SWMS - Licensed Asbestos Removalist (Class A / Class B)

What Is a SWMS - Licensed Asbestos Removalist (Class A / Class B)? A Safe Work Method Statement (SWMS) is a legal document that outlines the high-risk work activities carried out at a workplace. For asbestos removalists in Australia, this document is more than just paperwork. It acts as the primary safety plan for the job. When dealing with asbestos, the risks are severe and specific. The SWMS details how the work will be done safely, what equipment is needed, and how the team will manage the hazards associated with asbestos fibres. The distinction between Class A and Class B licenses is central to this document. A Class A license allows a removalist to work with friable asbestos. This material is dangerous because it can be crumbled or reduced to powder by hand pressure, releasing fibres easily. A Class B license covers non-friable or bonded asbestos. This material contains asbestos in a solid matrix, such as fibro cement sheets. The SWMS for a licensed asbestos removalist must address the specific requirements of the license class held. It is not a generic template. It must be site-specific and task-specific. Under the model Work Health and Safety (WHS) laws, asbestos removal is classified as High Risk Construction Work. This means the SWMS is mandatory before a single piece of material is touched. Regulation 300 of the WHS Regulations 2011 sets out the criteria for these statements. It requires the document to identify the work, the hazards, the control measures, and how those controls will be put into action. For professionals, the SWMS also serves to satisfy the requirement for an Asbestos Removal Control Plan (ARCP). Many Australian contractors combine these documents to their onsite safety management without duplicating information. ## When to Use This Document You must use this document whenever you perform licensed asbestos removal. The legal trigger depends on the amount and type of material involved. Class B Work

You need a SWMS for the removal of non-friable asbestos exceeding 10 square meters. If the area is under 10 square meters, non-licensed removal is permitted under specific circumstances. However, a risk assessment is still required. For a licensed removalist doing a job larger than 10 square meters, the SWMS is a non-negotiable legal requirement. Failure to have one on-site is a criminal offense. Class A Work Any amount of friable asbestos removal requires a Class A license and a SWMS. Friable asbestos is high-risk work by definition. It includes materials used for soundproofing, fireproofing, or insulation. The SWMS for Class A work is typically more detailed than for Class B because the risk of fibre release is much higher. Other Triggers You must also use this document if the removal work involves other high-risk activities alongside asbestos. For example, if you are removing an asbestos roof that requires working at heights of two meters or more, the SWMS must cover the fall risks as well. If you are using powered mobile plant, such as a scissor lift to reach the asbestos, that risk must be included too. The document must be prepared before work commences. Regulators expect to see the SWMS if they inspect the site. If you cannot produce it immediately, they can issue a Stop Work Order or levy significant fines. ## Key Sections and Required Elements A compliant SWMS cannot be a one-page checklist. It must be and address the specific reality of the job site. The following sections form the skeleton of a document. ### Section 1: Job Details and Scope of Work This section sets the scene. It defines exactly what the job entails. It must include the site address, the client name, and the specific date of work. Importantly, it must state the type of asbestos being removed. You need to identify if the work is Class A (friable) or Class B (bonded). You must also include the estimated quantity of asbestos in square meters. The license number of the supervising licensed removalist must be prominent here. This section should also describe the removal method. Will you be using wet methods? Will you be using a glove bag for pipe lagging? The scope must be clear so that anyone reading it knows exactly what boundaries the work covers. ### Section 2: Risk Assessment & Hazard Identification This is the core safety analysis. You must list every hazard that the specific task presents. For asbestos, the primary hazard is always exposure to respirable fibres. However, you must look beyond just the asbestos. If you are removing a fence, the hazard list might include manual handling injuries and heat stress. If you are removing a ceiling, you must include the risk of falling through the roof. Electrical hazards are common when removing roof sheeting near power lines. For Class A work, you must include hazards related to the setup of negative pressure enclosures and decontamination units. ### Section 3: Control Measures (Hierarchy of Controls) This section describes how you will manage the risks listed in the previous