Findings Report: Rooftop Solar 2024
Project Timeframe: 19/02/2024 - 16/08/2024
Sites: 102
Summary and overview
The 2024 Safe Rooftop Solar Installation project builds on key findings from the 2022 project, where inspectors observed widespread non-compliance at sites where installation was occurring. Issues included inadequate planning and implementation of fall protection measures, a preference for lower-order controls such as harness use, and a lack of fall protection during installation.
The 2024 project aimed to address the serious non-compliance issues identified in previous inspections and implement a targeted approach to primarily focus on the safety duties of retailers, as well as installers.
The primary goal was to reduce the number of incidents resulting in serious injuries or fatalities by improving compliance and promoting the adoption of higher-order controls, such as temporary edge protection, as standard practice.
Education and awareness
SafeWork's 2024 awareness campaign focused on serious non-compliance findings from 2022 and aimed to highlight the safety duties of retailers. Running from January to March 2024, the campaign sought to increase awareness of SafeWork’s ongoing focus on safe solar installation, encourage industry compliance through available guidance materials, and promote the new Solar Retailer's Safety Toolkit and templates.
Communications included a social media campaign, articles and a media release promoting the Solar Retailers Toolkit, which includes the “Know your Solar installer (PDF, 670.62 KB)" and "Fall protection assessment templates (PDF, 132.92 KB)." Industry consultation with key stakeholders, educational workshops, and a new Construction NSW learning module further supported the initiative. Additionally, the SafeWork webpage for solar panel retailers and installers was updated to reflect current best practices.
Inspector pro-active site visits
Types of sites
Inspectors visited 102 sites including:
- 10 Commercial
- 25 Residential 2 storey
- 53 Residential single storey
- 14 *Other
Catholic diocese, schools and visits where no checklist was completed.
Notices and fines
Inspectors continue their zero-tolerance approach to workers being placed at risk from falls from heights, issuing 165 compliance notices, including more than $110,340 in on-the-spot fines for serious safety risks. Falls related prohibition notices were issued at over half the sites visited.
Inspector observations
Inspectors also completed a checklist to record their on-site observations, to highlight the safety and compliance rates for working at heights with inadequate fall protections in place and other risks associated with solar installations, including electricity, manual handling and falling objects.
Compliance visits for this project were undertaken as part of requests for service, incident response, monitoring previous poor performers, as well as proactive drop-ins.
The below sections outline the percentage of sites that had safety measures in place, or not in place, with inspectors only completing each section where it was relevant to the site they visited.
Subcontracting arrangement
Has the work been subcontracted to the solar installer?
- Yes 43%
- No 57%
Planning for safety
Has an assessment been conducted between the retailer and installer to identify the required controls for the site specific scope of work?
- Yes 63%
- No 37%
If yes, at what stage did the installer provide evidence to the retailer, on their ability to implement the agreed control/s?
- 12% At the contract awarding stage
- 22% When job is allocated
- 41% At the worksite prior to commencement of work
- 6% At the worksite during work activity
- 19% Other
What safety control was agreed upon?
- 57% Roof rail
- 23% Work positioning system
- 4% Fall arrest system
- 15% Other
Safe work method statement (SWMS) and consultation
Has the installer prepared a SWMS for high risk construction work?
- Yes 87%
- No 13%
Is the SWMS adequate? E.g. task specific, falls and electrical controls
- Yes 76%
- No 24%
Is the SWMS being followed?
- Yes 56%
- No 44%
Have workers been consulted on high risk work activities?
- Yes 85%
- No 15%
Managing the risk of falls & falling objects
Is there safe access and egress to the roof?
- Yes 72%
- No 28%
If a ladder is being used for access, is the ladder secured and does it extend one metre past access point?
- Yes 72%
- No 28%
What fall protection control was in place for roof work?
- 2% Scaffold
- 43% Roof guard rails
- 14% Work positioning system
- 7% Fall arrest system
- 3% Other - (please see details below)
- 30% No controls
*Other
Combination, rail and harness, parapet wall
If roof rails or scaffold are not in place, ask "why the installer/retailer has not implemented that control"?
- 24% Did not know
- 8% Time / money
- 24% Roof design
- 27% Harnesses
- 3% Other system used/partial
- 14% Not applicable
Is the fall protection adequately installed or implemented so that workers are protected?
- Yes 59%
- No 41%
Are there adequate controls in place to prevent a fall through brittle/fragile roof materials?
- Yes 80%
- No 20%
What safe system of work is in place to move panels onto the roof?
- 55% No system
- 5% Panel lifter
- 17% Rope and panel bag
- 8% Scissor lift
- 15% Other (please see details below)
*Other
Manual lifting
Pulling up by rope - no bag
Has an exclusion zone been established around the work area to prevent public accessing and/or persons being hit by falling objects?
