Bathroom Accessibility Modification SWMS
This Safe Work Method Statement covers the modification of an existing domestic bathroom to make it accessible to an occupant with impaired mobility — most commonly the conversion of a hobbed or stepped shower to a level-entry, hobless shower, together with the installation of accessible fixtures. T
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Converting a standard domestic bathroom to a level-entry, accessible one is the highest-value single modification in the accessible housing market and the most hazard-dense. The work removes the shower screen, the hob, the floor and wall tiles and the existing waterproof membrane, grinds or demolishes the slab set-down to form a recess, re-grades the floor to a linear or centre waste, applies a new membrane, re-tiles, and installs an accessible pan, basin, tapware and shower fittings — plus the noggings or backing plates that will later carry grab rails.
What makes it dangerous is not any single task but the room. A domestic bathroom is three square metres of hard, reflective, poorly ventilated surface. Cutting tile and screed in that space produces respirable crystalline silica concentrations far above the same task performed outdoors; solvent vapour from membrane and epoxy accumulates rather than dissipating; noise from a grinder reflects off every surface; and the worker performs most of the job kneeling in a space too small to change posture. An outdoor tile-cutting method transplanted into a bathroom will under-control every one of those exposures. The controls in this document therefore isolate the room, put it under negative pressure and extract at the tool, rather than treating a respirator as sufficient.
The second defining risk is what is already in the walls. A bathroom strip-out in a dwelling built or renovated before 1990 is one of the most common ways an unlicensed crew disturbs asbestos — in wall sheeting, backing board, tile adhesive or vinyl. Concealed electrical cable runs above and below every switch, heat lamp and exhaust fan, and pipework sits behind every fixture. The document requires the age of the dwelling to be established and every material identified before a tool is used.
Where the work involves demolition of an element of a structure, or is carried out in an area that may contain asbestos, it is high risk construction work under section 291 of the Work Health and Safety Regulation and a Safe Work Method Statement is required under section 299 before work commences.
Hazards identified
12 hazards covered, sorted by priority.
Accelerated silicosis and lung cancer; concentrations in an enclosed wet area far exceed the same cutting performed outdoors
Mesothelioma and asbestosis decades later; a bathroom strip-out is a leading cause of uncontrolled domestic fibre release
Cardiac arrest; wet conditions and a tiled floor dramatically lower the resistance path to earth
Chronic lumbar and knee injury; the room is too small to change posture during long tiling and membrane work
Deep lacerations and arterial injury; toughened glass fails suddenly and completely into a confined space
Fall onto hard tiled surfaces, broken tile or exposed plumbing; ankle and wrist fracture, head injury
Respiratory sensitisation, central nervous system effects and dermatitis; vapour accumulates in an unventilated room
Structural rot, mould colonisation and a permanent slip hazard for an occupant with impaired balance; full re-do of the room
Fall onto a hard wet surface by a person already unsteady, at the moment they are relying on the rail
Room is unusable by the occupant; the entire modification fails despite technically compliant fixtures
Toileting and hygiene crisis for a person with impaired mobility; injury from demolition debris or open services
Gastrointestinal and respiratory infection; mould spore release during lining removal
Control measures
Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.
- 1Establish the age of the dwelling and identify every material to be removed before any tool is used; presume asbestos in any lining of unknown composition until sampled by a competent person.
- 2Stop work, vacate and secure the room if suspect asbestos is uncovered mid-demolition — withdraw rather than upgrading PPE and continuing.
- 3Isolate every circuit serving the bathroom and adjacent walls at the switchboard, test for dead at the point of work, and apply a personal lock and tag before any demolition or drilling.
- 4Locate cables and pipework by non-destructive means before cutting into any wall or ceiling, and treat wiring found in an unexpected position as live until proven otherwise.
- 5Eliminate dry cutting entirely; use on-tool water suppression or H-class on-tool extraction for every cut, grind and chase.
- 6Seal the doorway with a physical barrier and place the room under negative pressure discharging outside, so dust cannot migrate into the occupant's home.
- 7Specify a proprietary level-entry shower base where it avoids slab recess grinding altogether — the cheapest silica control is not cutting.
- 8Clean by H-class vacuum or wet method only; never compressed-air blow-down, never dry sweeping, and remove coveralls and boots at the room threshold.
- 9Remove the shower screen intact — taped and carried out as a unit — rather than breaking it in place, and never with one person.
- 10Cap the sewer opening on disconnection and keep it capped whenever work is not proceeding at it.
