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Asbestos Containing Materials Removal Risk Assessment

Asbestos Containing Materials Removal Risk Assessment

  • • 100% Compliant with Australian WHS Acts & Regulations
  • • Fully Editable MS Word & PDF Formats Included
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Asbestos Containing Materials Removal Risk Assessment

Product Overview

Identify and control organisational risks associated with Asbestos Containing Materials Removal through a structured, management-level Risk Assessment that focuses on governance, planning, systems and oversight rather than task-by-task work instructions. This document supports executive Due Diligence under the WHS Act, helping to demonstrate effective WHS Risk Management and reduce organisational and personal liability exposure.

Risk Categories & Hazards Covered

This document assesses risks and outlines management controls for:

  • Governance & Duty of Care: Assessment of WHS responsibilities, asbestos management policy, officer due diligence and the overarching asbestos management framework across the organisation.
  • Asbestos Identification & Register Integrity: Management of asbestos surveys, quality of identification processes, maintenance of asbestos registers and communication of information to workers and contractors.
  • Planning, Scoping & Work Authorisation: Controls for pre-work scoping, risk-based prioritisation of asbestos removal, permit-to-work systems and formal authorisation of asbestos-related activities.
  • Licensing, Competency & Training: Verification of asbestos removal licences, competency requirements, refresher training, awareness programs and record-keeping for all personnel involved.
  • Asbestos Removal Control Planning: Development, review and approval of asbestos removal control plans, selection of removal methodologies and integration with broader WHS management systems.
  • Air Monitoring, Clearance & Health Surveillance: Protocols for appointing competent hygienists, air monitoring strategies, clearance inspections, and health surveillance programs for exposed workers.
  • Site Isolation, Access Control & Occupant Protection: Management of work area isolation, signage, barricading, entry controls and protection of building occupants, neighbours and the public.
  • Decontamination, Waste Management & Transport: Systems for decontamination facilities, bagging and labelling, temporary storage, transport arrangements and disposal at licensed facilities.
  • Plant, Equipment & Engineering Controls: Selection, inspection and maintenance of negative pressure units, HEPA vacuums, tools and other plant used for asbestos removal and containment.
  • PPE & Respiratory Protection Programs: Management of respiratory protection programs, fit testing, PPE selection, issue, maintenance and training in correct use and disposal.
  • Emergency Preparedness & Incident Management: Planning for unplanned asbestos disturbance, fibre release incidents, emergency response procedures and notification requirements.
  • Contractor Management & Supply Chain Controls: Prequalification, selection and monitoring of asbestos contractors, as well as procurement controls for services, consumables and waste transport providers.
  • Monitoring, Audit & Continuous Improvement: Internal audits, performance monitoring, corrective actions, consultation processes and periodic review of asbestos management arrangements.

Who is this for?

This Risk Assessment is designed for Business Owners, PCBU representatives, Facility Managers and Safety Managers responsible for planning, approving and overseeing Asbestos Containing Materials removal activities across their organisation or sites.

