HSE installed fixed rail for facade cleaning at the Adina Pentridge Apartments, Melbourne.

Height safety for facility managers, building owners, developers and architects

Learn more about your responsibilities in creating safe work places

Providing adequate fall protection and safety systems for those working at height is a key responsibility for facility managers and building owners. There are also advantages for building developers and architects for incorporating safety systems into buildings from the start of the design process.

Falls from height remain one of the most common causes of workplace injury in Australia. Although this continues to be the case year after year, too many people still misunderstand or ignore the risks associated with working at height.

The reasons for this are as varied as there are grains of sand on a beach, but ultimately it boils down to people needing to get work done, and not fully appreciating how quickly a fall from height can occur.

Mitigating the risks of a fall from height is everyone’s responsibility, with each level of involvement taking on a different focus. For facility managers and building owners, their responsibility is to create a safe place of work.

This typically involves having a fall protection system or height safety system installed, ensuring that anyone needing to operate system has signed off on the system access procedures and that they also understand any limitations the system may have.

What a safety system might look like on a given building depends on the design of the building and the access requirements of those needing to use the system. When it comes to providing fall protection and height safety systems, there is not real one-size-fits-all solution. Each system should be designed to create ease of use for workers, while providing maximum protection against the risks of a fall.

Many fall protection and working at heights systems can be designed and retrofitted to a building once it is built. However, by incorporating a designed height safety system into a building’s planning stages, better safety solutions are often possible. Considering the safe access needs of a building before it leaves the drawing board often allows for a better integration between the system and the design goals of the architect, draftsperson or building designer. In some circumstances, it can even create a safer system than what is possible with a retrofitted system.

Safe access walkway on an office building roof.

Responsibilities under the law

In Australia, workplace safety is legislated federally through the Work Health and Safety Act 2011 and the Work Health and Safety Regulations 2011. In NSW, these laws are complemented by the state Work Health and Safety Act 2011 (NSW) and the Work Health and Safety Regulation 2017 (NSW). Other states and territories will have their own complementary WHS legislation in force in those jurisdictions.

Although different laws are in place across different parts of Australia, broadly, they all work to the same function. This is to provide a framework through which responsibility for workplace safety is defined and what measures need to be implemented.

When it comes to height safety, the Regulation (both NSW and federal) state:

“A person conducting a business or undertaking at a workplace must manage… risks to health and safety associated with a fall by a person from one level to another that is reasonably likely to cause injury to the person or any other person.”

This creates a duty of care between the person conducting a business or undertaking (PCBU) and those working for them. For facility managers and building owners, this takes the form of being responsible for creating a safe place of work. This duty of care also extends to any contractors or tradespeople that come on to site to complete work.

There are two main ways this duty of care can be met:


Completing these steps helps fulfil two important aspects of the hierarchy of control, and assists greatly in protecting people.

Safe access ladder and walkway around a piece of industrial plant at a logistics depot.
Design sketch of an access walkway completed on-site by a HSE system designer.

Hierarchy of control

The hierarchy of control is a method that ranks risk mitigation techniques from least to most effective when it comes to protecting people.

In this way it also works as something of a checklist for PCBUs and other responsible people to work through when assessing how a high-risk work situation may be able to be managed.

Although not having to complete work at heights is the best form of protection against a fall, this is simply not possible in a large number of cases – a roof cannot be removed in order to effect repairs, for example. Or the light towers at a sports stadium be lowered to enable maintenance access.

As a result, the rest of the hierarchy must be considered. In these situations, it is generally better to use multiple levels of protection to assist in best mitigating the risks. Depending on your definition, working at heights and fall protection systems can it into either the substitution or engineering controls.

Substitution works be replacing the existing risk with something that lessens the risk. In height safety, this could be replacing a temporary ladder access with a fixed ladder or stairs. Or having guardrail installed around the edge of a building to remove the risk of a fall while still allowing access to the roof as required.

Engineering controls work by providing a solution to a particular hazard as opposed to removing it. Engineering controls in fall protection include fall arrest devices, static lines, anchor points, elevating work platforms (EWPs) and scaffolding.

Administrative controls are the documents that a site supervisor and contractor use to ensure that workers understand how a safety system is supposed to be used and safe methods for completing work. For building owners and facility managers, these documents would be things like system manuals and roof plans, as well as a process to check that a contractor’s safe work method statement (SWMS) adequately covers use of the fall protection system in place.

Ensuring that a building’s safety system adequately covers a worker’s access and safe working at heights needs ensures that the PCBU (whether they be a facility manager, building owner or other relevant person) is doing all that is considered reasonably practicable under the state and federal laws.

