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Synthetic Mineral Fibre Insulation Removal SWMS

NSW — Synthetic Mineral Fibre Insulation Removal. Full task scope, hazards and controls to be authored to Phase 1 standard.

⚖️WHS Regulation 2025 & Codes of Practice — legally binding from 1 July 2026 (s26A)
👷Reviewed by certified occupational health and safety professionals
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Synthetic Mineral Fibre (SMF) insulation removal covers the extraction of glasswool, rockwool, ceramic fibre and refractory ceramic fibre products from ceilings, wall cavities, roof spaces, plant rooms, boilers, ductwork and industrial pipework. The work exposes workers to respirable fibres that mechanically irritate the skin, eyes and upper respiratory tract, and — in the case of refractory ceramic fibres — are classified by IARC as possibly carcinogenic to humans. Removal typically occurs in confined roof voids, on elevated platforms, and in older buildings where SMF is commingled with asbestos-containing materials, lead-based coatings or accumulated dust.

Under the Work Health and Safety Regulation 2025 (NSW), this task is high risk construction work where removal occurs at heights greater than 2 metres (section 291) or within a confined space, triggering the requirement under section 299 to prepare a Safe Work Method Statement before work commences. Controls follow the hierarchy under section 36, prioritising isolation and local exhaust ventilation over reliance on respiratory protective equipment.

Hazards identified

12 hazards covered, sorted by priority.

Fall from height during ceiling, roof-space or elevated plant insulation removal exceeding 2 metresHIGH

Fatal or catastrophic injuries from falls through ceiling linings, from ladders or from unprotected edges

Undisclosed asbestos-containing material commingled with or adjacent to SMF insulation (pre-1990 buildings)HIGH

Mesothelioma, asbestosis and lung cancer from inadvertent asbestos fibre release

Inhalation of respirable refractory ceramic fibres (RCF) from high-temperature insulation removalHIGH

Possible lung cancer (IARC Group 2B), pleural plaques and chronic respiratory disease

Confined space entry into roof voids, ceiling cavities and plant enclosures with restricted egressHIGH

Asphyxiation, heat stress, entrapment and inability to be rescued promptly

Contact with live electrical wiring, downlights and transformers concealed within insulationHIGH

Electrocution, arc flash burns or ignition of insulation debris

Heat stress in unventilated roof spaces during warm weatherHIGH

Heat exhaustion, heat stroke and impaired judgement leading to secondary incidents

Mechanical irritation of skin, eyes and upper airways from coarse SMF fibresMEDIUM

Dermatitis, conjunctivitis, epistaxis and persistent cough

Fall through fragile ceiling linings, skylights or deteriorated roof sheetingHIGH

Falls of 3-6 metres to the floor below causing serious or fatal injury

Manual handling of bulk insulation bags, waste and vacuum equipment in constrained posturesMEDIUM

Musculoskeletal injury to the back, shoulders and knees

Airborne nuisance dust and legacy contaminants (rodent droppings, bird faeces, lead paint flakes)MEDIUM

Zoonotic infection (histoplasmosis, leptospirosis) and lead exposure

Poor lighting and trip hazards from ceiling joists, wiring and stored materials in roof cavitiesMEDIUM

Slips, trips and falls onto or through ceiling structure

Waste handling and cross-contamination during bagging, transport and disposal of SMF debrisMEDIUM