Hazards & Risks Covered

Hazard Risk Description
1. Governance, WHS Duty of Care and Asbestos Management Framework
  • • Absence of a documented asbestos management plan compliant with WHS Act 2011 and WHS Regulations (e.g. Part 8 Asbestos)
  • • Officers and PCBUs not fully understanding due diligence obligations relating to asbestos containing materials (ACM) removal and associated work (e.g. work on asbestos roofs, fences, pipe, soil, barns/outbuildings)
  • • Inadequate integration of asbestos risk controls into the broader WHS management system (policies, procedures, consultation, reporting, auditing)
  • • Failure to clearly define responsibilities between client/PCBU, principal contractor, licensed asbestos removalist and competent persons (e.g. hygienists, assessors, air monitoring providers)
  • • Poor consultation with workers, health and safety representatives (HSRs), subcontractors and affected persons about asbestos risks and controls
  • • No formal process to ensure work around asbestos (e.g. excavation in potentially contaminated soil, debris removal, textured ceilings, tree work near asbestos, painting asbestos roofs) is identified as asbestos-related work before it commences
  • • Insufficient oversight of non‑licensed asbestos related tasks (e.g. short‑term disturbance of non‑friable ACM within legal limits, old parts repair and restoration) leading to uncontrolled exposure
  • • Inadequate consideration of vulnerable persons (e.g. visitors, neighbouring properties, school children) potentially affected by ACM removal or asbestos‑contaminated soil works
2. Asbestos Identification, Registers and Survey Quality
  • • Incomplete or outdated asbestos registers for older buildings, barns, sheds and outbuildings, leading to unrecognised ACM during renovation, repair or demolition
  • • Failure to identify asbestos-containing products in less obvious locations such as tile adhesive, textured ceilings, gaskets in old machinery, pipe insulation, asbestos-backed vinyl, debris piles and asbestos-contaminated soil
  • • Inadequate sampling methodology or non‑competent persons undertaking asbestos surveys, resulting in false negatives and underestimation of risk
  • • No structured process to identify asbestos risk in external elements such as asbestos-based fences, soffits, eaves, cement sheeting on roofs and walls, ACM debris in gardens and asbestos risk trees (e.g. branches entangled with ACM or growing through contaminated soil)
  • • Poor documentation of asbestos condition (friable vs non‑friable, deterioration, damage), hampering the ability to prioritise removal or remedial works
  • • Failure to update the asbestos register after asbestos removal, encapsulation, repair, painting or disturbance during emergency works (e.g. storm damage, fire clean‑ups, excavation)
  • • Unclear or inaccurate labelling and signage for identified ACM, especially in plant rooms, old machinery, pipe chases, barns and concealed voids
3. Planning, Scoping and Work Authorisation for Asbestos Activities
  • • Inadequate pre‑planning of asbestos removal and asbestos-related work, leading to scope gaps and unplanned disturbance of ACM or asbestos-contaminated soil
  • • Failure to distinguish between licensed asbestos removal work and limited non‑licensed asbestos tasks, resulting in unlicensed persons undertaking high‑risk work
  • • Lack of formal work authorisation processes (e.g. permits to work, excavation permits) for activities with potential asbestos contact such as debris removal, excavation, scraping textured ceilings, work near asbestos-affected trees and repair of old plant with asbestos insulation
  • • Poor assessment of interaction between asbestos works and concurrent activities (e.g. other trades in the area, building occupants, public access routes)
  • • Inadequate planning for staged removal, including sequencing of roof, fence, pipe, soil and internal ACM removal, leading to cross‑contamination or inefficient isolation
  • • Failure to consider environmental and weather conditions (e.g. wind, rain) and their impact on airborne fibre spread during external works such as asbestos roof removal, painting asbestos roofs, or handling fences and soil
  • • No contingency plans for discovery of hidden or unexpected ACM during excavation, demolition or restoration of old parts and equipment
4. Licensing, Competency, Training and Awareness
  • • Use of asbestos removal contractors who do not hold the appropriate class of licence for friable or non‑friable removal, including soil remediation involving friable asbestos
  • • Supervisors and workers undertaking asbestos-related tasks (e.g. repairing old parts with asbestos, removing ACM tile adhesive, scraping textured ceilings, painting asbestos roofs) without mandated asbestos awareness or specific competency training
  • • Inadequate training for health and safety representatives, site managers and project engineers on asbestos risk management and legal duties
  • • Lack of training for plant operators and ground workers on asbestos exposure during excavation and handling of asbestos-contaminated soil or debris
  • • No refresher training or competency reassessment for licensed removal workers and supervisors, leading to outdated work practices
  • • Contractor induction processes that do not adequately cover site‑specific asbestos locations, control zones, air monitoring arrangements and emergency procedures
  • • Poor understanding by workers of cross‑contamination controls when moving between asbestos work areas (e.g. from soil remediation zones to clean areas, or from asbestos roof work to internal spaces)
5. Asbestos Removal Control Planning and Methodology
  • • Asbestos removal control plans (ARCPs) that are generic, incomplete or not tailored to specific ACM types such as asbestos roofs, fences, pipework, tile adhesive, textured ceilings, outbuilding linings, asbestos-contaminated soil or machinery insulation
  • • Failure to adequately consider friability, condition and access constraints when selecting removal methods and equipment, increasing risk of fibre release
  • • Inadequate planning for progressive cleaning, waste handling, and verification steps during staged removal of multiple ACM types on a site
  • • Over‑reliance on encapsulation or painting (e.g. painting asbestos roofs) without ongoing management plans or future removal strategies, leading to unmanaged deterioration
  • • Insufficient integration between the ARCP and the hygienist’s air monitoring strategy and clearance criteria
  • • No clear criteria for when work must cease due to damage, uncontrolled breakage or loss of engineering controls (e.g. negative pressure failure, enclosure breach)
6. Air Monitoring, Clearance and Health Surveillance Systems
  • • Lack of a systematic approach to asbestos air monitoring for high‑risk or licensed removal work, resulting in undetected elevated fibre levels
