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The Asbestos Register – A cornerstone for managing asbestos
The asbestos register is the cornerstone to managing asbestos responsibly on site together with an Asbestos Management Plan (AMP).
Without an asbestos register, there is a very high risk of exposure to asbestos by accidental disturbance to anyone working on or near the asbestos containing material (ACM).
Drilling can be done in a commercial or domestic setting, and in both, people must be trained and aware of asbestos risks. Drilling should not be done without respiratory protective equipment (RPE) or personal protective equipment (PPE). For guidance refer to the Model Code of Practice How to manage and control asbestos in the workplace, and the SafeWork NSW Video 4 - Safe Handling and Controls (Drilling) Asbestos Safety for Tradies.
An asbestos register is a living document and must be kept current. Once asbestos has been identified on site it must be actively managed, including labelling and removal.
Legislation in each state and territory of Australia requires that the person conducting a business or undertaking (PCBU) must ensure, so far as is reasonably practicable, that all asbestos or ACM at the workplace is identified or assumed if inaccessible by a competent person (such as Greencap).
For the purpose of the regulations if asbestos is assumed at a workplace, it is taken to be identified at the workplace.
In 2022, SafeWork SA undertook a proactive campaign to measure compliance with Chapter 8 of the SA Work Health & Safety (WHS) Regulations across the asbestos industry. The audit included amongst other compliance issues whether an asbestos register existed, its currency and if it had been made available to asbestos removalist and workers.
This Risk Review does not cover imported goods, please read more about asbestos in imported goods here.
When are Asbestos Registers required and why are they needed?
Depending on the state or territory, an asbestos register is required for all workplaces constructed before 31 December 2003 (QLD before 31 Dec 1989) unless asbestos is likely to be present, and there is no cut-off date in Victoria.
Despite being a regulatory requirement for several decades now and hefty fines for an individual and businesses for not having an asbestos register, many workplaces do not have a register, or the register they do have in place is inadequate for the purposes of the works that are being undertaken. A common example of an inadequate register is when a management or compliance asbestos register is relied upon for demolition and refurbishment work.
An asbestos register is one of the key tools for managing asbestos on site. It documents all known asbestos areas and assumed-to-contain asbestos areas, and records areas that could not be accessed. It must be readily accessible on site and made available to anyone who intends to work on site. The register gives guidance on condition and frequency of reassessments and items to be labelled. It provides the foundation for the sites Asbestos Management Plan.
How long does an Asbestos Register last?
In addition to the ongoing vigilance in monitoring identified asbestos, in Victoria the validity of an asbestos register has a life that must not exceed five (5) years. The WHS regulations requires that the PCBU of a workplace where an asbestos register is kept must ensure that the register is reviewed and revised as necessary if and when the AMP is reviewed. The AMP must be reviewed at least once every five years.
Regardless of the jurisdiction, a crucial part of effective asbestos management is that the asbestos register must be kept up to date. This includes every time asbestos is removed, disturbed, damaged, sealed, labelled, enclosed or newly discovered at the workplace or if the controls have changed.
When a residential premises becomes a workplace, the PCBU/person with management or control must identify the asbestos before they commence work. If the asbestos is likely to be disturbed, depending on quantity and duration, it should be removed by a suitably trained person or Licensed Asbestos Removal Contractor (LARC) and lawfully disposed of.
What should an Asbestos Register include?
The asbestos register must include all asbestos under the management or control of the PCBU. This includes but is not limited to the building fabric, sealants, caulking, membranes, plant, equipment, lifts, escalators, electrical components pipes and pits and portable assets such as safes and pallet jacks. It should also reference any dusts and debris associated with current and historic asbestos on site.
The register should be written in a language that is easily understood and include as a minimum the following content:
- records of any asbestos or ACM identified or likely to be present from time to time
- date identified
- location, type and condition of the asbestos or ACM, or
- state that no asbestos or ACM is identified at the workplace if the person knows that no asbestos or ACM is identified or is likely to be present from time to time, at the workplace.
While the above content is the minimum information, is it useful to have items that could be mistaken for asbestos analysed (such as newer cement sheeting or gaskets) and reported together with photographs and marked up plans. Asbestos registers will often also include a risk assessment and control recommendations to support the audit findings.
Example of an asbestos register, and minimum requirements. Code of Practice 2021 P52.
Source: How to manage and control asbestos in the workplace - WHSQ
Who is required to prepare an Asbestos Register?
