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Civil & Infrastructure Waterproofing SWMS

⚖️WHS Regulation 2025 & Codes of Practice — legally binding from 1 July 2026 (s26A)
👷Reviewed by certified occupational health and safety professionals
🗺️State-specific variants for all 8 Australian jurisdictions
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SWMS variants reference your state’s WHS legislation. Instant download after payment.

Civil and infrastructure waterproofing is two hazards wearing one high-visibility vest, and they multiply each other. The first is the **structure**: water and wastewater tanks, reservoirs, tunnels, culverts, shafts, lift pits and below-ground slabs are confined spaces — limited entry, no natural ventilation, and an atmosphere that starts questionable and gets worse the instant coating begins. The second is the **chemistry**: the high-performance systems this work exists to apply are the trade's most hazardous. Spray polyurethane and polyurea are isocyanate systems, and isocyanates are respiratory sensitisers — a worker who becomes sensitised reacts to concentrations far below any exposure standard, forever, and the career in this trade is over. Sensitisation is not an overdose event; it can follow repeated small exposures that never felt like anything.

**That is why spray application of isocyanate systems inside enclosures is done on supplied-air respiratory protection — not filtering cartridges, which give no warning of breakthrough against isocyanates.** Methacrylate (MMA) systems bring the other half of the atmosphere problem: a monomer vapour heavier than air, aggressively odorous and flammable, that collects in the exact low points — pits, sumps, invert levels — the structure is made of. Ventilation is designed for the floor of the space, ignition control extends to everything electrical in the vapour zone, and quantities inside are limited to what is in use. Around these two chemistries run the scope's conventional hazards — falls into and inside the structures, plant interface on live civil sites, torch details, silica from concrete preparation and high-pressure injection — and every one of them is harder to control on the inside of a tank. This SWMS covers spray-applied polyurethane and polyurea, methacrylate and epoxy systems, sheet and torch-applied membranes, cementitious and crystalline coatings, and injection systems. Authored for New South Wales. Regulator: SafeWork NSW.

Hazards identified

14 hazards covered, sorted by priority.

Confined space entry into tanks, pits, culverts, shafts and tunnels — limited egress and an atmosphere the coating work itself degradesHIGH

Asphyxiation, engulfment or collapse in a space with no natural ventilation and one way out

Isocyanate exposure and sensitisation — spray polyurethane and polyurea in enclosures, where sensitisation ends the career and follows exposures that never felt like anythingHIGH

Permanent respiratory sensitisation — reaction below any exposure standard, forever, and the end of the trade

Structure floods, fills or receives flow during the work — inflows, stormwater, process connections or tide reaching an occupied spaceHIGH

Drowning in a culvert, tank or pit that fills on weather, a valve, or someone else's normal operations

Methacrylate (MMA) vapour — heavier than air, flammable, accumulating at the invert and low points of the structure being coatedHIGH

Fire, explosion or overexposure from vapour pooling at the sump and low end of the fall

Fall into or inside the structure — open shafts, tank hatches, pit edges, tunnel portals and wet coated surfacesHIGH

Fall through a hatch or off an edge, or a slide down a freshly coated surface into the low point

Torch and hot works on details — flame on membranes at portals, upstands and joints, with vapour and confined geometry nearbyHIGH

Ignition of solvent or MMA vapour, or a burn, where flame meets confined geometry

Powered mobile plant interface — waterproofing crews working among excavators, cranes, agitators and haulage on live civil sitesHIGH

Struck-by or crushing where the workface shares the structure with operating plant

Spray plant and heated high-pressure lines — proportioners, heated hoses and guns at pressure and temperature, and hydraulic-type injection injuriesHIGH

High-pressure injection injury — a surgical emergency regardless of the wound's size — or a burn

Silica dust from concrete preparation — grinding, scabbling, blasting and grooving inside structures that concentrate the dustHIGH

Silicosis from respirable crystalline silica concentrated by the enclosure

Working in remote, dark or trafficked infrastructure — culverts under roads, tunnels on possessions, and night worksHIGH

Struck-by or entrapment where protection arrangements lapse, coverage fails, or lone work goes unnoticed

Chemical contact — epoxies, primers, hardeners and cementitious systems on skin and eyes, and dermal isocyanate exposureHIGH

Chemical burns, eye injury and epoxy or isocyanate sensitisation through the skin

Injection works into cracks and joints — high-pressure polyurethane and epoxy injection against water-bearing defectsHIGH

A packer that lets go becomes a resin-carrying projectile; water-reactive resin cures in the eye as readily as the crack

Noise from blasting, grinding and spray plant amplified by the structureMEDIUM

Noise-induced hearing loss — the tank turns every source inside it up

Manual handling — drums, rolls, spray hoses, blasting pots and equipment into and out of structures with awkward accessMEDIUM

