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Sprayed Fireproofing Application SWMS

NSW β€” Sprayed Fireproofing Application. Full task scope, hazards and controls to be authored to Phase 1 standard.

βš–οΈWHS Regulation 2025 & Codes of Practice β€” legally binding from 1 July 2026 (s26A)
πŸ‘·Reviewed by certified occupational health and safety professionals
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Sprayed fireproofing application involves the pneumatic spraying of cementitious or fibrous fire-resistive materials (typically vermiculite-based or mineral fibre) onto structural steel, decking and services to achieve rated fire protection. Work is performed at height from scissor lifts, boom lifts or scaffold, frequently inside partially enclosed plant rooms, riser shafts, lift motor rooms and service voids that meet the definition of a confined space. Operators are exposed to airborne mineral fibres, respirable crystalline silica from cementitious binders, alkaline overspray, high-pressure hose whip, powered mobile plant movement and slip hazards from wet rebound. Older buildings may also present in-situ asbestos-containing fireproofing that must be identified before disturbance.

Under the Work Health and Safety Regulation 2025 (NSW), sprayed fireproofing triggers high risk construction work under section 291 β€” specifically risk of fall greater than 2 metres (291(a)), work in or near a confined space (291(f)), and work involving movement of powered mobile plant (291(o)). Section 299 requires a Safe Work Method Statement to be prepared before work commences, addressing hazards, controls and their implementation. Controls follow the hierarchy under section 36 of the Regulation, prioritising elimination and engineered controls over administrative measures and PPE.

Hazards identified

12 hazards covered, sorted by priority.

Fall from height exceeding 2 m from EWP baskets, scaffold or edge of elevated decks during overhead sprayingHIGH

Fatal or serious multi-system trauma from fall

Asphyxiation, engulfment or heat stress in confined spaces (plant rooms, risers, voids) where overspray displaces oxygen and traps heatHIGH

Loss of consciousness, asphyxiation, fatality

Struck-by or crush injury from powered mobile plant β€” scissor lifts, boom lifts, telehandlers and material pumps operating in shared workspaceHIGH

Crush injuries, fractures, fatality

Inhalation of respirable crystalline silica from Portland-cement and gypsum-based fireproofing binders during mixing and sprayingHIGH

Silicosis, lung cancer, chronic respiratory disease

Disturbance of pre-existing asbestos-containing fireproofing (limpet, sprayed asbestos) in buildings pre-1990 during overspray, patching or removalHIGH

Mesothelioma, asbestosis, lung cancer

Inhalation of synthetic mineral fibres (SMF) and vermiculite dust during spraying, cutting and clean-upHIGH

Respiratory irritation, dermatitis, potential long-term lung disease

High-pressure hose whip or blockage-clearing incidents releasing material at pump pressures up to 40 barHIGH

Eye injury, laceration, fracture, blindness

Alkaline burns to skin and eyes from wet cementitious slurry contact and oversprayMEDIUM

Chemical burns, dermatitis, corneal damage

Slips and falls on wet rebound accumulated on floors, EWP platforms and access waysMEDIUM

Fractures, sprains, secondary falls from height

Manual handling injury from lifting 20 kg bags of fireproofing material, hose drags and pump setupMEDIUM

Musculoskeletal injury, chronic back injury

Noise exposure above 85 dB(A) from spray pumps, compressors and generators in enclosed spacesMEDIUM

Noise-induced hearing loss, tinnitus

Electrical hazard from spray-coating live services, damp environments and pump power leadsMEDIUM

