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Trenchless Pipe Relining SWMS

NSW β€” Trenchless Pipe Relining. 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
πŸ—ΊοΈState-specific variants for all 8 Australian jurisdictions
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Trenchless pipe relining rehabilitates damaged sewer, stormwater and drainage pipelines by inserting a resin-impregnated liner (CIPP) through existing access points, then curing it in place with ambient, hot water, steam or UV light. The work involves entry into or breathing zone exposure to sewer manholes, pits and confined spaces; handling of styrene-based and epoxy resins; hot water, steam and UV curing equipment; high-pressure water jetting for pre-clean; and near-constant work adjacent to live traffic corridors because access points are almost always in roadways or footpaths.

Under the Work Health and Safety Regulation 2025 (NSW), section 291 defines high risk construction work, and section 299 requires a SWMS to be prepared before that work commences. Relining routinely triggers section 291(f) confined space entry, section 291(l) contaminated or flammable atmosphere (styrene vapour, sewer gases, resin fumes), and section 291(n) work on or adjacent to a road or traffic corridor. Controls follow the hierarchy in section 36 β€” elimination of entry where possible, atmospheric monitoring, ventilation, traffic control and respiratory protection.

Hazards identified

12 hazards covered, sorted by priority.

Confined space entry into manholes, wet wells and pits with oxygen deficiency, H2S and methaneHIGH

Rapid unconsciousness and fatality from asphyxiation or toxic exposure

Styrene vapour and epoxy resin fume exposure during liner impregnation and curingHIGH

Acute CNS depression, respiratory sensitisation, chronic neurotoxicity

Work adjacent to live traffic on roads, intersections and shared zonesHIGH

Fatal or serious injury from vehicle strike of workers or equipment

Flammable atmosphere from resin solvents, styrene and sewer methane ignited by curing plantHIGH

Explosion, flash fire, severe burns

Steam and hot water cure line failure or hose whip at up to 95Β°CHIGH

Full-thickness scald burns, eye injury

UV curing equipment β€” direct and reflected UV-C exposure at access pointsMEDIUM

Photokeratitis, skin burns, long-term skin cancer risk

High-pressure water jetting (>2000 bar) for pre-clean and root cuttingHIGH

Injection injury, degloving, projectile debris strike

Biological exposure to raw sewage, needlestick and pathogens (leptospirosis, hepatitis)MEDIUM

Serious infection and notifiable disease

Manual handling of resin drums, liner rolls (up to 200 kg) and drum reelsMEDIUM

Musculoskeletal injury, crush injury during deployment

Skin contact with uncured resins, hardeners and isocyanatesMEDIUM

Chemical burns, dermatitis, occupational asthma sensitisation

Uncontrolled release of hot condensate, cure water or resin wash to environment and workersMEDIUM