section. You must follow the Hierarchy of Controls. Elimination and Substitution These are difficult in asbestos removal because the hazard is the material itself. You generally cannot substitute the asbestos. However, you might eliminate a fall hazard by using scaffolding instead of a ladder. Engineering Controls These are physical controls. For Class B, this includes using HEPA vacuums and wet methods to suppress dust. For Class A, it involves setting up a fully sealed enclosure with negative pressure units to stop fibres escaping. It also includes the use of decontamination showers and transit zones. Administrative Controls These are work practices. It includes setting up exclusion zones with warning tape and signs. It involves restricting access to authorised personnel only. It also includes training records and induction processes for workers. PPE Personal Protective Equipment is the last line of defense. The SWMS must specify the exact PPE required. This usually includes disposable coveralls (Type 5), safety boots, and gloves. For respiratory protection, you must specify P3 respirators. The document should also note that workers must be fit-tested for these respirators to ensure they seal correctly. ### Section 4: Air Monitoring and Clearance This section verifies that the area is safe after the job is done. The requirements differ between license classes. For Class A (friable) removal, air monitoring is mandatory. You must engage an independent licensed asbestos hygienist. They will conduct background monitoring, exposure monitoring during the work, and clearance monitoring after the work. A Clearance Certificate is required before the enclosure can be taken down and the area re-occupied. For Class B work, a visual clearance is mandatory. A competent person or independent hygienist must inspect the area to ensure no dust or debris remains. Air monitoring is not always legally required for Class B unless the job is complex or if requested, but it is often included in the SWMS as a best practice measure. ### Section 5: Waste Transport and Disposal Asbestos waste cannot go to the tip. It is hazardous waste. This section must detail the procedures for wrapping and removing waste. The standard is double-bagging or wrapping in 200-micron polyethylene sheeting. The bags must be clearly labeled with warnings and the asbestos symbol. The SWMS must reference the consignment note process. You need a waste tracking form to transport asbestos waste to a licensed landfill. The document should state how the waste is transported, ensuring it is secured in a leak-proof vehicle or covered container to prevent spillage on the road. ## How to Write a SWMS - Licensed Asbestos Removalist (Class A / Class B) (Step by Step) Writing a SWMS is a collaborative process. It should not be done in isolation by a manager in an office. The people doing the work need to have input. ### Step 1: Gather Site Information Before you write, you need an asbestos register or a hazardous materials survey. If one does not exist, you must assume asbestos is present until testing proves otherwise. You need to visit the site to assess access, power availability for negative pressure units, and proximity to other buildings or air conditioning intakes. Take photos of the area. These will help you when describing the scope of work. ### Step 2: Consult with Workers Meet with your team. Ask them what they see as the biggest risks on this specific site. They often spot hazards that managers miss. For example, a worker might point out that the ground is uneven, creating a trip hazard while carrying heavy sheets. Document their input. This consultation is a legal requirement under the WHS Act. ### Step 3: Identify the Hazards List the hazards based on your site visit and consultation. Break them down by task. For example, "Setup Phase Hazards" might include manual handling of equipment. "Removal Phase Hazards" will include fibre release, cuts from sharp metal, and potential electric shock. ### Step 4: Select Control Measures Go through your hazard list and select controls. Be specific. Do not just write "Wear PPE." Write "Wear P3 half-face respirator, fit tested within the last 3 months." Instead of "Use wet methods," write "Apply water and surfactant via low-pressure spray until material is thoroughly saturated." If you are working on a Construction Contract Agreement, ensure your controls align with any contractual safety requirements. ### Step 5: Determine Emergency Procedures What happens if something goes wrong? You need a plan for emergencies. This includes first aid procedures for asbestos exposure. It includes a spill response kit for broken waste bags. You must list emergency contact numbers, including the Poisons Information Centre and local emergency services. If you are working in a confined space for Class A removal, you need specific rescue procedures. ### Step 6: Review and Sign Once drafted, review the document. Ensure it is easy to read. Print it out and bring it to the site. You must hold a "toolbox talk" before work