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Remedial Waterproofing & Rectification 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.

Remedial waterproofing is not new construction with a leak. It is surgery on a building that is already full — the balcony being stripped has a family behind its sliding door, the podium is the lobby's roof, and the facade drops onto a footpath the public uses all day. Every hazard on the job therefore has two audiences: the crew who signed on to it, and the occupants and public who did not. The controls have to run in both directions at once — containment and drop protection for whatever leaves the workface, and scheduling, notification and physical separation for the people the building keeps delivering to its own edge. Torch and hot works carry that doubled weight hardest of all: a concealed cavity fire lit on a balcony behaves exactly as it does on a new roof — it travels unseen and emerges after knock-off — except that here the cavity's far side is somebody's bedroom.

**The second thing an existing building brings is its own history.** Membranes, mastics, bedding and coatings installed before 1990 are **presumed to contain asbestos until sampling proves otherwise** — bituminous membranes, sealants and tile bedding of that era routinely do — so no grinding, cutting or stripping of unidentified existing material can proceed ahead of the register or the sample result. Solvent-based primers and adhesives add a third mechanism: a balcony wrapped in shrink-wrap or shade cloth, or a planter box being coated, becomes an enclosed space where vapour climbs toward its flammable range and toward the crew's exposure limits at the same time, with an occupied apartment on the other side of the glass. This SWMS covers failed membrane removal, substrate preparation, crack and joint rectification, torch- and cold-applied reinstatement, tiling interface works and water testing on existing and occupied buildings. Authored for New South Wales. Regulator: SafeWork NSW.

Hazards identified

14 hazards covered, sorted by priority.

Fall from the balcony edge, roof edge or facade — working at the unprotected perimeter of an existing building, often over public areasHIGH

A fatal fall from a balcony whose balustrade came off for the membrane termination

Concealed cavity fire from torch work — flame or heat entering a cavity, penetration or junction and emerging in the occupied building after knock-offHIGH

A building fire that starts hours after the crew has left, on the occupied side of the wall

Asbestos in existing membranes, mastics, bedding and coatings — pre-1990 materials disturbed by grinding, cutting or strippingHIGH

Uncontrolled release of asbestos fibres into an occupied building — a carcinogen with no safe exposure threshold

Solvent and primer vapour in enclosed balconies, planter boxes and wrapped work areas — flammable range and exposure limits approached togetherHIGH

Flash fire or over-exposure in a wrapped balcony that keeps weather out and vapour in

Falling objects to public and occupant areas — debris, tools and materials from balconies and facades onto footpaths, courtyards and lower unitsHIGH

Head or crush injury to a member of the public or an occupant below the workface

Fall through fragile or deteriorated substrates — rotted decks, corroded sheeting, brittle skylights and unverified suspended slabs on an old buildingHIGH

Fall through the very substrate whose failure caused the leak being repaired

EWP and elevated access operations against the facade — boom and scissor work over public areas and adjacent to the building's servicesHIGH

Overturn, entrapment or electrical contact on a streetscape stacked with pedestrians, cars and overheads

Silica dust from grinding, scabbling and preparing concrete substrates and screedsHIGH

Respirable crystalline silica exposure, with dust migrating into occupied units through doors and vents

Occupant and public interface — residents stepping onto the workface, children at balconies, and the building's daily life crossing the jobHIGH

An occupant or child reaching an open edge, wet membrane or removed balustrade the moment the crew steps away

LP Gas for torch work — cylinders, hoses and regulators on balconies and roofs of an occupied buildingHIGH

Leak, flashback or fire from fuel gas stored or run on an occupied building

Manual stripping and demolition of failed systems — tiles, screeds and bonded membranes removed by breaker, scraper and grinderHIGH

Cut, impact, vibration and dust injury, and disturbance of lead paints on older details

Water testing and leak investigation — flood testing suspended slabs and tracing leaks through an occupied buildingHIGH

A flood test that finds the leak by releasing water into the apartment below

Noise transmitted to occupants and the crew — breakers, grinders and preparation in courtyards and on balconies that amplify itHIGH