Burns, environmental non-compliance, POEO Act breach

Silica dust from cutting reinstated concrete/masonry at access chambersMEDIUM

Silicosis, chronic respiratory disease

Control measures

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

  1. 1Eliminate physical confined space entry wherever possible by conducting all liner insertion, inversion and cutting from surface using remote CCTV and robotic cutters
  2. 2Substitute high-styrene polyester resins with low-styrene, low-VOC or epoxy/silicate systems where the design permits, reducing atmospheric contamination at source
  3. 3Establish a permit-to-work confined space entry system compliant with AS 2865-2009 including pre-entry and continuous atmospheric monitoring for O2, LEL, H2S and CO, with defined action levels and rescue plan
  4. 4Provide forced mechanical ventilation of the pipeline and access chambers before and throughout curing; discharge exhaust away from workers and public and, where styrene may exceed 50 ppm TWA, apply local exhaust capture at manholes
  5. 5Implement a compliant Traffic Guidance Scheme prepared by a TfNSW-accredited person under the Traffic Control at Work Sites Manual (TCWS), including positive protection, tapers, speed reduction and, on classified roads, TfNSW road occupancy approval
  6. 6Bond and earth all metallic curing plant; use intrinsically safe gas detection (AS/NZS 60079 series) and keep ignition sources outside the hazardous zone until LEL is confirmed <5%
  7. 7Guard, restrain and pressure-test all steam, hot water and cure lines to AS 4041 and AS 2593; fit whipchecks, hose restraints and thermal insulation; exclude personnel from the cure line envelope during pressurisation
  8. 8For UV curing, enclose or shield access points, prohibit direct viewing of the light train, and provide UV-rated eye and skin protection to AS/NZS 1337.1 and AS/NZS 4501.2
  9. 9Water jetting to AS/NZS 4233.1 β€” trained operators only, dead-man controls, exclusion zone, and full jetting PPE including cut-resistant boots, apron and face shield
  10. 10SDS-driven chemical controls for resins and hardeners under the Hazardous Chemicals provisions of the WHS Regulation 2025 (NSW) Chapter 7; nitrile gloves to AS/NZS 2161.10.3, chemical splash goggles, and half-face APR with A2-P2 cartridges to AS/NZS 1716 selected per AS/NZS 1715
  11. 11Health monitoring for workers with significant styrene or isocyanate exposure in accordance with WHS Regulation 2025 (NSW) sections 368–378 and the SafeWork NSW health monitoring guidance
  12. 12All workers hold CPCCWHS1001 (White Card) and confined space/gas test/jetting competencies; the SWMS is developed in consultation with workers under section 47 of the WHS Act 2011 (NSW) and reviewed under section 302 of the WHS Regulation 2025 (NSW) whenever the control measure is revised, an incident occurs, or the work method changes

Applicable Codes of Practice

Confined Spaces Code of Practice (SafeWork NSW)βš– Legally binding Β· 1 Jul 2026

Approved Code β€” governs entry to sewers, manholes and pits for relining including risk assessment, permits, atmospheric testing and rescue

Managing the Work Environment and Facilities Code of Practice (SafeWork NSW)βš– Legally binding Β· 1 Jul 2026

Approved Code β€” ventilation, atmospheric contaminants and airborne exposure standards relevant to styrene and resin fume management

AS 2865-2009 Confined spaces

Referenced technical standard for confined space classification, entry procedures, monitoring and stand-by arrangements

AS/NZS 4233.1:2013 High-pressure water jetting systems β€” Safe operation and maintenance

Governs pre-clean and root-cutting jetting operations undertaken prior to liner installation

High-Risk Construction Work triggered

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

Sewer manholes, maintenance shafts, wet wells and the pipelines themselves meet the AS 2865 and section 5 definition of confined space; relining routinely requires entry for launch/receive, cutting reinstatement and inspection

s291(l)
Is carried out in an area that may have a contaminated or flammable atmosphere

Styrene vapour from CIPP liners, epoxy and isocyanate fumes, plus native sewer gases (H2S, methane) create both toxic and potentially flammable atmospheres at and downstream of the work face

s291(n)
Is carried out on, in or adjacent to a road, railway, shipping lane or other traffic corridor in use by traffic other than pedestrians

Access chambers are located within carriageways, footpaths and shared zones; plant, hoses and personnel routinely occupy road reserves during setup, cure and reinstatement

Legal consequence

Section 299 of the WHS Regulation 2025 (NSW) requires the SWMS to be prepared before HRCW starts, and section 302 requires review whenever controls are revised or an incident occurs. Failure exposes the PCBU and officers to Category 1 (reckless conduct) or Category 2 offences under sections 31 and 32 of the WHS Act 2011 (NSW). Current maximum penalties are published in the SafeWork NSW penalty schedule and are indexed periodically.

