Dental Surgery Fit-Out (Mercury Management) SWMS

Dental surgery fit-out with mercury management is the work that installs and connects dental chairs, units, suction and amalgam separators, and strips out and decommissions older surgeries where elemental mercury and amalgam residue may be present. The dominant hazards are electric shock connecting dental chairs, units and suction, elemental mercury vapour exposure during amalgam-separator work and an old-surgery strip-out, mercury and amalgam spill and contaminated waste, falls installing ceiling-mounted units and lighting, and biological and clinical residue in a used surgery. This SWMS covers the surgery fit-out, strip-out and mercury management; it does not cover the dental practice's clinical operation, the design of the surgery, or the central plant beyond the equipment connected, which are documented separately.

Under the model Work Health and Safety Act 2011 and the harmonised Work Health and Safety Regulations adopted in each state and territory, this is high risk construction work because it is carried out on or near energised electrical services and where a person can fall more than two metres installing ceiling-mounted units; it is also work in an area requiring respiratory protection from mercury vapour. Victoria operates the equivalent provisions under the Occupational Health and Safety Act 2004 and Occupational Health and Safety Regulations 2017. The workplace exposure standard for inorganic mercury is 0.025 mg/m3 as an eight-hour time-weighted average with a skin notation, and inorganic mercury is listed for health monitoring under the harmonised regulations where there is a significant risk of exposure; amalgam separators meet ISO 11143 with a minimum 95 per cent retention, the equipment connections follow AS/NZS 3000, and waterlines and suction follow AS/NZS 3500.

Failure to meet the primary duty of care is prosecuted under the Category 1 to 3 offences in the Work Health and Safety Act (and the equivalent provisions in Victoria's Occupational Health and Safety Act 2004), with maximum penalties indexed in most jurisdictions, imprisonment available for individuals, and a separate industrial manslaughter offence; current figures follow the prevailing penalty schedule of the responsible state regulator. This document is structured to satisfy the safe work method statement content requirements of the harmonised regulations and documents controlled mercury management and equipment installation.

Hazards identified

10 hazards covered, sorted by priority.

Control measures

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

1. 1Elimination: Isolate and lock out before work, test before touch, and use a licensed electrician under permit; use insulated tools.
2. 2Elimination: Avoid any heat or vacuuming that volatilises mercury, with ventilation and a mercury spill kit on site, and treat amalgam residue as a mercury hazard; wear a mercury-rated respirator and gloves.
3. 3Engineering: Keep a mercury spill kit on site, never use a domestic vacuum, and seal and dispose of mercury and amalgam waste as hazardous or clinical waste; wear gloves and a respirator.
4. 4Engineering: Use a platform or elevating work platform with edge protection for ceiling-mounted units and lighting, with a fall-arrest harness where a residual fall risk remains.
5. 5Engineering: Use mechanical handling aids for dental chairs, cabinetry and compressors, with two-person handling and a 25 kg single-person limit; wear gloves and footwear.
6. 6Engineering: Clean and disinfect a used surgery before works, treat residue as infectious with sharps awareness; wear gloves, eye protection and a respirator.
7. 7Elimination: Isolate and depressurise compressed-air and vacuum plant before work, with lock-out and a safe sequence; wear eye protection.
8. 8Engineering: Handle and dispose of existing instruments and swarf safely, with sharps controls; wear cut-resistant gloves.
9. 9Engineering: Flush and disinfect new dental waterline connections, with the AS/NZS 3500 controls; wear gloves and eye protection.
10. 10Engineering: Keep access clear with waste bins and housekeeping; wear safety footwear.

Applicable Codes of Practice

High-Risk Construction Work triggered

Worked example

A fit-out contractor is stripping out an older dental surgery and installing new chairs, units, suction and an amalgam separator, with the older surgery known to hold elemental mercury and amalgam residue. The work is high risk construction work because it is on or near energised electrical services and at a height where a person can fall more than two metres installing ceiling-mounted units, and it is also work in an area requiring respiratory protection from mercury vapour, so the contractor builds the safe work method statement around mercury management, the electrical connection and work at height. The mercury control is built on never applying heat or vacuuming that would volatilise mercury: a mercury spill kit is kept on site, a domestic vacuum is never used, the area is ventilated, the exposure is kept below the inorganic mercury workplace exposure standard of 0.025 milligrams per cubic metre, and workers wear a mercury-rated respirator and gloves, with health monitoring where there is a significant risk of exposure. Mercury and amalgam waste is sealed and disposed of as hazardous or clinical waste, and the amalgam separator meets ISO 11143 with a minimum 95 per cent retention. The dental chairs, units and suction are connected only after isolation and lock-out by a licensed electrician who tests before touch, and ceiling-mounted units and lighting are installed from a platform with edge protection. A used surgery is cleaned and disinfected before works, with clinical residue treated as infectious and sharps controls applied, and compressed-air and vacuum plant is isolated and depressurised before work. New dental waterlines are flushed and disinfected to control legionella. Workers sign on to the statement before starting, the mercury-management and electrical records are kept, and the signed statement is held on site for the responsible state regulator.

Related legislation

• Work Health and Safety Act 2011 (harmonised; enacted in all states and territories except Victoria, which applies the Occupational Health and Safety Act 2004), s.19 — Primary duty of care to workers and to other persons at or near the workplace
• Harmonised Work Health and Safety Regulations, section 291 — Defines high risk construction work (Victoria: Occupational Health and Safety Regulations 2017, Part 5.1)
• Harmonised Work Health and Safety Regulations, section 299 — Content and review requirements for a safe work method statement for high risk construction work (Victoria: regulation 327; Tasmania: regulation 312)
• Harmonised Work Health and Safety Regulations, Part 4.7 — Electrical safety: the prohibition on energised electrical work except where de-energising is not reasonably practicable and the prescribed conditions are met (Victoria applies the Occupational Health and Safety Regulations 2017 and state electrical-safety legislation)
• Harmonised Work Health and Safety Regulations, Part 4.4 — Managing the risk of falls (work above two metres; Victoria applies the equivalent provisions of the Occupational Health and Safety Regulations 2017)
• Harmonised Work Health and Safety Regulations — Hazardous chemicals: the workplace exposure standard for inorganic mercury and health monitoring where there is a significant risk of exposure

Frequently asked questions