starts. Read through the SWMS with the crew. Every worker must sign the document to acknowledge they understand the risks and controls. This is your proof of training and induction. ## Common Mistakes to Avoid Many businesses get fined because they treat the SWMS as a paperwork exercise rather than a living safety document. Avoid these common pitfalls. Using Generic Templates A generic SWMS is often worse than no SWMS at all. It shows you are not thinking about the specific risks. A regulator will look for a description of the actual site. If your SWMS says "removal of bathroom wall" but you are removing a warehouse roof, you will be in trouble. Set and Forget Failing to review the SWMS is a major issue. If conditions change on site, you must update the statement. If you start removing a wall and find unexpected pipe insulation behind it, stop work. Update the risk assessment and SWMS to include the new hazard. A disclaimer on the document stating it must be reviewed if conditions change helps legally, but you must actually do the review. Confusing JSA with SWMS While similar, a Job Safety Analysis (JSA) is not always a SWMS. In Victoria, regulators often refer to JSAs, but for High Risk Construction Work under the model laws, a SWMS meeting Regulation 300 is required. Ensure your document ticks all the legal boxes, not just the JSA boxes. Ignoring Electrical and Fall Hazards Focusing solely on asbestos is common. Inspectors often find SWMS that detail asbestos removal perfectly but fail to mention the risk of falling off the roof. Ensure you address all high-risk construction activities present in the scope. ## Legal Considerations (AU) The legal framework for asbestos removal is strict and carries heavy penalties. As a Person Conducting a Business or Undertaking (PCBU), you hold the primary duty of care. The WHS Act and Regulations Most states (NSW, QLD, SA, TAS, ACT, NT) use the model WHS laws. Under these laws, asbestos removal is High Risk Construction Work. Regulation 300 mandates the SWMS. Failure to prepare one is a criminal offense that can result in hefty fines for businesses and individuals. Safe Work Australia provides the Code of Practice: How to safely remove asbestos, which courts use as evidence of what is reasonably practicable. State Variations Victoria operates under the Occupational Health and Safety Act 2004 (Vic) and OHS Regulations 2017 (Vic). While they do not use the term "High Risk Construction Work" in the exact same way, Part 4.3 Division 9 requires a JSA or safety plan. Importantly, Regulation 439 in Victoria requires an Asbestos Removal Control Plan for licensed work. Western Australia uses the Occupational Safety and Health Act 1984 (WA) and requires a SWMS for high-risk work under the OSH Regulations 1996. You must ensure your document meets the specific legislation of the state you are working in. A document drafted for NSW might need slight adjustments to be fully compliant in a Victorian jurisdiction, although the safety principles remain the same. Duty to Consult The WHS Act requires you to consult with workers. If you write a SWMS without worker input, you are breaching Section 47 of the WHS Act. This makes the document less effective and you more vulnerable to prosecution if an incident occurs. Document Retention You must keep the SWMS for the duration of the project. If there is a notifiable incident, you must keep the SWMS for at least two years after the incident occurs. This is evidence during an investigation. ## Frequently Asked Questions (preview) Do I need a SWMS for non-licensed removal? Strictly speaking, no. The model WHS Regulations require a SWMS for High Risk Construction Work. Non-licensed removal (under 10sqm of non-friable asbestos) is not classified as High Risk Construction Work. However, you must still conduct a risk assessment. Many professionals choose to use a simplified SWMS or JSA anyway to ensure safety and demonstrate due diligence. Can I store the SWMS on a tablet? Yes. Safe Work Australia confirms that a SWMS can be kept in digital form. However, it must be easily accessible to workers at the job site. If the tablet battery dies or there is no signal, you must have a backup way to access the document. Who signs the SWMS? The Principal Contractor or PCBU representative must sign to verify the document. Most importantly, every worker engaged in the high-risk work must sign to acknowledge they have read and understood the methods. This usually happens during the pre-start toolbox talk. How often do I need to review it? You must review it whenever a change occurs at the workplace that creates a new risk., it is good practice to review it if the work is paused for a long period and then resumed, to ensure nothing on the site has changed in the interim. Is a Clearance Certificate part of the SWMS? No. The Clearance Certificate is a separate document issued by the hygienist after the work is done. However, the SWMS must reference the requirement for a clearance inspection as part of the "Close Out" or "Sign Off" process.