AFFF / PFAS Fire Suppression System Decommission SWMS
AFFF/PFAS fire suppression system decommission SWMS for NSW. PFAS exposure control, no environmental release, confined-space tank entry, decontamination against rebound and licensed high-temperature disposal. Editable DOCX.
SWMS variants reference your state’s WHS legislation. Instant download after payment.
Decommissioning an aqueous film-forming foam (AFFF) fire suppression system is the controlled draining, flushing, dismantling and disposal of a system whose concentrate and wetted internal surfaces are contaminated with per- and poly-fluoroalkyl substances (PFAS). The work is high risk construction work under the NSW WHS Regulation 2025 wherever it involves entry to a confined space — foam concentrate tanks, sumps and pits — or a risk of a person falling more than 2 m from elevated deluge pipework (s291), so a SWMS is mandatory under s299. The defining hazard is PFAS itself: a persistent, bioaccumulative contaminant that adheres to tank walls, pipework and pumps and that must not be released to stormwater, soil or sewer. Every litre of concentrate and rinsate is a regulated waste, and the residue rebounds onto cleaned surfaces, so decontamination is verified rather than assumed. Layered onto the PFAS problem are confined-space atmospheres in sealed concentrate tanks, work at height on deluge headers, stored hydraulic and pneumatic energy in the system, and the manual handling of heavy drums of recovered concentrate. The SWMS sequences isolation, energy lockout, concentrate recovery, triple-flush-and-test decontamination, and licensed high-temperature disposal so that no PFAS reaches the environment and no worker is exposed. It cites the hazardous chemicals provisions (Part 7.1), the confined space provisions (Part 4.3), and the PFAS National Environmental Management Plan, and it names SafeWork NSW as the regulator for the work health and safety duties that run through the task.
Hazards identified
7 hazards covered, sorted by priority.
Persistent environmental contamination and prosecution under the applicable environmental protection legislation; clean-up liability
Asphyxiation or toxic exposure; breach of the confined space entry-permit duty (WHS Reg Part 4.3)
Bioaccumulative uptake of a substance with no established safe exposure level
Fall fatality or serious injury (WHS Reg Part 4.4)
Struck-by injury or uncontrolled discharge of pressurised concentrate
Failed clearance, re-contamination and undisposed regulated waste
Musculoskeletal injury during lifting and drum movement
Control measures
Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.
- 1Elimination — Recover the entire foam charge into sealed, labelled containers and remove it from site for licensed high-temperature destruction before any dismantling begins, eliminating the source
- 2Substitution — Substitute a closed-circuit pump-and-flush rig for open draining so concentrate and rinsate are never exposed to the atmosphere or ground
- 3Engineering — Bunded capture, blanking plates and double-block-and-bleed isolation on every line before breaking containment
- 4Engineering — Mechanical ventilation and continuous atmospheric monitoring for any confined-space tank entry, with a non-entry rescue system rigged
- 5Engineering — Triple flush-and-test cycle with PFAS sampling of rinsate to confirm contamination is below the disposal threshold before surfaces are released
- 6Administrative — Confined space entry permit, energy-isolation lockout/tagout and a PFAS waste-tracking manifest for every container
- 7Administrative — Decontamination procedure for plant, PPE and personnel, with a verified clearance sign-off before demobilisation
- 8Administrative — Spill response plan with bunding and absorbents staged at every break point
- 9PPE — Chemical-resistant coveralls, nitrile gloves and face/eye protection for concentrate handling; air-supplied respiratory protection for confined-space entry
- 10PPE — Fall-arrest harness and certified anchorage for work on deluge headers and tank tops above 2 m
Applicable Codes of Practice
General workplace and decontamination duties for the work
Entry-permit, atmospheric monitoring and rescue duties for tank and sump entry
Fall-protection duties for work on elevated deluge pipework
National framework for PFAS containment, disposal and environmental protection
Technical basis for safe confined-space entry, ventilation and rescue
Selection, fit-testing and use of air-supplied respiratory protection
High-Risk Construction Work triggered
Draining and inspecting foam concentrate tanks, sumps and pits is confined-space entry.
Work on elevated deluge headers and tank tops carries a fall risk over 2 m.
