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SWMS Review Checklist for Builders

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Before a subcontractor starts high risk construction work, the principal contractor should check their SWMS is site-specific, identifies the actual high risk construction work categories, sets out a real work method, orders controls by the hierarchy of controls with PPE last, cites the right state legislation, and is signed by the workers doing the work. A generic or copy-paste SWMS is the main red flag: it means the hazards of your site have not been thought about.

  1. 1

    Confirm it is for your site

    Check the project name, site address, principal contractor, and dates match this job. A different site name or address anywhere in the document means it is recycled.

  2. 2

    Check the high risk construction work is identified

    The SWMS must state which of the 18 high risk construction work categories apply (19 in Victoria). If the sub is working at heights over 2 metres and the SWMS does not say so, it is incomplete.

  3. 3

    Read the work method as steps

    The job should be broken into logical steps that describe how this crew does this work, not boilerplate like "carry out works safely".

  4. 4

    Check each step has hazards and controls

    Every step needs its hazards identified and controls listed in hierarchy order: eliminate, substitute, isolate, engineer, administrate, then PPE last. A SWMS where PPE is the first control for everything has it backwards.

  5. 5

    Check plant, licences, and permits

    Plant and equipment listed should match the method, and licence classes (high risk work licences, electrical, plumbing) should be named where the work needs them.

  6. 6

    Check the legislation cited

    The SWMS should cite the WHS Regulations of your state, or the OHS Regulations 2017 in Victoria. A Victorian job citing the model WHS Regulations, or vice versa, is a sign of a copied document.

  7. 7

    Check emergency arrangements

    There should be emergency procedures relevant to the work: rescue from height for heights work, atmosphere and rescue for confined spaces, not just "call 000".

  8. 8

    Check consultation and sign-on

    The workers doing the work must be consulted on the SWMS and sign on to it before starting. Blank sign-on sheets mean the crew has not seen it.

  9. 9

    Keep a copy and file it

    Keep the SWMS available for inspection while the work is done. It is part of showing you have met your duty to co-ordinate the trades on your site.

  10. 10

    Knock it back in writing if it fails

    If the SWMS is generic or incomplete, tell the sub what needs fixing and do not let the high risk work start until it is fixed. Work done contrary to or without a SWMS must stop under the Regulations.

The red flags that mean knock it back

Why this is the builder's problem too

The subcontractor is responsible for its own SWMS, but the principal contractor has duties for the workplace it controls, and reviewing the SWMS of each trade is how site co-ordination is demonstrated in practice. If a generic SWMS goes unchallenged and something happens, the question asked will be why the document was accepted. A ten-minute review against this checklist is cheap insurance.

Many builders send this list to their subs before mobilisation so the SWMS arrives right the first time. If a sub needs help producing a compliant document quickly, a verified generator produces a site-specific SWMS in minutes, which is faster for everyone than a rejection cycle.

Common questions

โ–ธCan a builder reject a subcontractor's SWMS?

Yes. The principal contractor can and should refuse to let high risk construction work start until the SWMS properly covers the work on their site. Tell the sub specifically what is missing so they can fix it once.

โ–ธDoes the builder have to keep copies of subbies' SWMS documents?

The PCBU doing the work must keep the SWMS, and principal contractors routinely keep copies of every trade's SWMS as part of co-ordinating the site and demonstrating their own duties. Keep them until the work is complete, and longer if there was a notifiable incident.

โ–ธWhat if the sub says their insurance or their consultant approved the SWMS?

Approval by someone else does not change what the document says. Review it against the work on your site: site-specific details, the right high risk categories, a real method, controls in hierarchy order. If those are present it passes on its content.

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More on writing and passing a swms

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