Plumbing SWMS: Ladders, Silica Dust, Asbestos and the Hazards Plumbers Really Face

Most plumbing jobs include at least one type of high risk construction work, so most plumbing jobs need a SWMS (Safe Work Method Statement) before work starts. Roofs and gutters, trenches, pits, gas lines and old asbestos pipes are everyday plumbing work. Here’s what a plumbing SWMS must cover, what we see go wrong on real jobs, and how the silica dust rules fit in.

When does plumbing work need a SWMS?

A SWMS is legally required when the job includes high risk construction work. Plumbing commonly includes:

  • a risk of a person falling more than 2 metres: roofs, gutters, downpipes, solar hot water and the ladder getting up there
  • trenches or shafts deeper than 1.5 metres for sewer, stormwater and water connections
  • work in or near a confined space, such as pits, tanks, manholes and septic systems
  • work on or near pressurised gas mains or piping, and near chemical, fuel or refrigerant lines
  • work on or near energised electrical installations or services, like hot water systems, under sinks and in wall cavities
  • work likely to involve disturbing asbestos, such as old asbestos cement pipes and fibro walls in bathrooms and laundries
  • working where powered mobile plant is moving, like excavators and mini loaders on trenching jobs, or next to a road in use for connections

It’s also the first document a WHS inspector asks for when they walk onto a site.

What your plumbing SWMS needs to cover

A good plumbing SWMS follows the actual steps of the job, what could go wrong at each step, and what you’ll do about it. These are the hazards we’d expect to see:

HazardControls to include
Ladders and roof accessLadder on firm, level ground at about a 4:1 angle, tied off at the top and extending 1 metre above the gutter. Three points of contact. Never use the gutter as a handhold. Use scaffold or a stair tower for longer roof jobs.
Falls from roofs and guttersEdge protection or scaffold first, then harness systems with rated anchors. Identify fragile sheets and skylights. No access to wet roofs.
Silica dust from cutting concrete, brick and tilesWet cutting or on-tool dust extraction with an H-class vacuum, then a fit-tested respirator. Silica training for workers. No dry sweeping, and keep others away from the dust.
AsbestosCheck before you cut: AC pipes, fibro sheeting, flue pipes and old floor coverings. Never use power tools on it. Stop work and get it identified if you’re unsure. Asbestos awareness for every worker, including apprentices.
Trenches and excavationBYDA (Before You Dig Australia) plans, locate and pothole services, support or bench trenches over 1.5 metres, keep spoil and plant back from the edge, and have safe access in and out.
Confined spacesAvoid entry where you can. If entry is needed: a permit, gas testing, ventilation, a standby person and a rescue plan.
Gas workIsolate and purge correctly, leak test, no ignition sources, ventilate, and keep a fire extinguisher on hand for hot work.
Hidden electrical wiringTreat wiring under sinks, in walls and near hot water systems as live. Isolate and test with an electrician, and use RCD-protected tools.
Sewage and wastewaterGloves and eye protection, hand washing before eating, cover cuts, and keep vaccinations up to date (talk to your GP about hepatitis A and tetanus).
Hot water systemsIsolate power or gas and water, release pressure, allow to cool to avoid scalds, and use two-person or mechanical lifting for heavy units.
Hot work (brazing, soldering)A hot work permit where needed, fire extinguisher, clearing combustibles, and checking for smouldering afterwards.

What we see go wrong on real plumbing jobs

  • A ladder that slipped as the plumber stepped off the roof. He grabbed the gutter to save himself and was hurt on the guttering. A ladder tied off at the top, extending a metre above the gutter, would have stayed put.
  • An exposed wire under a sink. While replacing pipework, a worker found it by touch: an electric shock and a quick trip to the emergency department.
  • Cutting concrete, tiles and brick with the wrong mask, or no mask at all, and no idea about the silica rules.
  • Apprentices who’ve never had asbestos awareness, working on older homes full of it.

Silica dust: the rules have changed

Plumbers cut a lot of concrete, brick, pavers and tiles, and all of them contain crystalline silica. Breathing in the fine dust causes silicosis and lung cancer, and the damage is permanent. The silica rules were tightened recently and they differ by state, which is why so many plumbers aren’t sure what applies to them.

