirm that the
unit weight and dimensions of the items being hauled are stated. Without the
item weight, there is no basis for verifying the cord/system is appropriately
rated. This was identified in the Gecko Rope Access review where louvre
specifications were absent.
10. IRATA/ARAA qualifications constitute competency-based assessment.
When reviewing against an Appendix K-style SWMS checklist that asks whether
"competency-based assessment" arrangements are in place, IRATA and ARAA
qualifications satisfy this criterion. IRATA training involves "training and
assessment by a third-party assessor" with practical demonstration of rescue
techniques required at each tier level. Do not mark this as N/A for rope
access SWMS where all personnel hold current IRATA/ARAA qualifications.
11. Anchor point approvals may not transfer between work types.
If a SWMS states anchor points were "previously approved" for a different
purpose (e.g. sign installation, BMU operations), do not assume the approval
extends to rope access dynamic loading. Different work types impose different
dynamic load factors on anchor points. The approval should be confirmed as
applicable to the specific work type.
12. Pre-1990 vs pre-2004 asbestos thresholds.
There are two distinct asbestos-related thresholds for existing buildings:
(a) Buildings constructed before 31 December 1989 — must maintain an
asbestos register (WHS Regulation rr 425–427). Failure to reference the
register for work in these buildings is a P2 finding.
(b) Buildings with ACM installed before 31 December 2003 — ACM remains
subject to management obligations under Chapter 8.
The earlier "pre-2004 construction" label in the Work Type Modifiers was
imprecise. Both thresholds are now documented in the modifier.
13. Freestyle reviews must meet the same standard as modifier-based reviews.
When Freestyle Review Mode is activated for an unfamiliar work type, the
temptation is to produce a shallow review because no predefined checklist
exists. This defeats the purpose. The ad-hoc checklist must be built from
genuine research — web search for applicable codes of practice, WHSQ guidance,
and industry standards — and applied with the same rigour as a predefined
modifier. If the research does not yield enough information to build a
competent checklist, flag this to the reviewer and ask for guidance rather than
producing a superficial review.
14. Web search results do not replace verified legislation.
Web search is a tool for filling knowledge gaps about products, standards,
equipment, and industry practices. It does not replace the verified legislative
text in the safetysure-whs-legislation plugin skills. If a web search
result contradicts the loaded legislation, the legislation prevails. Always
cite the legislative provision, not the web search result, when making
regulatory findings.
15. Distinguish legislative requirements from good-practice recommendations.
Not every desirable SWMS inclusion is a legislative requirement. For example,
recording electrical licence numbers on the SWMS is prudent due diligence for
competency verification, but neither the Regulation nor the applicable electrical
safety legislation mandates that licence numbers appear on the SWMS document
itself — the obligation is that the person performing the work holds the
appropriate licence. Where the skill identifies an omission that is good practice
rather than a regulatory requirement, it must be classified as P3
(administrative/good practice), not P2 or P1. The finding narrative must
clearly state that no specific legislative provision requires the item to
appear on the SWMS, and frame it as a recommended due diligence control. If
uncertain whether an item is legislatively required or merely good practice,
apply Critical Rule 8 (flag and ask) rather than defaulting to a higher
priority classification.
16. "All Workers" in the Action By column is a reliability indicator.
When every step of a SWMS lists "All Workers" as the responsible party, it
reliably indicates the SWMS was drafted without mapping controls to
competencies. This is not merely an administrative deficiency — it means no
one has considered who actually performs each control. Checking the Action By
against licensing requirements (Licensed Electrician under the applicable electrical
safety legislation, Licensed Rigger/Dogger under the Regulation rr 207–216)
and competency definitions (Competent Person under r 146) is a productive line
of inquiry that frequently reveals P2 findings. This was identified in the River
Sands Concetti Overhaul review (March 2026) where every step listed "All Workers"
despite requiring electrical isolation, rigging work, OEM commissioning, and
formal handback.
17. Scope exclusions must be handled cleanly — state N/A and direct removal.
When a hazard category is explicitly excluded from the scope of work (e.g.
"no hot works"), the review comment must say "not applicable — remove this
row" and move on. The initial instinct is to still analyse the controls for
that hazard "just in case" or to critique their adequacy while noting the
exclusion. This creates confusion and contradicts the agreed position. If
something is excluded, say so plainly. Do not hedge. This was a recurring
correction in the River Sands review where the reviewer had to emphasise
twice that hot works were not in scope.
18. Systemic hierarchy-of-controls deficiencies are best raised as one finding.
When a SWMS relies predominantly on administrative controls ("ensure",
"observe", "follow procedures") and PPE across multiple or all steps, this
is a systemic issue — not a collection of individual step-level findings.
Raising it once as an overarching finding (citing WHS Act s 17 and WHS
Regulation r 36) is more effective than repeating the same point at every
step. A single systemic finding makes the structural nature of the problem
clear and avoids diluting the message with repetitive commentary.
