The Asbestos Register: What It Must Say, Who Keeps It, and Why It Is Not a Refurbishment Survey

At 7:20 on a Monday, a fit-out crew starts stripping level three of a 1978 office building in Adelaide. The client’s facilities manager has emailed the asbestos register, and it is reassuring: vinyl floor tiles in the kitchenette presumed to contain asbestos, fibre cement eaves on the roof, everything else “no asbestos identified in areas inspected”.

At 9:05 the electrician lifts a ceiling tile to run new cable and finds lagged pipework in the void. The register has a line about that void. It says “inaccessible, not inspected”. Nobody on site had read that far.

What is an asbestos register?

An asbestos register is a workplace document that records all asbestos and asbestos-containing material (ACM) that has been identified or assumed at a workplace: what it is, where it is, its condition, and when it was identified.[1]

Its purpose is narrow and specific. The register exists so that workers and others at the workplace do not accidentally disturb asbestos during normal use of the building. It is a day-to-day safety tool for occupants and maintenance trades, and that design purpose is exactly why it falls short once a builder arrives to pull the place apart.

Safe Work Australia’s guide to asbestos registers describes it as “a workplace safety management tool that records the location, type, condition and date of identification of all asbestos and asbestos containing materials at your workplace”.[2]

4,000

Estimated Australians who die each year from asbestos-related diseases, more than two decades after the final ban.

Asbestos and Silica Safety and Eradication Agency, 2025

Which workplaces need an asbestos register?

Under the model WHS Regulations, a person with management or control of a workplace must ensure an asbestos register is prepared and kept at the workplace.[1] The only exemption is narrow. A register is not required when all three of these are true:

• the workplace is a building constructed after 31 December 2003

• no asbestos has been identified at the workplace

• no asbestos is likely to be present from time to time

That date matters because the final, complete prohibition on asbestos in Australia took effect on 31 December 2003. The code notes that earlier bans were not absolute and that stockpiled or recycled materials may have been used, so buildings constructed before that date, and possibly after it, can contain asbestos.[1]

A pre-2004 building with no asbestos found still needs a register. In that case the register records that no asbestos has been identified. Queensland draws the line earlier for buildings: a register is not required there if the building was constructed after 31 December 1989 and no asbestos has been identified or is likely to be present.[4]

Residential premises are the other exception. The register duty does not apply to a house, but the moment a builder is engaged to refurbish or demolish one, it becomes that builder’s workplace and a different set of duties applies. More on that below.

Who is responsible for the asbestos register?

The person with management or control of the workplace. For a commercial building that is usually the owner or the facilities manager, not the head contractor who turns up for a fit-out.[1]

That does not leave the builder off the hook. Contractors who carry out or intend to carry out work at a workplace should obtain the current register and identify any asbestos under their own management or control. If they find something that is not on it, they should tell the person with management or control, who must then have a competent person identify it and update the register.[1]

When the building or business changes hands, the person relinquishing management or control must, so far as is reasonably practicable, give a copy of the register to whoever takes over.[1] A register that does not survive a sale is one way a builder ends up being told there is none.

What must an asbestos register record?

The model Code of Practice on managing asbestos sets out the mandatory content and a list of what a comprehensive register may also include.[1] The first column is the legal minimum. The second is what makes the register useful to a builder.

Inaccessible areas deserve the most attention. The regulations require that where part of a workplace is inaccessible and likely to contain asbestos, it must be assumed to contain asbestos until it is accessed and checked.[1] A register that lists a ceiling void as “not inspected” is telling you to assume, not reassuring you.

The Plexa asbestos register builder produces a structured register in this shape: material, location, form, condition, whether it is presumed or confirmed, accessibility, extent and review dates. It is a template, not an assessment. Identification still has to be done by a competent person.

How often must an asbestos register be reviewed?

