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Radon Mitigation Installation SWMS

NSW β€” Radon Mitigation Installation. 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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Radon mitigation installation involves designing and fitting active sub-slab depressurisation systems, sump pits, sealed membranes, in-line fans and discharge stacks to reduce indoor radon gas concentrations in existing dwellings, workplaces and below-ground structures. The work typically combines core drilling through slabs, excavation of sump pits below the floor, entry into subfloor voids and crawl spaces, penetrations through external walls and roofs, and electrical connection of extraction fans. Workers face confined space atmospheres, exposure to radon progeny and respirable crystalline silica from concrete cutting, trip and fall hazards in restricted access voids, and struck-by risks from mobile plant during external excavation for discharge routing.

Under the Work Health and Safety Regulation 2025 (NSW), this scope engages section 291 as high risk construction work β€” specifically work in or near a confined space, work in a trench deeper than 1.5 m, and work involving powered mobile plant. Section 299 requires a Safe Work Method Statement to be prepared before the work commences, identifying hazards, documenting controls applied through the hierarchy in section 36, and describing how controls will be monitored and reviewed.

Hazards identified

12 hazards covered, sorted by priority.

Confined space entry into subfloor voids, sump pits and crawl spaces with potential oxygen deficiency, radon accumulation and inadequate ventilationHIGH

Asphyxiation, loss of consciousness, chronic radiation exposure

Inhalation of radon gas and short-lived radon progeny during initial system installation in high-concentration structuresHIGH

Long-term lung cancer risk from ionising radiation

Exposure to respirable crystalline silica from core drilling, chasing and cutting concrete slabs for sump and pipe penetrationsHIGH

Silicosis, lung cancer, chronic obstructive pulmonary disease

Collapse of trench or excavation deeper than 1.5 m for external discharge piping or ground-level sump accessHIGH

Crush injury, asphyxiation, fatality

Struck-by powered mobile plant (mini-excavator, skid steer) during external trenching and reinstatement worksHIGH

Crush injuries, amputation, fatality

Disturbance of asbestos-containing materials in pre-1990 subfloor packing, vinyl tiles, cement sheet linings or lagged servicesHIGH

Mesothelioma, asbestosis, lung cancer

Contact with live electrical installations when routing fan wiring, penetrating cavities or working near unidentified subfloor cablingHIGH

Electrocution, arc flash burns, fatality

Falls from height when installing external discharge stacks, roof penetrations and fan housings above 2 mHIGH

Fractures, spinal injury, fatality

Manual handling of fan units, piping, sump materials and drilling equipment in restricted-access voidsMEDIUM

Musculoskeletal injury, hernia, chronic back injury

Hazardous noise from core drills, rotary hammers and impact tools in reflective subfloor environmentsMEDIUM

Noise-induced hearing loss, tinnitus

Slips, trips and falls on membranes, uneven subfloor terrain and around excavated sump pitsMEDIUM

Sprains, fractures, head injuries

Biological hazards in subfloor voids including rodent droppings, mould, spiders and standing waterMEDIUM

