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Aircraft Refuelling SWMS

Aviation fuel; bonding cable; over-wing/under-wing.

⚖️WHS Regulation 2025 & Codes of Practice — legally binding from 1 July 2026 (s26A)
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SWMS variants reference your state’s WHS legislation. Instant download after payment.

Aircraft refuelling operations involve the transfer of large volumes of highly flammable Jet A-1 or Avgas between bulk storage, hydrant systems, refuelling vehicles and aircraft fuel tanks, using either over-wing nozzles or under-wing single-point pressure couplings. This work generates significant ignition risk from static electricity, vapour accumulation, and proximity to running auxiliary power units, ground service equipment and other aircraft. Under WHS Regulation 2011 r291 and equivalent state provisions, refuelling activities conducted as part of construction, commissioning, or maintenance work on aerodromes constitute High Risk Construction Work due to the use of hazardous chemicals and ignition sources in confined apron environments. A Safe Work Method Statement is mandatory before any worker commences refuelling, must be developed in consultation with workers under s47 of the WHS Act, and must be kept available for inspection for the duration of the work plus two years after a notifiable incident.

Hazards identified

7 hazards covered, sorted by priority.

Static electricity discharge during fuel transfer igniting vapour at the nozzle interfaceHIGH

Flash fire or vapour cloud explosion causing fatal burns, blast lung injury and total hull loss of the aircraft

Hydrocarbon vapour inhalation from spills, vent outlets or open over-wing fill portsHIGH

Central nervous system depression, chemical pneumonitis and long-term hydrocarbon neurotoxicity under SWA exposure standards

Bonding cable not connected or connected to painted/non-conductive surface before flow commencesHIGH

Differential potential between bowser and airframe causes spark discharge igniting Jet A-1 vapours and catastrophic fire

Fuel spill onto hot brakes, APU exhaust or energised ground power unit cablingHIGH

Immediate auto-ignition, pool fire spreading under aircraft, regulatory notification under WHS Act s38 and CASA reporting

Overpressure or overfill of aircraft fuel tank from defective pressure control valveMEDIUM

Structural rupture of wing tank, fuel ejection through vent surge tank, environmental release and aircraft grounding

Manual handling of heavy under-wing single-point couplings and dragged hose lengthsMEDIUM

Musculoskeletal injury to lumbar spine and shoulder rotator cuff requiring workers compensation claim and lost time

Slip and fall from wing surface during over-wing refuelling of general aviation aircraftMEDIUM

Fall from height greater than 2 metres causing fractures, head injury and notifiable incident under WHS Act s35

Control measures

Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.

  1. 1Elimination — Use single-point pressure refuelling under-wing where aircraft type permits to eliminate worker exposure to open fill ports, vapour release and wing-top fall hazards.
  2. 2Elimination — Prohibit refuelling while passengers board, APU operates without flight crew authority, or other aircraft taxi within the designated fuelling safety zone.
  3. 3Substitution — Substitute Jet A-1 for higher-volatility Avgas where the airframe type certificate allows, reducing flash point exposure and vapour generation during transfer.
  4. 4Engineering — Verify bonding cable continuity with an integrated bond-loop monitor that interlocks the deadman valve and prevents flow until resistance is below 25 ohms.
  5. 5Engineering — Maintain a 3-metre vapour exclusion zone around vents, nozzle and tank openings using fixed signage and dry-break couplings compliant with AS 1940.
  6. 6Administrative — Conduct a documented pre-start brief against this SWMS, confirm aircraft type, fuel grade, quantity, and complete the refuelling checklist before connecting the nozzle.
  7. 7Administrative — Position the refueller vehicle for unobstructed emergency egress, with handbrake on, wheels chocked, and engine running only as required by AS 1940 Section 11.
  8. 8Administrative — Station a competent fire watch with charged 9 kg dry chemical extinguisher within 8 metres of the nozzle for the full duration of the transfer.
  9. 9PPE — Wear anti-static cotton or Nomex coveralls, conductive footwear tested to AS/NZS 2210.3, nitrile fuel-resistant gloves, and impact-rated safety eyewear to AS/NZS 1337.1.
  10. 10PPE — Use hearing protection rated to AS/NZS 1270 when working within 15 metres of running APU or GPU, and high-visibility apron garments to AS/NZS 4602.1.

