Asbestos register

The model work health and safety regulations put the duty on the person with management or control of a workplace. They have to ensure an asbestos register is prepared and kept at the workplace, that it is maintained so the information in it stays up to date, and that it is readily accessible.

For each item of asbestos or asbestos containing material identified, the register records what it is, where it is, what type it is, and the condition it is in. Where asbestos has not been identified but is likely to be present, that has to be recorded too. If no asbestos is present at all, the register says so rather than simply not existing.

The register is not required where the workplace is a building constructed after the national ban took effect at the end of 2003 and no asbestos has been identified and none is likely to be present. That exemption is narrower than people assume, because it turns on the construction date of the building rather than on a belief that the building is clean.

Readily accessible is the part most often failed. A register sitting on a head office server, or in a folder nobody on site can find, does not meet the duty. Anyone about to disturb the fabric of a building needs to be able to read it before they start. On a construction project the register sits alongside the WHS management plan, and the trades need access to both.

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These are two separate documents with separate duties, and having one does not satisfy the other.

The asbestos register is the inventory. It says what asbestos is present, where it is and what condition it is in.

The asbestos management plan is the plan of action. The model regulations require a written plan for a workplace where asbestos has been identified, and it has to cover the identification of the asbestos with a link back to the register, signage and labelling, the decisions made about managing the asbestos and the reasons for them, procedures for dealing with incidents or emergencies involving asbestos, and the arrangements for workers carrying out work involving it. Like the register, it has to be kept up to date.

The split mirrors other hazard records: a safety data sheet tells you what a substance is, while the risk assessment and the method decide what is done about it. In practice the register answers where is it, and the management plan answers what are we doing about it. A site with a register and no plan has identified a hazard and documented no response to it, which is a common and easily found audit failure.

This is the most expensive misunderstanding on refurbishment work, and it catches experienced builders.

A register reflects asbestos that has been identified in a building in its current, occupied state. The inspection behind it is largely non intrusive, because nobody is going to open up walls and floors in a working building to look.

Before demolition or refurbishment, more is required. The model regulations impose specific duties to identify asbestos before that work begins, which means a more intrusive investigation that looks in the places an occupied building survey could not reach: wall cavities, under floor coverings, behind linings, in plant and in buried services.

So a clean register is not a clearance to start stripping out. Pricing a refurbishment on the strength of a register, then discovering bonded sheet behind a lining or lagging in a riser, converts into variations, programme delay, licensed removal and sometimes a notifiable exposure. On older building stock that risk belongs in the tender qualifications, not in the contingency.

The practical sequence is to obtain the existing register, commission the pre demolition or pre refurbishment identification appropriate to the scope, update the register with what is found, and reflect it in the management plan and the work method before anyone disturbs anything.

Treating the register as a one off document. Condition changes. Material that was sound and sealed five years ago may now be damaged, and the register is supposed to reflect the current state, which means it gets reviewed rather than archived.

Not making it available to the people who need it. Trades about to drill, cut or demolish are the audience. If the only copy is with the facilities manager, the duty is not met in any useful sense.

Assuming a post 2003 building is exempt by default. The exemption depends on the construction date and on no asbestos being identified or likely. Refurbishments to a newer building can still involve older imported materials or retained structure.

Confusing the register with clearance. A register is not a clearance certificate, and neither is it a survey for demolition or refurbishment.

Not updating it after removal. When asbestos is removed, the register should record that, along with the clearance, so the next team is not told to expect material that is no longer there.

Leaving it out of the handover. On a project that disturbs or removes asbestos, the updated register, the management plan, the removal records and the clearance certificates belong in the handover documentation.