News & Insights
Understanding Asbestos Surveys and Key Controls
Updated: April 2020
Despite being banned from use in Australia since 31st December 2003, asbestos is still a very topical issue in today’s workplaces. The continued raising of awareness is required to adequately mitigate the risk associated with this deadly product. This is exemplified by recent issues with imported products from overseas still containing asbestos and a general lack of understanding of asbestos registers and the requirements for intrusive or destructive testing prior to refurbishment.
Whilst many organisations have committed to ‘asbestos free’ workplaces, the lack of understanding of risk factors and the sheer cost and practicability of removal have been significant challenges for business and Government.
This Risk Review will make a distinction between the two common types of asbestos surveys and detail two key control measures for eliminating the risk of potential exposure to asbestos in the workplace.
Detecting Asbestos – Types of Asbestos Surveys
Depending on which state or territory you are in, there is a plethora of names given to the types of asbestos surveys including:
- Management Surveys
- Compliance Surveys
- Division 5 Surveys
- Destructive Surveys
- Intrusive Surveys
- Division 6 Surveys
- Refurbishment Surveys
The various WHS/OHS/OSH legislation in each state and territory require that asbestos surveys are undertaken in the identification, assessment and control of asbestos, and all state jurisdictions operate either under this requirement or under equivalent state-based regulations.
There is confusion at various levels as to what the difference is between these types of surveys, what their applications are, and when additional testing and investigations may be required.
The Victorian terminology of ‘Division 5’ and ‘Division 6’ arguably makes the clearest delineation between the types of surveys.
To simplify the distinction:
- A Division 5 (or ‘Compliance’) survey is prescribed to cover asbestos in the workplace under the conditions of normal building operations including ongoing maintenance (in situ) where no works are being undertaken.
- A Division 6 (or ‘Intrusive’) survey is prescribed to address the requirements for when planned renovation, upgrade, demolition and/or refurbishment works are proposed. There are other requirements, but this covers off on the general intent of the clauses.
Common Characteristics of a Compliance Survey or ‘Division 5’ Survey:
- Proactive – As required for all workplaces
- Non-Intrusive / Surface Materials only
- Low levels of destruction to building, plant, fixtures and fittings
- Low levels of accessibility due to occupants and ongoing operations
- Low disturbance potential to asbestos materials
- Need to assume asbestos is unassessed areas if presence is likely
- Generally inadequate for the purposes of renovations and upgrade works
A Division 5 Survey will often have a number of areas that are unable to be accessed. These may be height restricted or cannot to be accessed without major damage to building, for example ripping up carpet to see whether there are vinyl floor tiles underneath or putting holes in walls to see what pipework and materials are behind. End-users should be aware of these limitations when using surveys or registers for determining whether there is asbestos in the areas they are planning works. It is important to remember that the register may not be a fully ‘exhaustive’ list of all asbestos materials in the property.
The regulations require that if there is any uncertainty, the assumption should be made that the areas contain asbestos until it can be proven otherwise.
Common Characteristics of an Intrusive Survey or ‘Division 6’ Survey:
- Reactive – Required as a result of planned / current works
- Highly intrusive / Base building and internal plant materials
- Requirement for significant localised destruction to building, plant, fixtures and fittings
- High levels of accessibility required due to the expected disturbance of installed materials
- High disturbance potential to asbestos materials
- Greater access but may still need to assume the presence of asbestos is likely
- Adequate for the purposes of renovations and upgrade works if conducted properly
To undertake a full Division 6 audit requires the premises, or area in question, to be unoccupied. Consultants generally end up being quite ‘destructive’ as the name suggests – putting holes in walls or ripping up carpet to try and identify, so far as reasonably practicable, what asbestos exists within the property. To complicate things, often a client may request a survey in between a Division 5 and 6 in which the area may still be operational and/or occupied but slightly more intrusive investigations are required to assist with the project planning and budgeting process.
This may be further compounded by the motivation of the engaging party. Paying additional costs up-front to understand the risks and their extent may favour one party whereas the ability to price a lower initial cost and then claim variations for time/cost due to missing information may favour another.
Re-inspection requirements can also vary between states and the consultant used. Some scopes may be limited to re-inspection of previously identified items, meaning that if the previous survey missed something, it is not addressed in the subsequent re-inspection. A full re-survey of the property may not be required pending the quality of the previous survey, the areas not accessed and so on. A risk-based approach is recommended.
Users at all levels of the process need to be aware of these types of surveys and potential limitations that exist. Care should be taken to understand areas that may not have been accessed or assessed and identify where further investigations are required. Having an ‘unexpected finds’ procedure as part of the Asbestos Management Plan for the property is also critical. An Asbestos Management Plan for each property is required under the various state based legislation with a requirement to be kept up to date.
The PCBU must clearly indicate the presence and location of known and assumed asbestos. This is usually done by labelling.
Having as much of this information up front prior to project commencement is essential. An assessment of the adequacy of the existing register against the planned works and then undertaking further investigations (where required) to obtain that extra level of detail and information can prove critical in avoiding project delays and expensive variations due to unexpected finds and/or removals required in relation to asbestos.