Crew hearing damage and occupant amenity breach off hard surfaces that reflect everything

Manual handling — membrane rolls, tile and screed waste, water containers and equipment through an occupied building's lifts and stairsMEDIUM

Musculoskeletal injury moving heavy loads through corridors, stairs and shared lifts

Control measures

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

  1. 1Eliminate edge exposure by working from EWPs, scaffolding or behind temporary edge protection wherever the structure allows — an existing balcony's balustrade is not edge protection once the work requires reaching past it, and it comes off for membrane terminations more often than not.
  2. 2Engineer temporary edge protection or scaffolding to the existing structure's fixings, and use only anchorages a competent person has verified — existing buildings do not come with certified anchors and a balustrade post is not one — with a rescue plan established before the first harness connection.
  3. 3Prefer flame-free membrane systems — self-adhesive, liquid-applied or hot-air welded — wherever the specification allows, and make them the default on any detail over or beside a cavity, because on an occupied building the cavity's far side is somebody's bedroom.
  4. 4Carry out any torch work under a hot work permit with combustibles cleared or protected, heat barriers at junctions and penetrations, a fire watch during work and for the full permit period after flame-off checking cavities and the occupied side, and the building's fire system isolations coordinated and reinstated same-day.
  5. 5Identify before touching: consult the building's asbestos register and presume materials installed before 1990 contain asbestos until sampling by a competent person proves otherwise, leaving unidentified material undisturbed pending results — asbestos residual risk stays elevated because there is no safe exposure threshold.
  6. 6Remove confirmed asbestos-containing membranes and mastics above the licensed thresholds only through a licensed removalist using the licensed method — wet methods, containment, decontamination, air monitoring and clearance before reoccupation — and never dry-grind, cut, sand or strip unidentified existing material.
  7. 7Select water-based and low-VOC systems where the specification allows, treat wrapped, hoarded or recessed areas as enclosed spaces for vapour, ventilate during and after application per the SDS, and exclude every ignition source from the vapour zone including the torch on the next bay.
  8. 8Assess planter boxes, pits and enclosed voids against the confined space definition before entry and apply AS 2865 where they meet it.
  9. 9Contain the workface with screens, mesh, kickboards and sealed chutes so nothing leaves the balcony or scaffold by air, provide overhead protection or hoarding and maintain exclusion zones at ground per the approved public protection arrangement, and lower waste by chute or crate — never dropped.
  10. 10Verify what is underfoot before loading it — treat skylights and sheeting as fragile by default, exclude or bridge suspect areas on load-spreading walkways, and obtain structural verification where deterioration is found, because the reason the membrane failed is often the reason the substrate is unsound.
  11. 11Separate occupants from the workface physically — locked access, hoarding, balcony doors secured by arrangement — install temporary protection before every break, and give affected units advance notification with agreed access windows and the building manager's contact live during work.
  12. 12Control substrate-preparation dust with on-tool H-class extraction or wet methods, plan respirable crystalline silica work per the Regulation with exposure assessed by a competent person, and seal occupant openings on the dust path with clearance cleaning before handback.
  13. 13Ensure all workers hold a current White Card (CPCCWHS1001) plus asbestos awareness training, with licensed asbestos removalists and assessors, trained fire watch and hot work permit issuers, competent height workers and licensed EWP operators as the task requires.
  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 whenever the system, substrate, occupancy or method changes, after any incident, and at minimum every 12 months.

Applicable Codes of Practice

Code of Practice: How to manage and control asbestos in the workplace⚖ Legally binding · 1 Jul 2026

The benchmark for identifying, assessing and controlling asbestos in pre-1990 membranes, mastics, bedding and coatings before any disturbance.

Code of Practice: How to safely remove asbestos⚖ Legally binding · 1 Jul 2026

The benchmark for licensed removal method, containment, decontamination, air monitoring and clearance where sampling confirms asbestos above the licensed thresholds.

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

The benchmark for edge protection, EWPs, harness work and fragile-substrate control at balconies, roof edges and facades on existing structures.