Electric shock, arc flash, electrocution

Control measures

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

  1. 1Eliminate work at height where practicable by pre-spraying steelwork at ground level or in fabrication yard prior to erection; where not practicable, use EWPs selected and operated per AS 2550.10 with harness and lanyard anchored to the manufacturer-designated point.
  2. 2Substitute high-silica cementitious products with low-silica mineral fibre or vermiculite formulations where the fire rating specification permits; obtain SDS confirmation of crystalline silica content <1%.
  3. 3Prior to any work in buildings pre-2004, review the asbestos register (WHS Regulation 2025 section 425) and conduct pre-work sampling of existing fireproofing; do not disturb suspect material until cleared or removed by a licensed Class A removalist under section 485.
  4. 4For confined space entry, apply AS/NZS 2865 β€” issue a confined space entry permit, conduct pre-entry atmospheric testing (Oβ‚‚, LEL, dust), provide continuous mechanical ventilation and forced-air extraction, and maintain a trained standby person with rescue equipment.
  5. 5Engineer traffic management to separate powered mobile plant from workers on foot: exclusion zones, spotters, plant-pedestrian barriers and reversing alarms per AS 2550.1; only ticketed operators with HRW licence (WP for booms >11 m) may operate EWPs.
  6. 6Control airborne dust with on-tool water suppression at the spray nozzle, LEV extraction in enclosed areas, and wet clean-up methods; comply with the workplace exposure standard of 0.05 mg/mΒ³ (8-hr TWA) for respirable crystalline silica.
  7. 7Provide respiratory protection selected per AS/NZS 1715 and AS/NZS 1716 β€” minimum P2 for low-dust tasks, powered air-purifying respirator (PAPR) with P3 filter for spraying and confined space work; conduct fit-testing per AS/NZS 1715 Appendix E.
  8. 8Implement health monitoring for workers exposed to crystalline silica and SMF per WHS Regulation 2025 sections 368–378, including baseline and periodic chest imaging and respiratory function testing.
  9. 9Inspect hoses, couplings and whip-checks before each shift; fit hose restraints at all connections; establish blockage-clearing procedure including depressurising the line, locking out the pump and standing clear of the nozzle end.
  10. 10Provide chemical-resistant PPE per AS/NZS 2210 (safety footwear), AS/NZS 1337 (eye protection β€” sealed goggles for spraying), nitrile or PVC gauntlets, and disposable Type 5/6 coveralls; hearing protection to AS/NZS 1270 where sound levels exceed 85 dB(A).
  11. 11Isolate and de-energise electrical services within the spray zone under a permit-to-work; verify dead with a tested test-lamp before spraying near switchboards, cable trays or luminaires.
  12. 12All workers to hold CPCCWHS1001 (White Card); the SWMS is to be developed in consultation with workers per section 47 of the WHS Act 2011 (NSW), signed on before commencement, and reviewed under section 302 of the WHS Regulation 2025 whenever controls change, an incident occurs or a worker raises a concern.

Applicable Codes of Practice

SafeWork NSW Code of Practice β€” Managing the Risk of Falls at Workplacesβš– Legally binding Β· 1 Jul 2026

Approved Code providing the accepted means of managing fall risk during elevated spraying from EWPs and scaffold.

SafeWork NSW Code of Practice β€” Confined Spacesβš– Legally binding Β· 1 Jul 2026

Approved Code addressing permit systems, atmospheric testing, ventilation and rescue arrangements for spraying inside plant rooms, risers and voids.

SafeWork NSW Code of Practice β€” Managing Risks of Hazardous Chemicals in the Workplaceβš– Legally binding Β· 1 Jul 2026

Approved Code for SDS management, exposure control and health monitoring for silica, alkaline binders and SMF.

AS/NZS 2865:2009 Confined spaces

Technical standard for confined space entry procedures, atmospheric testing and rescue referenced by the confined space controls.

High-Risk Construction Work triggered

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

Sprayed fireproofing is applied overhead to structural steel and soffits from EWP baskets, scaffold decks and elevated slabs, routinely exceeding 2 m above the surface below.

s291(f)
Is carried out in or near a confined space

Application within plant rooms, lift motor rooms, service risers and enclosed voids meets the section 5 definition of a confined space where overspray displaces atmosphere and restricts egress.

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

Operators work from scissor lifts, boom lifts and telehandlers, and share workspace with material pumps and delivery plant, creating crush and struck-by exposure.

Legal consequence

Under section 299 of the WHS Regulation 2025 (NSW), the SWMS must be prepared before HRCW commences, and under section 302 must be reviewed and revised when controls change, an incident occurs or a health and safety representative requests it. Failure to prepare, comply with or maintain a SWMS is an offence attracting penalties under the WHS Regulation 2025, and where the failure exposes a worker to a risk of death or serious injury, Category 1 or Category 2 offences apply under sections 31 and 32 of the WHS Act 2011 (NSW). Current penalty amounts are set out in the SafeWork NSW penalty schedule.

