SWMS Review Checklist: How to Review a Contractor's SWMS Before Work Starts

The SWMS arrives the afternoon before the crew is booked. If you run facilities for a property portfolio, or operations at a distribution centre, it is the last document between a booking and a gate pass.

This checklist is for the facilities manager, operations manager or safety lead who receives a contractor's safe work method statement (SWMS) and decides whether work can start. What a SWMS must contain, and why review queues form, is in Why SWMS Review Becomes a Bottleneck, and What Fixes It. This guide takes the reviewer's chair, with examples from property and facilities management and transport and logistics.

Who Reviews a Contractor's SWMS, and What Does the Law Ask of Them?

The business doing the work prepares the SWMS and answers for it. Under the model WHS Regulations, a business carrying out high risk construction work must, before the work starts, ensure a SWMS is prepared, or already prepared by another person.¹ Duties cannot be transferred under the model Act, so reading the SWMS does not move that duty to you.²

First check that a SWMS is required at all. Construction work includes fitting-out, renovation, repair and maintenance of a structure, but not testing, maintenance or repair work of a minor nature, and the construction chapter reaches plant only in listed cases, including work on plant that relates to construction work.¹ Safe Work Australia's Construction Work Code of Practice gives servicing an air-conditioning system, replacing a door and repairing individual roof tiles as minor, and treats work as minor if it is small scale, needs little or no pre-start preparation and involves minimal control measures.³

Then work out which seat you are in. The business that commissions a construction project is its principal contractor, unless it engages another business and authorises it to manage or control the workplace and carry out the principal contractor's duties.¹ Under the model Regulations a construction project is one where the construction work costs AU$250,000 or more; in Victoria the owner is the principal contractor at AU$350,000 or more unless it appoints and authorises one.¹⁴ A cheaper job has no principal contractor. Where there is one, it must take all reasonable steps to obtain a copy of each SWMS before high risk construction work starts, and its WHS management plan must include the arrangements for the collection and any assessment, monitoring and review of SWMS.¹ In either seat, the person with management or control of a workplace, to the extent its business involves managing or controlling it, must ensure, so far as is reasonably practicable, that the workplace, the ways in and out and anything arising from the workplace are without risks to anyone.²

Neither seat carries a duty to approve a SWMS: the Regulations do not use the word approve in the SWMS duties.¹ The basis for reading one is the duty to consult: where more than one person has a duty over the same matter, each must, so far as is reasonably practicable, consult, co-operate and co-ordinate activities with the others.² The Code applies that to SWMS directly, and says a principal contractor must be given each one and monitor the work.³ In Victoria, WorkSafe Victoria says a principal contractor with control over a matter involving high risk construction work should review the SWMS before it starts.⁵ Your review is your own control, and its value is the evidence it leaves.

The Five-Minute Gate: Send It Back Before You Read It.

Run these 6 checks on the cover and contents before reading 30 pages; a SWMS that fails one was not prepared for your job.

Check	A pass looks like	Send it back when	Basis	Result
Right work	Names the job in your terms, such as fitting out cold chamber 5, and each high risk category it falls under	Says "general maintenance", or the categories do not match the booking	Law
Right site	Names your building, dock or zone and how the crew reaches it	Names another site, an old project or no site	Law
Right business	The contractor's name and ABN match the booking, insurance and licences	A different entity, or another company's name in the template	Practice
Dated and owned	Dated and versioned, naming who makes sure the work follows it and who supervises on site	No date, or nobody named	Practice
Complete	Every attachment it mentions is there, such as the rescue plan	"See attached", with nothing attached	Practice
In time	Reaches you early enough to read before the booking	Arrives at the gate on the day	Practice

The law asks only that a SWMS exists before the work starts, and that a principal contractor takes reasonable steps to obtain a copy.¹ Dates, versions and lead times are your own rules, so put them in the booking email, and name the failed check in your reply.

What Does a Pass Look Like Inside the SWMS?

A SWMS has to cover four things: the work, its hazards and risks, the control measures, and how the controls are put in place, monitored and reviewed. It must also be readable by the people who use it.¹ The table turns each into a test.

Check	A pass looks like	Send it back when	Basis	Result
Hazards that are real	Tasks in order, each with the hazards of this job: stored refrigerant, forklift traffic, the mezzanine edge	One block of text, or 20 hazards copied from a template	Law
Controls say what, who and where	"Isolate circuit 14 at the board, test dead, tag with the electrician's name"	"Isolate power", "take care", "use appropriate PPE"3	Law
One method, not a menu	Names the method used on this job	"Harness, scissor lift or scaffold as required"5	Practice
Strongest control first	Removes or isolates the hazard where possible, before relying on procedures and PPE	PPE and care are the main control for a fall or an isolation	Law
Who checks, and when	A named role checks each critical control before work starts and while it runs	"Supervisor to monitor", with no check described	Law
Readable by the crew	Plain language and diagrams the crew can follow, with the literacy and language needs of the workers in mind3	Pages of policy copied in, so the task steps cannot be found	Law

Two rows need a note. Where it is not reasonably practicable to eliminate a risk, the Regulations minimise it by substitution, isolation or engineering controls, then administrative controls, then personal protective equipment, so far as is reasonably practicable.¹ And the Regulations ask for hazards, risks and measures, not a risk score,¹ so say in the booking email if your site requires a residual risk rating.

