By Greg Allan, tradesman and creator of Data First Coaching
What health and safety duties does a roof plumbing business owner have under HSWA?
Most roof plumbers in New Zealand are running a PCBU, a person conducting a business or undertaking, under the Health and Safety at Work Act 2015. WorkSafe New Zealand is the regulator responsible for administering and enforcing HSWA, as set out in Working at height in New Zealand. A PCBU must, so far as reasonably practicable, protect the health and safety of workers and anyone else the work could affect.
That duty follows every job, from a straightforward guttering and downpipe maintenance call to a full re-roof with new box gutters and ridge flashing. According to Working at height in New Zealand, a PCBU must also provide welfare facilities for workers, give training, instruction or supervision so far as reasonably practicable, and monitor conditions at the workplace and worker health to prevent illness or injury. For a roof plumber moving between sites across the week, this is not a once-a-year policy document sitting in a drawer. It is a standard that has to hold on every roof, every box gutter and every valley the crew works in, whether the job is routine maintenance, new work for a builder, or insurance work after a storm.
What extra duties come with working at height on a roof?
Roof plumbing work almost always carries a fall risk, which is why WorkSafe treats working at height as its own area of focus. According to Scaffolding in New Zealand, a PCBU must, so far as reasonably practicable, eliminate the need to get onto the roof at all by carrying out as much of the job as possible from the ground, and roof edge protection built from scaffolding components counts as scaffolding in its own right.
On a metal roof re-roof, a storm repair or a flashing job that turns into more than expected, that distinction matters. Scaffolding in New Zealand says scaffolding above a certain height must be erected by a certified scaffolder, and that the work also has to be notified to WorkSafe once the fall distance reaches a certain point, with the current figure kept on their page rather than repeated here, because it can change. Working at heights: roof restoration and maintenance adds that notification rules differ for smaller residential buildings, which matters to a roof plumber whose week mixes two-storey homes with bigger commercial metal roof and box gutter work, and whose schedule already moves around a weather day here and there.
What must you do before your crew gets up on the roof?
Before anyone on your crew gets up on a roof, WorkSafe expects them to have had training from a competent person on how to work safely at height, with extra training where the roof or wall cladding is brittle. If your crew uses a harness or fall arrest system, close supervision, at least two people present and a rescue plan everyone has actually been shown through are all part of the standard.
Working on roofs - good practice guidelines says anyone using a harness system should be closely supervised by a competent person, or be competent themselves, that at least two workers should be present when fall arrest gear is in use and trained in it, and that a rescue plan should always be in place with workers trained in the procedure. As the owner, you also carry a due diligence duty as an officer of the business. Introduction to the Health and Safety at Work Act 2015 sets this out as keeping your own knowledge of health and safety current, understanding the hazards in your own roof plumbing work, and making sure the business actually uses the resources and processes it has, not just owns them on paper. For a roof plumber, that applies whether the job is a quiet downpipe repair or a storm callout where the crew is racing a closing weather window.
What do you have to do if something goes wrong on site?
If a notifiable event happens on one of your jobs, such as a serious injury or a fall, HSWA requires you to notify WorkSafe as soon as possible, and to give written notice if WorkSafe asks for one within the time it sets. You also have to keep the site undisturbed until an inspector says work can start again, and keep a record of the event.
Health and Safety at Work Act 2015 No 70 sets out the duty to notify a notifiable event to the regulator and to follow up in writing if required. What events need to be notified? explains that the PCBU in control of the site must take all reasonable steps to preserve it until an inspector gives the go-ahead, which matters on a roof job where scaffold, ladders and tools are normally packed up and moved to the next site the same day. HSWA also sets a record keeping duty for notifiable events, covered on Notifiable events for adventure activities, under the same section of the Act that applies to every PCBU, not only adventure operators.
This is general information, not legal, tax or employment advice. Check your own situation with the body named here or a qualified adviser.
How can your own job data make these duties easier to carry?
The real record of whether your roof plumbing business is meeting its HSWA duties is not a policy folder, it is what actually happened on each job: who went up on the roof, what training and height safety gear they had, what the weather and fall risk looked like that day, and whether a notifiable event was ever logged and reported on time. Data first thinking means building those records from the job itself, not recreating them from memory after WorkSafe asks.
AI agents are software that does a job the way you would, using your own wording, your own site rules and your own forms, rather than a generic template. For a roof plumber, that can mean AI agents that prompt for a height safety check before a job is marked started, or that keep training and scaffold records tied to the job rather than filed away until an audit finds the gap. Whether your yard is in Auckland, Wellington, Christchurch or a smaller New Zealand town, Data First Coaching starts from your own job and safety data, so where the business is based does not change how the coaching works.
Where can you check the current rules?
- Working at height in New Zealand - covers PCBU duties under HSWA and WorkSafe's role as the regulator.
- Scaffolding in New Zealand - covers when roof edge protection counts as scaffolding and when work must be notified.
- Introduction to the Health and Safety at Work Act 2015 - covers the due diligence duty of officers, including a business owner.
- Working on roofs - good practice guidelines - covers training, supervision and rescue plans for roof work.
- Working at heights: roof restoration and maintenance - covers notification rules for residential roof jobs.
- Health and Safety at Work Act 2015 No 70 - sets out the legal duty to notify a notifiable event.
- What events need to be notified? - explains how to preserve a site after a notifiable event.
- Notifiable events for adventure activities - sets out the record keeping duty for notifiable events under HSWA.
How does Data First Coaching approach this?
Data First Coaching, built by Greg Allan, starts from a roof plumber's own job and safety records before it talks about policy at all: who went up on which roof, what training and height safety gear was logged, and whether a notifiable event was ever caught and reported properly. Through the Trade Business Intelligence, that picture is read alongside years of coaching trade businesses, so the real gap, often sitting in records rather than rules, shows up instead of being guessed at. The how, the systems and the agents that carry this work day to day are worked through inside the Academy, with members, because the Trade Business Intelligence is powered by every member who is open minded, innovative and willing to share what they learn.