Secondary exposure to workers, occupants and waste transport personnel

Control measures

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

  1. 1Eliminate working at height where possible by removing insulation from below using pole-mounted vacuum lances, or programming removal to coincide with ceiling demolition at ground level.
  2. 2Where SMF is suspected of being commingled with asbestos, cease work and engage a licensed asbestos assessor for sampling in accordance with the SafeWork NSW Code of Practice — How to Manage and Control Asbestos in the Workplace before recommencing.
  3. 3Substitute manual removal with negative-pressure HEPA vacuum extraction using H-Class industrial vacuums compliant with AS/NZS 60335.2.69, minimising airborne fibre generation.
  4. 4Isolate and lock out all electrical circuits penetrating the work area under AS/NZS 4836, and verify de-energisation with a tested voltage indicator before disturbing insulation around downlights, cabling or transformers.
  5. 5Establish a controlled work area with polythene sheeting, negative air machines fitted with HEPA filtration, and airlock entry/exit where fibre release is significant, in accordance with AS 4361.2 principles adapted for SMF.
  6. 6Install compliant fall protection: edge protection, temporary work platforms spanning ceiling joists, or a fall-arrest system anchored in accordance with AS/NZS 1891.4 for work above 2 metres or over fragile surfaces.
  7. 7Implement a confined space entry permit system under AS 2865 for roof voids and plant enclosures, including atmospheric testing, standby person, and rescue arrangements before entry.
  8. 8Provide fitted P2 (minimum) or P3 respiratory protection selected and fit-tested to AS/NZS 1715 and AS/NZS 1716; upgrade to powered air-purifying respirators for RCF removal and heat-stressed environments.
  9. 9Issue disposable Type 5/6 coveralls, nitrile gloves, and sealed eye protection to AS/NZS 1337.1; provide a decontamination area with wash facilities and separate change rooms for clean and contaminated clothing.
  10. 10Double-bag SMF waste in labelled heavy-duty polythene, seal with gooseneck ties, and dispose of via an EPA-licensed waste facility; transport under a waste tracking manifest where jurisdictionally required.
  11. 11Schedule heat-exposure work in cooler parts of the day, rotate workers, provide cool drinking water and monitor for heat illness in accordance with the SafeWork NSW Managing the Risks of Working in Heat guidance.
  12. 12All workers hold the CPCCWHS1001 White Card, receive task-specific SMF training, and are consulted in accordance with section 47 of the WHS Act; the SWMS is reviewed under section 302 whenever controls, personnel or site conditions change, or immediately after a notifiable incident.

Applicable Codes of Practice

SafeWork NSW Code of Practice — How to Manage Work Health and Safety Risks⚖ Legally binding · 1 Jul 2026

Provides the risk management framework and hierarchy of controls applied to SMF removal planning.

SafeWork NSW Code of Practice — Managing the Risk of Falls at Workplaces⚖ Legally binding · 1 Jul 2026

Directly applicable where removal occurs above 2 metres, over fragile surfaces or from elevated work platforms.

SafeWork NSW Code of Practice — Confined Spaces⚖ Legally binding · 1 Jul 2026

Governs entry to roof voids, ceiling cavities and plant enclosures that meet the confined space definition.

AS/NZS 1715:2009 Selection, use and maintenance of respiratory protective equipment

Sets the technical basis for respirator selection, fit testing and maintenance for SMF fibre exposure.

High-Risk Construction Work triggered

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

SMF removal is routinely performed in roof cavities, from ladders and on elevated platforms where fall distances to the floor below exceed 2 metres, and often involves work over fragile ceiling linings and skylights.

Legal consequence

Because the work is high risk construction work under section 291 of the Work Health and Safety Regulation 2025 (NSW), a SWMS must be prepared before work commences (section 299) and reviewed under section 302 if controls are revised or an incident occurs. Failure to prepare, comply with or review a SWMS is a strict-liability offence; where non-compliance exposes a worker to a risk of death or serious injury, Category 1 (section 31) or Category 2 (section 32) offences under the WHS Act 2011 (NSW) may apply. Current maximum penalties are published in the SafeWork NSW penalty schedule and are indexed annually.