Leptospirosis, respiratory infection, envenomation

Control measures

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

  1. 1Eliminate confined space entry where possible by installing external sump access points, remote-actuated fans and pre-fabricated discharge assemblies designed at the survey stage.
  2. 2Substitute dry cutting with wet-cut core drilling equipment or tools fitted with on-tool H-class extraction (HEPA) to control respirable crystalline silica exposure below the workplace exposure standard of 0.05 mg/mΒ³ (8-hour TWA).
  3. 3Engineer confined space ventilation using powered forced-air ventilation and continuous atmospheric monitoring (Oβ‚‚, CO, LEL) with radon screening measurements before and during entry, in accordance with AS 2865 Confined Spaces.
  4. 4Shore, bench or batter all excavations deeper than 1.5 m in accordance with the SafeWork NSW Code of Practice: Excavation Work, with a competent person inspecting trenches daily and after weather events.
  5. 5Establish exclusion zones and spotters around powered mobile plant, use plant fitted with reversing alarms and cameras, and separate pedestrian workers from plant travel paths per AS 2601 Demolition of structures principles and manufacturer traffic management guidance.
  6. 6Complete a pre-work asbestos assessment for all pre-1990 structures; where ACM is confirmed or presumed, engage a Class A or B licensed asbestos removalist as required under section 458 of the WHS Regulation 2025 (NSW) before further work.
  7. 7De-energise and lock out electrical circuits before penetration; verify with a licensed electrician and use non-conductive tools and RCD-protected temporary supplies in accordance with AS/NZS 3012 Electrical installations β€” Construction and demolition sites.
  8. 8Provide edge protection, harness-based fall arrest anchored to certified points, or elevating work platforms for all roof and stack installation work above 2 m, in accordance with AS/NZS 1891.4 Industrial fall-arrest systems.
  9. 9Issue P2/P3 respiratory protection selected and fit-tested in accordance with AS/NZS 1715 and AS/NZS 1716; supply Class 5 hearing protection to AS/NZS 1270, safety eyewear to AS/NZS 1337.1, cut-resistant gloves and safety footwear to AS/NZS 2210.3.
  10. 10Implement a confined space entry permit system with standby person, retrieval harness and rescue plan; radon-specific dosimetry (integrating passive detectors or continuous radon monitors) where prior indoor readings exceed 200 Bq/mΒ³.
  11. 11Conduct daily pre-start toolbox talks covering the day's specific hazards, atmospheric test results and rescue arrangements; document sign-on to the SWMS.
  12. 12All workers to hold CPCCWHS1001 General Construction Induction (White Card); consult workers under section 47 of the WHS Act 2011 (NSW) when developing and amending this SWMS, and review under section 302 of the WHS Regulation 2025 (NSW) when controls change, an incident occurs, or work methods are revised.

Applicable Codes of Practice

SafeWork NSW Code of Practice: Construction Work (2019)βš– Legally binding Β· 1 Jul 2026

Establishes general duties for planning, SWMS preparation and consultation for construction work including specialist mitigation trades.

SafeWork NSW Code of Practice: Confined Spaces (2019)βš– Legally binding Β· 1 Jul 2026

Directly applies to subfloor voids, sump pits and sealed crawl spaces entered during radon system installation.

SafeWork NSW Code of Practice: Excavation Work (2018)βš– Legally binding Β· 1 Jul 2026

Governs trenching >1.5 m for external discharge routing, ground-condition assessment and shoring requirements.

AS 2865:2009 Confined spaces

Technical standard for atmospheric testing, ventilation, entry permits and rescue arrangements referenced by the Code.

High-Risk Construction Work triggered

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

Subfloor voids, sealed crawl spaces and sump pits meet the section 5 definition of a confined space: enclosed or partially enclosed, not designed for human occupancy, restricted access, and with the potential for oxygen deficiency and hazardous atmospheres including radon and CO from tools.

s291(g)
Is carried out in or near a shaft or trench deeper than 1.5 metres, or a tunnel

External trenching for radon discharge piping, ground-level sump access and re-routing services frequently exceeds 1.5 m excavated depth, engaging collapse-risk provisions.

s291(o)
Is carried out in an area at a workplace in which there is any movement of powered mobile plant

Mini-excavators, skid steers and truck-mounted core drills operate in shared work areas with pedestrian workers during excavation, spoil removal and reinstatement phases.

Legal consequence

A SWMS complying with section 299 of the WHS Regulation 2025 (NSW) must be prepared before HRCW commences and reviewed under section 302 whenever controls are revised, an incident occurs, or a person raises a concern. Failure to prepare, comply with or review a SWMS exposes the PCBU and officers to Category 1 offences under section 31 (reckless conduct) or Category 2 offences under section 32 of the WHS Act 2011 (NSW). Current maximum penalties are published in the SafeWork NSW penalty schedule and indexed periodically.

