Working at heights and confined space entry are the two most common High Risk Work categories in utilities, civil and infrastructure labour hire — and they are also two of the most frequently mismanaged. The licensing and training requirements exist because the consequences of getting them wrong are severe, and a labour hire arrangement does not transfer those consequences away from the host employer.
This guide covers the licensing framework for working at heights and confined space in utilities and infrastructure environments, and what employers need to verify before placing or accepting labour hire workers in these roles.
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Key takeaways
- Working at heights High Risk Work licences (rigging, scaffolding, dogging) are nationally recognised — but the class of licence must match the specific work being performed, not just the general category.
- Confined space entry is a training requirement, not an HRW licence — but it is mandatory under the WHS Regulations, and a permit-to-enter system and rescue plan are required for every entry.
- The host employer controls the site and the confined space — the obligation to issue permits, maintain rescue equipment and have a standby person in place sits with the host, not the labour hire provider.
Working at heights — the HRW licence classes that apply
The Work Health and Safety Regulations define High Risk Work (HRW) that requires a licence issued by a state or territory regulator. For working at heights in utilities and infrastructure, the relevant licence classes are in the rigging, scaffolding and dogging categories. Like all HRW licences, these are nationally recognised — a licence issued in any state is valid across Australia, subject to being current and covering the correct class.
- Dogging (DG): the application of slinging techniques and the directing of crane or hoist operators. Required where workers are directing the movement of loads — common in utilities construction and infrastructure projects involving crane lifts.
- Rigging — Basic (RB): covers basic rigging activities including the rigging of plant and equipment, the use of gin wheels, the rigging of prefabricated materials, and the use of ropes. The entry-level rigging licence for most site work.
- Rigging — Intermediate (RI): extends to more complex rigging activities including steel erection and placement of precast concrete elements. Required for many utilities civil and structural tasks.
- Rigging — Advanced (RA): covers high-complexity rigging — suspended scaffolds, masts and towers. Required for some transmission line and telecommunications tower work in the utilities sector.
- Scaffolding — Basic (SB), Intermediate (SI), Advanced (SA): erection, alteration and dismantling of scaffolding. The class required depends on the height and complexity of the scaffold — basic covers most ground-level and simple elevated scaffolds; advanced covers cantilevered, suspended and hung scaffolds.
The key compliance point: confirm the specific class of licence, not just whether the worker “has a rigging ticket.” A worker with an RB licence cannot legally perform RI rigging work. Confirming this before placement — not at the point of the lift — is the responsibility of both the provider and the host.
Confined space — training, not a licence
Confined space entry is not governed by an HRW licence system. Instead, the WHS Regulations (Model WHS Regulations, adopted across most jurisdictions) impose specific obligations on the person conducting the business or undertaking (PCBU) — in a host employer context, that is the host — whenever a worker enters a confined space.
A confined space is defined in the Regulations as an enclosed or partially enclosed space that is not designed or intended primarily for human occupancy, has a restricted means of entry or exit, and has the potential for a dangerous atmosphere (oxygen deficiency/enrichment, flammable gas, airborne contaminants) or risk of engulfment, drowning, or entrapment. In utilities environments, this includes pits, vaults, underground cable chambers, tanks and tunnels.
Workers who enter confined spaces must have completed confined space training that covers hazard identification, atmospheric testing, entry permit procedures, use of PPE and emergency response. There is no single nationally standardised unit of competency that covers this in all contexts — training content must be appropriate to the specific class of confined spaces the worker will encounter.
The permit-to-enter system
Before any person enters a confined space, a confined space entry permit must be issued by a competent person. The permit confirms that the hazard assessment has been completed, atmospheric testing has been done, isolation and purging controls are in place, rescue arrangements are established, and the entry is authorised. The permit is site-specific and time-limited — it does not carry over from a previous entry or from another site.
For labour hire workers entering confined spaces on a host employer’s site, the permit is issued by the host (or their delegate) — not the labour hire provider. The host controls the confined space and is responsible for the permit system, the atmospheric testing equipment, the rescue plan and the standby person. What the provider is responsible for is confirming that the worker has completed appropriate confined space training and understands their obligations as an entrant.
Rescue plans and standby persons
Every confined space entry requires a rescue plan and a designated standby person — someone stationed outside the confined space who monitors the entrant, maintains communication and can initiate rescue without themselves entering if the entrant is incapacitated. The standby person must also have confined space training and must understand the rescue procedure.
This has direct rostering implications for labour hire arrangements. If a confined space task requires one entrant and one standby, you need two trained workers on site for the task. Sending a single trained confined space worker cannot satisfy the requirement. Plan for this in shift design and resource allocation before work starts.
What to verify before placing a worker in these roles
- For HRW licensed roles: licence class, issuing state, expiry date, and whether any conditions are attached. Verify against the state authority register rather than relying on a copy of the licence card.
- For confined space roles: training certificate, the date of training, what class of confined spaces was covered, and when the worker last worked in a confined space. Currency of practical experience matters as well as the training date.
- For both: confirm site-specific induction covers the specific hazards, permit requirements and emergency procedures for the host’s site — generic training does not substitute.
For broader context on utilities workforce planning and the lineworker licensing framework, see utilities workforce planning: lineworkers, HV switching and infrastructure trades. For WHS responsibilities shared between host employers and labour hire providers more generally, see WHS responsibilities in labour hire.
Related reading
For a closely related guide, read Utilities Workforce Planning: Lineworkers, HV Switching and Infrastructure Trades.
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FAQ
Does a working at heights licence cover all elevated work?
No. An HRW licence in the rigging or scaffolding category covers the specific activities defined for that class. General work at heights — for example, working from a ladder, a fixed platform or an elevating work platform — may require specific training or an HRW licence for the EWP class (boom-type or vehicle-mounted), but is not covered by a rigging or scaffolding licence. Confirm the specific work being performed and the relevant requirement before placement.
Can the labour hire provider issue the confined space entry permit?
The permit must be issued by a competent person who controls the confined space — which is typically the host employer or their site representative. A labour hire provider cannot issue a confined space entry permit for a space on the host’s site because they do not control that space. The host’s permit system applies.
How often does confined space training need to be refreshed?
There is no single nationally mandated refresher period for confined space training — it depends on the risk assessment, the worker’s currency of practice, and site or operator requirements. Some organisations require annual refresher training; others require refresher training after a defined period away from confined space work. Host employers should specify their requirements to their labour hire provider before sourcing workers for these roles.
Who is liable if a worker is injured during confined space entry on a host’s site?
Both the host employer and the labour hire provider carry WHS duties. The host controls the confined space and is responsible for the permit system, atmospheric testing, rescue equipment and standby arrangements. The provider is responsible for confirming the worker is trained and competent. In practice, both will be examined in any incident investigation — and both can face regulatory action if their obligations were not met.
Next step
If you need verified, licence-checked workers for working at heights or confined space roles in utilities or infrastructure, explore staffing services.
General information only: This article is for general informational purposes only and does not constitute legal advice. Legislation varies by state and territory — consult a qualified employment lawyer or Fair Work adviser for guidance specific to your situation.