AS 4654 series — Waterproofing membranes for external above-ground use

The design and installation benchmark for the external membrane systems being stripped and reinstated on balconies, podiums, planters and roofs.

AS 3740 — Waterproofing of domestic wet areas

The benchmark for internal wet area rectification within the scope of the works.

AS/NZS 1891.1 and AS/NZS 1891.4 — Industrial fall-arrest systems and devices

Harness, lanyard and anchorage selection and use where edge protection cannot be provided on the existing structure.

High-Risk Construction Work triggered

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

Membrane strip-out and reinstatement are carried out at the unprotected perimeter of balconies, podiums, roofs and facades — often over public areas — and existing balustrades come off for terminations, with fragile and deteriorated substrates adding a fall-through path.

12
Construction work carried out in an area that may have a contaminated or flammable atmosphere

Solvent-based primers and adhesives applied in wrapped, hoarded or recessed balconies and in planter boxes build vapour toward its flammable range and toward the crew's exposure limits, and enclosed voids may meet the confined space definition.

Legal consequence

Remedial waterproofing and rectification on existing buildings is high risk construction work under section 291 of the Work Health and Safety Regulation 2025 (NSW), 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. Where pre-1990 materials are disturbed, the asbestos duties in Chapter 8 apply in full — the register, sampling and identification, the licensed-removal thresholds and the prohibition on uncontrolled disturbance — and asbestos is treated as a carcinogen with no safe exposure threshold, so its residual risk stays elevated even after controls. Part 4.4 requires the risk of a fall to be managed at every stage. A fall from height, a fire, an uncontrolled asbestos disturbance, or an injury to an occupant or member of the public 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 stripping failed membranes and reinstating balconies, podiums, planter boxes, roofs and wet areas on occupied buildings.
  • Building surveyors, remedial engineers and strata managers scoping and supervising rectification of leaking common property and lots.
  • Owners corporations and facilities managers commissioning defect and remediation works and needing to see the contractor's method before occupants are exposed to it.
  • Principal contractors coordinating occupant protection, hot work permits, asbestos clearance and public protection on a live building.
  • WHS managers and HSE advisors responsible for falls, hot work, asbestos and occupant-interface controls across a remedial portfolio.

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.
  • A document control table with editable fields for trade, document slug, version, date issued, review date, jurisdiction, prepared/reviewed/approved by, site and PCBU.
  • An activity scope section that fixes the boundary of the work — strip-out, substrate preparation, crack and joint rectification, torch- and cold-applied reinstatement, tiling interface and water testing on existing and occupied buildings.
  • A regulatory references section citing section 291, section 299 and section 302, the Chapter 8 asbestos duties, Part 4.4 falls, and the applicable Australian Standards and Codes of Practice.
  • A workers, roles and qualifications section covering the applicator, licensed asbestos removalist and assessor, fire watch, competent height worker, EWP operator, building manager and site supervisor.
  • A hazards table of 14 identified hazards with initial and residual risk ratings on a printed 5x5 matrix, each with controls ordered through the full hierarchy — eliminate, engineer, administrative, PPE.
  • The occupant-and-public control set that runs every hazard in two directions at once: containment and drop protection for the workface, and notification, separation and scheduling for the people the building keeps at its edge.
  • A PPE matrix mapping each task to the required equipment and Australian Standard, emergency procedures covering falls, cavity fire, asbestos disturbance, vapour exposure and water release into occupied units, and a worker sign-on table.
  • Microsoft Word (.docx) format, unbranded, with editable fields for PCBU, ABN, site, prepared by, reviewed by, approved by and review date.