The model regulations tie the review to events. The register must be reviewed and, where necessary, revised when:[1]

• the asbestos management plan is reviewed

• further asbestos or ACM is identified at the workplace

• asbestos is removed from, disturbed, sealed or enclosed at the workplace

• refurbishment or demolition work is to be undertaken

On top of those triggers, the model code says the register should be reviewed at least once every five years, with a visual inspection of the listed asbestos to check its condition.[1] Queensland and Victoria both state the five-year review as a firm requirement.[4][5] The asbestos management plan has its own mandatory review at least once every five years under the model regulations.[1]

The trigger that matters to builders is the last one on the list. A planned refurbishment is itself a reason the register must be reviewed before work starts.

Who is entitled to see the asbestos register?

The register must be kept at the workplace and be readily accessible to:[1]

• workers who have carried out, carry out or intend to carry out work at the workplace

• health and safety representatives for those workers

• any business that has carried out, carries out or intends to carry out work there

• any business that requires or intends to require work to be carried out there

Where a contractor’s work involves a risk of exposure to airborne asbestos, the person with management or control must give that contractor a copy.[1] A subcontractor who asks for the register is not being difficult. They are entitled to it.

Register, management plan or refurbishment survey: what is the difference?

These three documents get used interchangeably on site, and the confusion is where the risk sits.

“Asbestos registers might not identify all asbestos at the workplace or plant.”

Safe Work Australia, Model Code of Practice: How to manage and control asbestos in the workplace[1]

The management plan is the document that says what happens next. It must cover identification (including a reference to the register and the location of signs and labels), decisions about managing the asbestos and the reasons for them, procedures for incidents and emergencies, and consultation, information and training for workers.[1]

What must happen before refurbishment or demolition starts?

For a structure or plant built before 31 December 2003, the person with management or control must, before any demolition or refurbishment work:[1]

1. review the asbestos register, and revise it if it is inadequate for the proposed work

2. give a copy of the register to the business carrying out the work

3. ensure asbestos likely to be disturbed is identified and, so far as is reasonably practicable, removed before work starts

The builder has a matching obligation to obtain a copy of the register before starting. If there is no register at all, the builder must not carry out the work until a competent person has determined whether asbestos is present. Where the competent person is uncertain, the builder must assume it is.[1]

This is where a refurbishment survey earns its cost. The code describes demolition or refurbishment surveys as including extensive sampling of areas the works will disturb, and notes they reduce cost variations by making unexpected finds less likely.[1] In a fixed-price fit-out, an asbestos find in week three is a variation, a stop-work and a programme hit at the same time.

On residential jobs there is no register to rely on. The builder engaged to refurbish or demolish a house must identify and remove asbestos likely to be disturbed before work starts, and the code says a pre-demolition or pre-refurbishment survey should be done by a competent person.[1]

Disturbing asbestos is also one of the high risk construction work categories, so the SWMS for that activity needs to reflect what the register and survey found.

Who can remove asbestos, and when is a licence needed?

Once asbestos is identified and has to come out, the licence required depends on what it is and how much, as set out in the model Code of Practice on safely removing asbestos.[6]

Two jurisdictions tighten this. In the ACT, removing any asbestos requires a licence.[7] In Victoria, unlicensed removal of non-friable ACM is limited to 10 square metres and no more than one hour of removal work in a seven-day period.[5] Licensed removalists under the model regulations must also notify the regulator in writing at least five days before starting.[6]

10 m²

The most non-friable asbestos that can be removed without a licence under the model WHS Regulations, roughly a small bathroom. In the ACT, any removal needs a licence.

Safe Work Australia

What good looks like

The fit-outs that do not stop in week three are the ones where the asbestos information was treated as a project input, not a building document someone else owns.