Who this is for

  • Licensed asbestos and hazardous materials removal contractors performing SMF works
  • Insulation installation and stripping subcontractors on refurbishment or demolition projects
  • Commercial and industrial maintenance contractors servicing boilers, kilns and ductwork
  • Principal contractors managing ceiling replacement, re-roofing or plant room upgrades
  • Facility managers coordinating in-house SMF removal in schools, hospitals and government buildings

What you receive

  • Fully editable SWMS in Microsoft Word format, pre-populated for NSW SMF removal
  • Task-by-task hazard register with risk ratings before and after controls
  • Hierarchy-of-control matrix aligned to WHS Regulation 2025 (NSW) section 36
  • Pre-start inspection and daily site verification checklists
  • Respiratory protection selection and fit-test record template compliant with AS/NZS 1715
  • Fall protection and confined space entry permit templates
  • Worker consultation, sign-on and toolbox talk record sheets
  • Emergency response and decontamination procedure for SMF and suspected asbestos contact
  • Version control block with review triggers referencing section 302 of the WHS Regulation 2025

Worked example

A commercial refurbishment contractor was engaged to remove degraded glasswool ceiling insulation across 1,800 square metres of a 1970s office building in Parramatta prior to a lighting upgrade. Access to the ceiling void was via a mobile scaffold at 3.2 metres, satisfying the section 291 trigger for high risk construction work. During pre-start sampling, the licensed assessor identified friable amosite lagging on adjacent steam pipes, prompting a stop-work and a variation to engage a Class A licensed asbestos removalist for that portion. SMF removal proceeded under a documented SWMS using H-Class HEPA vacuum extraction, PAPRs, Type 5/6 coveralls, and a two-stage decontamination unit. Electrical circuits to recessed downlights were isolated and tagged under AS/NZS 4836. The SWMS was reviewed under section 302 following the asbestos discovery, and workers were re-consulted under section 47 before recommencement.

Related legislation

  • Work Health and Safety Act 2011 (NSW)
  • Work Health and Safety Regulation 2025 (NSW)
  • Protection of the Environment Operations Act 1997 (NSW)
  • Protection of the Environment Operations (Waste) Regulation 2014 (NSW)
  • Electricity Supply Act 1995 (NSW)
  • Public Health Act 2010 (NSW)

Frequently asked questions

Is Synthetic Mineral Fibre treated the same as asbestos under NSW law?

No. SMF is not a prohibited or licensed material under the WHS Regulation 2025 (NSW), and no asbestos removal licence is required. However, SMF exposure must still be controlled under sections 49-50 (airborne contaminants and exposure standards) and the general risk management duties. Where SMF is suspected of being contaminated with asbestos — common in buildings constructed before 1990 — the asbestos provisions in Chapter 8 apply and licensed removal may be required.

What respiratory protection is required for SMF removal?

Selection must follow AS/NZS 1715. As a minimum, a fitted P2 disposable or half-face respirator is used for short-duration low-disturbance work. For refractory ceramic fibre removal, prolonged work, hot environments or where visibility is poor, a powered air-purifying respirator (PAPR) with P3 filters is appropriate. All tight-fitting respirators require quantitative or qualitative fit testing and clean-shaven contact surfaces.

Does the 2-metre fall trigger apply if we are working from a scaffold with edge protection?

Yes. Section 291 of the WHS Regulation 2025 (NSW) defines high risk construction work by the risk of a fall greater than 2 metres, regardless of whether that risk is controlled by fall protection. A SWMS is still required under section 299; the SWMS will document how the edge protection, work platform or fall-arrest system eliminates or minimises the risk.

How should SMF waste be disposed of in NSW?

SMF is classified as general solid waste under the NSW EPA waste classification framework, provided it is not contaminated with asbestos, lead or other regulated substances. It should be double-bagged in heavy-duty polythene, labelled, and disposed of at a facility licensed to receive that waste stream. If asbestos contamination is confirmed or suspected, the entire waste stream must be managed as asbestos waste under the Protection of the Environment Operations (Waste) Regulation 2014 (NSW).

What's in this SWMS

Document details

Regulation
Work Health and Safety Regulation 2025 (NSW), Section 291 — High Risk Construction Work
HRCW Category
s. 291(a) — Risk of fall greater than 2 metres
Hazards Identified
12 hazards with controls
Format
Editable DOCX (Microsoft Word)
Author
Certified Industrial Hygienist (CIH)
Delivery
Instant download after payment
CIH-reviewed SWMS · from $99 · instant download

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