When should an asbestos register and management plan be reviewed?

I get this query many times when an annual review arises for an asbestos register and management plan at a workplace within Western Australia.

The National Occupational Health and Safety Commission (NOHSC) (2005), Code of Practice for the Management and Control of Asbestos in Workplaces [NOHSC:2018(2005)] is the legislative reference for managing asbestos within Western Australian workplaces.

Quoting from this code of practice from section 9.3.1.

Reviewing the register of ACM, including any risk assessments, should be reviewed every 12 months or earlier where: 

1. a risk assessment indicates the need for reassessment (see section 10.1); 
2. any ACM has been disturbed or removed. 

A visual inspection of identified ACM should be undertaken as part of any review.

This means an asbestos register needs to be reviewed annually. However, the review should be less if points 1 and 2 aren’t met.

The asbestos management plan should be reviewed whenever the register of ACM is reviewed (see above). These reviews should critically reassess all asbestos management processes and their effectiveness in: 

• preventing exposure to airborne asbestos fibres; 
•  controlling maintenance workers and contractors; 
•  highlighting the need for action to maintain or remove ACM; 
•  raising awareness among all workers; and 
•  maintaining the accuracy of the register of ACM.

There is some confusion in regards to the review period due to different guidelines for other Australian states that come under the Commonwealth WHS Act.

There is also the following advice listed on the Western Australian WorkSafe Website.

Asbestos management is based on appropriate management of risk, and some asbestos containing material (ACM) products are known to have a very long and stable effective life. A competent person may reasonably consider that ACM in very good condition and with low risk of disturbance requires less frequent review and assessment than the 12 months stated in the asbestos management Code of Practice. Reduction in review and assessment frequency must be supported by:

• the written recommendation of a competent person based on risk; and
• adequate systems at the workplace to report any damage, disturbance or work involving the ACM that occurs during the interval until the next risk assessment and register review.

In any event, the register of ACM and associated risk assessments must be reviewed at least every three years. 

This can be misconstrued as the review can be pushed out to 3 years.

If you read this and understand what Worksafe are advising is that a workplace that has the following scenario.

• All asbestos containing materials are in very good condition, this means the material is in pristine condition with no damage at all to the material, would need to be coated with a suitable sealant or fully encapsulated and there is no chance of further deterioration of that material in the next 3 years.
• Low risk of disturbance means any asbestos containing materials have no potential damage or disturbance from the following over the next 3 years.
  • exposure to weathering conditions including heating/cooling cycles, moisture ingress and winds
  • exposure to potential structural movements 
  • exposure to maintenance activities by contractors or others at the site
  • Damage from wear and tear such as contact from doors, vehicles, foot traffic and the movement of items.

Typically, a site that has just ACM gaskets in place that are in good condition are coated and in protected areas like a fire cupboard would meet this level of very good condition and low risk of disturbance. Buildings that have been constructed from 1995 onwards typically come into this review guidance up until 2004 after which there should be no buildings that were built with any asbestos containing materials.

A site that has had less than 3-4 annual reviews will typically always present new asbestos items that are less obvious or inaccessible and become apparent with each annual review as the competent person (consultant) gets to know and understand the site better.

To ensure the site meets a 3 year review period the following would need to be achieved on site:

• All asbestos onsite to be non-friable
• All ACM effectively labelled, and label integrity guaranteed for 3 years.
• Training systems proven to be in place for asbestos awareness for all contractors who encounter asbestos.
• The same responsible parties involved over the 3 years including property management, facility management, landlords and hazardous material consultant.
• A clear understanding from all responsible parties the hazard reporting process, site safety rules, emergency procedures, risk assessment process and other information crucial to effective management of asbestos at the specific workplace.
• Budgets for asbestos removal discussed as part of the objectives of the Commonwealth 

To ensure your workplace is meeting asbestos compliance and is assessed with the correct review period contact Opira for a discussion. We have asbestos consultants based in Brisbane, Perth and Melbourne to assist with all asbestos management requirements relevant for each state.

– Written by Mark Graham, January 2021.