- 11Specify a low-VOC water-based membrane and cement-based grout in preference to solvent-borne or epoxy systems, and mechanically extract to outside air during application and cure.
- 12Install noggings, backing plates or full-sheet backing behind every future grab rail position while the wall is open — retrofitting into a lined cavity is not an equivalent control.
- 13Photograph and dimension the backing positions before the wall is closed, and keep the record with the job file so a future installer knows where they are.
- 14Hold a documented flood test for the specified period before tiling, with the substrate condition, coat count and result recorded by the supervisor.
- 15Set out fixture positions, circulation and transfer space from the occupational therapist's assessment before any demolition, and confirm with the occupant before fixtures are plumbed in.
- 16Agree in writing before work starts what bathroom or toilet facility the occupant will use for the whole duration, and arrange temporary facilities where the dwelling has only one bathroom.
Applicable Codes of Practice
Sets the framework for SWMS preparation, high risk construction work and demolition of an element of a structure.
Governs identification, presumption and control of asbestos in pre-1990 wall sheeting, backing board, adhesive and vinyl.
Applies to the licensed removal that must occur before this work resumes; asbestos removal is not performed under this SWMS.
Governs tile, screed and concrete cutting, on-tool controls, exposure assessment and health monitoring.
Applies to membrane, primer, epoxy grout, adhesive, silicone and solvent used and cured in an enclosed room.
Applies to sustained kneeling, twisting and confined-space postures during tile removal, grinding and membrane application.
The technical standard for substrate preparation, bond breakers, membrane coverage and the flood test the SWMS makes a hold point.
High-Risk Construction Work triggered
Engaged when the hob, floor screed, wall linings and slab set-down are removed to form the level-entry recess. Even where the elements are non-load-bearing, the demolition trigger applies to the removal of structural elements of the wet area.
Engaged in any dwelling built or renovated before 1990, where wall sheeting, backing board, tile adhesive or vinyl behind the tiles may contain asbestos. The trigger applies to the possibility, not the confirmation — which is why identification precedes the first tool.
Engaged because concealed cable runs above and below every switch, heat lamp and exhaust fan in the room, and demolition of wall linings exposes them. The wet environment materially increases the consequence of contact.
Where any of these categories applies, the work is high risk construction work under section 291 of the Work Health and Safety Regulation and a Safe Work Method Statement must be prepared before the work commences under section 299. It must be readily accessible to every worker, must set out the hazards, controls and how they are implemented and monitored, and must be reviewed under section 302 whenever the method changes, a new hazard is identified or a notifiable incident occurs. Separately, asbestos removal may only be performed by a licensed asbestos removalist under an asbestos removal control plan, with a clearance certificate issued before other trades resume.
Who this is for
- →Bathroom renovators and builders delivering NDIS, Home Care Package or My Aged Care funded modifications
- →Waterproofers and tilers subcontracted to accessible wet-area conversions
- →Specialist Disability Accommodation (SDA) builders delivering Improved Liveability, Fully Accessible or High Physical Support dwellings
- →Aged-care and retirement-village maintenance contractors converting hobbed showers to level entry
- →Occupational therapists and case managers requiring a compliant SWMS before approving a bathroom modification
What you receive
- ✓Editable Microsoft Word (.docx) document delivered as an instant download.
- ✓Fourteen identified hazards, each with an initial risk rating, a full control set written to the hierarchy of control, a residual rating and a nominated responsible person.
- ✓Nine regulatory reference bullets citing the governing sections verbatim, so the statutory basis renders in the document rather than sitting in metadata.
- ✓A completed risk matrix using 5×5 likelihood × consequence scoring with both initial and residual ratings.
- ✓A PPE matrix mapping each task to the required protective equipment and the actual AS/NZS standard it must comply with.
- ✓Emergency response provisions covering electric shock, suspected asbestos, glass and tile lacerations, uncontrolled water release, chemical splash and silica overexposure.
- ✓The notifiable incident duty with the regulator's notification number stated in the document.
- ✓A worker sign-on register for recording that each person has read and understood the statement before starting.
- ✓Fully editable text so your PCBU details, site address, personnel, plant and site-specific controls can be inserted.
- ✓State-specific variants available for all eight Australian jurisdictions with the correct Act, Regulation and regulator for each.
