This fact sheet provides advice to builders, contractors, sub-contractors and others involved in the handling, transport and disposal or recycling of combustible cladding waste materials.
Cladding waste is the external wall system, cladding and other materials removed from a building as part of cladding rectification works. Combustible cladding waste is managed as industrial waste.
The Victorian Government supports the safe recycling of combustible cladding waste in Victoria. The government expects that at all stages (removal, storage, transport, recycling and disposal) the cladding waste is managed in accordance with relevant State and Commonwealth laws, including but not limited to Victoria’s environment protection and occupational health and safety laws.
What products are classified as combustible cladding?
There are two types of combustible cladding that may pose a risk to building occupants and the community more broadly. These are:
- Aluminium composite panels (commonly referred to as ACP)
- Expanded polystyrene (commonly referred to as EPS).
What is the risk of these combustible cladding products?
In the event of a fire, these materials may increase the rate at which the fire spreads, posing an increased risk to building occupants, firefighters and other first responders and those in the immediate vicinity of the building including neighbours.
What are the requirements of contractors removing cladding?
Cladding removal contractors should ensure that risks caused by the removal of cladding waste are eliminated so far as reasonably practicable and managed effectively where it is not reasonably practicable to eliminate the risk. Long-term storage and stockpiling of cladding waste should be avoided where possible due to its combustibility.
Contractors removing cladding from buildings should ensure that waste is appropriately stored in skip bins as a temporary storage measure, prior to transporting it to an appropriately permissioned industrial waste receival facility.
The building contractor engaging the cladding removal contractor should keep record of the following:
- date, name and contact details of the cladding removal contractor
- date, name and contact details of the waste transporter
- amount of cladding removed (volume or weight)
- Details of industrial waste receivers or industrial waste recycling facilities.
Where cladding waste cannot be transported off site promptly after removal, it should be stored in accordance with Guideline 1667.3 Management and storage of combustible recyclable and waste materials which is available from Environment Protection Authority Victoria (EPA).
It is important that any person or organisation involved in the storage of cladding materials becomes familiar with this Guideline.
What are the requirements for transporting cladding waste?
Transporters of cladding waste and other materials should ensure that it is delivered to premises licensed or permitted to receive it. It is advisable to transport cladding waste in a horizontal position (as opposed to a vertical position) to avoid any possible spontaneous combustion of the materials.
The transporter of cladding waste should ensure the following records are kept and submitted to the contracted builder to meet the requirements of Cladding Safety Victoria, who may ask for these records at any time:
- receipt of location of waste including the date the waste was received and name of company receiving the waste
- name of waste transporter
- contact details of contracted builder
- amount of cladding transported (volume or weight)
- details of industrial waste receivers or industrial waste recycling facilities.
Who can accept cladding waste?
Only facilities that are permissioned by EPA to accept industrial waste can accept cladding waste.
A receiver of cladding waste should ensure the following records are kept and submitted to the contracted builder. Cladding Safety Victoria may require this information at any time, so it is crucial all documentation is kept.
- Industrial waste receival facility details including company name and date delivered.
- Contact details of the waste transporter.
- Amount of cladding received (volume or weight).
What laws apply?
The Environment Protection Act 2017 (the EP Act), as significantly amended by the Environment Protection Amendment Act 2018 and other Acts, came into effect on 1 July 2021.
A key feature of the EP Act is the general environmental duty (GED), which requires all Victorians to understand the risks of their activities to human health and the environment, and to undertake reasonably practical steps to eliminate or otherwise reduce those risks.
If you are removing, handling or disposing of cladding, you need to understand your obligations under the GED and to ensure that transporters and facilities accepting cladding waste have the appropriate permits/licences to accept this waste. Please check the EPA’s website for updates and guidance about these legislative requirements.
Under the Occupational Health and Safety Act 2004 (Vic) (OHS Act), and associated regulations, duty holders such as employers, self-employed people and those with management or control of a workplace have obligations relating to the safety of employees and others. For example:
- employers must provide and maintain a safe working environment without risk to health, so far as is reasonably practicable.
- employers and self-employed people must ensure, so far as is reasonably practicable, that others are not exposed to risks to their health or safety arising from business conduct.
There are also specific obligations relating to construction work, including work involving the complete or partial demolition of any building or structure. WorkSafe Victoria has a range of guidance materials to assist duty holders understand and meet their OHS obligations.
Where can I find more information?
- For general guidance on environmental requirements, including asbestos waste, please refer to Environment Protection Authority Victoria’s website.
- For general guidance on employer duties to provide and maintain a safe workplace, including working at heights safely, demolition and asbestos removal compliance requirements, please refer to WorkSafe Victoria’s website.
- For more information about Cladding Safety Victoria please visit our website.
- For more information about recycling construction and demolition materials.
- For information about managing asbestos waste and asbestos transport and disposal.
- For more information about management and storage of combustible recyclable and waste materials.
You can also download a PDF version of the Fact Sheet:
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