• The current register is requested and read before the tender is priced, not on day one of site works

• Every “inaccessible” or “not inspected” entry is flagged and either surveyed or assumed to contain asbestos in the programme

• A refurbishment survey scoped to the actual works is in place before strip-out starts

• The SWMS and permits to work for affected areas reference the register and survey findings directly

• Workers and subcontractors can see the register on site, on the day, without asking the office

• New finds are reported back to the person with management or control so the register is updated, not just the builder’s own records

• Clearance certificates and removal records are filed where handover documentation will find them

The Australian context

The asbestos problem in Australian buildings is not historical. The Asbestos and Silica Safety and Eradication Agency advises that asbestos is present in around 1 in 3 Australian homes, that asbestos was used in more than 3,000 products, and that many homes built before 1990 contain it.[3]

Most states and territories apply the model WHS Regulations, but Victoria regulates asbestos under its own Occupational Health and Safety Regulations 2017, with its own compliance code. The core duties are similar, with differences in detail such as the one-hour limit on unlicensed removal.[5] Queensland’s 1989 cut-off for buildings is another.[4]

For a builder working across state lines, that means the pre-start asbestos check cannot be a single national checklist. It has to reflect the regulator where the building stands.

If something does go wrong during the works, the reporting and site preservation duties that may follow are covered in notifiable incidents in construction. The same pre-start discipline applies to crystalline silica, the subject of our post on silica dust in construction.

Where Plexa fits

Plexa does not identify asbestos. That is a job for a competent person. What it does is make sure the information a competent person produced reaches the people about to drill into a wall.

The asbestos register, the management plan and any refurbishment survey can be stored in Plexa’s document control, version-controlled so the site is always working from the current revision, and linked as reference documents to the project’s safety and risk management plans.

Workers’ inductions record the SWMS they have signed and the permits they hold, and permit-to-work workflows mean high-risk activities in affected areas are reviewed and approved before they start.

Photographs of what was found can be captured and attached on site, and an unexpected find can be raised as an observation with corrective actions tracked to close-out.

Back on level three in Adelaide, the difference is one step earlier. The team flags the “inaccessible, not inspected” line when the register is uploaded, the ceiling void is surveyed before strip-out, and the electrician lifts the tile already knowing what is there and who is licensed to remove it.

Frequently asked questions

What is an asbestos register? A document kept at a workplace that records all identified or assumed asbestos and asbestos-containing material, including its location, type, condition and the date it was identified. If none has been found, it records that no asbestos has been identified.[1]

Is an asbestos register a legal requirement in Australia? Yes, for workplaces covered by the WHS or OHS regulations. Under the model WHS Regulations, a register is required unless the building was constructed after 31 December 2003 and no asbestos has been identified or is likely to be present. In Queensland the building cut-off is 31 December 1989. Residential premises are not required to have one.[1][4]

Who is responsible for keeping the asbestos register? The person with management or control of the workplace, usually the building owner or facilities manager. Contractors should obtain the register before starting work and report any asbestos they find that is not on it.[1]

How often does an asbestos register need to be reviewed? Whenever the asbestos management plan is reviewed, further asbestos is found, asbestos is removed, disturbed, sealed or enclosed, or refurbishment or demolition is planned. The model code says it should also be reviewed at least every five years, and Queensland and Victoria state the five-year review as a requirement.[1][4][5]

Can a builder rely on the asbestos register before refurbishment? Not on its own. The register must be reviewed before refurbishment or demolition, and asbestos likely to be disturbed must be identified and, so far as reasonably practicable, removed before work starts. Safe Work Australia notes registers might not identify all asbestos, which is why refurbishment surveys are used.[1]

How much asbestos can be removed without a licence? Under the model WHS Regulations, up to 10 m² of non-friable asbestos by trained workers. Friable asbestos always requires a Class A licence. In the ACT any removal requires a licence, and Victoria also limits unlicensed removal to one hour in seven days.[5][6][7]

Related reading

What to do if an incident occurs during the works is covered in notifiable incidents in construction. The SWMS for asbestos work is explained in what is a SWMS. And the control that gates high-risk work in affected areas is the subject of permits to work.

If you want to see how asbestos registers, surveys and permits sit together on a live refurbishment project, book a 30-minute demo with the Plexa team.