Working at height, order pickers and getting to elevated racking
The model falls Code covers a fall from one level to another that is reasonably likely to cause injury. That is general language, and it is worth being precise about what it does not contain: we found no mention of racking, mezzanines or order pickers anywhere in the content we retrieved.
Last updated 2026-08-24
What the falls Code actually says it covers
The model Code states that it "provides guidance on managing the risk of a fall by a person from one level to another that is reasonably likely to cause injury". Level to level, and injury-likely — that is the scope in one sentence.
It is deliberately general-purpose. It is not a warehouse document, not a construction document, and not tied to a particular kind of structure. That generality is a strength in law and a weakness in application: it means the Code applies to a warehouse without ever describing one.
A separate Code for elevating work platforms
Safe Work Australia maintains a distinct model Code of Practice for elevating work platforms, and references it from the same place as the falls Code. This matters in a warehouse because order pickers and similar equipment raise an operator, which puts the work in both territories at once.
So a page dealing with fall risk on elevated equipment that anchors only to the falls Code is anchoring to half the material. The plant side applies too, since the machine is plant whatever else it is, and the equipment itself is covered under what an order picker is and does.
Licensing follows the machine rather than the height. Which licence class applies to an order-picking machine is a specific question, and the LO and LF licence classes are where that gets sorted out — the distinction is not intuitive and getting it wrong is a common problem.
What the Code does not say about racking
We looked specifically for this. In the content we retrieved, the falls Code does not name pallet racking, mezzanine floors or order pickers as examples. That is a finding, not an oversight on our part, and we are reporting it rather than assuming the examples exist somewhere in the full document.
The practical consequence is a wording discipline. Saying "the falls Code specifically addresses racking access" would be inventing a connection. What is accurate is that the Code addresses falls between levels generally, and that reaching elevated racking is a reader-drawn application of that general scope. The difference sounds small and is exactly the sort of small claim that content in this area gets wrong.
Anyone applying the Code to a mezzanine will find the physical requirements sitting elsewhere anyway — edge protection on a raised floor is the practical control, the structure itself is a storage decision, and the platforms, walkways and ladders standard is the designation usually cited for fixed access.
Climbing racking, which is the real warehouse problem
The fall risk that actually injures people in warehouses is rarely exotic. It is someone climbing a rack frame to reach a carton because the machine is in use, the shift is nearly over, or the item is one level up and looks close. Racking is not access equipment and was never designed as any, which is the whole of the argument.
Why people climb racking, and what to do about it deals with that directly. The control that works is making the correct access available and quick, because a rule against climbing competes with a physical reality of a person, a carton and no machine.
Where fall arrest equipment enters the picture, it sits at the bottom of the control hierarchy rather than the top, and it carries its own designation under the fall arrest systems standard. Reaching for a harness before you have exhausted the options above it is the wrong order.
When height work becomes a project
Ongoing warehouse work at height sits under the ordinary duty framework. A project is different: work at height is one of the categories that can require SWMS versus a risk assessment where the work is construction work, which is why racking installation and dismantling are treated differently from picking.
The same is true of other unusual work. Entry into a pit or vessel can involve a descent, and a task can sit in two hazard categories at once. Keeping them named separately is what stops one control being credited with covering both, and the duty structure underneath does not change either way.
Common questions
- Does the falls Code of Practice cover racking access?
- It covers falls from one level to another that are reasonably likely to cause injury, which is general language. In the content we retrieved it does not name racking, mezzanines or order pickers as examples, so applying it to racking access is a reader drawing on general scope rather than following a specific worked example in the document.
- Is an order picker covered by the falls Code or the plant Code?
- Realistically both, plus the separate model Code for elevating work platforms. The operator is raised, so the fall risk applies; the machine is plant, so the plant requirements apply; and the elevating work platform material is directly on point. Anchoring to only one of the three misses material.
- Is it ever acceptable to climb racking?
- Racking is a storage structure, not access equipment, and it is not designed or rated for a person to climb. The useful question is why someone felt they had to, because the answer usually points at access equipment that was unavailable, slow or in the wrong place.
- Is there a height at which fall protection becomes required?
- Specific height figures appear in various regulations and in the high risk construction work categories, and they differ by context and jurisdiction. We are not quoting one here, because a height figure lifted out of its context is the kind of detail that misleads. Read it in your own regulator's material.
Sources
- Safe Work Australia — Model Code of Practice: Managing the risk of falls at workplaces — Covers falls from one level to another generally. No verbatim mention of racking, mezzanines or order pickers was found in the retrieved content. Retrieved 2026-08-24.
- Safe Work Australia — High risk construction work requiring a SWMS — The categories of high risk construction work that require a safe work method statement. Fetched directly. Retrieved 2026-08-24.
Part of our guide to work health and safety in a warehouse.