19. Controls copied from generic templates often do not match the site.
A common drafting failure is copying controls from a template library without
adapting them to the actual work environment. Examples from the River Sands
review: "work only to be carried out in daylight hours / ensure sufficient
lighting" applied to work conducted entirely inside an enclosed industrial
building with permanent artificial lighting; "ensure all handrails and
walkways are in good condition" when the agreed methodology required
temporary removal of a handrail section. Each control must be assessed for
site-specific applicability, not just presence.
20. Commissioning is a distinct hazard phase requiring distinct controls.
SWMS documents frequently treat commissioning/testing as a brief afterthought
("test and verify" or "observe procedures for testing"). First energisation
after major mechanical and electrical work is one of the highest-risk phases
of an overhaul. It requires: emergency stop verification, guard and interlock
confirmation, progressive run-up, airborne dust/product management (especially
where crystalline silica is present), and joint authorisation by the
electrician, OEM technician, and site supervisor. The River Sands review
identified five separate gaps in a single commissioning step.
21. Stored energy extends beyond electrical isolation.
SWMS documents for plant overhaul work routinely address electrical isolation
but fail to address other stored energy sources. Gravity-fed product in bins,
hoppers, and chutes above the work area can release unexpectedly when
mechanical connections are broken. Pneumatic and hydraulic accumulators
retain pressure. Springs and counterweights store mechanical energy. VSD DC
bus capacitors store lethal voltage for up to 15 minutes after electrical
isolation. The isolation procedure must identify and address every energy
source, not just electrical supply.
22. Deisolation and handback are safety-critical steps that SWMS documents
routinely omit.
Deisolation (the reverse of the isolation process) and formal handback to
operations are frequently missing from SWMS documents. Deisolation requires:
removal of all LOTO devices, verification that tools and personnel are clear,
a controlled re-energisation sequence, and formal notification to operations.
Handback requires a nominated person with authority to accept the completed
work on behalf of the PCBU. Without these steps documented, there is no
controlled process for returning the plant to service.
Version
Created: February 2026
v0.1.0 — Initial release based on Riverside Centre cooling tower SWMS
review (Expoelle Pty Ltd, SWMS No. 737 Rev 03)
v0.2.0 — Updated February 2026 based on Gecko Rope Access SWMS review
(Job 3933, Louvre Removal, Riverside Centre). Added: rope access work type
modifier; hazardous manual tasks checklist (Section L); risk ratings
checklist (Section K); refined asbestos register thresholds (pre-1990 vs
pre-2004); anchor point certification detail; site-specific rescue plan
requirement; rescue plan sign-on check; measurement units check; expanded
P1/P2/P3 examples; 6 new lessons learned (items 7–12).
v0.3.0 — Updated February 2026: Safetysure customisation. Added: Freestyle
Review Mode (Step 4A) for any work type without a predefined modifier; web
search guidance for unfamiliar items (Critical Rule 9); flag-and-ask
behaviour for uncertain findings (Critical Rule 8); jurisdiction scope
limited to Queensland; suggested modifier output for building future
checklists; 2 new lessons learned (items 13–14).
v0.3.1 — Updated February 2026 based on CRM Electrical Services SWMS review
(SWP001 Rev 1, Electrical Switchboard Upgrade). Added: 1 new lesson learned
(item 15 — distinguish legislative requirements from good-practice
recommendations; electrical licence number display is not a SWMS requirement).
Bundled whs-act-checker and whs-regulation-checker skills into the plugin
(previously external dependencies). [Note: these were unbundled in v0.6.0.]
v0.4.0 — Updated March 2026 based on River Sands Pty Ltd Concetti Bagging
Head Overhaul SWMS review (March 2026). Added: 3 new Critical Rules (10 —
Action By competency verification; 11 — scope exclusion handling; 12 —
systemic findings as single comments); enhanced Section D (Electrical Work)
with RCD/ELCB, VSD capacitor discharge, and stored energy checks; new
Section M (Action By / Competency Verification); new Section N (Hierarchy
of Controls systemic assessment); new Work Type Modifier for Plant Overhaul
/ Major Maintenance covering isolation/stored energy, methodology changes,
lifting during disassembly, commissioning, handback, non-English-speaking
workers, and site-specific control validation; 7 new lessons learned
(items 16–22).
v0.5.0 — Updated March 2026. Added: FSC Hazard Benchmarks reference file
(references/fsc-hazard-benchmarks.md) derived from the Federal Safety
Commissioner's Audit Criteria (Version 1.5, April 2024). Step 4 updated
to load and apply FSC hazard-specific benchmarks (H1–H19) alongside
existing Work Type Modifiers, providing domain-specific knowledge about
expected controls for each hazard category. FSC findings classified per
the existing P1/P2/P3 framework with guidance on distinguishing legislative
requirements from best-practice expectations.
v0.6.0 — Updated March 2026. Architecture consolidation: removed bundled
whs-act-checker and whs-regulation-checker skills. This plugin now references
the canonical safetysure-whs-legislation plugin for all legislative lookups.
Requires safetysure-whs-legislation to be installed.