  • • Using non‑independent or non‑competent persons to conduct air monitoring and clearance inspections, creating conflicts of interest or technical deficiencies
  • • Failure to undertake background, control, personal and clearance monitoring where required, especially for friable removal and asbestos-contaminated soil remediation
  • • Inadequate interpretation and communication of air monitoring results to workers, management and affected persons (e.g. adjacent tenants, neighbours, schools)
  • • No structured process to respond to air monitoring exceedances, near misses or repeated elevated readings
  • • Absence of a system for identifying workers who require health surveillance due to significant asbestos exposure risk (e.g. repeat asbestos removal, extensive soil remediation, frequent work around deteriorated ACM)
  • • Poor record‑keeping of health surveillance, air monitoring and clearance certificates for future reference or regulatory review
7. Site Isolation, Access Control and Public/Occupant Protection
  • • Inadequate delineation and isolation of asbestos work areas from occupied zones, resulting in uncontrolled access by workers, building occupants or the public
  • • Poor management of access routes leading to cross‑contamination between asbestos removal zones (including soil remediation areas) and clean areas
  • • Insufficient signage and communication about asbestos works in and around residential complexes, public buildings, farms, barns and shared access ways
  • • Failure to consider impact on neighbouring properties during external works, such as roof removal, fence removal or remediation of asbestos-contaminated soil
  • • Uncontrolled movement of vehicles and plant through contaminated zones, tracking asbestos‑contaminated dust onto public roads or clean site areas
  • • Lack of systems to manage emergency egress through or around asbestos work areas without exposing occupants to airborne fibres
8. Decontamination, Waste Management and Transport Systems
  • • Inadequate decontamination facilities and procedures for workers, tools, plant and equipment involved in asbestos removal, soil remediation, debris removal and old parts restoration
  • • Improper packaging, labelling or storage of asbestos waste, increasing risk of fibre release and regulatory non‑compliance during transport or on‑site handling
  • • Unclear responsibilities and procedures for waste tracking from point of generation to final disposal at licensed facilities
  • • Cross‑contamination of reusable equipment, vehicles or storage areas due to poor segregation between clean and contaminated items
  • • Engagement of waste transporters who are not authorised or not adequately informed of the asbestos nature of the waste
  • • Inadequate record‑keeping for asbestos waste volumes, destinations and disposal receipts, hindering traceability and compliance demonstration
9. Plant, Equipment and Engineering Controls for Asbestos Work
  • • Use of unsuitable or poorly maintained plant and equipment (e.g. vacuums, negative air units, water suppression systems) leading to inadequate fibre control
  • • Failure to specify and enforce the use of H‑class (or equivalent) asbestos‑rated vacuum cleaners and filtration systems for cleaning and enclosure management
  • • Insufficient maintenance and testing of negative pressure units, HEPA filters and monitoring devices, resulting in undetected equipment failures
  • • Inappropriate selection or modification of excavation plant, hand tools or high‑pressure equipment that increases fibre release during work on ACM or asbestos-contaminated soil
  • • Lack of a formal system for inspection, testing and tagging of electrical equipment used in wet conditions during asbestos work (e.g. roof and external removal with water suppression)
  • • No structured process for assessing and approving new technologies or equipment (e.g. encapsulants, remote tools) used for asbestos tasks
10. Personal Protective Equipment and Respiratory Protection Programs
  • • Over‑reliance on PPE and respiratory protection in lieu of higher order controls, leading to systemic exposure risk if engineering or administrative controls fail
  • • Inadequate selection, fit, use and maintenance of respirators for workers involved in asbestos removal, soil remediation, debris clean‑up and work around deteriorated ACM
  • • Lack of a formal respiratory protection program, including fit testing, medical assessment and training, particularly for frequent or high‑risk tasks
  • • Poor management of disposable PPE (e.g. coveralls, gloves) and re‑usable items (e.g. half‑face respirators), leading to cross‑contamination between work areas
  • • Inconsistent enforcement of PPE requirements among workers, subcontractors and visitors entering or near asbestos work areas
11. Emergency Preparedness, Incident Management and Unplanned Asbestos Disturbance
  • • Lack of clear procedures to manage accidental disturbance of ACM or asbestos-contaminated soil during excavation, demolition, debris removal or tree work
  • • Inadequate response plans for enclosure failures, fibre release incidents, severe weather impacts on external asbestos works or vehicle accidents involving asbestos waste transport
  • • Poor communication and escalation pathways for asbestos emergencies, leading to delays in securing areas and engaging competent assessors
  • • Failure to investigate and learn from asbestos-related incidents, near misses and monitoring exceedances, resulting in repeated systemic issues
12. Contractor Management, Procurement and Supply Chain Controls
  • • Engaging asbestos removal contractors or consultants based on cost alone without adequate assessment of competence, licensing, safety performance or capacity
  • • Fragmented responsibilities between multiple PCBUs, subcontractors and consultants (e.g. removalists, hygienists, transporters, demolition contractors) leading to gaps in control implementation
  • • Procurement of unsuitable materials or products for encapsulation, sealing or painting of asbestos roofs and surfaces without assessing long‑term performance and compatibility
  • • Inconsistent requirements for asbestos management across different projects or regions, creating confusion among contractors and workers
13. Monitoring, Audit, Review and Continuous Improvement
  • • Absence of systematic monitoring and auditing of asbestos management practices, leading to drift from procedures over time
  • • Failure to integrate findings from air monitoring, incidents, complaints and regulator feedback into continuous improvement processes
  • • Inadequate management review of asbestos risk performance indicators and emerging issues
  • • No benchmarking against industry best practice or regulatory updates, resulting in outdated methods and controls