Musculoskeletal injury handling drums and equipment through hatches and down ladders

Control measures

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

  1. 1Eliminate the entry by applying from outside — spray lances, remote application and surface-side details — wherever the method allows; a confined space entry permit under AS 2865 governs every entry that cannot be eliminated.
  2. 2Test the atmosphere before and continuously during entry for oxygen, flammables and the system's specific vapours, with mechanical ventilation designed for the enclosure's volume and the application's vapour load, and a trained standby person outside who does not enter under any circumstances.
  3. 3Isolate every inflow, outfall and process connection to the structure before entry — valves closed and locked, lines blanked or physically disconnected where the asset owner's procedure requires — because a culvert, tank or pit can fill on weather, on a valve, or on someone else's normal operations, and evacuate on any water entry however small.
  4. 4Use supplied-air respiratory protection for spray application of isocyanate systems in tanks, pits and enclosed structures — filtering cartridges give no warning of breakthrough against isocyanates and are not accepted for enclosure spray — with everyone except the protected applicator out of the space during spray and cure.
  5. 5Provide health monitoring for isocyanate-exposed workers per the Regulation, treat any respiratory symptom — tightness, wheeze, flu-like evening reaction — as reportable and medically assessed before the worker sprays again, and protect skin because dermal exposure also sensitises.
  6. 6Design MMA ventilation to sweep the FLOOR of the space where the heavier-than-air vapour collects, exclude ignition sources from the vapour zone with electrical equipment rated for it, and hold continuous LEL monitoring at the low point during application.
  7. 7Rig edge protection or attended barricades at every open hatch, shaft and pit for the whole open period, treat freshly coated surfaces as no-go until cured because a wet membrane is a slide into the low point, and provide anchorage with a rescue plan before any harness use.
  8. 8Use flame-free membrane details wherever the specification allows and always where solvent or MMA vapour can reach the flame; where torch work is unavoidable, run it under a hot work permit with a fire watch, cylinders outside the enclosure, and no torch inside a confined space unless the entry permit and atmosphere testing specifically allow it.
  9. 9Separate the waterproofing workface from plant operations with physical barriers and agreed exclusion under the site's traffic management plan, spot plant movements near open structures, and prohibit work below or beside operating plant without the plant stood down.
  10. 10Operate spray plant to the manufacturer's method with the pump outside the enclosure where the arrangement allows, relieve pressure before any gun or line service, locate leaks visually never by hand, and treat any injection injury as a surgical emergency regardless of the wound's appearance with the SDS sent with the person.
  11. 11Control respirable crystalline silica by wet preparation or on-tool H-class extraction discharging outside the enclosure, assess exposure by a competent person, and upgrade respiratory protection to supplied-air or PAPR where the assessment requires inside enclosures.
  12. 12Work remote and trafficked structures under the asset owner's protection arrangement — road occupancy, rail possession or waterway control — confirmed before setup, with lighting, proven communications, maintained egress at both ends where the structure allows, and no lone work in tunnels and culverts.
  13. 13Ensure all workers hold a current White Card (CPCCWHS1001), with confined space entrants and standby persons competent to AS 2865, atmospheric testing by a competent person, and spray isocyanate applicators trained in the system and its respiratory protection.
  14. 14Consult workers on WHS matters affecting them under Section 47 of the WHS Act 2011 (NSW), record the consultation, and review the SWMS under Section 302 of the WHS Regulation 2025 (NSW) whenever the structure, system, chemistry, atmosphere or access changes, after any incident, or at minimum every 12 months.

Applicable Codes of Practice

Code of Practice: Confined spaces⚖ Legally binding · 1 Jul 2026

The benchmark for every entry this scope makes — classification, atmospheric testing, ventilation, entry permits, standby and non-entry rescue for the tanks, pits, culverts, shafts and tunnels the work enters.

Code of Practice: Managing risks of hazardous chemicals in the workplace⚖ Legally binding · 1 Jul 2026

The benchmark for the isocyanate, MMA, solvent and epoxy controls, including exposure standards, safety data sheet duties and health monitoring for isocyanate-exposed workers where the Regulation requires it.

Code of Practice: Managing the risk of falls at workplaces⚖ Legally binding · 1 Jul 2026

The benchmark for edge protection and access at open shafts, tank hatches, pit edges and bridge decks, and on wet coated surfaces that become a slide into the low point.

AS 2865 — Confined spaces

The benchmark for classification, atmospheric testing, ventilation, entry and non-entry rescue for the enclosed structures this work coats.

AS/NZS 1715 and AS/NZS 1716 — Respiratory protective equipment (selection, use and maintenance; specification)

The basis for supplied-air respiratory protection selection for isocyanate spray in enclosures, and for respirator selection against MMA, solvent and silica exposures.