Case Study: Currong Public Housing – ACT
The 2015 Currong Public Housing demolition project saw costs blow out to more than double the original contract price for a second time. There was a failure to identify and understand the extent of asbestos materials present. The then current demolition audit was inadequate as many areas not accessed were recorded as free from asbestos materials and these areas could have been reasonably assumed to contain asbestos materials.
An adequately thorough understanding of the asbestos materials in construction are required to plan demolition and refurbishment projects properly.
Greencap were engaged on this project in late 2015 to review the original report for the site. Areas previously not accessed were re-assessed as assumed to contain asbestos materials. A relatively inexpensive sampling program confirmed these assumptions to be correct. Asbestos found embedded in the concrete walls throughout the site was not considered in an earlier report.
The additional findings from the more considered, comprehensive and intrusive survey saw demolition costs escalate from an already revised $6.25 million price tag (originally $3 million) to an expected $14 million.
This project is a timely reminder of the importance of conducting an in-depth survey at the start of a project, with assumptions on inaccessible areas made, which can save clients significant time and money in the long run.
This particular outcome was inevitable without adequate asbestos and hazardous materials assessments being conducted at all phases of a property’s lifecycle. The situation could have been worse if asbestos containing building materials were allowed to be demolished without controls; putting people, the project and the environment at risk.
A detailed understanding of the implications of asbestos materials, construction and project work is critical to managing the risk regardless of the type of assessment being conducted.
Key Control Measures
Whether it be pre-existing or newly imported asbestos materials, these products continue to cause problems for normal occupation, ongoing maintenance works, and demolition and refurbishment projects – costing time and money and presenting significant health implications.
These problems can be relatively easy to eliminate if expert services are engaged to partner in these processes by closing the gaps in the survey before work commences in an area where there is uncertainty and labelling both the known and assumed asbestos items as well as the areas not accessed. Early detection of asbestos is critical to managing the risk, whether at procurement and/or survey and testing phases to prevent unexpected finds and unnecessary worker exposure, to a detailed understanding of the implications of asbestos materials, construction and project work is critical to managing the risk regardless of the type of assessment being conducted.
These common problems highlight the importance of two key control measures in attempting to eliminate the risk of potential exposure to asbestos in the workplace:
Asbestos Management Plans
As required under Regulation 429 of the harmonised Work Health and Safety Regulations, a written Asbestos Management Plan (AMP) is required to be established, adopted and maintained up to date, by building owners and / or managers wherever asbestos is known or assumed to be present in a workplace. All state/territory jurisdictions operate under this requirement or equivalent.
An asbestos management plan is the key tool for property owners and business managers for use in their regulatory obligations to identify, assess and control the risks associated with asbestos but unfortunately often overlooked. This practical solution, tailored properly to the client’s needs would have been adequate in foreseeing the issues, preparing properly for situations and occurrences and ultimately saving many problems for owners, managers, occupants, contractors and the public.
An AMP must include information about:
- Persons responsible for managing the asbestos risk
- Known asbestos materials identified and/or assumed
- Consultation and decisions regarding the management of the known asbestos
- Procedures for works, incidents, emergencies, and health monitoring involving asbestos
- Identification of workers, contractors, tenants and other persons effected by these activities
- Requirements for labelling, warning signage, notifications and inductions
- Working safely around asbestos
Asbestos Awareness Training
Regulations require that a person conducting a business or undertaking must ensure that all of their workers who they reasonably believe will work with asbestos or asbestos containing materials have received asbestos awareness training. These workers include construction workers as well as a number of other workers in occupations. Training must be given to the same people under other jurisdictions in Australia. Clause 445 of the Harmonised Work Health and Safety Regulations require that workers be trained about asbestos and that records are kept to confirm such training, Clauses 434 also covers naturally occurring asbestos.
The ACT Work Health and Safety Regulation 2011 requires that a person conducting a business or undertaking must ensure that all of their workers who they reasonably believe will work with asbestos or asbestos containing materials are trained in 10675NAT – Course in Asbestos Awareness.
Greencap offer face to face asbestos awareness training and provide an online offering. Trainers have a wealth of experience and can customise courses to meet the needs and operational requirements of your business.
Proper training is required to be provided by building owners and/or managers wherever asbestos is known or assumed to be present in a workplace. Similar to the case with AMPs and other obligations, all state/territory jurisdictions either operate under this requirement or equivalent.
Having managers, workers and contractors (where required) adequately trained and aware is another key requirement for the proper management of asbestos materials and is also required to be conducted if needed under a well-considered AMP. Trained people are empowered to understand the presence the nature of the risk and is thus a key element in the hierarchy of controls.
Having increased awareness at all levels of management and phases of the project cycle is critical to effectively reducing risk.
Asbestos Awareness Training should include information about:
- The nature of the naturally occurring asbestos mineral
- The health risks posed by exposure to asbestos fibres
- The common uses for and likely occurrences for asbestos in buildings
- The asbestos materials known to be present at their workplace and at similar workplaces
- Identification, assessment and management requirements for known asbestos
- How to interpret and understand an Asbestos Register or Management Plan
- Health monitoring systems and requirements for themselves and other workers
How Greencap Can Assist
Greencap has offices in all mainland state 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.
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