Hierarchy of control diagram, with elimination at the top, then moving down to substitution, isloation, engineering, administrative and PPE controls.
HSE installers installing Sayfa RAPTOR rail onto the roof of the Adina Pentridge Apartment building during construction.
Safe access ladders and walkways installed onto the World Heritage Listed Royal Exhibition Building in Melbourne, Victoria.
HSE installation team conducting a pre-work briefing and risk assessment check.

What is reasonably practicable?

What is reasonably practical when it comes to workplace safety can be difficult to define, as it is dependent entirely on the specific situation in question. By the letter of the law, reasonably practicable is defined as “a duty to ensure health and safety, means that which is, or was at a particular time, reasonably able to be done in relation to ensuring health and safety, taking into account and weighing up all relevant matters”

The relevant matters include things like:

  • The likelihood of the risk occurring.
  • The amount of harm the risk is likely to cause.
  • What the person concerned knows, or ought to reasonably know, about the risk and methods of mitigating or eliminating it.
  • The suitability of available ways to mitigate the risk.
  • The costs associated with eliminating the risk versus and whether or not they are grossly disproportionate to the risk itself.

It might seem at first reading that what is considered reasonably practicable is open to a wide amount of interpretation, and that assessment would be correct. As ever when it comes to safety, it can be extremely difficult to define what has been done correctly and what has not.

For building owners, facility managers and other similar PCBUs, it is best to look at what can be reasonably done within their own power to minimise risk of a fall from height. In their case it is generally to have safe access and fall protection systems installed, and there be procedures and checks in place to make sure anyone working on the site knows how to correctly use the system and work safely while they are doing so.

What is a height safety system?

Height safety systems come in two distinct flavours – safe access systems and fall protection systems. Both, when used correctly, provide protection against the risks of a fall for workers.

Safe access systems focus on providing workers with the means to gain safe entry to their work areas, while fall protection systems are more focussed on keeping workers safe in a work area that has a fall risk. Many systems will be made up of both safe access and fall protection components, while others may only need safe access and others only need fall protection. It all depends on the site, how frequently access is needed and what work is being completed.

No matter what sort of height safety system is needed, it should always be manufactured and installed according to the relevant Australian standards and codes of practice.

Caged ladder leading up to an access platform for maintenance access.

Safe access systems

Safe access systems take on many different shapes and sizes, depending on where they are going to be installed, what sort of access is needed and its frequency.

Typical safe access systems can be made up of stairs, ladders, ladder brackets and more. A ladder bracket, coupled with a first-man up cable, is a common form of roof access system. This setup is common in places where access needs may be infrequent. It provides a safe method for portable ladder placement, allowing easy access to a single story. A ladder bracket and portable ladder system also removes the ability for access to be made by the general public.

In areas where access is required more frequently, and access by the public is limited – for example, in an industrial facility, a permanent ladder is installed. In circumstances where access is required very frequently, a stair case and guard rails may be used to allow access to the space without the need of a harness or other personal protective equipment (PPE).

Fall protection systems

While it is preferred that work be completed in a ways where the risks of a fall from height are eliminated completely, such as staying firmly on the ground, in many cases that is simply not possible.

The simplest form of a fall protection system, is a single anchor point onto which a lanyard is attached. The lanyard connects the worker’s harness to the anchor point. Working together, the anchor point, harness, lanyard and a shock absorber act as a complete system to protect the wearer should a fall occur.

Similar this is the static line. A static line is a tensioned steel cable onto which a shuttle is attached. The shuttle acts similar to an anchor point and is connect to a lanyard, which in turn is connected to the harness. The shuttle travels along the static line, allowing the operator to reposition themselves without having to transfer to a new anchor point.

There are many different types of fall protection components that can be used individually and in concert with each other to create a fully compliant fall protection system. What is needed is unique to each individual building, access need and work being completed as there is never a one size fits all solution for fall protection.

Walkways to provide fall protection and safe access to solar panel arrays on a warehouse roof.

Advantages of designing for safety

While many height safety systems are installed into buildings after (or as part of) construction, often the detail design of these systems is left until the last minute. Having the fall protection and safe access needs of a building fully incorporated into the design stages gives architects, developers, owners and builders many advantages that often go unrealised.

For architects, engaging a specialist height safety company during building design allows for a better marriage between the safety needs of those working on the building over its lifetime and the aesthetic/design goals of the building itself.