Check It Against Your Own Site, Not Just the Page.

A SWMS can be complete and still wrong for your building, and only you can check that. The Code says a generic SWMS must be reviewed to take into account the hazards and risks for the specific workplace and be revised as necessary, and SafeWork NSW says the same.³⁶ Victoria's guidance applies the test to a SWMS that began as output from an AI tool: duty holders review it on site and include all the high risk construction work and risks first.⁵

Check	A pass looks like	Send it back when	Basis	Result
Access and zone	The route, exclusion zone and isolation points match your layout and signs	It describes a generic site or ignores your dock or plant room	Practice
Other people	Names who shares the area, such as tenants, other trades and trucks, and how they are kept apart3	It assumes the area is empty	Practice
Permits and isolations	Refers to your permit to work and its isolation steps, and the two agree	It sets its own isolation steps that contradict yours	Practice
Licences and plant	The plant and licences it names are what the crew can show at the gate	It needs a lifting device or truck and shows no operator licence where one is required	Law
Emergency	Rescue and emergency arrangements work with your assembly point, call-out and access	"Call emergency services" is the whole plan	Practice
Site rules	Takes account of your site rules and, on a construction project, the WHS management plan	It contradicts either	Law and practice

A Worked Review: Fitting Out a Cold Chamber at a Distribution Centre.

This is a made-up case, built to show the checks in order. A refrigeration contractor is booked for Monday to fit out a new cold chamber, chamber 5, in a distribution centre: insulated panels from a mezzanine, the evaporator and the refrigerant lines, with forklifts running through the aisle below. Fitting-out is construction work and not minor, and work on plant that is part of it is covered, so a SWMS is required.¹ The operations manager and site safety lead receive it on Friday.

Version 1 fails at the gate: the cover names chamber 3, and the booking says chamber 5. The contractor has reused last month's document. Version 2 names chamber 5 and the four high risk construction work categories that apply: a fall of more than 2 metres, work on or near refrigerant lines, artificial extremes of temperature, and powered mobile plant.¹

It then fails on contents and site fit. The fall control reads "harness or scissor lift or edge protection as required", a menu. Nothing says how the aisle below is closed while the old unit is lowered. It isolates at a board that does not exist here; the centre's permit isolates at the plant room. It names a mobile lifting device but no operator licence. That is a rejection with 4 comments.

Version 3 arrives on Saturday. The safety lead approves it on one condition: the aisle is closed with barriers and a spotter before the lift, confirmed by the shift supervisor. The centre keeps all three versions, the comments, the decision, the name and the time.

Should You Approve, Approve With Conditions, or Reject?

Reject when the gate fails, or when a serious hazard has no control. Approve with conditions when a named person can close the gap on the day and you can see it closed before work starts: a barrier, a permit, a licence shown at the gate. A condition you cannot check is a rejection with a friendlier name.

Write each comment as the item, what you found, and what you need to see: "the fall control lists three methods, name the one used on this job", not "controls inadequate". Do not rewrite their controls yourself: a reviewer who changes the method has decided for a crew that was not consulted.

Record every decision, approvals included: reviewer, contractor, site, SWMS title and version, decision, any conditions and who closes them, and the date and time. The Code says every revised version of a SWMS should be kept, so keep the version you reviewed beside the record.³

After Approval, Check the Work Matches the Page.

Approval is a statement about a document. The Code says the business that directly engages the workers is best placed to ensure the work follows the SWMS, for example by routine or random inspections.³ If the work does not follow the SWMS, that business must stop it immediately or as soon as it is safe to do so and resume only in accordance with the statement.¹ Your part is a short walk on the first day with the SWMS in your hand. Is the exclusion zone set up as written? Is the isolation applied as written? Is the version on site the one you approved? A copy must be readily accessible to any worker the business engages to do the work, so a foreman who cannot produce it is the first finding.¹

When a SWMS must be revised is in the SWMS review post, how long it is kept is in Site Documents Management, and your wider duties to the contractor are in PCBU Responsibilities.

Where an AI Review Fits Before You Open the SWMS.

A review agent can run the gate and contents rows before a person opens the document. It cannot run the site-fit rows and does not write the SWMS.

In ComplyFlow, an AI agent attaches to a form type such as a SWMS and to its file-upload questions.⁷ Where AI review is on, the contractor can run up to 3 reviews per question before submitting, sees a result for each criterion, and can still submit.⁸ A Display Criteria link shows the criteria first.⁹ The reviewer sees the AI result beside the document and still decides: approve, or request more information, which returns the form as Feedback Required.¹⁰ See AI in ComplyFlow and digital permits.

What to Do With the Next SWMS That Arrives.

Fill in the result column and the decision record for each of the next 5 SWMS, and keep both with the version you reviewed. If an incident happens, those are what you will be asked for.