Who this is for

  • β†’Licensed plumbing and drainage contractors delivering CIPP, patch and spiral wound relining
  • β†’Civil and utility maintenance PCBUs holding Sydney Water, Hunter Water or council panel contracts
  • β†’Confined space entry teams and rescue standby providers supporting relining crews
  • β†’Principal contractors coordinating relining works within active road reserves
  • β†’WHS managers and site supervisors preparing SWMS packs for tendered relining projects

What you receive

  • βœ“NSW-specific SWMS pre-populated for trenchless CIPP, UV, steam and ambient cure relining
  • βœ“Section 291(f), (l) and (n) HRCW justification aligned to the WHS Regulation 2025 (NSW)
  • βœ“Full hazard register with priority-rated consequences and hierarchy-ordered controls
  • βœ“Confined space permit template and pre-entry atmospheric test record referencing AS 2865
  • βœ“Traffic management prompts aligned to the TfNSW Traffic Control at Work Sites Manual
  • βœ“Chemical register prompts for styrene, epoxy and isocyanate resins with SDS linkage
  • βœ“Consultation and sign-on register meeting section 47 of the WHS Act 2011 (NSW)
  • βœ“SWMS review log meeting section 302 review triggers
  • βœ“Editable Word and PDF formats with company branding fields and version control

Worked example

A drainage contractor is engaged to reline a 225 mm sewer main under Parramatta Road at Ashfield, with launch and receive manholes located in the traffic lane and adjacent parking bay. The crew is running a styrene-based polyester liner cured with hot water at 85Β°C, overnight, under a full lane closure. Before starting, the PCBU prepares a SWMS citing sections 291(f), (l) and (n). A TfNSW-accredited traffic controller implements the TGS with positive barrier separation. Prior to any manhole entry, atmospheric testing records O2 20.9%, LEL 0%, H2S 2 ppm and CO 0 ppm; forced ventilation is established and continuous monitoring is worn by the entrant. Styrene monitoring at the receive manhole is undertaken during inversion. The cure line is whip-checked and thermally lagged. All workers hold CPCCWHS1001 plus confined space entry and gas test competencies. The SWMS is signed on by all workers, and reviewed the following night after a hose fitting weep triggers a section 302 review.

Related legislation

  • Work Health and Safety Act 2011 (NSW)
  • Work Health and Safety Regulation 2025 (NSW) β€” including Chapter 4 Part 4.3 (Confined Spaces) and Chapter 7 (Hazardous Chemicals)
  • Protection of the Environment Operations Act 1997 (NSW) β€” discharge of cure water and resin waste
  • Plumbing and Drainage Act 2011 (NSW) and Plumbing Code of Australia
  • Roads Act 1993 (NSW) β€” road occupancy and works within road reserves
  • Public Health Regulation 2022 (NSW) β€” sewer and cross-connection controls

Frequently asked questions

Is trenchless relining always HRCW even when we don't physically enter the pipe?

In NSW practice, yes. Even 'no-man-entry' methods still require entry to launch and receive manholes for setup, cutter access and reinstatement, which triggers section 291(f). The styrene and sewer gas atmosphere triggers 291(l) and roadway access almost always triggers 291(n). A SWMS is required under section 299 of the WHS Regulation 2025 (NSW) before work starts.

How do we manage styrene exposure during CIPP curing?

Styrene has an established workplace exposure standard published by Safe Work Australia. Control at source with low-styrene liners where possible, forced ventilation of the line and downstream manhole, exhaust discharge away from workers and public, and where residual exposure remains, half-face APR with A2-P2 cartridges selected per AS/NZS 1715 and AS/NZS 1716. Workers with ongoing exposure require health monitoring under sections 368–378 of the WHS Regulation 2025 (NSW).

Do we need traffic control approval from council or TfNSW?

Yes. Any work occupying a road or footpath requires a Traffic Guidance Scheme prepared by a TfNSW-accredited person. On classified roads a Road Occupancy Licence is required from TfNSW; on local roads, a permit is issued by the relevant council under the Roads Act 1993 (NSW). The TGS must be attached to or referenced by the SWMS.

When must the SWMS be reviewed?

Section 302 of the WHS Regulation 2025 (NSW) requires review whenever the control measure is revised, a notifiable incident occurs, the work method changes, or when workers or their HSR reasonably request it. For a multi-shift relining project, this typically means a documented review at the start of each shift and after any deviation from the planned method.

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(f) β€” Work in or near a confined space; s. 291(l) β€” Work in an area with a contaminated or flammable atmosphere; s. 291(n) β€” Work on, in or adjacent to a road, railway, shipping lane or other traffic corridor in use
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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