In many cases, having safe access and fall protection systems included as part of the building design, to be installed during construction, can offer a better outcome on both the cost and implementation fronts. Some height safety components can only be installed during a building’s construction, and they offer distinct advantages over equivalent retrofit components.

Owners, developers and builders will also have a better grasp on the expected costs of the safety systems if fully compliant fall protection is included as part of the building’s design documents. This reduces the likelihood of variations being sought as those tendering for the installation work will know the full scope of what needs to be accounted for in their pricing.

Upgrading buildings for improved safety

Even if a building has finished construction, or is an older building where access needs may have changed over time, there are still many opportunities to review and improve height safety. This is especially true if workers are known to be working in areas of fall risk, but there is no system in place to offer them protection.

Even if a system exists, it is required to undergo regular compliance (recertification) inspections to ensure that it remains in good working order and is not suffering from damage or other degradation that could inhibit it working as designed.

In some cases, as a building’s use changes, or additional plant is added, or even renovations or expansions are completed, an existing system could be rendered non-compliant or not be adequate to provide fall protection in every area it is needed.

For facility managers or building owners that do not feel as though they have a firm grasp on where the fall risks are for their building, a height safety and confined space audit would help in identifying risk areas, the ability of any existing systems to mitigate those risks, and areas where additional height safety, safe access or fall protection systems may need to be installed.

In cases where it is known that no fall protection system or safe access system is present, design and installation of one can be completed. Facility managers and building owners should always be seeking out ways to improve building safety for those needing to work at heights on their sites.

Having compliant, comprehensive safety systems in place can also bring additional benefits including reducing operating and maintenance costs by reducing the time needed to complete routine work.

HSE installation technicians unloading materials ahead of starting work on a warehouse roof.
Roof anchor points installed on a building overlooking Sydney Harbour.
Walkway and guardrail for fall protection on a education facility's roof.

Documentation and risk mitigation

Having a safety system installed is not enough on its own. As the PCBU responsible for sending people up onto your roof or other areas where the system is installed, there must be checks in place to ensure those workers understand the system, know how to use it and have the skills to complete work safely.

To that end, each safety system should have a thorough procedure document that details how the system is to be used, what PPE will be required, what skills or experience a worker should have and the limitations of the system. Before using the system, the PCBU should ensure the worker has made themselves familiar with the documents and signed on to them, acknowledging they understand and will follow what is required of them.

This documentation provides two different types of risk mitigation for facility managers and building owners. Firstly, it ensures that workers are aware of what is required of them, and that they should not start work if they cannot follow the procedure, have the right equipment or are not trained to safely carry out the work.

For workers, it allows them to understand what systems are in place on a building and makes it much easier to determine whether or not they are adequate for the work they are being asked to complete.

Documentation and procedures assists in mitigating risks by providing a check against other aspects of the full safety system. It allows a PCBU to check that a worker has the skills required to complete work, and vice-versa, it allows a skilled worker to voice concerns about whether or not the system is adequate for its intended purpose.

Ultimately, unless all parties to the work, both the PCBU, contractors and workers have signed off on all the relevant documentation, work should not progress.

Compliance inspection report being completed by a technician following a recertification inspection.
Compliance inspector signing off on a compliant safety system.

Ongoing compliance and management

Every safe access and fall protection needs to be maintained. It should go without saying that making sure safety systems are kept operating as they are supposed to is incredibly important. Like other types of plant, safety systems that go without maintenance will lose effectiveness over time. This can be disastrous in the event of an accident.

For height safety systems, routine maintenance is generally an annual compliance inspection, sometimes called recertification. During this inspection, a technician attends the site to physically check over all the installed safety system components. They look to see if they are still fixed correctly in place, have not corroded or are otherwise damaged. They also check to see if the system has been installed following the manufacturers requirements and that it has been done in a way that meets the requirements under the relevant Australian standards.

If everything is OK, the system is signed off and a certificate is issued showing that everything is compliant. In the event a system fails this inspection, a report is produced that shows the details around where the failures have been observed and what remedial action should be taken to bring the system back to a compliant state.

Creating holistic safety systems to protect people

At Height Safety Engineers, we are all about creating holistic safety systems in order to provide people with the best protection possible. This goes as much for building owners and facility managers as it does each individual worker attending a site and completing a job at height.

Improving safety takes commitment from every part of the work chain – from owners to managers and workers – to collaborate, discuss and trust that everyone is working towards the same outcome.

The experts at HSE bring decades of real-work experience in developing and implemented holistic safety systems to every job that we do. We are proud to be your partners in protecting people.

Call 1300 884 978 or email enquiries@heightsafety.net to start your safety journey with us today.