Portable Toilet Service & Pump-Out SWMS

Portable toilet servicing covers the servicing and pump-out of portable toilets and portable sanitary units — emptying the waste holding tank, cleaning and restocking the unit, and disposing of the waste. It is sanitation service work whose hazards centre on the biological hazards of the sewage, the chemicals used in the units, the pump-out equipment and tanker, and the manual handling involved in servicing the units, often at construction sites and events. This document is written on the basis that portable toilet servicing is carried out by a competent operator, with the biological, chemical and manual-handling hazards controlled and the waste disposed of correctly.

Portable toilet servicing is sanitation service work involving the pump-out of the waste holding tank, the cleaning and restocking of the unit, and the disposal of the waste in accordance with the requirements. The defining hazards are the biological hazards of the sewage and the sanitising chemicals used in the units. This document coordinates the biological, chemical, equipment and disposal controls so the units are serviced safely and the waste disposed of correctly.

Hazards identified

9 hazards covered, sorted by priority.

Control measures

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

1. 1Administrative: manage the biological hazard with hygiene controls, washing facilities, gloves and protective clothing, and prohibition of eating, drinking and smoking until decontaminated.
2. 2Administrative: manage the sanitising and deodorising chemicals to their safety data sheets, with skin, eye and respiratory protection and handling controls where required.
3. 3Engineering: control the splash and aerosol during pump-out and cleaning, and manage the pump-out equipment, hoses and tanker safely.
4. 4PPE: gloves, eye and face protection and protective clothing against sewage contact, and respiratory protection where aerosol or odour requires it, per AS/NZS 1715 and AS/NZS 1716.
5. 5Engineering: use correct manual-handling technique or aids servicing and moving the units, and manage the wet work area against slips.
6. 6Administrative: where servicing at construction sites and events, apply the site and event controls — traffic, plant and crowd management — for the location.
7. 7Administrative: handle and dispose of the pumped-out waste correctly, controlling spills, and restock and leave the unit serviced and hygienic.
8. 8Administrative: ensure the work is carried out and certified by an appropriately licensed plumber under the relevant state or territory plumbing licensing scheme, with the backflow, testing or other endorsement required and a compliance or test certificate issued where required.
9. 9Administrative: all workers must hold a valid White Card (General Construction Induction Training, CPCCWHS1001) where the work is construction work, with the plumbing competencies and any backflow, confined space or testing endorsements required for the work.
10. 10Administrative: conduct a pre-start toolbox talk covering the day's work, identified hazards, isolations, required PPE and emergency procedures, and record attendance in the consultation section.
11. 11Administrative: consult workers and any health and safety representatives on the work and its risks, record the consultation, and keep this document available at the workplace.
12. 12PPE: eye protection to AS/NZS 1337.1, hearing protection where required, gloves appropriate to the task, and Class I or Class II safety footwear with protective toecap to AS/NZS 2210.3.
13. 13Administrative: review and update this SWMS whenever the work scope changes, after any incident or near miss, when a worker or health and safety representative raises a concern, when new hazards are identified, or at minimum every 12 months.

Applicable Codes of Practice

Worked example

A sanitation service operator is engaged to service the portable toilets at a construction site. The biological hazard of the sewage and waste is managed with hygiene controls, washing facilities, gloves, eye and face protection and protective clothing, and no eating or drinking until decontaminated, with respiratory protection where aerosol or odour requires it. The sanitising and deodorising chemicals are managed to their safety data sheets with skin, eye and respiratory protection. The splash and aerosol during pump-out and cleaning are controlled, and the pump-out equipment, hoses and tanker managed safely. Correct manual-handling technique is used servicing the units, and the wet work area managed against slips. The site controls — traffic, plant and access — are applied for the construction site. The pumped-out waste is handled and disposed of correctly, controlling spills, and the units restocked and left serviced and hygienic. The operator retains the records.

Related legislation

• Model Work Health and Safety Act — primary duty of care; the duty to consult workers; the reckless-conduct offence; and notifiable-incident provisions, as enacted in each jurisdiction.
• Model Work Health and Safety Regulations — Section 291 high risk construction work and the SWMS preparation and review duties, and the confined space provisions where applicable, as enacted in each jurisdiction.
• The relevant plumbing and drainage standards AS/NZS 3500 (Parts 0–5), AS/NZS 1547 for on-site wastewater, the AS 4032 and AS 1357 valve standards, AS/NZS 2845.3 for backflow field testing, and AS 1851 for fire-system service, are called up by the state and territory plumbing and building safety legislation, together with the requirements of the relevant network utility.
• Plumbing work is licensed under each state and territory's plumbing licensing scheme, with backflow and testing accreditation required for that work, and compliance or test certification required for notifiable work; electrical work is carried out by a licensed electrician.
• Victoria operates under the Occupational Health and Safety Act 2004 and the Occupational Health and Safety Regulations 2017, with the high risk construction work and confined space provisions applying in place of the model instruments.

Frequently asked questions