  • Queensland, NSW and most other states (from 1 September 2024): any material with at least 1% crystalline silica is covered. If cutting, grinding or drilling it is high-risk processing, you must control the dust, train workers in silica risks, and provide respirators where the dust can’t be controlled any other way. For construction work, your SWMS can cover the silica controls instead of a separate silica plan.
  • Victoria: high-risk silica work needs a hazard control statement. If the job also has a SWMS that covers the same things, you don’t need a separate statement.
  • Engineered stone benchtops have been banned for new work across Australia since 1 July 2024.

Getting the mask right: a disposable dust mask from the hardware store usually isn’t enough. Use a respirator rated for the job, at least P2 for most cutting. Tight-fitting respirators need to be fit-tested and worn by someone who’s clean-shaven where the seal sits. Masks are the last line of defence: wet cutting and dust extraction come first.

Asbestos: don’t let apprentices learn the hard way

Any home or building from before 1990 can contain asbestos, and plumbers work right where it’s most common: asbestos cement pipes, fibro walls and eaves, flue pipes, and the adhesive and backing under old floor coverings in bathrooms and laundries.

  • Asbestos awareness for everyone, especially apprentices and new workers, before they work on older buildings.
  • If in doubt, assume it’s asbestos. Stop and get it identified before you cut, drill or break it.
  • No power tools, grinders or high-pressure water on asbestos.
  • Removing more than 10 square metres of non-friable asbestos, or any friable asbestos, needs a licensed asbestos removalist.

Make your SWMS work on site

  • Read it and talk it through with the crew before work starts, then everyone signs. It isn’t a “tick, flick and sign here” exercise.
  • Make it site-specific: this roof, this trench, this pit, this house’s age and materials.
  • Keep it on site, and review it when the job or the crew changes.
  • Give a copy to the builder before work starts. If there’s a principal contractor, it’s your responsibility to provide your SWMS before the high risk work begins, not just when asked.

How we can help

SWMS Done For You: $240. Tell us about the job, whether it’s maintenance, new homes, civil, commercial or gas, and we write a plumbing SWMS that fits your work, including your silica and asbestos controls. It arrives as a Word document within about 2 business days, ready to review, talk through, sign and take to site.

Running a busy plumbing business? The Projects One app lets you copy last job’s SWMS, update it for the new site on your phone, get the crew to sign on screen, and send it to the builder. Toolbox talks, inductions and plant pre-starts are in there too.

Not sure what you need? Talk to a real person

Wendy Bishop from Projects One Safety Online, sitting with a cup of coffee

Hi, I’m Wendy. We help plumbers in Queensland, NSW and Victoria keep up with rules that keep changing, like silica. Call me about your jobs and I’ll tell you what you actually need, even if that’s not our app.

Plumbing SWMS questions

Do I need a SWMS for every plumbing job?

You need one for any job that’s high risk construction work, such as roof work with a fall over 2 metres, trenches over 1.5 metres, confined spaces, gas lines or asbestos. A simple tap washer inside a house may not need one, but most plumbing jobs tick at least one box. You can reuse a SWMS, as long as you review it for each site. More on reusing a SWMS.

Do I need silica training to cut concrete or tiles?

If cutting, grinding or drilling materials with crystalline silica is high-risk processing, workers must be trained in silica risks in Queensland, NSW and most states (since 1 September 2024). Victoria has its own silica rules. The simplest answer is to control the dust, train your crew, and include it in your SWMS.

What mask do I need for cutting concrete and tiles?

Water suppression or dust extraction first. Then a respirator rated for silica, usually at least P2, that’s been fit-tested to the wearer. A loose disposable mask isn’t enough, and beards stop tight-fitting masks from sealing.

Can I cut asbestos cement pipe myself?

Only with the right controls, and never with power tools. Small amounts of non-friable asbestos (up to 10 square metres) can be removed without a licence if you follow the rules, but anything more, or anything friable, needs a licensed removalist. Your SWMS should cover how you’ll identify and handle it.

Does the builder’s SWMS cover my plumbing work?

No. The business doing the high risk work prepares the SWMS for that work. As the plumbing contractor, you’re responsible for your SWMS, and you must give a copy to the builder (principal contractor) before work starts.

Do the rules change between Queensland, NSW and Victoria?

The SWMS rules are almost the same in every state, but silica and some other rules differ, and Victoria uses its own OHS laws. A well-written SWMS works across states as long as it’s reviewed for each site. See our SWMS rules in each state.

Related guides

General information based on the model Work Health and Safety Regulations used in Queensland, NSW, WA and most states. Victoria uses its own OHS laws, but SWMS rules there are very similar. This isn’t legal advice, so check the detail for your state or ask us.

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