Refurbishing or Demolishing? Your Hazardous Materials Survey Obligations Explained

Planning a demolition or refurbishment in Queensland? When a hazardous materials survey is legally required, what it covers, and how to manage contractor risk.

Every refurbishment and demolition project carries a hidden inventory of risk built into the fabric of the building: asbestos in eaves and flooring, lead in old paint, synthetic mineral fibre in insulation. Disturb these materials without knowing they're there and a routine project becomes a health incident, a stop-work notice and a remediation bill. A hazardous materials survey finds the inventory before the demolition saw does — and for property and facilities managers, the legal duty often sits with you, not just the contractor.

When is a survey legally required?

The Work Health and Safety Regulation 2011 (Qld) is direct. Before demolition or refurbishment work begins, the person with management or control of the workplace must ensure all asbestos and ACM likely to be disturbed is identified by a competent person. That obligation is met in one of two ways:

  • By relying on a current asbestos register for the structure; or
  • Where there's no register — or it doesn't cover the work area — by inspecting the structure to determine whether asbestos or ACM is present before work starts.

In plain terms: a contractor must not commence demolition or refurbishment until the relevant materials have been identified. If your register doesn't cover the works, a survey is what makes the project lawful.

Two types of survey: know which you need

A management survey supports ongoing occupation and routine maintenance. It locates ACM that could be disturbed during normal use and underpins the asbestos register and management plan. It's non-intrusive by design.

A refurbishment or demolition survey is more intrusive and far more thorough. It's required wherever the building, or part of it, is to be upgraded, refurbished or demolished, and it actively looks for hazardous materials in places a management survey deliberately leaves alone - inside wall cavities, beneath floor finishes, above ceilings. Commissioning the wrong survey is a common, costly mistake: a management survey won't discharge your obligations ahead of a demolition.

What a good survey covers

A robust hazardous materials survey ahead of works typically identifies and assesses:

  • Asbestos and ACM, bonded and friable, with sampling and laboratory identification.
  • Lead-based paint and lead dust.
  • Synthetic mineral fibre (SMF) insulation.
  • Polychlorinated biphenyls (PCBs) in older electrical fittings.
  • Other regulated materials where relevant.

The deliverable is a survey report and an updated register the demolition or refurbishment contractor can use to plan safe removal and sequencing.

The removal rules that follow

Identification drives the controls. Once asbestos is found, the WHS Regulation sets clear thresholds for who may remove it:

  • Removing more than 10 square metres of non-friable (bonded) asbestos must be carried out by a business holding a Class A or Class B asbestos removal licence.
  • Removing friable (loosely bound) asbestos must be carried out by a business holding a Class A licence.
  • So far as is reasonably practicable, asbestos must be removed before demolition begins — and if it isn't, the duty holder must be able to show why removal wasn't reasonably practicable.

Knowing the quantities and types in advance lets you engage the right licensed removalist and price the works accurately, rather than discovering the problem mid-project.

Managing the contractor risk

It's tempting to treat hazardous materials as the contractor's problem. That's a mistake — as the party with management or control, you hold a duty to ensure identification happens before work starts. Practical steps:

  • Commission the refurbishment or demolition survey during planning, not after the contractor mobilises.
  • Provide the survey and register to every tendering contractor so pricing reflects the real scope.
  • Confirm the removalist holds the correct licence class for the material identified.
  • Keep clearance certificates and air monitoring records as evidence the controls worked.

How BBN helps

BBN Consulting conducts management and refurbishment/demolition surveys across Queensland through our asbestos and hazardous materials team — identifying the full range of hazardous building materials, sampling and assessing them, and delivering a contractor-ready report and register. Get in touch or call 0421 748 867.

FAQs

Do I need a survey if I already have an asbestos register?
If the register is current and covers the area being refurbished or demolished, it may be enough. Where it doesn't cover the work zone, a refurbishment or demolition survey is required before work starts.

What's the difference between a management and a demolition survey?
A management survey supports day-to-day occupation and is non-intrusive. A refurbishment or demolition survey is intrusive and locates hidden materials before upgrade or demolition works.

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