AS 1940 — The storage and handling of flammable and combustible liquids

The benchmark for solvent and MMA storage, decanting and the quantities of flammable product kept at the workface inside the structure.

High-Risk Construction Work triggered

6
Construction work carried out in or near a confined space

Tanks, reservoirs, tunnels, culverts, shafts and lift pits are confined spaces — limited entry and egress, not intended for continuous occupancy, and with an atmosphere the coating work itself degrades the moment application begins.

12
Construction work carried out in or near a contaminated or flammable atmosphere

Spray polyurethane and polyurea release isocyanate, and methacrylate systems release a flammable monomer vapour heavier than air that pools at the invert and low points, creating a contaminated and flammable atmosphere inside the enclosure being coated.

1
Construction work involving a risk of a person falling more than 2 metres

Open shafts, tank hatches, pit edges, tunnel portals and vertical access into deep structures carry a fall risk over 2 m, compounded by freshly coated surfaces that become unwalkable slides into the low point.

15
Construction work carried out in an area at a workplace in which there is any movement of powered mobile plant

Waterproofing crews on live civil and infrastructure sites work among excavators, cranes, agitators and haulage, and share the structure with operating plant during set-up, delivery and coating.

Legal consequence

Civil and infrastructure waterproofing is high risk construction work under Section 291 of the WHS Regulation 2025 (NSW) on four counts — confined space, contaminated or flammable atmosphere, falls more than 2 metres, and movement of powered mobile plant — so a SWMS must be prepared before work commences (Section 299), kept readily accessible, reviewed as necessary (Section 302), and given to the principal contractor if one is appointed. Confined space entry is separately regulated under Part 4.3 Division 2, which requires entry permits, atmospheric testing, and standby and rescue arrangements before any person enters. The isocyanate, methacrylate, solvent and epoxy duties fall under Chapter 7 (hazardous chemicals), including exposure standards and health monitoring for isocyanate-exposed workers. A confined space incident, an exposure requiring treatment, a fire, a fall, an injection injury or any incident requiring immediate hospital treatment is a notifiable incident under Sections 35–38 of the WHS Act 2011 (NSW) and is prosecuted as a Category 1 or Category 2 offence, with the most serious breaches carrying imprisonment for individuals.

Who this is for

  • Waterproofing and remedial contractors coating water and wastewater tanks, reservoirs, tunnels, culverts, bridge decks, basements, lift pits and retaining structures.
  • Spray isocyanate and polyurea applicators and their spray-equipment operators working inside enclosed and below-ground structures.
  • Confined space entry teams, standby persons and atmospheric-testing competent persons supporting civil waterproofing entries.
  • Principal contractors and asset owner representatives responsible for structure isolations, inflow control, plant interface and permit coordination.
  • WHS managers and HSE advisors responsible for hazardous chemical duties, health monitoring for isocyanate-exposed workers, and confined space compliance.

What you receive

  • A complete, editable Safe Work Method Statement authored for New South Wales — the WHS Act 2011 (NSW), the WHS Regulation 2025 (NSW) and SafeWork NSW as regulator.
  • 14 identified hazards with initial and residual risk ratings on a 5x5 matrix, each with controls ordered through the full hierarchy — eliminate, engineer, administrative, PPE — printed alongside the matrix legend.
  • The confined space control set built on entry permits under AS 2865, continuous atmospheric testing, ventilation designed for the enclosure, asset-owner isolation of inflows, and a standby person who does not enter under any circumstances.
  • The isocyanate control set: supplied-air respiratory protection for enclosure spray, the explicit rejection of filtering cartridges against isocyanates, health monitoring, and the sensitisation-symptom reporting rule that keeps a career alive.
  • The MMA control set for a vapour heavier than air — floor-swept ventilation, ignition control across the vapour zone, LEL monitoring at the low point, and flammable-liquid quantity limits at the workface.
  • Controls for the scope's conventional hazards — falls into and inside structures, powered mobile plant interface, torch details, spray-plant injection injuries, respirable silica from concrete preparation, high-pressure injection and structure flooding.
  • The full high risk construction work breakdown — confined space, contaminated or flammable atmosphere, falls over 2 m and powered mobile plant — with the reason each category applies, plus the Part 4.3 and Chapter 7 duties.
  • A PPE matrix mapping each task to the required equipment and Australian Standard, an emergency section covering confined space rescue, isocyanate exposure, water entry, LEL alarm, injection injury and chemical splash, and a worker sign-on table.
  • Microsoft Word (.docx) format, unbranded, with editable fields for PCBU, site, prepared by, reviewed by, approved by and review date.