Worked example

A remedial contractor is engaged to rectify a leaking third-floor balcony in a 1980s Sydney apartment block. The unit below has been reporting water stains for a year, so the strata committee wants it fixed fast, over a fortnight, with residents staying in place. The scope looks routine: lift the tiles, strip the failed membrane, re-prime, re-membrane and re-tile. Three things turn it from routine into high risk construction work. The balcony's balustrade has to come off for the upstand termination, which puts the applicator at an unprotected edge more than 2 metres above a courtyard residents walk through — so the SWMS requires temporary edge protection or a harness on an anchorage a competent person has actually verified, because the building came with no certified anchors and a balustrade post is not one. The bituminous membrane under the tiles predates 1990, so it is presumed to contain asbestos until a sample says otherwise — no grinding or dry stripping starts before the result, and if it is positive above the threshold a licensed removalist takes it under containment with clearance before the tilers return. And the specified primer is solvent-based, applied on a balcony the crew has shade-clothed against the weather — which turns it into an enclosed space where vapour builds toward its flammable range with an occupied bedroom on the other side of the glass, so ventilation, low-VOC selection where allowed, and exclusion of every ignition source apply. This SWMS names each of those triggers, rates them, and sets the controls in both directions — for the crew, and for the family still living behind the sliding door.

Related legislation

  • Work Health and Safety Act 2011 (NSW) — section 19 primary duty of care extending to occupants, visitors and the public below; 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) — Chapter 8 (asbestos): the register, sampling and identification, licensed-removal thresholds and the prohibition on uncontrolled disturbance of material likely to contain asbestos.
  • Work Health and Safety Regulation 2025 (NSW) — Part 4.4 (falls): the duty to manage the risk of a fall at balconies, roof edges, facades and penetrations at every stage of the work.
  • AS 4654 series (external waterproofing membranes), AS 3740 (domestic wet areas), AS 2865 (confined spaces) and AS/NZS 1891.1 and 1891.4 (fall-arrest systems).

Frequently asked questions

Does buying this SWMS make us compliant?

No. This is a documentation set — a professionally authored, editable SWMS that identifies the hazards of remedial waterproofing on occupied buildings and sets out controls to the WHS Regulation 2025 (NSW). Compliance is what you do on site: you must edit it to your actual building, membrane system, occupancy and access, consult your workers on it under section 47, use it to control the work, and review it under section 302 whenever the job changes or after an incident. A SWMS filed and never followed protects nobody. It is the starting framework, not a certificate.

Why is asbestos in the hazard table but not listed as a high risk construction work category?

Because the high risk construction work triggers for this document are the falls-over-2-metres work and the flammable-atmosphere work from solvents in enclosed balconies — those are the section 291 categories named in the breakdown. Asbestos is handled as its own hazard row and controlled through the Chapter 8 duties and the asbestos removal Code, which apply in full wherever pre-1990 material is present. It is a carcinogen with no safe exposure threshold, so its residual risk stays elevated even after controls — the register, sampling, licensed removal and clearance requirements are all in the document; they are just not framed as a section 291 category.

Our building is occupied. What does the SWMS actually add for the residents?

That is the core of this document. Every hazard is written with two audiences — the crew, and the occupants and public who did not sign on to the work. So the controls run in both directions: containment, screens and chutes so nothing leaves the workface by air; hoarding and exclusion zones for the footpath and courtyard below; notifications and agreed access windows for affected units; balcony doors secured and temporary protection installed before every break so an open edge or wet membrane is never left accessible to a resident or a child; and torch work kept to permit with a fire watch because a cavity fire on an occupied building is a building fire from the first minute.

Can we torch-apply the membrane, or do we have to use a cold system?

You can torch-apply where the specification allows it and the detail is safe for flame, but the SWMS makes flame-free systems — self-adhesive, liquid-applied or hot-air welded — the preferred method, and the default on any detail over or beside a cavity. On an occupied building the far side of a cavity is somebody's bedroom, and heat entering a junction can emerge as a fire hours after the crew has left. Where torch work does proceed it runs under a hot work permit, with combustibles cleared, heat barriers at junctions, and a fire watch during the work and for the full permit period after flame-off checking the cavities and the occupied side.

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 — remedial waterproofing and rectification on existing buildings involves a risk of a person falling more than 2 metres at balconies, roofs and facades, work in areas that may have a contaminated or flammable atmosphere from solvents and primers in enclosed spaces, disturbance of material likely to contain asbestos in pre-1990 membranes and mastics, and torch and hot works on occupied buildings (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