SA Falls from Height: The 3m to 2m Threshold Change Explained

South Australia is aligning its falls from height provisions with the national model WHS Regulation by lowering the threshold at which work at height becomes high-risk construction work (HRCW) from 3 metres to 2 metres. Under the current SA provisions, work involving a risk of a person falling more than 3 metres is classified as HRCW requiring a Safe Work Method Statement. Under the amended provisions, this threshold drops to 2 metres, matching the model WHS Regulation 2025 and the position in NSW, Queensland, and other harmonised jurisdictions.

This change means that a significant volume of construction work in South Australia that currently does not require a SWMS will require one once the amendment commences. Work on single-storey residential roofs, commercial mezzanine installations, elevated platform scaffolds, and many other activities where workers are between 2 and 3 metres above a lower level will now trigger the HRCW provisions. Businesses operating in SA must review their current work practices and SWMS inventory to identify activities that will be reclassified.

Under the WHS Regulation 2025, a PCBU that carries out HRCW must ensure a SWMS is prepared before the work commences. The SWMS must identify the work as high-risk construction work, specify the hazards relating to the HRCW and the risks to health and safety, describe the measures to be implemented to control the risks, and describe how the control measures will be implemented, monitored, and reviewed. The SWMS must be prepared in consultation with workers who are to carry out the HRCW.

For SA businesses, the 2-metre threshold change means any task where a worker could fall 2 metres or more now requires a documented SWMS before work begins. This includes roof work on single-storey buildings (typically 2.4 to 3 metres to the eave), work on elevated platforms and mezzanines, installation of ceiling fixtures from ladders or scaffolds, and work near open edges of elevated floors. Businesses that previously treated these as routine tasks with general safe work procedures must now prepare site-specific SWMS that address the specific fall hazards, control measures (edge protection, scaffolding, harnesses), and rescue procedures.

The hierarchy of fall prevention controls under the WHS Regulation 2025 must be applied to all work where a person could fall 2 metres or more. The first preference is to carry out the work on the ground or on a solid construction. Where this is not reasonably practicable, the PCBU must provide a fall prevention device such as a guardrail, scaffolding with edge protection, or an elevated work platform. Where a fall prevention device is not reasonably practicable, a work positioning system such as a travel restraint may be used. Fall arrest systems (harnesses and lanylines) are the last resort and must only be used when higher-order controls are not reasonably practicable.

For work between 2 and 3 metres, many SA businesses have historically relied on safe work procedures and ladders without formal fall prevention devices. This will no longer be acceptable. A documented risk assessment must demonstrate that higher-order controls have been considered and that the selected control is appropriate for the specific task and environment. Rescue plans must be included in the SWMS for any work where a fall arrest system is used — suspension trauma can be fatal within minutes if a fallen worker is not rescued promptly.

The SA Government has announced the 2-metre threshold change as part of its broader alignment with the model WHS Regulation 2025. Businesses should not wait for the formal commencement date to begin preparation. Updating SWMS templates, training workers on new height work procedures, procuring additional edge protection equipment, and auditing current practices against the 2-metre standard are all activities that take time and should begin immediately.

During the transition period, SA businesses should conduct a comprehensive audit of all work activities where workers operate at heights between 2 and 3 metres. For each activity, prepare a SWMS if one does not already exist, review and upgrade fall prevention controls, and ensure workers are trained in the new procedures. Businesses operating across multiple states should consider standardising on the 2-metre threshold nationally, as this simplifies compliance management and provides a higher standard of protection for all workers regardless of jurisdiction.

Failure to prepare a SWMS for HRCW, or preparing a SWMS that does not comply with the requirements of the WHS Regulation 2025, is a breach of the regulation that can attract enforcement action. SafeWork SA inspectors can issue improvement notices requiring a compliant SWMS to be prepared and prohibition notices stopping work until the breach is rectified. If a worker falls from a height of 2 metres or more and no SWMS was in place, the PCBU faces potential prosecution for a Category 2 offence with maximum penalties of $1.65 million for a body corporate and $330,000 for an individual.

Beyond regulatory penalties, a fall from 2 metres onto a hard surface can cause life-changing injuries including spinal fractures, traumatic brain injury, and death. Falls from height remain the leading cause of workplace fatalities in the Australian construction industry. The 2-metre threshold change reflects the evidence that falls from relatively low heights are more dangerous than many businesses appreciate because workers often do not expect to fall and do not adopt protective postures. Compliance with the new threshold is not just a regulatory requirement but a genuine life-safety measure.