Working at Heights: What to Ask a High-Access Cleaning Contractor

Booking external window cleaning or façade work on a multi-storey building looks like a straightforward procurement decision. It isn’t. The moment someone is working above ground level on your site, height safety becomes a shared legal problem — and the way a contractor proposes to get to the glass tells you most of what you need to know about how they run a job.

This guide sets out what Queensland law actually requires when work is carried out at height, in the order the law requires it, and what a facilities or property manager should be asking before the first rope is rigged.

The duty doesn’t stop at the contract

Under the Work Health and Safety Act 2011 (Qld), a person conducting a business or undertaking must eliminate the risk of falls so far as is reasonably practicable, and minimise what cannot be eliminated. Engaging a specialist contractor does not transfer that duty away from you — it adds a second duty holder alongside you.

Where more than one business holds a duty in relation to the same matter, each must consult, cooperate and coordinate activities with the others so far as is reasonably practicable. In practice that means the building owner or occupier and the cleaning contractor are expected to talk to each other about access, anchor points, exclusion zones and rescue before the work is scoped, not after an incident.

The order the law actually requires

This is the part most buyers get wrong. Height safety is not a menu of equally valid options. Two sections of the Work Health and Safety Regulation 2011 (Qld) do different jobs here.

Section 78 imposes two duties outright. So far as is reasonably practicable, work involving a risk of a fall must be carried out on the ground or on a solid construction — the first question is always whether anyone needs to be at height at all. Separately, you must provide safe means of access to and exit from the workplace, or any area within it from or through which a person could fall, such as a platform or scaffolding. Both duties aim at eliminating the hazard, and neither is conditional on the other.

Section 79 takes over only when elimination is not reasonably practicable. At that point you must minimise the risk by providing adequate protection, working down this order:

1. a fall prevention device — a guardrail, scaffold or similar, which stops the fall happening;
2. if that isn’t reasonably practicable, a work positioning system — which holds the worker in place at the workface;
3. if neither is reasonably practicable, a fall arrest system — which does nothing until after someone has already fallen;
4. and if a risk still remains after all of those, administrative controls to minimise what is left.

A combination of controls may be used where a single control isn’t enough on its own. The code is also explicit that using administrative controls on their own is only appropriate when no higher-order control is reasonably practicable — a rule about safe work, not a substitute for one.

The ranking is deliberate: every step down the list is a weaker form of protection than the one above it — which is why the access method a contractor proposes tells you where they started.

Where rope access sits — and what that means for your quote

Industrial rope access is a work positioning system. It is a legitimate, well-established method, but the Queensland code of practice is explicit about its place in the sequence:

Other methods of accessing a workface, for example EWPs or building maintenance units, must be considered before industrial rope access systems.

So if a quote goes straight to abseiling, the reasonable question is not “are your operators any good?” — it is “what did you rule out first, and why?” On a building with a functioning building maintenance unit, or on a façade an elevating work platform can reach from the ground, defaulting to rope is skipping a rung.

That question costs you nothing to ask, and a competent contractor will have the answer ready.

When a SWMS is legally required — and when it isn’t

A safe work method statement is mandatory for high risk construction work, and the Regulation classifies construction work involving a risk of a person falling more than two metres as high risk construction work. Where the job meets that definition, a SWMS must be prepared before work starts — not written up afterwards to close out a file.

There is a nuance worth understanding. The legal SWMS trigger is tied to construction work. Routine periodic window cleaning is not automatically construction work, so the SWMS duty may not be triggered on every job. What does not change is the underlying duty: the risk of a fall still has to be managed under section 78 and section 79, and a documented method is still how a contractor demonstrates that it was. Treat a written method statement as the standard you expect, whether or not the statutory trigger has been pulled on that particular job.

Anchor points are your asset, not the contractor’s

If rope access or fall arrest is used on your building, the anchorages are usually part of your structure — which makes their condition your problem long after the contractor has driven away.

The code of practice is specific here:

• Anchorages should be tested and approved by a competent person before use. For insert-type anchors — those installed into partial-depth holes in concrete or masonry — that should include pull-out testing, because the grip below the surface cannot be assessed by looking at it.
• Insert-type anchors should not be used for fall arrest where the potential loading is a direct pull-out load.
• Anchorage strength should comply with AS/NZS 1891.4:2009, Industrial fall-arrest systems and devices — Part 4: Selection, use and maintenance.
• Each component of a fall arrest system should be inspected by a competent person after installation but before use, and at regular intervals after that.
• Before rope access lines are attached, fixed anchorage points should be checked by a competent person.

If nobody can tell you when your roof anchors were last tested, or produce the records, that is a finding about your building — and it is worth resolving before it becomes the reason a job can’t proceed.

Rescue is part of the plan, not a contingency

Section 80 of the Regulation is unambiguous: a business that provides a fall arrest system as a control measure must establish emergency and rescue procedures, and those procedures must be tested so that they are effective. Workers must be given information, instruction and training on them.

This matters more than it sounds. A worker suspended in a harness after a fall can suffer suspension intolerance, so “call triple zero and wait” is not a rescue plan. The code also expects rope access systems to be installed where prompt assistance or rescue is actually possible, that operators do not work alone, and that supervisors are competent to supervise both the work and any rescue arising from it.

Put this in your scope of works

Before the next high-access job on your site, ask the contractor for:

• The access method proposed, and what higher-ranked options were considered and ruled out.
• Confirmation of whether the work is high risk construction work, and a SWMS provided before work starts where it is.
• The name of the competent person who checked the anchorages, and when.
• Inspection and test records for the anchor points on your building.
• A rescue plan, including how prompt rescue is achieved on your particular structure.
• For rope access: a back-up system, such as two independently anchored ropes per person.
• Exclusion zones below the work area and beneath the anchorage locations, to keep the public and other trades clear.

None of that is unreasonable, and none of it is expensive to provide if the contractor was going to do it anyway. The ones who hesitate are telling you something.

Getting height work done properly

Broadsafe Maintenance delivers window, high-access and façade work across Greater Brisbane and Ipswich, with access and safety assessed and a method agreed before crews go up. The same documented approach runs through our building maintenance and commercial cleaning programs, and through the safety obligations covered in our guide to warehouse and industrial cleaning compliance.

To scope window cleaning, façade work or a periodic high-access program for your site, contact our team.

This article is general information about Queensland work health and safety duties, not legal advice. The authoritative sources are the Work Health and Safety Act 2011 (Qld), the Work Health and Safety Regulation 2011 (Qld) and the Managing the risk of falls at workplaces Code of Practice 2021.