Who this is for

  • β†’Licensed radon mitigation contractors and specialist environmental remediation firms operating in NSW
  • β†’HVAC and ventilation contractors expanding into radon-reduction system installation
  • β†’Building services PCBUs undertaking sub-slab depressurisation in commercial and residential premises
  • β†’Environmental consultancies self-performing installation following radon screening
  • β†’Principal contractors coordinating radon mitigation as part of broader remediation or refurbishment projects

What you receive

  • βœ“Editable SWMS document in Microsoft Word (.docx) format, pre-populated for radon mitigation installation
  • βœ“NSW-specific legislative references to the WHS Act 2011 and WHS Regulation 2025
  • βœ“Hazard and control register aligned to the hierarchy of control in section 36 of the Regulation
  • βœ“HRCW identification matrix mapping tasks to section 291 categories (f), (g) and (o)
  • βœ“Confined space entry permit template and atmospheric monitoring log
  • βœ“Daily pre-start briefing and SWMS sign-on register
  • βœ“Plant and equipment pre-use inspection checklists for core drills and mobile plant
  • βœ“SWMS review record aligned to section 302 trigger events
  • βœ“Guidance notes on integrating asbestos and silica controls without duplicating separate SWMS documents

Worked example

A specialist mitigation contractor is engaged to install an active sub-slab depressurisation system in a 1975-built two-storey office in Chatswood following indoor radon screening of 340 Bq/mΒ³. The scope includes core drilling a 150 mm penetration through the ground-floor slab, excavating a 400 mm deep sump, entry into a 900 mm-high subfloor void to seal the membrane, and external trenching to 1.7 m depth along the eastern elevation to route the discharge stack behind the building. Before mobilisation, the PCBU consults the two-person crew and site supervisor under section 47 of the WHS Act, prepares this SWMS covering all three HRCW categories, and confirms a Class B asbestos clearance for the identified vinyl floor tiles. On day one, atmospheric testing of the subfloor void records 20.4% Oβ‚‚ and 180 Bq/mΒ³ radon; forced-air ventilation is deployed and continuous monitoring maintained. The 1.7 m trench is battered at 1:1 in the sandy fill and inspected by the supervisor. A spotter separates the mini-excavator from the pedestrian corridor. On day three, an unplanned second slab penetration is required; the SWMS is reviewed under section 302, the crew re-signed, and work resumes.

Related legislation

  • Work Health and Safety Act 2011 (NSW) β€” sections 19, 31, 32, 47
  • Work Health and Safety Regulation 2025 (NSW) β€” sections 36, 66-77 (confined spaces), 291, 299, 302
  • Work Health and Safety Regulation 2025 (NSW) β€” Chapter 4 Part 4.1 (hazardous chemicals) and Part 4.4 (asbestos)
  • Radiation Control Act 1990 (NSW) and Radiation Control Regulation 2013 (NSW)
  • Protection of the Environment Operations Act 1997 (NSW) β€” discharge and spoil management
  • Electricity (Consumer Safety) Act 2004 (NSW) β€” licensed electrical work

Frequently asked questions

Does radon exposure itself trigger HRCW under section 291?

No. Radon exposure is not itself a section 291 category. The HRCW triggers for this scope are confined space entry (291(f)), trenching over 1.5 m (291(g)) and powered mobile plant (291(o)). Radon is managed as a hazardous atmosphere within the confined space controls and as a chronic health hazard through respiratory protection and monitoring.

Do we need a separate SWMS for the silica and asbestos components?

Not necessarily. Silica and asbestos-related tasks can be integrated into this SWMS provided controls are specific, measurable and applied to the actual tasks. However, if licensed asbestos removal is required, that work must be performed by a licensed removalist under their own Asbestos Removal Control Plan in accordance with section 458 of the WHS Regulation 2025 (NSW).

When must this SWMS be reviewed?

Section 302 of the WHS Regulation 2025 (NSW) requires review whenever the control measures are revised, the work method changes, a notifiable incident occurs, a new hazard is identified, or a health and safety representative requests a review. Review outcomes must be recorded and re-communicated to workers.

Who must hold a White Card on this job?

Every worker carrying out construction work β€” including radon mitigation installation β€” must hold a CPCCWHS1001 General Construction Induction card. Evidence of currency should be verified and recorded at induction to the site, alongside any confined space entry, working-at-heights and plant operator competencies applicable to individual tasks.

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(g) β€” Work in or near a shaft or trench >1.5 m or a tunnel; s. 291(o) β€” Work where there is movement of powered mobile plant
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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