Combustible Cladding Risk Assessment SWMS

Combustible cladding risk assessment involves the systematic identification, sampling, and fire-spread evaluation of external wall materials on existing buildings — including aluminium composite panels (ACP) with polyethylene cores, expanded polystyrene (EPS) render systems, and high-pressure laminates (HPL). The work spans desktop document review, intrusive sampling at height, laboratory analysis, fire engineering modelling, occupant evacuation planning, and sequencing of interim and permanent rectification measures. A SWMS is mandatory under WHS Regulation 2025 because the assessment activity itself constitutes high-risk construction work — operatives access façades at height, disturb potentially friable insulation, and work on or near buildings with known fire-propagation risk. NSW Building Products (Safety) Act 2017, VIC Building Act 1993 cladding provisions, and the ABCB advisory framework all require documented risk assessments prepared by competent persons, and PCBUs must demonstrate consultation, hazard control, and worker sign-on before any façade intervention commences. Without a compliant SWMS, the PCBU cannot lawfully mobilise assessors, EWP operators, or rectification crews to a suspect building.

Hazards identified

7 hazards covered, sorted by priority.

Control measures

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

1. 1Elimination — Conduct desktop assessment of building documentation, façade drawings, and supplier declarations before any intrusive sampling to eliminate unnecessary façade entry.
2. 2Elimination — Prohibit all hot work, grinding, and spark-producing activities on or within five metres of suspect combustible cladding during the assessment phase.
3. 3Substitution — Replace destructive core sampling with non-destructive XRF analysis and infrared spectroscopy where panel identification can be achieved without disturbance.
4. 4Substitution — Use cold-cutting hydraulic shears instead of abrasive saws when sample extraction is unavoidable to remove ignition energy from the cladding system.
5. 5Engineering — Install perimeter catch fans, hoarding, and exclusion zones extending one-third of building height per AS 4576 to capture dropped objects and debris.
6. 6Engineering — Deploy continuous fire watch with thermal imaging cameras and charged hose reels positioned within 15 metres of all sampling locations throughout works.
7. 7Administrative — Issue permit-to-work authorised by competent fire safety engineer for each sampling location, with cladding type, evacuation plan, and interim measures documented.
8. 8Administrative — Conduct daily pre-start briefing referencing this SWMS, confirm occupant notification, and verify fire indicator panel isolation procedures with building management.
9. 9PPE — Issue P2 respirators, cut-resistant gloves to AS/NZS 2161.3, FR-rated coveralls to AS/NZS 4824, and full-body harness with twin lanyards to AS/NZS 1891.1.
10. 10PPE — Provide impact-rated hard hats with chin straps to AS/NZS 1801, sealed safety eyewear to AS/NZS 1337.1, and high-visibility garments to AS/NZS 4602.1 for all façade personnel.

Applicable Codes of Practice

High-Risk Construction Work triggered

Worked example

A cladding assessment crew mobilises to an eight-storey mixed-use building flagged on the state affected-buildings register, suspected to contain polyethylene-core ACP across the northern elevation. At the 6:30am pre-start brief in the ground-floor amenities room, the supervisor walks the four-person team through this SWMS line by line. The team reviews the hazard register and confirms today's primary risks: fall from EWP at level seven, dropped sample fragments onto the laneway below, and ignition risk from any spark source near the panel. Controls are selected from the hierarchy — hot work is eliminated entirely, an XRF analyser will be used at three locations before any cold-cut sampling is attempted, perimeter hoarding has been verified by the site engineer, and a fire watch with charged hose reel is stationed at level six. Each worker signs on, confirming competency for EWP operation (HRWL WP licence sighted) and rope access (IRATA Level 1 minimum). At 10:15am, the assessor identifies an unexpected services penetration behind the proposed sample location. Work stops, the SWMS is reopened on the supervisor's tablet, and an additional control — services isolation permit through building management — is added before any cutting proceeds. The amended SWMS is re-signed by all four workers before the task resumes.

Related legislation

• WHS Act 2011 (model)
• WHS Regulation 2025
• National Construction Code; AS 5113 — Combustible cladding

Frequently asked questions