Marine Pile Driving SWMS

Marine pile driving for wharves, jetties and offshore structures involves driving steel or concrete piles into seabed material from a barge, jack-up rig or temporary platform using diesel, hydraulic or vibratory hammers suspended from crawler or floating cranes. The work combines high-energy powered mobile plant operating over water, suspended loads at height, underwater noise emissions affecting marine mammals, and continuous drowning exposure at unprotected platform edges. Under WHS Regulation 2025 this activity is High Risk Construction Work triggering multiple section 291 categories simultaneously — work in or near water (Cat. 17), diving work where pile inspection or cutting is required (Cat. 18), and powered mobile plant operation (Cat. 15). A Safe Work Method Statement is mandatory before work commences and must be developed in consultation with divers, crane crew, dogmen and marine crew under s38 of the WHS Act. The SWMS must remain accessible at the work location, be reviewed when conditions change (sea state, tide, crew rotation), and retained for the project duration plus two years, or indefinitely where a notifiable incident occurs.

Hazards identified

7 hazards covered, sorted by priority.

Control measures

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

1. 1Elimination — Pre-drill or jet pilot holes in soft sediment to eliminate the need for high-energy impact driving where geotechnical conditions permit refusal-free penetration.
2. 2Elimination — Schedule pile driving outside identified cetacean migration windows confirmed via DCCEEW marine fauna data to remove acoustic exposure entirely.
3. 3Substitution — Replace impact diesel hammers with vibratory or hydraulic press-in hammers reducing peak sound pressure level by 15-20 dB re 1 µPa underwater.
4. 4Substitution — Use biodegradable hydraulic fluid (ISO 15380 HEES grade) in hammer power packs to substitute petroleum-based oil in marine-sensitive zones.
5. 5Engineering — Deploy bubble curtain or noise mitigation sleeve around pile during driving to attenuate underwater sound transmission per AS/NZS 2299.1 marine guidance.
6. 6Engineering — Install certified barge edge protection — 1m rails, mid-rail and toe-board — plus retractable fall arrest lines compliant with AS/NZS 1891.4 across the work platform.
7. 7Administrative — Conduct daily pre-start SWMS review including tide chart, sea state forecast under Bureau of Meteorology, marine mammal observer briefing and dogman radio protocol confirmation.
8. 8Administrative — Maintain dive supervisor logs, hammer cycle counts and exclusion zone monitoring records per AMSA Marine Order 504 and AS/NZS 2299.1 commercial diving standards.
9. 9PPE — Issue AS 4758 Level 100 marine inflatable PFDs with integrated AIS beacons, thermal protection coveralls, and hearing protection rated SLC80 26 for hammer crew.
10. 10PPE — Provide divers with full surface-supplied breathing apparatus, hot-water suits, helmet comms and through-water comms compliant with AS/NZS 2299.1 clause 5.

Applicable Codes of Practice

High-Risk Construction Work triggered

Worked example

On a regional port berth-extension project, the marine works supervisor opens the Marine Pile Driving SWMS at the 0600 pre-start brief on the accommodation barge. Tide is making, swell is forecast at 0.8m rising to 1.4m by 1400, and a humpback pod was logged 3km offshore by the marine mammal observer the previous evening. Walking the crew through Section 3 hazard ID, the supervisor highlights drowning at the new pile template edge (rails were repositioned overnight) and the cetacean exclusion zone trigger. Controls selected from the hierarchy include deploying the bubble curtain before the first hammer blow, soft-start protocol for the first 30 minutes, and stand-down if any cetacean enters the 500m observation zone. The dive supervisor signs on separately under the AS/NZS 2299.1 dive plan annex. Each crew member — crane operator, dogman, two riggers, two divers, MMO and deck crew — initials the sign-on register against the controls they are responsible for executing. At 1130 the swell exceeds the 1.2m threshold recorded on the SWMS trigger table; the supervisor halts driving, annotates the field copy, briefs the change, and re-signs the crew before resuming with reduced hammer energy. The marked-up SWMS is scanned to the project records at end of shift, preserving the audit trail for the two-year retention requirement.

Related legislation

• WHS Act 2011 (model)
• WHS Regulation 2025
• AS 2550 — Cranes, hoists and winches; AS 1418 series

Frequently asked questions