Roof and Subfloor Space Work — Safe Work Method Statement
Safe Work Method Statement for working in roof spaces (ceiling cavities) and subfloor crawl spaces, including deciding whether the space is a confined space under the WHS Regulations, and controls for falls, electricity, heat, asbestos and restricted access.
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Electricians, plumbers, pest controllers, insulation installers and builders spend a lot of time in roof spaces and subfloors, and many SWMS label these spaces as confined spaces by default. Under the model WHS Regulations, that's often wrong. A confined space is an enclosed or partially enclosed space that is not designed or intended primarily to be occupied by a person, is at normal atmospheric pressure while someone is in it, and is or is likely to be a risk to health and safety from an atmosphere without a safe oxygen level, contaminants that could cause fire or explosion, harmful concentrations of airborne contaminants, or engulfment. Being cramped, dark or hard to get out of does not, on its own, make a space a confined space.
A typical ventilated roof space or subfloor, with no hazardous atmosphere and no engulfment risk, is therefore usually not a confined space. It can become one when the work or the conditions create an atmospheric hazard: spraying foam insulation, solvent-based adhesives or fumigants; running a petrol generator or pump nearby; hot work in an enclosed subfloor; sewer gas or a gas leak under the floor; or a subfloor that is flooded or in poorly ventilated ground that may be low in oxygen. Assess each job. If the space meets the definition, the full confined space requirements apply, including an entry permit, atmospheric testing, a standby person and a rescue plan, and this becomes High Risk Construction Work for work in a confined space.
Even when it is not a confined space, roof space work is usually HRCW because a fall through the ceiling is commonly more than 2 metres to the floor below, and because work is near energised electrical cabling. Subfloor work rarely has a 2 metre fall, but has its own hazards: tight access, sharp debris, vermin, spiders and snakes, and old fibre cement or asbestos-containing materials. Roof spaces can exceed 50°C on a warm day and may contain loose-fill asbestos insulation in some homes in NSW and the ACT.
Electrical isolation of circuits in the roof space should be done wherever practicable, and only licensed electricians may work on wiring. Some states have specific isolation rules for certain roof space work, so check your state or territory regulator.
Customise this template with the space type and access point, your confined space assessment result and reasons, the atmospheric hazards you have ruled in or out, electrical isolation details, asbestos register findings, heat management, how a worker who is injured or overcome would be removed, and the tasks to be performed in the space.
Personal Protective Equipment
High Risk Construction Work Types
- •Risk of a person falling more than 2 metres
- •Work on or near energised electrical installations or services
Risk Assessment
1.Confined space assessment and pre-entry inspection
| Hazard / Risk | Initial Risk | Control Measures | Residual Risk | Responsibility |
|---|---|---|---|---|
| Space is a confined space but treated as ordinary work | Catastrophic | Before entry, a competent person assesses the space against the WHS Regulations definition: not designed for occupancy, normal atmospheric pressure, and a risk from unsafe oxygen, flammable contaminants, harmful airborne contaminants or engulfment. Record the result. If it is a confined space, issue an entry permit and follow the confined space SWMS, including atmospheric testing, standby person and rescue plan. | Low | Supervisor / Competent Person |
| Work creates a hazardous atmosphere in the space | High | Avoid bringing fuel-powered plant near access points. Use low-VOC products. Where spraying, fumigating or hot work is planned in the space, reassess it as a potential confined space and provide forced ventilation and gas monitoring. | Low | Supervisor |
| Asbestos or loose-fill insulation present | High | Check the asbestos register and inspect from the hatch. Do not enter if loose-fill asbestos or damaged asbestos materials are suspected until tested. | Low | Supervisor |
2.Electrical isolation
| Hazard / Risk | Initial Risk | Control Measures | Residual Risk | Responsibility |
|---|---|---|---|---|
| Electric shock from damaged cabling, downlights or junctions | Catastrophic | Isolate circuits passing through the space at the switchboard, lock and tag where practicable. Treat all cables as live unless tested. Don't handle cables or fittings unless licensed. Use non-conductive tools when moving insulation. | Low | Supervisor / Licensed Electrician |
3.Access via hatch or subfloor opening
| Hazard / Risk | Initial Risk | Control Measures | Residual Risk | Responsibility |
|---|---|---|---|---|
| Fall from ladder at the hatch | Moderate | Use a platform ladder or extension ladder secured and extending 1 m above the hatch. Pass tools up separately. Keep the area under the hatch clear. | Low | Worker |
| Unable to get out quickly from a subfloor | Moderate | Identify a second exit where one exists. Keep access clear of tools and hoses. Someone outside knows the worker is in the space and checks on them at set intervals. | Low | Worker / Supervisor |
4.Moving and working in the roof space
| Hazard / Risk | Initial Risk | Control Measures | Residual Risk | Responsibility |
|---|---|---|---|---|
| Fall through ceiling linings | High | Walk only on joists or on crawl boards laid across joists. Light the work area well. Never step on plasterboard between joists. | Low | Worker |
| Heat stress | High | Do roof space work early in the day in warm weather. Limit continuous time in the space and take breaks outside. Water at the hatch. Stop if roof space temperature makes work unsafe. | Moderate | Supervisor / Worker |
| Head and eye injuries from roofing nails and framing | Moderate | Bump cap and safety glasses. Move slowly. Mark low beams. | Low | Worker |
5.Moving and working in the subfloor
| Hazard / Risk | Initial Risk | Control Measures | Residual Risk | Responsibility |
|---|---|---|---|---|
| Bites from snakes, spiders or vermin | Moderate | Inspect with a torch before entering. Gloves and coveralls. First aid kit with pressure bandages on site. | Low | Worker |
| Contact with sewage, sharp debris or broken fibre cement | Moderate | Check for leaking drains before entry. Coveralls, gloves and knee pads. Do not disturb suspected asbestos. | Low | Worker |
6.Emergency response and exit
| Hazard / Risk | Initial Risk | Control Measures | Residual Risk | Responsibility |
|---|---|---|---|---|
| Injured or unwell worker cannot get out | High | Work with a second person nearby, or a check-in arrangement at set intervals. Plan how a worker would be removed through the hatch or opening. Call 000 early. | Moderate | Supervisor |
| Fibres and dust carried into the building | Low | Bag waste in the space. Remove coveralls at the hatch. Vacuum the area below the hatch. | Low | Worker |
Relevant Codes of Practice
Worker Acknowledgement
By signing below, I confirm that I have read, understood and agree to comply with this Safe Work Method Statement.