Rodent Control SWMS

Rodent control programs across commercial, residential and food-handling premises involve the deployment of anticoagulant and non-anticoagulant rodenticides, mechanical trapping, exclusion proofing and carcass retrieval, frequently within roof voids, subfloor cavities, ceiling spaces and service ducts. The work exposes technicians to Schedule 7 and 6 poisons, biological agents including Leptospira, Hantavirus and Salmonella shed in rodent urine and faeces, and confined or restricted spaces with poor ventilation and atmospheric hazards. Under WHS Regulation 2025, the combination of hazardous chemical use, biological exposure and confined space entry classifies elements of this work as High Risk Construction Work under section 291, mandating a Safe Work Method Statement prepared in consultation with workers before work commences. The SWMS must identify each hazard, document the hierarchy of controls applied, and be reviewed whenever the work method, product or site conditions change. PCBUs delivering rodent management services hold a non-transferable duty under s19 of the WHS Act to ensure this documentation is in place, signed and accessible on site for the duration of the program.

Hazards identified

7 hazards covered, sorted by priority.

Control measures

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

1. 1Elimination — eliminate the need for confined space entry by using external tamper-resistant bait stations and remote monitoring sensors wherever rodent activity can be addressed at the perimeter.
2. 2Elimination — eliminate use of second-generation anticoagulants in sensitive sites by deploying snap-trap-only programs in food premises, schools and wildlife-adjacent properties.
3. 3Substitution — substitute brodifacoum with first-generation anticoagulants (warfarin, coumatetralyl) or non-anticoagulant alternatives (cholecalciferol) where label permits to reduce secondary poisoning severity.
4. 4Substitution — substitute manual carcass retrieval with mechanical pick-up tools, sealed bags and long-handled scoops to avoid direct hand contact with contaminated remains.
5. 5Engineering — install lockable tamper-resistant bait stations secured to substrate per APVMA label, with mechanical ventilation of roof voids before entry and atmospheric testing for O2, CO and H2S.
6. 6Engineering — provide LED inspection lighting, mechanical fans achieving 20 air changes prior to entry, and fixed or temporary edge protection where roof access exceeds 2 metres.
7. 7Administrative — implement confined space entry permit per AS 2865:2025, standby person with communications, pre-start atmospheric monitoring logged, and APVMA-compliant chemical register with current SDS on site.
8. 8Administrative — restrict work to licensed pest management technicians holding current state pest licence, with documented annual training in rodenticide handling, zoonotic disease awareness and confined space entry.
9. 9PPE — P2 respirator (or PAPR for heavy contamination per AS/NZS 1715:2009), nitrile gloves over cotton liners, disposable Type 5/6 coveralls, sealed safety eyewear and steel-midsole boots.
10. 10PPE — post-task decontamination station with hand wash, eyewash, sealed disposal bags for contaminated PPE, and immediate change of clothing before leaving site; biological waste consigned to clinical waste stream.

Applicable Codes of Practice

High-Risk Construction Work triggered

Worked example

A pest management technician arrives at a suburban restaurant reporting rodent activity in the rear food storage area and roof void above the kitchen. Before commencing, the technician opens the Rodent Control SWMS on the tablet at the pre-start brief with the restaurant duty manager. Walking through the hazard register, the technician identifies that roof void access triggers the confined space and falls-from-height controls, and that brodifacoum bait placement near food preparation requires tamper-resistant stations secured per APVMA label. The SWMS confined space checklist prompts atmospheric testing with the four-gas monitor, which records 20.4% O2 and zero CO — entry is authorised and logged, with the restaurant manager nominated as standby person on radio contact. The technician dons P2 respirator, nitrile gloves and Type 5/6 coveralls per the PPE control, places snap traps along identified runways in the roof void, and installs three external lockable stations at the rear loading dock. During the task, the technician discovers a deceased rodent showing fly activity — the SWMS biological hazard control directs sealed double-bagging, clinical waste consignment and immediate glove change. All technicians and the duty manager sign on, the SWMS is left on site, and a 7-day monitoring visit is scheduled with the same document reviewed at each return.

Related legislation

• WHS Act 2011 (model)
• WHS Regulation 2025
• AS 2865 — Confined spaces

Frequently asked questions