Pre-Construction Pest Treatment SWMS

Pre-construction termite management involves applying registered termiticides to soil, slab penetrations, and reticulation systems before the concrete slab is poured, in accordance with AS 3660.1. The work exposes technicians to organophosphate, pyrethroid, or fipronil-based chemicals through dermal absorption, inhalation of drift, and accidental ingestion, while operating in active construction zones alongside formworkers, plumbers, and steel fixers. Because the activity involves the use, handling and storage of hazardous chemicals on a construction site, it is classified as High Risk Construction Work under WHS Regulation 2025 section 291, Category 17. A Safe Work Method Statement is mandatory before work commences, must be developed in consultation with workers, and must be available for inspection by the principal contractor and the regulator. This SWMS documents hazard identification, the hierarchy of controls applied, certification obligations under AS 3660.1, and the chemical-specific emergency response required when working with Schedule 6 and Schedule 7 termiticides.

Hazards identified

7 hazards covered, sorted by priority.

Control measures

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

1. 1Elimination — Where building design permits, substitute chemical barrier with physical termite barrier system (e.g. stainless mesh or graded stone) eliminating chemical exposure entirely.
2. 2Elimination — Schedule chemical application outside other trades' working hours so no concurrent workers are present in the treatment footprint or downwind drift zone.
3. 3Substitution — Select lower-toxicity termiticide actives (Schedule 6 fipronil or bifenthrin) over Schedule 7 organophosphates where AS 3660.1 efficacy criteria can still be satisfied.
4. 4Substitution — Use ready-mixed cartridge formulations or closed-transfer systems instead of manual decanting of concentrate from bulk drums.
5. 5Engineering — Install closed-loop reticulation pipework with above-slab fill points eliminating future re-treatment exposure and isolating chemical from occupied building zones.
6. 6Engineering — Use low-pressure coarse droplet spray nozzles (under 300 kPa) to minimise aerosol generation and drift beyond the treatment perimeter.
7. 7Administrative — Conduct pre-start SWMS sign-on, verify SDS for the specific termiticide batch, confirm wind speed under 15 km/h, and isolate the work zone with hazard tape and signage.
8. 8Administrative — Maintain certification records, batch numbers, application volumes and a treatment plan per AS 3660.1 clause 8, retained by the PCBU for the life of the structure.
9. 9PPE — Chemical-resistant nitrile gloves, P2 respirator with organic vapour cartridge, splash goggles, Type 4 chemical coveralls and rubber boots compliant with AS/NZS 1715/1716.
10. 10PPE — On-site decontamination station with emergency eyewash, potable rinse water, spill kit and atropine information card accessible within 10 metres of the application zone.

Applicable Codes of Practice

High-Risk Construction Work triggered

Worked example

On a slab-stage detached housing project in a greenfield estate, a licensed pest technician arrives at 6:30am to apply a fipronil-based perimeter and penetration treatment ahead of a 10:00am concrete pour. At the pre-start brief, the site supervisor opens this SWMS with the technician and the formwork leading hand. They walk the hazard register: drift exposure is flagged HIGH, and the technician notes a 12 km/h easterly wind — within tolerance per the administrative control, but they reposition the application sequence to work upwind of the plumbing apprentice still finishing penetration boxing. The SDS for the specific fipronil batch is reviewed, decontamination station location is confirmed at the site shed, and all three workers sign on. Mid-task, the plumber asks to access a penetration the technician has just treated; referring to the SWMS re-entry control, the supervisor enforces a 30-minute exclusion until the surface is touch-dry. The technician completes the application, photographs the treated zone, records batch numbers and litres applied on the AS 3660.1 certificate, and lodges it with the builder. The SWMS is filed with the site safety folder and remains available for the principal contractor and regulator inspection throughout the build.

Related legislation

• WHS Act 2011 (model)
• WHS Regulation 2025
• Managing Risks of Hazardous Chemicals CoP; APVMA registered product label requirements

Frequently asked questions