Applicable Codes of Practice

AS 1940:2017 The storage and handling of flammable and combustible liquids⚖ Legally binding · 1 Jul 2026

Mandates bonding, separation distances, spill containment and ignition source control directly governing fuel transfer to aircraft on the apron.

Managing the Risks of Hazardous Chemicals in the Workplace Code of Practice (SWA 2020)⚖ Legally binding · 1 Jul 2026

Requires PCBU to identify, assess and control hydrocarbon vapour exposure under WHS Reg r35 and maintain register and SDS access.

AS/NZS 60079.10.1:2022 Classification of areas — Explosive gas atmospheres

Defines Zone 0, 1 and 2 hazardous areas around nozzle and vents dictating intrinsically safe equipment selection during refuelling operations.

Civil Aviation Safety Regulation Part 139 MOS — Aerodrome Refuelling Operations

Sets operational duties for fuel quality control, refueller positioning, and incident reporting that complement WHS duties on the airside.

High-Risk Construction Work triggered

14
Work involving the use or storage of hazardous chemicals requiring placarding

Aviation kerosene and Avgas exceed manifest quantities under Schedule 11 of the WHS Regulations and are transferred in placardable volumes during refuelling.

15
Work carried out in an area with a risk of fire or explosion

Open transfer of Class 3 flammable liquid adjacent to ignition sources, hot surfaces and electrical equipment creates classified hazardous zones during every refuel cycle.

Legal consequence

PCBU must consult workers, prepare and implement the SWMS before work starts, monitor compliance and retain records; penalties for Category 1 breaches are substantial and indexed annually under the prevailing WHS schedule.

Who this is for

  • Into-plane refuelling operators at regional and capital city aerodromes
  • Fixed base operator (FBO) ground crew servicing general aviation
  • Aviation fuel facility maintenance and commissioning contractors
  • Defence and emergency services aviation refuelling personnel

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 a regional aerodrome, a hydrant refuelling operator arrives at Bay 3 to uplift 12,000 litres of Jet A-1 into a turboprop ahead of a scheduled departure. Before connecting any hose, the operator opens this SWMS on the tablet mounted in the refueller cab and runs the pre-start brief with the trainee assisting. They identify the live hazards for that bay: APU running on the adjacent aircraft, a baggage tug operating within 10 metres, and a forecast 18-knot crosswind blowing vapour toward the terminal. Working down the control hierarchy, they request the apron controller halt tug movement within the safety zone (administrative elimination), confirm under-wing single-point coupling is available (engineering), and verify the bonding cable clamps onto bare metal at the designated bonding point with the bond-loop monitor showing continuity. Both workers sign on to the SWMS electronically, acknowledging the fire watch position and emergency stop location. Midway through the uplift, the trainee notices a small fuel sheen near the coupling. Following the during-task response in this SWMS, the operator activates the deadman release, isolates the hydrant pit valve, deploys absorbent from the spill kit, and records the deviation. Work resumes only after the coupling seal is replaced and a second sign-on is completed against the amended SWMS.

Related legislation

  • WHS Act 2011 (model)
  • WHS Regulation 2025
  • Construction Work CoP; AS 1940 — Flammable & combustible liquids
What's in this SWMS

Document details

Regulation
WHS Regulation 2011 r291 — High Risk Construction Work; applicable state WHS Regulations and Codes of Practice.
HRCW Category
Aviation fuel, bonding/grounding, ignition
Hazards Identified
6 hazards with controls
Format
Editable DOCX (Microsoft Word)
Author
Certified Industrial Hygienist (CIH)
Delivery
Instant download after payment