Do You Need Working at Heights for an EWP? WA Requirements Explained
In Western Australia, using an Elevated Work Platform (EWP) almost always involves a risk of falling from height. That means two things are in play:
- Legal requirements under WA work health and safety (WHS) laws, and
- Site and employer requirements, which are often stricter than the legal minimum.
Working at Heights training is one of the main ways PCBU’s (employers, builders, contractors) meet their duty to manage fall risks, but the law doesn’t name a specific “ticket”. This guide explains how Working at Heights fits in with EWP use on WA sites.
What Is an Elevated Work Platform (EWP)?
WorkSafe WA describes elevating work platforms as mobile platforms that lift or lower people and equipment from a base using a hinged, articulated, or telescoping mechanism
Common EWP types used on WA construction and industrial sites include:
- Scissor lifts (SL)
- Vertical lifts (VL)
- Boom lifts under 11 m (BL < 11 m)
- Boom lifts with a boom length of 11 m or more (BL ≥ 11 m) – require a High Risk Work Licence (class WP)
EWPs are used across construction, maintenance, electrical, warehousing, resources and fabrication. Whatever the type, the PCBU must make sure operators have appropriate training, instruction and supervision in:
- hazard identification
- safe set-up and operation
- fall-prevention measures and emergency procedures.
When Is Working at Heights Training Used With EWP?
Under the WHS Act 2020 (WA) and WHS (General) Regulations 2022, duty holders must manage the risk of falls wherever a person could fall from one level to another in a way that could cause injury.
The law does not name a specific course like RIIWHS204E, but in practice:
- most major WA builders and contractors use “Work safely at heights” (RIIWHS204E) as the standard for height training, and
- many sites write it into their site rules, contracts or induction requirements.
Below is how Working at Heights commonly applies by EWP type on WA construction sites.
Scissor Lifts (SL)
Is Working at Heights training legally required?
- There is no specific regulation in WA that says you must hold a particular “Working at Heights ticket” just to operate a scissor lift.
- However, WHS laws still require that fall risks are identified and controlled, and that operators are trained and competent.
Scissor lifts usually operate within a guarded platform. On some lower-risk jobs, and on smaller sites, scissor work may be covered by:
- EWP-specific training (e.g. RIIHAN301E), and
- site induction and task-specific instruction,
without a separate Working at Heights unit.
Working at Heights training is typically expected when:
- you are exposed to a fall risk outside the platform (e.g. leaning out, low guardrails, open edges nearby)
- you enter or exit the EWP at height (step-off/step-on at an elevated level)
- the builder or principal contractor requires it for all EWP work (common on Tier 1 & Tier 2 sites and many resources projects)
Because requirements differ by site, many WA employers now prefer operators to hold both:
a recognised EWP (scissor) competency, and
- a Work safely at heights qualification,
- to avoid compliance issues when moving between sites.
Boom Lifts (BL) Under 11 m
Is Working at Heights training required?
- Under WHS law, employers must ensure operators are properly trained and the risk of falls is controlled.
- On most WA construction and industrial sites, that translates into a practical requirement to hold a Working at Heights qualification plus boom lift/EWP training, even though it’s not named specifically in the regulations.
Boom lifts introduce a higher risk of:
- catapulting (sudden movement throwing workers upwards/outwards)
- tipping or uncontrolled movement
- platform ejection
- greater exposure outside the handrails
Because of these risks, many principal contractors and mining operators in WA treat Working at Heights training as essential for boom-type EWP work at any height, and write it into their site requirements.
So, for BL < 11 m, the typical industry expectation in WA is:
- Recognised EWP/boom training (e.g. RIIHAN301E + CPCCCM3001 or equivalent), and
- Work safely at heights (RIIWHS204E) or equivalent height safety training.
Boom Lifts With Boom Length 11 m or More (BL ≥ 11 m)
Legal requirements:
For any boom-type EWP where the boom length is 11 metres or more:
- You must hold a High Risk Work Licence – class WP, issued by WorkSafe WA or the relevant state authority.
- The PCBU must ensure you are trained and competent to operate the EWP and manage fall risks.
In practice, that means operators will usually need:
- High Risk Work Licence (WP) – legal requirement for BL ≥ 11 m
- Formal WP training/assessment (e.g. TLILIC0005 Licence to operate a boom-type EWP)
- Working at Heights training – strongly expected on most sites because boom-type EWPs always present a fall hazard
While Working at Heights isn’t named in the regulations, boom-type EWPs over 11 m are high-risk plant, and height training is generally treated as part of due diligence and best practice for fall prevention.
WA Site Requirements (The “Real World”)
Across WA, especially on larger commercial and resources projects, it’s common for:
- major builders and principal contractors
- mining and oil & gas operators, and
- facility managers and national contractors
to mandate both:
- Working at Heights training (usually RIIWHS204E), and
- EWP training + Verification of Competency (VOC) appropriate to the type of EWP.
This is why combination training (EWP + heights) is rapidly becoming the default expectation for new workers on reputable WA sites, even where the strict legal minimum might be lower.
EWP Ticket Options at Equip-Safe (Orange Card Training)
Equip-Safe’s Orange Card training is an industry-recognised alternative to the EWPA Yellow Card, delivering nationally recognised units of competency for EWP operation (under 11 m), with the option to bundle in Working at Heights.
The card itself is an Equip-Safe/industry credential, while the training and Statements of Attainment are nationally recognised.
Orange Card course options:
Nationally recognised unit: e.g. RIIHAN301E – Operate elevating work platform (scissor configuration).
Nationally recognised units:
RIIHAN301E – Operate elevating work platform and CPCCCM3001 – Operate elevated work platforms up to 11 metres
Nationally recognised units:
RIIHAN301E – Operate elevating work platform, CPCCCM3001 – Operate elevated work platforms up to 11 metres and RIIWHS204E – Work safely at heights
All successful participants receive:
- a Statement of Attainment listing the completed units, and
- an Equip-Safe Orange Card, which many WA sites accept as evidence of EWP training in place of the Yellow Card.
Book Your Orange Card Course
Equip-Safe delivers EWP and Working at Heights training built around WA’s WHS requirements and industry expectations.
With our Orange Card pathways, you can:
- gain nationally recognised units of competency for scissor and boom lifts (under 11 m)
- add Work safely at heights to meet the standards used on most major WA sites
- complete the full combo (EWP + heights) in roughly one and a half days of training, depending on the course selected
Enrol in an Orange Card + Heights course today and get job-ready for WA construction, maintenance and industrial worksites.
CTF funding is available for eligible apprentices on selected Orange Card + Heights courses. Check current funding and eligibility details at the time of booking.
Disclaimer: This information is general in nature and based on current WA work health and safety requirements at the time of publication. It does not replace the WHS laws or legal advice. For site-specific or legal questions, please refer to WorkSafe WA, the WHS legislation, or a qualified adviser.
