Asbestos remains one of the most significant occupational health and safety concerns facing commercial property owners and managers in Australia. Despite a national ban on the manufacture, use, and importation of asbestos-containing materials (ACMs) in 2003, an estimated one-third of Australia’s existing building stock still contains asbestos in some form. For those responsible for managing commercial premises, whether office buildings, industrial facilities, retail complexes, or public infrastructure, understanding the nature and purpose of asbestos audits is not merely advisable; it is a legal imperative.
Defining the Asbestos Audit
An asbestos audit is a systematic inspection of a building or structure, conducted by a qualified competent person, to identify the presence, location, condition, and extent of any asbestos-containing materials within the premises. The term is used broadly across the industry but encompasses several distinct assessment types, each serving a specific regulatory and operational purpose.
The audit process involves a visual inspection of accessible building components, review of existing documentation, and collection of samples when ACMs are suspected but not confirmed. Laboratory analysis of samples is then conducted to definitively determine whether asbestos fibres are present (chrysotile, amosite, crocidolite, tremolite, actinolite, anthrophyllite) and the material type.
Why Commercial Properties Require Asbestos Audits
The legal framework governing asbestos management in Australian workplaces is primarily established under the Work Health and Safety Act 2011 and the Work Health and Safety Regulation 2011, with corresponding state and territory legislation. Under these instruments, persons conducting a business or undertaking (PCBUs) have a duty to manage asbestos-related risks in the workplace, which fundamentally begins with determining whether ACMs are present.
For commercial property owners and managers, this obligation is not optional. Failure to conduct an appropriate audit and maintain an accurate asbestos register can result in significant regulatory penalties, civil liability, and, most critically, exposure of workers, tenants, and contractors to asbestos fibres, with potentially fatal health consequences including mesothelioma, asbestosis, and lung cancer.
Types of Asbestos Audits
There are two principal categories of asbestos audit surveys relevant to commercial property management:
- Asbestos Management Survey: Designed for properties in normal use and occupation, this survey identifies the presence and condition of ACMs that could be disturbed during routine maintenance and day-to-day activities. It is the baseline audit required to produce or update an asbestos register.
- Refurbishment and Demolition Survey: Required prior to any refurbishment, renovation, or demolition works. This is a more intrusive inspection that seeks to locate all ACMs in areas to be disturbed, including within the building fabric. It is essential for contractor safety planning and regulatory compliance prior to the commencement of works.
In addition, the Work Health and Safety Regulation 2011 imposes specific audit requirements for particular categories of commercial premises, including those engaged in specific industries or built within defined timeframes. This is discussed separately in our guide to Division 6 asbestos audits.
The Audit Process: What to Expect
A professional asbestos audit for a commercial property typically proceeds through the following stages:
- Pre-audit documentation review: The auditor will review any existing asbestos register, building plans, maintenance records, and prior inspection reports.
- Site inspection: A systematic visual inspection of all accessible areas is conducted, including plant rooms, roof spaces, service ducts, external cladding, and internal finishes.
- Sampling and laboratory analysis: Where materials cannot be positively identified as non-ACM by visual inspection alone, bulk samples are collected and submitted for analysis using polarised light microscopy (PLM) or in some cases scanning electron microscopy (SEM) or transmission electron microscopy (TEM).
- Risk assessment: Each identified ACM is assessed for its condition, friability, and likelihood of disturbance, generating a risk priority rating.
- Reporting: A comprehensive written report is produced, forming the basis of or an update to the asbestos register.
Who Is Qualified to Conduct an Asbestos Audit?
Under Australian WHS legislation, asbestos assessments must be carried out by a competent person, defined as an individual who has acquired, through training, qualification, or experience, the knowledge and skills to carry out the task. For licensed asbestos assessment work, the auditor must be competent or hold the relevant licence issued under the Work Health and Safety Act 2011 or Occupational Health and Safety Act 2004.
It is essential that commercial property managers engage only accredited, licensed auditors with demonstrated experience in commercial environments. The complexity of commercial building systems, including HVAC, fire protection, and structural elements, demands expertise that extends well beyond residential inspection practice.
Maintaining Compliance After the Audit
An asbestos audit is not a one-time event. The asbestos register produced as a result of an audit must be reviewed and updated whenever new information comes to light, whenever works are carried out that may affect ACMs, and, at a minimum, on a regular basis as determined by the site risk assessment. Where ACMs are identified in poor condition or in locations likely to be disturbed, remediation or removal by a licensed asbestos removalist must be arranged.
Commercial property managers are also obligated to ensure that the asbestos register is readily accessible to workers, contractors, and emergency services, and that it is provided to any person who may be involved in work that could disturb identified ACMs.
To arrange an asbestos audit or management survey for your property or portfolio, contact our team today for a tailored consultation and obligation-free quote.