PFAS-Contaminated Soil & Water SWMS

PFAS-contaminated soil and groundwater remediation works involve the excavation, handling, treatment, transport and disposal of per- and polyfluoroalkyl substance impacted media at legacy firefighting training grounds, industrial sites, landfills and airports. Workers face dermal, inhalation and ingestion exposure pathways to bioaccumulative substances with established human health endpoints, including immunological, hepatic and developmental effects documented in the PFAS National Environmental Management Plan (NEMP) 2.0. A Safe Work Method Statement is mandatory under WHS Regulation 2025 because the work involves hazardous chemicals under Regulation 347, contaminated site remediation triggering airborne contaminant duties under Regulation 49, and health monitoring obligations under Regulation 368 for workers with significant exposure risk. The SWMS documents the exposure control strategy, decontamination regime, waste classification approach and biological monitoring programme aligned with the NEPC PFAS HEPA guidance 2020 and state EPA contaminated land frameworks. It must be developed in consultation with workers and reviewed whenever site conditions, soil concentrations or treatment methods change.

Hazards identified

7 hazards covered, sorted by priority.

Control measures

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

1. 1Elimination — Where feasible, leave low-concentration PFAS soil in situ under a validated capping and institutional control strategy rather than excavating, eliminating worker handling exposure entirely.
2. 2Elimination — Schedule intrusive works to avoid simultaneous high-risk activities such as dewatering during excavation, removing concurrent exposure pathways from the work envelope.
3. 3Substitution — Replace dry mechanical screening with wet processing or stabilisation/solidification techniques to substitute a high-dust generating method with a lower-aerosol alternative.
4. 4Substitution — Use granular activated carbon or ion exchange treatment of groundwater in lieu of open-air sparging to avoid generating PFAS aerosols above the water table.
5. 5Engineering — Establish clearly demarcated exclusion, contamination reduction and support zones with hard barriers, wind socks and continuous dust suppression using fixed misting systems and water carts.
6. 6Engineering — Provide closed-cab plant with HEPA-filtered positive pressure cabins, bunded stockpile areas with impermeable liners, and lined decontamination pads draining to captured-water tanks.
7. 7Administrative — Implement a written exposure control plan, daily pre-start briefings against this SWMS, real-time dust monitoring with action levels, and biological monitoring of serum PFAS for sustained-exposure workers under Regulation 368.
8. 8Administrative — Enforce a strict no-eating, no-drinking, no-smoking rule in exclusion zones; mandate full doff and shower-out before crib breaks; segregate work clothing laundering from domestic streams.
9. 9PPE — Issue chemical-resistant coveralls (Type 3/4 or Tychem equivalent), nitrile inner and outer gloves, P2/P3 respiratory protection or PAPR for dust-generating tasks, and dedicated chemical boots per AS/NZS 1716 and AS/NZS 2161.
10. 10PPE — Maintain a fit-testing register under AS/NZS 1715, daily PPE inspection records, and a clearly documented donning/doffing sequence posted at the decontamination unit with trained decon attendant oversight.

Applicable Codes of Practice

Worked example

A remediation crew mobilises to a regional airport apron where historical aqueous film forming foam use has impacted shallow soil and groundwater. At the 6:30 am pre-start brief, the site supervisor opens the PFAS-Contaminated Soil & Water SWMS on a tablet and walks the four-person excavation team through the day's tasks: bulk excavation of 80 cubic metres of impacted clay into a lined stockpile, with concurrent groundwater dewatering to a GAC treatment train. The team identifies that overnight rain has saturated the cell, raising the dewatering volume and dermal contact risk. The supervisor selects the engineering and PPE controls listed — closed-cab excavator with HEPA cabin filtration, fixed misting at the stockpile, Type 3 coveralls with double nitrile gloves, and P3 half-face respirators for the spotter working at the excavation edge. Workers sign on against the SWMS, confirm respirator fit-test currency on the register, and confirm decon-unit water levels. Mid-morning, real-time dust monitoring alarms at the action level due to a wind shift; following the administrative control in the SWMS, the supervisor stops loadout, increases misting and rotates the spotter upwind. The adjustment is documented as a SWMS variation, initialled by the crew, and the controls return the task to compliance without an exposure incident.

Related legislation

• WHS Act 2011 (model)
• WHS Regulation 2025
• Managing Risks of Hazardous Chemicals CoP; PFAS National Environmental Management Plan

Frequently asked questions