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Facade Corrosion Treatment and Protective Coatings SWMS

Safe Work Method Statement for treating corroded steel on building facades and applying protective coatings β€” balustrades, lintels, fixings and exposed steel; hand and power tool preparation; rust converters, zinc-rich primers, epoxy and 2-pack polyurethane systems; work at height on occupied buildings, lead paint, asbestos in old sealants, isocyanates and silica.

βš–οΈWHS Regulation 2025 & Codes of Practice β€” legally binding from 1 July 2026 (s26A)
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This Safe Work Method Statement covers the treatment of corroded steel on building facades in New South Wales: balcony balustrades, steel lintels, brackets and fixings, spandrel and frame steel, exposed structural steel and the localised concrete spalling caused by corroding reinforcement. It is written for remedial building contractors, protective coatings applicators and strata maintenance contractors working on occupied residential and commercial buildings. It covers swing stage, building maintenance unit, EWP, scaffold and rope access work, hand and power tool surface preparation, rust converters, zinc-rich and epoxy primers, two-pack polyurethane topcoats by brush, roller and airless spray, and sealants, with hold points for the asbestos register and lead paint testing, Part 7.2 lead risk work controls, isocyanate spray permits and Schedule 14 health monitoring, the crystalline silica assessment for concrete break-out, exclusion zones for occupants and the public below, and controls in hierarchy order with inherent and residual risk ratings.

Hazards identified

15 hazards covered, sorted by priority.

Falls from swing stages, EWPs, scaffolds, rope access and balcony edgesHIGH

Death or serious injury

Falling tools, rust scale and concrete onto residents, the public and vehicles belowHIGH

Death or serious head and body injury

Lead in existing paint on older steel disturbed during preparationHIGH

Lead poisoning of workers and contamination of occupied units

Asbestos in older sealants, mastics, coatings and panelsHIGH

Inhalation of asbestos fibres causing mesothelioma, asbestosis and lung cancer

Isocyanates in two-pack polyurethane coatings, especially when sprayedHIGH

Respiratory sensitisation and occupational asthma

Solvents, epoxies, rust converters and chromate or zinc primersHIGH

Dermatitis, sensitisation, chemical burns and cancer risk from hexavalent chromium

Flammable solvent vapour in enclosed balconies and stairwellsHIGH

Fire, explosion and burns

Respirable crystalline silica from grinding and breaking out concreteHIGH

Silicosis and lung cancer

Spalled concrete and corroded lintels or balustrades found to be structurally unsoundHIGH

Falling concrete or collapse of a balustrade or lintel

Electrical hazards from power tools, facade services and overhead linesHIGH

Electric shock and burns

Wind, rain, heat and dew point affecting access and coatingMEDIUM

Stage instability, heat illness and coating failure

Overspray and dust onto occupants, vehicles and neighboursMEDIUM

Respiratory irritation and property damage

Working beside occupied units and balconiesMEDIUM

Occupant exposure to dust, chemicals and falling objects

Hand-arm vibration and noise from needle guns and grindersMEDIUM

Vibration white finger and hearing loss

Carrying coatings, stage components and repair materialsLOW

Back, shoulder and hand strain

Control measures

Hierarchy-of-controls order: elimination β†’ substitution β†’ isolation β†’ engineering β†’ administrative β†’ PPE.

  1. 1Elimination β€” Lead paint and asbestos not disturbed until identified; removable balustrade panels and brackets treated at ground level; no open abrasive blasting.
  2. 2Substitution β€” Brush and roller instead of spray near occupied units; non-isocyanate, low-VOC and chromate-free products where the specification allows; wet or chemical methods instead of dry power-tool removal of lead paint.
  3. 3Isolation β€” Exclusion zones and overhead protection below the work; balconies closed; screening and drop sheets; vehicles relocated; windows and air intakes closed during spraying.
  4. 4Engineering β€” Guardrails on stages, EWPs and scaffolds; certified anchors and independent lifelines; tool lanyards and debris nets; shrouded tools with H-class or M-class extraction; RCDs.
  5. 5Administrative β€” Asbestos register and lead test hold points; Part 7.2 lead risk work controls; isocyanate spray permit; written silica assessment; weather and dew-point limits; tested rescue plan; occupant notices; health monitoring where required.
  6. 6PPE β€” Supplied-air respirator for isocyanate spraying, fit-tested P2/P3 respirators for dust and lead, chemical-resistant gloves, coveralls, eye and hearing protection, full body harness.