Worked example
A renovator is engaged to convert the only bathroom of a 1968 fibro-and-brick cottage to a level-entry shower for an occupant who has recently begun using a wheelchair. The dwelling's age immediately drives two decisions before any quote is finalised. First, a hazardous materials survey is commissioned. It identifies the wall sheeting behind the tiles as asbestos cement. That removal is scoped out to a licensed asbestos removalist under its own control plan, with a clearance certificate required before the renovator's crew returns. The renovator does not touch it — the correct response to asbestos is not better PPE, it is a different licensed contractor. Second, because it is the dwelling's only bathroom, the renovator arranges a hired accessible portable bathroom on the driveway for the three-week duration, and confirms the occupant can reach it in their chair. This is written into the contract before work starts, not negotiated once the room is stripped. During the strip-out the crew seals the doorway, runs a negative-pressure unit discharging out the window, and cuts the slab recess with on-tool water suppression. The occupant remains in the house throughout, so the isolation is what keeps silica out of their living space. With the wall open, the crew installs full-sheet ply backing across the entire shower wall and the pan wall — not just where rails are specified today, but across the whole area, because the occupant's needs will change. They photograph and dimension the backing before lining, and that photograph goes into the job file. Eighteen months later the occupant's condition progresses and a second grab rail is needed in a new position. The installer opens the job file, sees exactly where the backing sits, and fits a load-rated rail in twenty minutes without opening a wall. That photograph was worth more than any other single record on the job.
Related legislation
- Work Health and Safety Act 2011 (NSW) — section 19 primary duty of care, section 47 consultation, sections 35–38 notifiable incidents
- Work Health and Safety Regulation 2025 (NSW) — section 291 high risk construction work, section 299 SWMS required, section 302 review
- Work Health and Safety Regulation 2025 (NSW) — Chapter 7 Hazardous chemicals, including the respirable crystalline silica and asbestos provisions
- Work Health and Safety Regulation 2025 (NSW) — Part 4.7 Electrical safety and Part 4.2 Hazardous manual tasks
- National Construction Code — wet area waterproofing and accessible facility provisions
- Plumbing Code of Australia and AS/NZS 3500 — sanitary plumbing and drainage for the relocated waste and accessible fixtures
Frequently asked questions
Is a bathroom modification really high risk construction work?
Yes, in almost every case. Removing the hob, floor screed, wall linings and slab set-down is demolition of an element of a structure under section 291. In a pre-1990 dwelling the asbestos category applies as well — and it applies to the possibility of asbestos being present, not to its confirmation. Concealed wiring in the walls commonly engages the energised electrical services category too. A SWMS is required under section 299 before work commences.
Why does this need more dust control than cutting tiles outdoors?
Because the room concentrates the exposure. A domestic bathroom is around three cubic metres of enclosed, hard-surfaced, poorly ventilated space, so the same cut that would disperse outdoors produces far higher respirable silica concentrations at the operator's breathing zone — and the dust then migrates into the occupant's home. The controls require on-tool water or H-class extraction, the doorway sealed, and the room under negative pressure discharging outside. A respirator alone is the last line, not the control.
Can I remove the asbestos sheeting myself if it's a small area?
No. This SWMS does not authorise asbestos removal in any quantity. Asbestos removal is licensed work performed under an asbestos removal control plan, with the area enclosed and under negative pressure and a clearance certificate issued before other trades resume. If suspect material is uncovered mid-demolition, the correct response is to stop, withdraw, secure the room and refer — not to fit a mask and finish the job.
What is the flood test hold point and why does it matter?
After the membrane is applied and before any tiling, the wet area is flooded and held for the period the membrane manufacturer and AS 3740 specify, and the result is recorded. It matters because a level-entry shower has no hob to retain water — the membrane and the fall to the waste are the only things keeping water out of the structure. A failure discovered after tiling means removing the new floor entirely, and a failure discovered after handover means rot, mould and a slip hazard for an occupant with impaired balance.
Why does the SWMS make me install grab rail backing during the bathroom job?
Because this is the only practical opportunity. Once the wall is lined and tiled, there is no way to install a structural nogging without opening it again. The controls require backing behind every position where a rail, fold-down seat or rail set may be fitted — and require the positions to be photographed and dimensioned before the wall closes. That record is what allows a future installer to fit a load-rated rail without demolition when the occupant's needs change.
Which states does this cover?
All eight Australian jurisdictions. The NSW version cites the Work Health and Safety Act 2011 (NSW) and Work Health and Safety Regulation 2025 (NSW) with SafeWork NSW as the regulator. Each state variant carries the correct Act, Regulation and regulator — including Victoria, which operates under the OHS Act 2004 and OHS Regulations 2017 with Compliance Codes and its own asbestos Regulations rather than the harmonised section 291 framework. AS 3740, AS 1428.1 and the AS/NZS PPE standards are national.