Worked example

A remedial crew is relining a stormwater culvert that runs under a suburban arterial in Western Sydney. The specification calls for spray polyurea over a primed invert, and the access is a single manhole at each end. The ganger has done tanks before and treats this as another one — proportioner at the top, heated hose down the shaft, applicator inside on a harness. What this SWMS forces into the plan before anyone enters is the intersection nobody was thinking about: the culvert is a confined space, the polyurea is an isocyanate system, and the structure fills on rain in a catchment the crew cannot see. So the entry runs on a permit under AS 2865 with continuous atmospheric testing and a standby person at the manhole who does not enter; the applicator sprays on supplied-air, not a cartridge respirator, because filtering cartridges give no warning of isocyanate breakthrough; the asset owner confirms and documents upstream isolation before entry; and work is suspended on any forecast rain in the catchment because a culvert can fill on weather while everyone inside is coating. When an evening tightness in the applicator's chest is reported that night, it is medically assessed rather than slept off — because isocyanate sensitisation is permanent, and the SWMS treats the first symptom as the last warning.

Related legislation

  • Work Health and Safety Act 2011 (NSW) — Section 19 primary duty of care; Section 47 consultation; Sections 35–38 notifiable incidents.
  • Work Health and Safety Regulation 2025 (NSW) — Section 291 (high risk construction work) and Section 299 (preparation and content of a SWMS), with review under Section 302.
  • Work Health and Safety Regulation 2025 (NSW) — Part 4.3 Division 2 (confined spaces): entry permits, atmospheric testing, and standby and rescue arrangements before entry.
  • Work Health and Safety Regulation 2025 (NSW) — Chapter 7 (hazardous chemicals): duties for isocyanates, methacrylates, solvents and epoxies including exposure standards and health monitoring.
  • AS 2865 (Confined spaces), AS/NZS 1715 and AS/NZS 1716 (respiratory protective equipment) and AS 1940 (storage and handling of flammable and combustible liquids).

Frequently asked questions

Can our applicators use cartridge respirators for spraying inside a tank?

Not for isocyanate spray in an enclosure. Filtering cartridges give no warning of breakthrough against isocyanates — when the cartridge is exhausted, the wearer keeps breathing the vapour with no smell, no taste and no signal. That is why spray application of polyurethane and polyurea inside tanks, pits and enclosed structures is done on supplied-air respiratory protection, with everyone except the protected applicator out of the space during spray and cure. The SWMS states this explicitly and does not accept filtering cartridges for enclosure spray.

Why treat a stormwater culvert as a confined space if it is open at both ends?

Because open ends do not make it ventilated, safe to enter, or immune to flooding. A culvert has limited entry and egress, is not intended for continuous occupancy, and its atmosphere degrades the moment coating begins — which puts it squarely within the confined space definition and Part 4.3 Division 2. It also fills on weather, on a valve upstream, or on someone else's normal operations, none of which the crew inside can see. The SWMS runs every entry on a permit under AS 2865 with atmospheric testing, a standby person, asset-owner isolation of inflows, and suspension of work on forecast rain in the catchment.

What is so serious about isocyanate exposure if the worker feels fine?

Isocyanates are respiratory sensitisers, and sensitisation is not an overdose event. It can follow repeated small exposures that never felt like anything, and once a worker is sensitised they react to concentrations far below any exposure standard, permanently — the career in this trade is over. That is why the controls do not rely on how a worker feels on the day: supplied-air protection for enclosure spray, health monitoring for isocyanate-exposed workers, skin protection because dermal exposure also sensitises, and any respiratory symptom — tightness, wheeze, a flu-like evening reaction — reported and medically assessed before the worker sprays again.

Does buying this SWMS make us compliant?

No. This is a documentation set, not a compliance certificate. A SWMS is one part of the duties under the WHS Regulation 2025 (NSW): you still have to run the confined space entry permits and atmospheric testing under Part 4.3, provide and fit-test the supplied-air respiratory protection, arrange health monitoring for isocyanate-exposed workers under Chapter 7, isolate the structure's inflows with the asset owner, consult your workers under Section 47, and review the document under Section 302 whenever the structure, system or conditions change. The SWMS is the framework that makes those controls explicit and auditable — it does not perform them for you.

What's in this SWMS

Document details

Regulation
Work Health and Safety Regulation 2025 (NSW) — High Risk Construction Work (s291; SWMS s299)
HRCW Category
High risk construction work — civil and infrastructure waterproofing is carried out in or near confined spaces including tanks, pits and tunnels, in areas that may have a contaminated or flammable atmosphere from spray-applied and solvent systems in enclosed structures, involves a risk of a person falling more than 2 metres, and is carried out in areas with movement of powered mobile plant (s291); a SWMS is required (s299).
Hazards Identified
14 hazards with controls
Format
Editable DOCX (Microsoft Word)
Author
Certified Industrial Hygienist (CIH)
Delivery
Instant download after payment