Applicable Codes of Practice

Construction work β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

High risk construction work, SWMS, falling objects and public protection.

Managing risks of falls at workplaces β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

Swing stages, EWPs, scaffolds, fall arrest and rescue.

Managing risks of hazardous chemicals in the workplace β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

Coatings, solvents, isocyanates and primers β€” SDS, register, exposure and storage.

Labelling of workplace hazardous chemicals β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

Decanting and labelling coatings and thinners.

How to manage and control asbestos in the workplace β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

Asbestos register and presumed asbestos in older sealants and coatings.

Managing noise and preventing hearing loss at work β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

Needle guns, grinders and scalers.

Hazardous manual tasks β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

Handling coatings, stage components and repair materials.

Managing electrical risks β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

Portable power tools, leads and RCDs.

Work health and safety consultation, cooperation and coordination β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

Coordination with the building manager, owners corporation and occupants.

First aid in the workplace β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

First aid and chemical exposure response.

Spray painting and powder coating β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

Airless spraying of two-pack isocyanate and solvent-borne coatings.

Elevating work platforms β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

EWPs used for facade access.

Managing risks of respirable crystalline silica in the workplace β€” Code of Practiceβš– Legally binding Β· 1 Jul 2026

Breaking out and grinding concrete around corroded reinforcement.

High-Risk Construction Work triggered

s291(a)
Involves a risk of a person falling more than 2 m

Facade work from swing stages, building maintenance units, EWPs, scaffolds or rope access almost always involves a fall risk of more than 2 m.

s291(k)
Is carried out on or near energised electrical installations or services

Applies where work is near energised facade lighting, outlets, signage or overhead power lines.

s291(l)
Is carried out in an area that may have a contaminated or flammable atmosphere

Applies where solvent-borne coatings are applied, especially sprayed, in enclosed balconies, stairwells or undercrofts.

s291(n)
Is carried out on, in or adjacent to a road, railway or other traffic corridor in use by traffic other than pedestrians

Applies where the work zone or EWP is on or next to a road or driveway in use.

s291(o)
Is carried out in an area at a workplace in which there is any movement of powered mobile plant

Applies where EWPs or forklifts move in the work area, such as a car park.

Legal consequence

Repair and maintenance of a building facade is construction work. Where a section 291 paragraph applies β€” most often section 291(a) β€” section 299 of the Work Health and Safety Regulation 2025 (NSW) requires a SWMS before the work starts, the work must be carried out in accordance with it (s300), and stopped work resumes only in accordance with it. Where the work is part of a construction project, a copy goes to the principal contractor before the work starts (s301). The SWMS is kept until the high risk construction work is completed, and for 2 years after a notifiable incident (s303). The Applies column is left for the PCBU to complete for the actual site.

Who this is for

  • β†’Remedial building contractors repairing corroded balustrades, lintels and spalled concrete
  • β†’Protective coatings applicators working on occupied strata and commercial buildings
  • β†’Strata maintenance contractors and painters treating rust on facades
  • β†’Contractors working from swing stages, building maintenance units, EWPs or rope access

What you receive

  • βœ“Editable DOCX template β€” Microsoft Word compatible
  • βœ“Hazard register with inherent and residual risk ratings and controls in hierarchy-of-control order
  • βœ“High risk construction work table against section 291 paragraphs (a) to (r), with the Applies column left for site completion
  • βœ“Hold points for the asbestos register, lead paint testing, access inspection and clean-up before hand back
  • βœ“Lead risk work, isocyanate, chromate and crystalline silica controls and a health monitoring table
  • βœ“Step-by-step procedure and stop-work triggers for unsound lintels and balustrades
  • βœ“Coating conditions record (temperature, humidity, dew point, steel temperature)
  • βœ“Plant, PPE, training, permits and emergency response sections, including suspended worker rescue
  • βœ“Worker consultation, sign-on and review log
  • βœ“Prepared for the Work Health and Safety Regulation 2025 (NSW)