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Legislation & References

This document was researched and developed to align with:

  • Work Health and Safety Act 2011
  • Work Health and Safety Regulations 2017
  • Code of Practice: How to Manage and Control Asbestos in the Workplace: Guidance on asbestos management plans, registers and control measures.
  • Code of Practice: How to Safely Remove Asbestos: Requirements for planning, licensing, control measures and clearance procedures for asbestos removal.
  • AS/NZS ISO 31000:2018: Risk management — Guidelines.
  • AS 4964: Method for the qualitative identification of asbestos in bulk samples.
  • AS/NZS 1715: Selection, use and maintenance of respiratory protective equipment.
  • AS/NZS 1716: Respiratory protective devices — Performance and design requirements.
  • AS 2601: The demolition of structures — Relevant where asbestos-containing materials are present in demolition works.
  • AS/NZS ISO 45001:2018: Occupational health and safety management systems — Requirements with guidance for use.
Standard Risk Assessment Features (Click to Expand)
  • Comprehensive hazard identification for all activities
  • Risk rating matrix with likelihood and consequence analysis
  • Existing control measures evaluation
  • Residual risk assessment after controls
  • Hierarchy of controls recommendations
  • Action priority rankings
  • Review and monitoring requirements
  • Consultation and communication records
  • Legal compliance references
  • Sign-off and approval sections

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