The PCBU with management or control has the responsibility to arrange for a competent person to prepare an asbestos register for those assets under their control. If you are a tenant, you are responsible for the assets you introduce.
The following list provides examples of people responsible for ensuring an asbestos register is prepared for what they are responsible for.
- Building owner
- Facility manager on behalf of the building owner (depending on contract)
- Principal contractor
- Builder / demolisher (for domestic and depending on contract).
What type of register is needed?
Depending on which state or territory you are in, there are a lot of names given to the different types of asbestos surveys including:
Walk though (minimal disturbance)
The Management, Compliance or Division 5 surveys are typically undertaken while the business is under normal operation and therefore limited access is available to areas such as beneath floor coverings, lift shafts, ceiling spaces and behind wall coverings and voids to name a few. In this type of register and survey a number of items or areas may be assumed to contain asbestos.
An asbestos survey is undertaken to identify and assess the risks associated with confirmed or assumed asbestos and includes recommendations for the controls required to adequately manage each situation and create an asbestos register for the site.
The asbestos register forms part of the report that is produced following a survey. This asbestos survey report must be read in its entirety to fully understand the context of the document and its limitations and exclusions.
Prior to any works such as demolition, refurbishment or maintenance, the management or compliance asbestos register document must be reviewed, read and understood.
There are always limitations to an asbestos register and therefore additional testing and investigations will be required to close these gaps before work commences. Further controlled investigation may also be required once demolition starts.
Failure to do this could lead to a preventable exposure to asbestos.
Who must the register be provided to?
There are dual responsibilities for asbestos registers. Firstly, the PCBU has a duty to ensure the asbestos register is readily accessible and provide it to any licenced asbestos removalist, tenant, health and safety representative and persons who intend to work on site. It also extends to the following:
a) PCBU who has carried out, carries out or intends to carry out works
b) PCBU who has required, requires, or intends to require work to be carried out at the workplace
The PCBU must also ensure that the register is understood by those workers who intend to work on site.
Equally, the parties listed above must not start work until they have reviewed the current register against the work they propose to undertake, and have implemented the appropriate controls to avoid disturbance of asbestos containing materials (ACM). If ACM is identified or assumed this will likely include further investigations and arranging for its removal (depending on contractual arrangements) prior to commencing work.
The tenants and persons who work or intend to work on the site have the same responsibility to pass this information on to their staff and workers.
A PCBU who carries out demolition or refurbishment at a workplace must obtain a copy of the asbestos register from the person with management or control of the workplace before the person commences the demolition or refurbishment. The person managing or in control of the workplace also has a duty to provide the register to the demolition contractor. If the register is inadequate for the proposed demolition or refurbishment, the PCBU undertaking the works should ensure the register is updated to reflect the inadequacies before they commence.
Asbestos is still prevalent across construction sites nationally
Non-managed asbestos increases ongoing costs
There are over 3000 products listed as containing asbestos. When asked “where do you find asbestos?”, tradespeople often answer “everywhere”. Each year, Greencap staff regularly find new and unusual uses or applications of asbestos in workplaces which is shared across the organisation.
Asbestos registers with no samples analysed are seen regularly. Non-managed asbestos can make it difficult to complete projects in a workplace, resulting in extra callouts and costs to the business. A register without supporting sample analysis may still be compliant, however, it makes ongoing asbestos and project management difficult for the PCBU.
Asbestos must be analysed by a NATA approved laboratory.
Greencap’s lab services table showing each offices laboratory capabilities
With regards to demolition and refurbishment works the register is only as good as the access and scope of proposed works, and the extent to which the PCBU allows the surveyor to intrusively investigate the building structure, fabric and plant.
A good intrusive survey will close the gaps and allow the proposed works to be quoted accurately (reducing the likelihood of variations) and undertaken without exposing workers to asbestos. Any areas that have been assumed to contain asbestos must be closed out prior to working on that item or in that area.
The advantage of well-prepared asbestos register - case study
Greencap undertook a significant intrusive audit for a 24-storey property in the Melbourne CBD out of hours with the assistance of a licenced asbestos removalist, knowing very little history of the site.
The survey accessed many column voids and cavities as well as the tenancy floors. With hundreds of samples and the findings from the intrusive audit the owner was able to redesign their work and avoiding any unnecessary exposures to asbestos during the project. While the survey at $55K appeared to be expensive in the short term, with this planning in the long-term it saved on unnecessary exposure of asbestos to construction workers and saved the client hundreds of thousands of dollars in variations, project delays and overruns.
