What should a window cleaner do above two metres?

What changes at two metres, state by state

The duty is not new at two metres; the paperwork starts there. In each of the four states below, the two metres is the point at which the work is classified as high risk construction work, or the point at which a specific set of duties switches on, and in all four a safe work method statement comes with it.

1. VictoriaA fall of two metres or more is where Part 3.3 of the OHS Regulations takes over: employers have to remove the risk of the fall, or cut it down, working down the prevention of falls hierarchy of control. Construction work carrying a fall risk of more than two metres also counts as high risk construction work, which means a safe work method statement has to exist before the first tool comes out, and the job has to be done the way the statement says.
2. New South WalesSafeWork NSW puts the statement this way: “A safe work method statement (SWMS) is required for construction work where a person could fall more than two metres.” It adds that the statement “must be site-specific and made available to workers, supervisors and any other persons at the workplace, so they can understand the hazards, risks and safety controls that must be used.” And where the work is not construction work, the duty from the top of this page still stands underneath it: the protection is owed against the risk of falling from one level to another no matter the height.
3. QueenslandThe WHS Regulation writes out its own list of high risk construction work, and a fall of more than 2 metres puts a job on it, with a safe work method statement owed before the work starts. Rope access is judged the same way: where it is construction work with a fall risk past two metres, no work begins until the statement exists. The falls code also folds the statement into its training expectations for scaffold work, where the instruction may include that any work at or above 2 metres needs a written statement prepared for it.
4. TasmaniaOn a construction job with a fall risk past 2 metres, the controls have to be chosen by working down the hierarchy, and a safe work method statement has to be prepared and then followed, because that job is high risk construction work. Below that height the same ladder guide is careful not to let the line read as permission: working from a ladder, a person must still, so far as reasonably practicable, be provided and maintained with safe systems of work.

The fall controls, in order

The hierarchy is the spine of every one of those state rules, and it is a ranking, not a menu. SafeWork NSW states it as the requirement to use the hierarchy of control to manage risks: “eliminating the risk where possible”, and then, where it cannot be eliminated, “reduce it through substitution, isolation and engineering controls, before finally considering administrative controls.” Read from the top, the order a window cleaner’s job has to walk down is this.

1. Work on the ground, or from a solid construction

   The state regulator’s first answer is to not be up there at all: “If you don’t have to work at heights, don’t,” its page states, and it calls working from the ground or solid construction the safest option there is. Queensland’s code reaches the same conclusion for the same reason: take the height out of the job and the fall risk goes with it, which is why one of its examples of work moved to the ground is a tool with an extendable handle, though the code adds that the risk of musculoskeletal disorders has to be considered.

2. A fall-prevention device

   Where the work cannot be done from the ground or a solid construction, the first protection is a device that stops a fall happening at all. SafeWork NSW’s examples run from scaffolds and elevating work platforms through mast climbing work platforms and work boxes to building maintenance units, with perimeter guardrails and secure fences, barriers or covers among them. Queensland’s code agrees on the rank, and adds a definition worth keeping: a fall prevention device is designed so that, once installed, it needs no ongoing adjustment to keep its integrity.

3. A work-positioning system

   Only where a fall-prevention device is not reasonably practicable does the next rung apply: a work-positioning system, which the NSW page describes as “a harness-based system that either prevents a fall hazard being reached ... or enables a person to work supported in tension,” industrial rope access included. Queensland’s code sets the same condition and warns that work positioning asks a lot of the people using it and supervising it before it is safe.

4. A fall-arrest system

   Last of the devices, and only when neither of the two above is reasonably practicable: a fall-arrest system, such as industrial safety nets, catch platforms, or a harness-based system. The honest limit of this rung is in the same sentence that gives it: “Fall-arrest systems do not prevent a fall, however, if installed and used properly, they reduce the impact of the fall.” A harness brings rescue duties with it as well: put a fall arrest system to work, and procedures for an emergency and a rescue have to exist, tested for their effectiveness.

5. Administrative controls, to support the rest

   At the bottom sit the controls that rely on people: whatever fall risk is left after the higher order measures can be minimised with administrative controls, which SafeWork NSW lists as “safe work procedures, safe sequencing of work, safe use of ladders, permit systems, ‘no go’ areas, signs etc.” The same page says plainly why they are last: “Many of these controls rely heavily on user competency to be effective.” And in the trade this guide is about, the code sets the order for reaching a workface: other ways of getting there, elevating work platforms and building maintenance units among them, have to be considered before industrial rope access.

The window trade’s own access methods

Queensland’s falls code names the window cleaner explicitly. At the design and planning stage, its examples include window cleaning bays or gangways that are built into the structural frame, and permanent anchorage and hoisting points designed into a structure where maintenance will one day need them at height. The code keeps a list of the workers whose later installation, maintenance or repair work needs its own safety requirements, and the first group it names is window and gutter cleaners and repairers.

What those cleaners stand on is a short list. Scaffolds, elevating work platforms, mast climbers, workboxes and building maintenance units all count as temporary work platforms, and so does anything else built to give a working area that stops a fall. The building maintenance unit is the one purpose-built for this trade: a power-driven platform that hangs from the building and stays there, installed for good, there to carry someone down the face for maintenance or window cleaning. Working from one, the code expects it to be built to AS 1418.13, to carry clearly marked harness anchorage points strong enough for a fall from anywhere on the platform, and to be run by competent people under AS 2550.13. Where a boom lift or a cherry picker is used instead, the code names its dangers: live wires, the machine tipping, a fall off the platform, and crushing as the platform rises or slides.

Ropes are the last method in, and the code’s caution is explicit. A rope access job is expected to have operators competent in the technique and fit for height work, and, above all, never alone: the code’s reason is the one that matters on a tall building, that an operator on their own has no one to help if the emergency arrives. It adds a second set of conditions for the systems themselves: a second rope rigged as a backup, on its own anchor, so each person hangs from two separately anchored lines; anyone working within 3 metres of an unguarded edge secured against the fall; a full-body or work-positioning harness with shoulder straps worn; and an exclusion zone fenced off below the work and the anchors, keeping the public out and clear of anything the job could drop.

What that gives the person hiring

The duties above are written for the businesses that do the work, and none of them needs the customer to memorise a regulation to check that the work is set up the way the law expects. What the sources give someone comparing window cleaners is the shape of the right answers. The method should be the highest one the building allows, not the most convenient: rope access is supposed to be considered only after the platforms have been ruled out. A statement of the work should exist before the work does if the job is high risk construction work. The points a harness clips to should have passed a competent person’s test and approval first, and every part of an individual fall arrest kit should get a competent person’s inspection, as the code asks. And the person on the rope should not be on it alone: the code’s reason is that an operator on their own has no one to help if the emergency arrives.

There is one more layer the code is clear about, and it is the one people assume away: on a site with more than one business at work, the duties do not all sit on the same shoulders. A workplace often holds several businesses or undertakings at once, and more than one of them can be answerable for the same health and safety matters, whether because their work overlaps or because the site is shared; the WHS Act then asks each of them to consult, cooperate and coordinate with the others. For a cleaner arriving at an apartment building, that is the layer between the cleaner and the glass: a building whose fixed anchorage points have to be checked by a competent person before the ropes go on, and a cleaner whose own method, training and rescue arrangements are theirs.