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Why your SWMS got knocked back

SWMS rejected by the principal contractor? The three reasons PCs on WA mine sites send them back, and how to fix each one before you resubmit.

7 min readChecked against the WHS (Mines) Regulations 2022 (WA)Updated October 2026

The short version

  • It's a generic template. If your SWMS could be handed in on any site in the state, it fails.
  • Nothing in it says which site. Reviewers look for the area, the plant and their own site rules.
  • The controls have no "how". PPE listed first, nobody named to check it, no record the crew was consulted.
Site supervisor in hi-vis reading a safe work method statement on a clipboard at a WA mine site, with a processing plant and crew behind him

Crew's booked. Mob date's locked in. Then the SWMS comes back from the principal contractor with red pen all over it, and the job sits still while you rewrite it.

It happens all the time, and it's rarely because the work itself is unsafe. It's because the document doesn't prove the work has been planned for this site.

On a WA mine, a SWMS for high risk construction work sits under the Work Health and Safety (Mines) Regulations 2022. Regulation 299 sets out what it has to contain. Whoever reviews it for the principal contractor (PC) is checking two things: does it meet r.299, and does it fit their site. Nearly every knock-back comes down to one of the three reasons below.

It's a generic template

Downloaded from the internet, bought in a pack, or copied from the last job with the company name swapped. Everyone's done it. Reviewers can spot it fast, because the hazards don't have a place in them.

WorkSafe WA's own SWMS information sheet warns that a generic template may not meet the regulations unless it's amended for the actual workplace. It also warns that a long SWMS is harder to apply and review. A 40-page document for a two-day job isn't thorough. It's a sign nobody edited it.

How reviewers spot it

Generic template, task 3 of 12
TaskWork at height
HazardFallsFrom what? Where on site?
ControlUse appropriate PPE. Follow safe work practices.PPE first, hierarchy skipped
RiskMediumSame rating as every other line
Checked by Nobody named
Written for the site, task 3 of 5
TaskReplace idler frames on conveyor walkway, approx. 4 m above ground
HazardFall from open edge of walkway where handrail is removed for access
ControlTemporary edge protection fitted before handrail removed. Harness on rated anchor only where edge protection can't be fitted. Rescue plan in place.Higher-order control first
RiskRated for this task, before and after controls
Checked bySupervisor name, at each shift start
Same task, two versions. The one on the left could come from any site in Australia. The one on the right tells the reviewer what you're actually doing. Illustrative example only: your controls have to come from your job and your site.

Fix it: delete every hazard that doesn't apply. Rate each risk for this job, not the template's. Cut it down until your crew would actually read it before they sign it.

Nothing in it says which site

A SWMS can have genuine, decent controls and still get bounced because it doesn't engage with the site it's going on. Under the regs, a SWMS has to take into account the circumstances at the workplace. On a construction project, it also has to fit the principal contractor's WHS management plan.

That plan isn't just paperwork for the PC. WorkSafe WA says it has to set out the site-specific health and safety rules and how SWMS will be collected, assessed, monitored and reviewed. In other words, the PC is checking your document against their rules. If yours doesn't mention them, it's going back.

On top of that, plenty of PCs require you to use their own SWMS template. That's a contract or site requirement rather than a regulatory one, but it'll still get you knocked back if you ignore it.

How reviewers spot it

Fix it: ask the PC for the site's Safety Plan or WHS management plan before you write the SWMS, not after. Name the location and the plant. Reference their permits and isolation process by name. Get the muster point and emergency contacts from the site. Don't guess them.

Never fill site details with a guess. A made-up muster point is worse than a blank one. SWMSCheck marks genuinely site-specific gaps as highlighted fields for you to complete, rather than inventing them.

The controls have no "how"

Regulation 299 doesn't just want a list of controls. It wants the measures to control the risks and a description of how they'll be implemented, monitored and reviewed. This is where good-looking SWMS quietly fail. Three things usually go wrong.

The hierarchy is upside down

The regs require control measures to follow the hierarchy of controls: eliminate the risk if you can, then isolate it, substitute it or engineer it out, and only then lean on admin controls and PPE. A SWMS that leads with "wear a harness" before it mentions edge protection tells the reviewer the hierarchy was never considered.

Nobody's named to check it

Who confirms the controls are in place? How often? What triggers a review? The regs require a SWMS to be reviewed and revised when controls aren't working or the work changes. If your document doesn't say who's watching, it hasn't met r.299.

No sign the crew saw it

WHS law requires you to consult the workers doing the job. A SWMS with no names, no date and no sign-on sheet reads like it was written at a desk the night before. The regs also require it to be set out so the people using it can understand it, so plain language beats safety jargon.

What a reviewer checks in the first minute A SWMS page with five numbered areas: site and work identified, high risk work and hazards specific, controls follow the hierarchy, monitoring and review named, consultation and sign-on recorded. 1 2 3 4 5 1. Which site, which job? Site, area, plant ID, PC named, dates. 2. Is the high risk work named? Hazards specific to this task, not a template. 3. Do controls follow the hierarchy? Higher-order controls first, PPE last. 4. Who checks it, and when? Monitoring, review triggers, person responsible. 5. Did the crew see it? Consultation names, dates, sign-on sheet.
The order most reviewers scan a SWMS in. Fail at step 1 or 2 and they often stop reading.

Fix it: for every control, add one line on who checks it and when. Put elimination and engineering controls ahead of PPE. Add a consultation block with names and dates, and a sign-on sheet the crew actually signs.

What a knock-back really costs

Every resubmission burns days, not minutes. The crew waits, the mob date slips, and someone is paying for that time. If you send it out to be fixed, the bill adds up quickly.

Typical cost of getting a SWMS fixed Bar chart. Safety consultant review: about 200 dollars per hour. Consultant-written SWMS: 500 dollars or more per document. SWMSCheck: 15 dollars per report. Getting one SWMS fixed (A$) Consultant review, per hour ~$200 / hr Consultant-written SWMS $500+ each SWMSCheck report $15
Consultant hourly rate from our conversations with WA safety professionals. Per-document figure from published industry pricing. Your rates will vary.

Before you hit send: the 2-minute check

Not sure which regulations your job falls under? Read mining or construction rules: which WHS regs apply to your SWMS in WA.

Don't wait for the knock-back. Get your SWMS checked today.

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Common questions

Does the principal contractor have to approve my SWMS?

The regulations require you to give the principal contractor a copy before the high risk construction work starts, and the PC has duties around obtaining and monitoring it. A formal sign-off is often a site or contract requirement on top of that, so check the site's rules.

Can I use the same SWMS on every job?

Only if you review it and amend it for each site and task. WorkSafe WA warns that a generic template may not meet the regulations unless it is changed to suit the actual workplace.

How long should a SWMS be?

As short as it can be while still covering everything regulation 299 requires. WorkSafe WA notes that a long SWMS is harder to apply and review, and your crew needs to read and understand it.

Do I need a SWMS for every task?

No. A SWMS is legally required for high risk construction work. Other tasks are usually covered by a JHA, permits and a Take 5, depending on the site.

Sources

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