Cladding Rectification (Combustible ACP) SWMS
Removal and replacement of non-compliant combustible aluminium composite panel (ACP) cladding — building access, fire-safe handling, waste classification, and façade restoration.
SWMS variants reference your state’s WHS legislation. Instant download after payment.
Cladding rectification involves the systematic removal of non-compliant aluminium composite panels (ACP) with polyethylene (PE) cores from existing building façades and replacement with compliant non-combustible cladding systems. This work is classified as high-risk construction work under WHS Regulation 2025 s291 because it combines work at height above two metres on building façades with handling of materials containing a combustible polymer core that presents fire and toxic decomposition hazards. The work typically occurs on occupied or partially occupied multi-storey residential and commercial buildings where façade access systems, hot work exclusions, and waste segregation must be coordinated with building occupants and adjoining property protection. A SWMS is mandatory before work commences and must be developed in consultation with workers under s49, signed by all persons performing the task, and kept available for inspection by the regulator for the duration of the works plus two years after a notifiable incident.
Hazards identified
7 hazards covered, sorted by priority.
Fatal impact injury, traumatic brain injury, or multiple fractures from falls exceeding two metres onto hard surfaces
Rapid flame spread across façade, structural fire, worker burns, and potential prosecution under Building Products Safety Act
Acute chemical pneumonitis, pulmonary oedema, cardiac arrhythmia, and long-term respiratory impairment requiring hospitalisation
Fatal head injury to pedestrians or workers below, civil liability, and EPA prosecution for unsafe demolition
Metal fume fever, chronic occupational asthma, and reduced lung function under prolonged exposure conditions
Acute lumbar disc injury, rotator cuff tears, crush injuries from panel movement, and lost-time injury claims
EPA prosecution for unlawful waste classification, contractor licence suspension, and remediation costs at landfill receival points
Control measures
Hierarchy-of-controls order: elimination → substitution → isolation → engineering → administrative → PPE.
- 1Elimination — Remove panels by unscrewing concealed fixings and lifting intact sheets off rails rather than cutting in-situ, eliminating ignition and dust hazards entirely where panel geometry permits.
- 2Elimination — Schedule all façade work outside building occupant hours and exclude the public from the fall zone using hard barricades extending two metres beyond the façade footprint.
- 3Substitution — Replace angle grinding with low-speed nibblers or shears with captured-blade guards where panels must be reduced in size for safe lowering to ground level.
- 4Substitution — Specify A2-s1,d0 non-combustible aluminium honeycomb or solid aluminium replacement panels tested to AS 1530.1 in lieu of any PE or FR-core composite product.
- 5Engineering — Install fully boarded perimeter scaffold with double handrails, mid-rail, kickboard, and containment screening complying with AS/NZS 1576 across the entire work face.
- 6Engineering — Use enclosed debris chutes or mechanical hoists for panel descent; prohibit dropping or sliding panels down the façade or via open scaffold lifts at any time.
- 7Administrative — Implement a hot work permit system prohibiting grinding, oxy cutting, or welding within six metres of stored or in-situ ACP until panels are confirmed removed and isolated.
- 8Administrative — Conduct daily pre-start briefings using this SWMS, verify scaffold handover certificates, wind readings below 40 km/h, and rescue plan readiness before height access.
- 9PPE — Issue full-body harnesses with twin shock-absorbing lanyards rated to AS/NZS 1891.1, fire-retardant cotton drill coveralls, and Class 5 cut-resistant gloves for panel handling.
- 10PPE — Provide P2 respiratory protection compliant with AS/NZS 1716 during any mechanical cutting, plus impact-rated safety glasses and Class 5 hearing protection during nibbler operations.
Applicable Codes of Practice
Mandates SWMS preparation, worker consultation, sign-on, and retention for any work at height above two metres or near fire risk on construction projects.
Specifies minimum harness, lanyard, and anchor requirements for façade access workers performing panel removal from scaffold or BMU positions.
Defines the non-combustibility test that replacement cladding must pass; identifies which existing ACP products are non-compliant and triggers rectification scope.
Sets the hierarchy of fall control selection used in this SWMS — eliminate, fall prevention, work positioning, fall arrest — for façade access decisions.
High-Risk Construction Work triggered
Panel removal and reinstatement occurs on building façades typically between 4 and 80 metres above ground, well exceeding the 2-metre threshold for every task.
Existing PE-core ACP presents a combustible material hazard; any cutting, grinding, or hot work near in-situ panels creates fire and rapid flame spread risk.
PCBUs must consult workers under s49, sign and retain the SWMS for the duration of works plus two years after any notifiable incident; breach penalties are substantial and indexed annually under the prevailing WHS schedule.
Who this is for
- →Façade rectification contractors on residential cladding projects
- →Principal contractors managing Tier 1 commercial remediation works
- →Scaffolders and BMU operators supporting cladding crews
- →Building surveyors auditing combustible cladding compliance
What you receive
- ✓Editable DOCX template — Microsoft Word compatible
- ✓State-specific WHS legislation schedule (NSW/VIC/QLD/SA/WA/TAS/NT/ACT)
- ✓Hazard register with risk ratings + hierarchy-of-control mapping
- ✓Worker sign-on register, pre-start checklist, and incident escalation flow
Worked example
On a 14-storey mixed-use residential rectification project, the cladding crew supervisor opens the pre-start brief at 6:45am on the loading bay deck of the perimeter scaffold. Wind speed is logged at 22 km/h, below the 40 km/h threshold listed in the administrative controls section of this SWMS. The supervisor walks the four-person crew through the hazard register, pausing on the dropped-object and PE-core ignition rows because today's task involves nibbling panels at level 9 directly above a partially active loading dock. A worker raises that the debris chute terminates one bay short of the planned cutting position; the supervisor consults the engineering control requiring enclosed descent and amends the work plan to relocate the cutting station two bays east, aligning with the chute and adding a second spotter at street level. All four workers and the scaffolder sign onto the SWMS on the tablet, including the amendment note. At 10:20am, light rain begins and a worker calls a stop because the harness anchor inspection tag for one bay is illegible. The supervisor refers to the AS/NZS 1891.1 PPE control, isolates that anchor, and redeploys the worker to the adjacent bay while the rigger replaces the tag. Work resumes after the SWMS amendment is re-signed, demonstrating the document operating as a live field control rather than a filing-cabinet record.
Related legislation
- WHS Act 2011 (model)
- WHS Regulation 2025
- Managing the Risk of Falls at Workplaces CoP