- Yes 68%
- No 32%
Fall arrest and positioning system
Is there a plan that shows the system layout?
- Yes 42%
- No 58%
Does the system protect the worker from risk of falls when accessing the roof from the ladder?
- Yes 51%
- No 49%
Does the system prevent the worker from reaching a fall hazard?
- Yes 48%
- No 52%
Are proprietary anchors points installed in accordance with the manufacturer’s instructions including the number/type of fixings?
- Yes 55%
- No 45%
Are improvised anchors e.g. slings, connected to a structurally adequate point?
- Yes 79%
- No 21%
Are multiple anchors being used to prevent the user's rope extending beyond the distance of the fall risk?
- Yes 53%
- No 47%
If using a fall arrest system has the installer ensured enough clear space to prevent impact with the surface below?
- Yes 63%
- No 37%
Are workers adequately trained in the use of the fall arrest system/work positioning system?
- Yes 93%
- No 7%
If workers are adequately trained in the use of fall arrest/work positioning system, what type of training did they undertake?
- 61% RTO training
- 16% Training by a third-party provider (non RTO)
- 14% In house training
- 10% Other - (please see details below)
*Other
On the job
Work at heights training/and in house training
Is the harness and associated equipment in serviceable condition? E.g. no cuts, in date
- Yes 100%
Are the workers wearing the harness correctly? E.g. leg loops attached, harness firm and orientated correctly
- Yes 73%
- No 27%
If harness(es) is/are being used, are they connected?
- Yes 50%
- No 50%
Has an emergency plan including a rescue procedure, been developed in relation to the use of a fall arrest system?
- Yes 47%
- No 53%
If yes, have workers been provided adequate information, training and instruction, relating to the plan?
- Yes 75%
- No 25%
Has the emergency plan been tested for effectiveness?
- Yes 20%
- No 80%
Managing electrical & installation risks
Has an exclusion zone been set up to prevent unauthorised access to the electrical work area? E.g. main switchboard
- Yes 68%
- No 32%
Is the electrical work being conducted or appropriately supervised by a licenced electrician?
- Yes 99%
- No 1%
Before workers enter a ceiling space or drill into walls, has the electricity been switched OFF at the meter box?
- Yes 91%
- No 9%
Has a lock been placed on the main switch or the meter box itself? E.g. lock out/tag out procedure "LOTO"
- Yes 70%
- No 30%
Are authorised electrical workers testing for dead to ensure power is isolated prior to conducting electrical work?
- Yes 84%
- No 16%
Have the risks associated with overhead powerlines been adequately controlled, as these will be live even after meter box isolation? E.g. safe approach distances, spotter
- Yes 86%
- No 14%
Conclusion
While the awareness-raising campaign aimed at informing retailers of their duties succeeded in reaching these stakeholders, it is evident from on-site inspections that unsafe solar installation work continues to occur at unacceptable levels on NSW building and construction sites.
Regarding work on roofs, 46% of sites had edge protection in place, such as scaffold or roof guard rails. However, a significant number of workers who opted for lower-order controls, such as harnesses, were not using them safely or in compliance with regulations. Additionally, nearly one third of the sites with work occurring on roofs had no fall protections in place, and 55% did not have safe work systems for moving panels on to the roof.
The inspections showed that while managing the risks of falling objects was generally compliant on-site, nearly a third of sites did not have safe access or egress to the roof and did not set up exclusion zones to prevent people being hit by falling objects.
More than half of the fall arrest and positioning system plans did not include a system layout. Similarly, systems designed to reduce the risk of falls when accessing roofs via ladders were found to be compliant only about 50% of the time. Proprietary anchor points require improvement, as do emergency planning, rescue procedures, training, testing, and instructions.
Managing electrical risks was generally compliant, with appropriate supervision of electrical work, risk controls in place for over overhead powerlines, and power being switched off at the mains or meter box. There is improvement required for the establishment of exclusion zones around electrical work areas to prevent unauthorized access and for lock out/tag out of the mains or meter box.
Safe work method statements (SWMS) are a legislative requirement for high risk construction work, designed to ensure that risks associated with working at heights are adequately consulted, identified and managed. 13% of the sites did not have a SWMS in place, and of those that did, nearly a quarter were inadequate and nearly half were not being following, indicating that some sites were using the SWMS planning tool as a tick box and not a used plan.
SafeWork NSW will continue addressing the areas of low compliance identified in these inspections, working with the industry to raise awareness, provide education, and secure the safety of workers on NSW construction sites.
Useful resources
Solar panel retail and installation
Codes of practice
Code of practice: Managing the risk of falls at workplaces (PDF, 2326.56 KB)
Code of practice: Managing the risk of falls in housing construction (PDF, 2296.79 KB)
Code of Practice – Construction Work (PDF, 1014.41 KB)