Who should prepare the asbestos register?
The asbestos register should always be prepared by a competent person. A person with the skill and knowledge of the nature and type of asbestos, its locations, regulations and health risks. The company undertaking this work should be able to stand by the report.
Prior to engaging someone to undertake an asbestos survey to prepare an asbestos register, the person engaging the workers should consider and ensure that the people tasked to do the work have a proven track record in the type of survey being requested, such as domestic, high rise, power stations, rolling stock and more.
The regulations require that all asbestos is identified under the PCBU management or control including plant and equipment and that this information is readily available to anyone working, intending to work or who has worked at the workplace.
With this information ACM’s can be effectively managed to protect the public, staff and workers from inadvertently disturbing asbestos. The information obtained from a comprehensive asbestos register should also be used to ensure ACMs are labelled, monitored and assist with the preparation of an AMP, as well as working towards safe ACM removal.
When engaging a competent person, it is important that the company and the auditor can demonstrate their competencies with regards to the nature and type of your workplace and that both parties understand the limitations before commencing the survey. Limitations to the survey can include no plans available, locked doors, live electrical or plant and equipment, availability of site history and sampling expectations.
Greencap holds NATA accreditation under ISO/IEC 17020 (2012) for Hazardous Materials, Surveys. Greencap also has a national network of NATA accredited laboratories for fibre counting and bulk sample analysis and have Licenced Asbestos Assessors (LAAs) in every office.
Learn in depth about asbestos labelling and signage requirements and more in Greencap's Online Asbestos Awareness Training course
How Greencap Can Assist
Greencap has offices in all mainland states and territories of Australia and has been specialising in the area of asbestos for over 35 years.
Asbestos Management Plans
Greencap partners with building owners and managers to provide tailored, practical, cost-effective solutions like Asbestos Management Plans to provide security for assets and people.
To ensure that clients receive technical excellence and long-term value, Greencap operates under rigorous internal and externally accredited quality manual systems and technical procedures including ISO17020 (Inspection), ISO17025 (Laboratory Analysis) and ISO9001 (Quality).
Muddy Boots Asbestos Training
Greencap’s Muddy Boots Asbestos Training provides industry-leading asbestos training* that is customised to meet client requirements, policies and procedures. Courses can be delivered at Greencap training facilities or at your workplace, and include:
- Asbestos Awareness
- Asbestos Management Responsibilities
- Asbestos Management Plans
- Asbestos Handling (design for people working with less than 10 m2 of asbestos)
- Silica Awareness
NATA Accredited Laboratories
To provide asbestos identification and fibre counting services, Greencap has NATA-accredited laboratories in Sydney, Wollongong, Darwin, Melbourne and Adelaide, with an XRD machine in the Adelaide laboratory for mineral identification and specialised testing around vinyl floor tiles and silica/quartz.
Greencap has an exemption to import samples into Australia for the purpose of testing and analysis, enabling samples to be tested before the materials are shipped to Australia. Advice and sampling is available for builders, importers, architects, customs agents and clients prior to the materials being exported.
Additional Asbestos & Hazardous Materials Services
- Asbestos in soils
- Asbestos audits
- Asbestos compliance risk assessments
- Demolition and refurbishment risk assessments
- Clearance inspections and reporting
- Asbestos fibre air monitoring
- Preparation of asbestos removal specifications
- Project management and tendering services
- Due diligence assessment and reports
- A range of innovative and cost effective risk and contractor management tools
- Competent and Licensed Asbestos Assessors across Australia
For more information about how asbestos could impact your workplace or facility, and how Greencap can help deliver value to your business:
The information in this material is not intended to provide, and should not be relied upon, for legal or professional advice and is subject to change. This material provides general information only and does not take into account your particular circumstances. Before making any decisions, you should assess whether this material is appropriate for you and obtain legal advice tailored to you having regard to your particular needs and circumstances. Greencap Pty Ltd (Greencap), its officers, employees and agents believe that the information in this material and the sources on which the information is based (which may be sourced from third parties) are correct as at the date of publication. While every care has been taken in the preparation of this material, no warranty is given for its reliability or accuracy and no responsibility is accepted by Greencap, its officers, employees or agents. If this material contains links to third party websites, Greencap does not control and is not responsible for the information contained within these websites. None of these links imply Greencap’s support, endorsement or recommendation of any other company, product or service.
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