Sealed concentrate tanks may hold contaminated or oxygen-deficient atmospheres.
Who this is for
- →Fire-protection system technicians decommissioning AFFF installations
- →Hazardous-materials and environmental remediation supervisors
- →Confined-space entry supervisors and standby/rescue attendants
- →Principal contractor HSE managers coordinating PFAS works
- →Licensed waste contractors handling PFAS concentrate
What you receive
- ✓Editable DOCX template — Microsoft Word compatible
- ✓State-specific WHS legislation schedule (NSW/VIC/QLD/SA/WA/TAS/NT/ACT)
- ✓Hazard register with risk ratings + hierarchy-of-control mapping
- ✓Worker sign-on register, pre-start checklist, and incident escalation flow
Worked example
At 7:00 am, a crew from Halon Fire Services arrives to decommission the AFFF deluge system in a disused aircraft hangar. Before anything is opened, the supervisor confirms the foam charge was recovered and removed the previous week, then isolates and locks out the pump set and pressurised lines. The concentrate tank is treated as a confined space: the lid is removed, the atmosphere is tested and found oxygen-deficient, mechanical ventilation runs until readings clear, and a non-entry rescue line is rigged before the attendant signs the entry permit. Inside, residue is pump-flushed in a closed circuit and the rinsate sampled; the first sample is above the PFAS disposal threshold, so the crew runs a second and third flush until the lab-confirmed result clears. Work on the elevated deluge header is done from a harness clipped to a certified anchor. All rinsate and stripped pipework leave the site under a PFAS waste manifest for high-temperature destruction, and the decontamination clearance is signed before the crew demobilises — nothing PFAS-bearing reaches the yard drains.
Related legislation
- WHS Act 2011 (model)
- WHS Regulation 2025
- PFAS National Environmental Management Plan (NEMP) 2.0
- Confined Spaces Code of Practice
Frequently asked questions
Do I need a SWMS for AFFF or PFAS fire suppression decommissioning?
Yes. Wherever the decommissioning involves entry to a confined space such as foam concentrate tanks, sumps and pits, work in a potentially contaminated or oxygen-deficient atmosphere, or a fall risk of more than 2 m on elevated deluge pipework, it is high risk construction work under s291 of the NSW WHS Regulation and a SWMS is mandatory under s299 before work starts. The document must be prepared and workers consulted before any line is opened.
This SWMS is written for NSW — can I use it in Victoria or other states?
You can use it as a starting point; the template includes a state-specific WHS legislation schedule covering NSW, VIC, QLD, SA, WA, TAS, NT and the ACT. Victoria operates under the OHS Act 2004 and OHS Regulations 2017 rather than the model WHS framework, so update the legislation schedule with OHS-Act equivalents and cite WorkSafe Victoria compliance materials in place of the model Codes of Practice. The PFAS National Environmental Management Plan is a national framework, so the containment and disposal approach carries across jurisdictions.
Are the Codes of Practice cited in this SWMS legally binding?
In New South Wales, yes. The Confined Spaces, Managing the Risk of Falls at Workplaces, and Managing the Work Environment and Facilities Codes of Practice referenced in this SWMS are legally binding under Section 26A of the WHS Act (NSW) since 1 July 2026, so their entry-permit, atmospheric monitoring, rescue and fall-protection duties are enforceable obligations rather than guidance.
Does this SWMS authorise PFAS waste disposal or confined space entry on its own?
No. Recovered concentrate, rinsate and stripped pipework must leave site as regulated waste under a PFAS waste-tracking manifest for licensed high-temperature destruction — the SWMS sequences that process but does not replace waste licensing or environmental approvals. Similarly, every tank, sump or pit entry still requires its own confined space entry permit, atmospheric testing and a rigged non-entry rescue system before anyone goes in.
What do I need to change before using the SWMS on my site?
Every SWMS must be made site-specific before use. Map your actual system — tank and sump locations, isolation and lockout points, elevated pipework runs and drainage paths to be bunded — and insert the laboratory arrangements and PFAS disposal threshold used to clear the triple flush-and-test cycle. Then record the crew consulted, confirm the spill response kit staging at each break point, and have workers sign on before mobilisation.