Asbestos & Hazardous Material Surveys Before Major Commercial Demolition or Refurbishment: What Developers Must Know
Prepared by Confluence Environmental — independent asbestos and hazardous materials consultants working with developers, builders and project teams across NSW, including Central Coast, Lake Macquarie and Newcastle.
Before any major demolition or refurbishment in a commercial building, the identification and management of asbestos and other hazardous materials are not just “best practice” — they are statutory obligations. Failure to properly assess and report on these hazards can lead to work stoppages, regulatory action, project delays and significant cost impacts.
This guide explains the role of asbestos and hazardous material surveys in commercial projects, why they matter, when they are required, and how a structured approach protects both people and projects.
Why Asbestos & Hazardous Materials Matter in Commercial Buildings
Many commercial buildings constructed prior to the late 1990s contain asbestos-containing materials (ACMs). These can be present in:
- Suspended ceilings and ceiling tiles
- Wall linings and partitioning
- Fire doors and insulation
- Floor tiles and sheet vinyl
- Ductwork, HVAC components
- Adhesives, mastics and sealants
But asbestos is not the only hazard. Commercial properties may also contain:
- Lead-based paint
- Polychlorinated biphenyls (PCBs)
- Ozone depleting substances (ODS) in older chillers or insulation
- Synthetic mineral fibres (SMF)
- Chemical storage residues
These materials can pose risk to workers and occupants if disturbed, and many are regulated under work health and safety (WHS) law, planning approvals and environmental controls. Understanding asbestos risk in older commercial buildings is critical for safe project planning and regulatory compliance.
What a Hazardous Material Survey Is — and Why It’s Not Optional
A hazardous material survey is a systematic, documented investigation to identify the presence, type and condition of hazardous building materials prior to demolition or intrusive works.
This survey is not a “nice to have” — it is a legal and operational necessity because:
- WHS legislation requires duty holders to identify hazards before work begins.
- Planning conditions / DA consents often include survey requirements.
- Occupational hygiene standards rely on surveys to define control measures.
- Insurance and risk management frameworks reference documented hazard identification.
In practice, a hazardous material survey provides the baseline information needed to plan safe demolition or refurbishment — including scope, sequencing, controls and cost forecasting.
Asbestos Surveys vs Hazardous Material Surveys: What’s the Difference?
It’s common to conflate asbestos surveys with hazardous material surveys — but they are distinct:
Asbestos Survey
Focused on identifying asbestos-containing materials (ACMs) and determining their location, condition and risk. It is required where demolition or refurbishment might disturb asbestos.
Hazardous Material Survey
Broader in scope. Includes asbestos and other hazardous materials such as lead, PCBs, SMF, ODS, and chemical residues.
Both surveys may overlap, but the hazardous material survey provides a comprehensive risk profile for the entire building, not just asbestos.
When Surveys Are Required
Surveys are typically required in the following circumstances:
1. Before Demolition
Whether full or partial demolition, the demolition contractor and PCBU are required to understand all hazardous materials that could be disturbed.
2. Prior to Major Refurbishment
Where intrusive works, penetrations or removal of building fabric are proposed.
3. As Part of DA / CDC Conditions
Councils and certifiers often include hazardous material survey requirements in planning or construction certificates.
4. At the Request of Project Teams
Early identification helps with tendering, cost planning and risk management.
In all cases, surveys should be completed before demolition permits are issued or before equipment is mobilised.
How Surveys Are Conducted — Practical Insight
A thorough hazardous material survey involves:
Desktop Review
Review of building plans, renovation history and any previous reports to identify likely hazards.
Visual Assessment
A systematic room-by-room inspection by a qualified inspector to identify suspicious materials.
Targeted Sampling
Where materials are suspected but not visually confirmed, sampling is undertaken and submitted to NATA-accredited laboratories. Examples include:
- Asbestos bulk sampling
- Lead in paint chips
- PCB sampling from caulking or electrical components
Condition Assessment
Condition and potential for fibre release or hazard exposure is recorded. Poorly maintained ACM is more hazardous than intact, sealed material.
Report Preparation
The final survey report includes:
- Identified hazardous materials
- Locations and quantities
- Risk ratings
- Recommended control measures
- Colour-coded building plans
This report becomes the foundation for work planning, permit applications and control measures.
How Survey Findings Inform Project Planning
Survey results directly influence:
Work Health & Safety Planning
Including:
- Safe work method statements (SWMS)
- Control measures (containment, tagging, PPE)
- Air monitoring requirements
Scope of Licensed Asbestos Removal
Where ACM is identified, the quantity, type and friability determine whether licensed removal is required under WHS Regulations.
Cost Estimation and Scheduling
Hazardous material removal adds cost and time to demolition or refurbishment. Knowing this early avoids surprises.
Regulatory Compliance
Council and certifier reviews rely on validated surveys to assess compliance with DA or CDC conditions.
Common Missteps and How to Avoid Them
Projects often run into issues when:
- Surveys are done too late — after demolition or intrusive works commence
- Surveys are incomplete — limited only to asbestos and ignore other hazards
- Reports lack clear locations or risk ratings — creating ambiguity for contractors
- Samples are not analysed by accredited labs — creating compliance risk
The solution is simple: commission comprehensive hazardous material surveys early, from qualified practitioners, with clear reporting and site plans.
Early survey work de-risks the entire project.
Clearance and Verification: What Happens After Removal
Once hazardous materials have been removed, the work area must be verified as suitable for further construction or occupancy.
For asbestos this may involve:
- Clearance inspections by an independent assessor
- Air monitoring in accordance with WHS guidance
- Clearance certificates accepted by regulators and certifiers
For other hazardous materials, verification includes documentation confirming removal and residual risk control measures.
Verification is not optional — work should not proceed without it.
A Practical Scenario — Demolition Case Study
A commercial office building constructed in the 1970s was scheduled for full demolition. An initial asbestos survey identified friable ACM in suspended ceiling insulation, floor tiles with asbestos backing, and suspected lead paint in older boardrooms.
A broader hazardous material survey then identified:
- Polychlorinated biphenyls (PCBs) in electrical ballasts
- Ozone depleting substances (ODS) in old chillers
- Old chemical storage residues in a storeroom
This comprehensive survey allowed the project team to:
- Accurately quantify removal scope
- Engage licensed removalists with appropriate risk controls
- Schedule removal works ahead of demolition
- Provide clearance reports to the certifier
- Avoid mid-construction stop-works
The project proceeded on schedule with clear documentation accepted by regulators.
Key Takeaways for Developers and Project Teams
- Surveys must be done early, not after works begin
- Hazardous material surveys are broader than asbestos surveys
- Accredited labs and qualified inspectors matter
- Clear reporting supports WHS, approvals and contractor planning
- Verification (clearance/air monitoring) is essential before recommencing works