Worked example

An owners corporation engages a remedial contractor to treat rusting steel balustrades and lintels on a 1960s eight-storey apartment building on the lower north shore. The supervisor obtains the asbestos register, which records asbestos in the original window mastics, and has the existing paint tested β€” it contains lead. The PCBU assesses the paint removal as lead risk work, notifies the regulator and arranges health monitoring, including blood lead testing, before the crew starts. Work is done from a swing stage with independent lifelines and a tested rescue plan; the footpath below is closed under a council approval. Lead paint is removed by wet scraping and shrouded needle guns on H-class extraction, with balconies screened and residents' doors closed. The mastics are left untouched. A lintel with heavy section loss is found, work stops and the engineer is called. The two-pack polyurethane topcoat is rolled, not sprayed, beside occupied units, and conditions are recorded for each coat before balconies are cleaned and handed back.

Related legislation

  • Work Health and Safety Act 2011 (NSW) β€” ss19, 20, 26A, 27, 28, 29, 35–39, 46, 47, 84
  • Work Health and Safety Regulation 2025 (NSW) β€” s289 construction work; s291 high risk construction work; ss299–303 SWMS; s317
  • Work Health and Safety Regulation 2025 (NSW) β€” Part 4.4 falls (ss78–80); s81 and Schedule 3 high risk work licences
  • Work Health and Safety Regulation 2025 (NSW) β€” Part 7.1 hazardous chemicals (ss344, 346, 351, 355, 357, 368 and Schedule 14); Part 7.2 lead
  • Work Health and Safety Regulation 2025 (NSW) β€” crystalline silica (ss529C–529CE)
  • Work Health and Safety Regulation 2025 (NSW) β€” Chapter 8 asbestos (ss419, 422, 425, 427)
  • Work Health and Safety Regulation 2025 (NSW) β€” ss36, 38, 39, 42, 44, 48, 49, 50
  • AS 2312.1; AS/NZS 4361.1; AS 4361.2; AS/NZS 1715; AS/NZS 1716; AS/NZS 1891; AS 1418.13; AS/NZS 4576; AS 2550.10

Frequently asked questions

Is facade rust repair high risk construction work?

Almost always. Repair and maintenance of a building is construction work, and work from a swing stage, EWP, scaffold or rope access where a person could fall more than 2 m is high risk construction work under section 291(a) of the Work Health and Safety Regulation 2025 (NSW). It can also fall under section 291(k), (l), (n) or (o) depending on the site.

What if the old paint contains lead?

The document has a hold point to test existing coatings before preparation, and treats untested paint on pre-1970 buildings as lead paint. Where removal is lead risk work under Part 7.2, the regulator is notified in writing within 7 days, workers have health monitoring (including blood lead) before starting and 1 month after, then ongoing blood lead monitoring, and the work area is enclosed with extraction and hygiene controls. Dry sanding, heat guns and abrasive blasting are not used.

Does it cover spraying two-pack polyurethane?

Yes. Spraying isocyanate coatings is done only under a spray permit, with supplied-air respirators, the area screened and residents' windows and air intakes closed. Brush and roller are preferred near occupied units, and health monitoring under Schedule 14 is provided where there is a significant risk to health.

Does it cover abrasive blasting or major concrete repair?

No. Open abrasive blasting and major structural concrete repair, propping or steel replacement are outside this document and need their own SWMS. It covers hand and power tool preparation and minor patch repair of spalled concrete to the engineer's specification.

What about asbestos in old sealants?

The asbestos register is read before work starts, and any sealant, mastic, coating or panel recorded as or presumed to be asbestos is not disturbed under this document. Suspect material that is not on the register stops the work until it is sampled.

What's in this SWMS

Document details

Regulation
WHS Regulation 2025
HRCW Category
Where present: risk of a fall of more than 2 m, near energised electrical installations, contaminated or flammable atmosphere, adjacent to a road in use by traffic, movement of powered mobile plant (s291)
Hazards Identified
15 hazards with controls
Format
Editable DOCX (Microsoft Word)
Author
Certified Industrial Hygienist (CIH)
Delivery
Instant download after payment
CIH-reviewed SWMS Β· from $99 Β· instant download

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