Who this is for

  • β†’Passive fire protection contractors delivering sprayed cementitious or fibrous fireproofing to structural steel
  • β†’Insulation and fire-stopping subcontractors on commercial construction and refurbishment projects
  • β†’Principal contractors coordinating fireproofing scopes within Class 2–9 building projects
  • β†’EWP and scissor-lift operators applying spray-on fire-rated coatings
  • β†’WHS managers and site supervisors responsible for HRCW SWMS review and sign-on

What you receive

  • βœ“Editable Microsoft Word SWMS aligned to WHS Regulation 2025 (NSW) sections 299–303
  • βœ“Pre-populated HRCW declarations for section 291(a), (f) and (o)
  • βœ“Full hazard register covering silica, SMF, asbestos-in-situ, alkaline slurry and mobile plant
  • βœ“Hierarchy-of-controls matrix with AS/NZS and Code of Practice references
  • βœ“Confined space entry permit template aligned to AS/NZS 2865
  • βœ“EWP pre-start and inspection checklist per AS 2550.10
  • βœ“Worker sign-on and consultation register satisfying WHS Act section 47
  • βœ“SWMS review trigger log for section 302 compliance
  • βœ“Emergency response and rescue procedure for confined space and fall arrest incidents

Worked example

A passive fire protection subcontractor is engaged to apply sprayed vermiculite fireproofing to 2,400 mΒ² of structural steel across three levels of a new commercial building in Parramatta. The steel beams sit 4.2 m above the working slab, and a portion of the scope is inside two mechanical plant rooms accessed via a single doorway β€” a confined space under AS/NZS 2865. The crew works from two 19 ft electric scissor lifts while a telehandler shuttles bagged product. Before mobilisation, the subcontractor prepares this SWMS, verifies operator HRW licences and White Cards, and consults the crew under section 47. Pre-entry atmospheric testing and forced ventilation are established for the plant rooms, and PAPR respirators with P3 filters are issued. Mid-project, an HSR raises a concern about visible rebound accumulating on the scissor lift platform, triggering a section 302 review β€” the SWMS is revised to require mid-shift platform cleaning and additional non-slip matting before work resumes.

Related legislation

  • Work Health and Safety Act 2011 (NSW) β€” sections 19, 31, 32, 47
  • Work Health and Safety Regulation 2025 (NSW) β€” sections 36, 291, 299, 302
  • Work Health and Safety Regulation 2025 (NSW) β€” Part 4.3 Confined Spaces (sections 62–77)
  • Work Health and Safety Regulation 2025 (NSW) β€” Part 4.4 Falls (sections 78–80)
  • Work Health and Safety Regulation 2025 (NSW) β€” Part 8 Asbestos (sections 419–529)
  • Work Health and Safety Regulation 2025 (NSW) β€” Chapter 7 Hazardous Chemicals (silica health monitoring, sections 368–378)

Frequently asked questions

Is sprayed fireproofing automatically high risk construction work?

Yes. Sprayed fireproofing typically triggers at least three section 291 categories β€” fall risk over 2 m (291(a)), confined space work (291(f)) and powered mobile plant (291(o)). A SWMS complying with section 299 of the WHS Regulation 2025 (NSW) must be in place before work commences.

How is respirable crystalline silica managed on fireproofing works?

The workplace exposure standard is 0.05 mg/mΒ³ over an 8-hour TWA. Controls include selecting low-silica formulations, on-tool water suppression, LEV, PAPR respirators fit-tested to AS/NZS 1715, and health monitoring per sections 368–378 of the WHS Regulation 2025 for any worker with ongoing exposure.

What if we encounter existing sprayed asbestos fireproofing?

Stop work immediately. Sprayed asbestos coatings (e.g. limpet) were widely used pre-1990. The building's asbestos register must be consulted under section 425, and any removal is Class A licensed work under section 485 of the WHS Regulation 2025. Do not overspray, patch or disturb suspect material until it is sampled and cleared.

Who must sign the SWMS and when is it reviewed?

All workers performing the HRCW β€” sprayers, EWP operators, labourers and supervisors β€” must sign on before commencing. Under section 302 of the WHS Regulation 2025, the SWMS must be reviewed and revised when controls are altered, an incident or near-miss occurs, or a worker or HSR raises a health and safety concern.

What's in this SWMS

Document details

Regulation
Work Health and Safety Regulation 2025 (NSW), Section 291 β€” High Risk Construction Work
HRCW Category
s. 291(a) β€” Risk of fall greater than 2 metres; s. 291(f) β€” Work in or near a confined space; s. 291(o) β€” Work where there is movement of powered mobile plant
Hazards Identified
12 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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