Petition updateUpdate WorkSafe NZ's good practice guidelines for working at height

Clarify terms Hazard & Risk, and map lifecycle risk.

Steve TillingAuckland, New Zealand
Sep 26, 2026

Working at Height Good Practice Advocacy

Ask that the GPG define and use the terms Hazard & Risk consistently. While commonly used synonymously, they are not synonyms. For working at height, interchanging the terms confuses the application and performance side of things when defining controls.

A Hazard is a physical object or event that is the agent of harm. A hazard can exist without causing harm, such as gravitational potential or a fall hazard.

A Risk is an interaction or exposure to the hazard that creates potential for harm, such as working at height near a fall hazard.

When you select controls, you must be clear about whether the control addresses the Hazard (Elimination) or the Risk (Minimisation). Eliminating the hazard also removes the risk.

With Fall protection, the hazard never really goes away. You can isolate it with guardrails and floor covers, but that only manages the interaction during elevated work. The hazards still exist on the other side of the isolation.

Risk Assessment suggests controls, but controls can drift over their lifecycle while the hazard remains constant. Different teams may interact differently with the hazards and require different controls. Multiple risks can derive from a single hazard.

The guidance should reflect that controls are also interactions that create risk. I call this the Cascade, and in working at height, it is a particular problem when you try to apply the hierarchy of control as a primiary prioritiation.

It should be clear what derivative risks arise throughout the control lifecycle, and that risk is measured holistically.

The lifecycle of a control scheme is:

Establishment - Interaction - Withdrawal

Within the this lifecycle, you also have Cascade Risks and Emergency Risks that impose or require additional controls.

Mapping these out would be a great service to industry, within the recognised guidance. The mapping exerise also makes it cleat that sometimes, higher level controls, create much more risk overall. This is intuitively understood and seen in industry choices, but currently contradicted by advice in the guidance.

If you would like to see the guidance map lifecycle controls, let me be your voice and sign the petition to show support so I can advocate on your behalf.

 

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