Commercial Asbestos Removal in action at a warehouse

TL;DR — Key Takeaways

  • An asbestos management plan is a legal requirement for any Queensland industrial or commercial facility where asbestos or asbestos-containing materials (ACMs) have been identified or are assumed to be present.
  • Under the Work Health and Safety Act 2011 (QLD) and the Work Health and Safety Regulation 2011 (QLD), site operators must maintain an up-to-date asbestos register and management plan, reviewed at least every five years.
  • An asbestos removal control plan is a separate, job-specific document required whenever licensed asbestos removal work is carried out. It differs from a management plan, which is an ongoing site document.
  • Failing to maintain a compliant asbestos management plan in QLD can result in significant financial penalties exceeding $30,000, as well as potential criminal liability.
  • HM Group’s A-Class licensed specialists can prepare, review, and update your asbestos management plan or asbestos removal control plan to ensure full compliance with current QLD legislation and Safe Work Australia guidelines.

While it is now recognised as a dangerous carcinogen, asbestos was once an incredibly common building material across Australia. As the operator or owner of an industrial site in Queensland, it is your responsibility to manage the risks of asbestos exposure.

One of the key methods by which you can achieve this is by implementing an asbestos management plan. While this plan might seem like the sole domain of your site’s health and safety representative, everyone has a role to play when it comes to the safe management of asbestos.

What is an asbestos management plan?

An asbestos management plan is a formal, written document designed to minimise and eliminate the risks of asbestos exposure at a workplace. It contains accurate, up-to-date information that can be used by workers, site owners, and contractors to manage the risks associated with asbestos and asbestos-containing materials (ACMs). Under Australian Work Health and Safety (WHS) legislation, asbestos management plans are required for all commercial and industrial sites where asbestos has been identified or is assumed to be present.

A comprehensive asbestos management plan for an industrial facility should include:

Asbestos register – information on identified asbestos

Any building that has asbestos or asbestos-containing materials (ACMs) must, by Australian law, have an asbestos register. This register contains detailed information on the nature of the asbestos materials within a structure. This includes the type of asbestos, its location and its condition.

Decisions and justifications around asbestos management

Your plan will need to contain clear rationales for the way you’ve chosen to manage asbestos onsite. Be prepared to justify why asbestos has or hasn’t been removed, and to outline the necessity for any work involving asbestos on your site.

Incident protocols, control measures, and health and safety information

Asbestos is most commonly disturbed through renovations and demolition work. However, situations such as fires, storms, and structural degradation can also bring about asbestos exposure. Your plans should contain contingencies for all of these situations.

The plans should identify the steps to take immediately after the accident or disturbance, as well as the protocols for establishing exclusion zones around affected areas. You should also delineate the immediate health precautions to be taken by any individuals who may have experienced an exposure. These health precautions should involve information on decontamination, when and how workers should access medical attention, and any air and health monitoring that needs to occur in the aftermath.

Training responsibilities

Explain clearly who onsite needs to have what kind of training around asbestos and asbestos exposure. This level of training will be dependent on their level of risk exposure, but if your site does have asbestos or ACMs, all staff must be aware of the location of the asbestos, as well as emergency response procedures, the appropriate use of personal protective equipment, and know the relevant people to contact in an emergency.

Maintenance register

Your asbestos management plan needs all details of asbestos maintenance or service work onsite, with clear details on date, the scope, and the parties responsible. It should also contain any relevant clearance certificates, including information about any inspections that take place.

Testing results

As an extension of the maintenance register, it’s a good idea to keep track of any test results around asbestos on site. These can include lab data testing conducted by specialist contractors as well as information from regular air monitoring procedures.

Priorities and timelines for asbestos removal

Your asbestos management plans should contain a clear schedule for asbestos removal or review, explaining how the risks of asbestos exposure will be managed long term. Highlight the most important risk management steps, and explain in what order they will be executed.

Roles and responsibilities

Who is in charge of what when it comes to your asbestos control measures and procedures? Clearly outline the roles of workers, health and safety representatives, as well as which emergency contractors should be contacted in the event of an asbestos disturbance.

Do I need an asbestos safety management plan?

Under the Work Health and Safety Act 2011 (QLD) and the Work Health and Safety Regulation 2011 (QLD), any person conducting a business or undertaking (PCBU) with management or control of a workplace built before 1 January 2004 must ensure an asbestos register is prepared (unless a competent person confirms no asbestos is present) and that an asbestos management plan is in place if asbestos is identified or assumed to be present.

According to the Australian Asbestos and Silica Safety and Eradication Agency, asbestos is estimated to be found in up to one-third of Australian buildings, particularly in commercial and industrial properties built before 1990. If your property has identified or assumed asbestos, you are legally required to have an asbestos management plan in place.

Financial and legal penalties for non-compliance can exceed $30,000, and in serious cases may include criminal liability. Your asbestos management plan QLD must also be in written form and readily accessible to all workers and site attendees who may need it — not just your health and safety representative.

You also need asbestos management plans for sites with naturally occurring asbestos, with the same requirements for registration, control measures, and emergency protocols.

What is an asbestos removal control plan?

An asbestos removal control plan is a separate, job-specific document that is distinct from an asbestos management plan. While an asbestos management plan is an ongoing site document used to manage and monitor asbestos risks over time, an asbestos removal control plan is prepared specifically for a particular licensed asbestos removal job.

Under the Work Health and Safety Regulation 2011 (QLD), a licensed asbestos removalist must prepare and document an asbestos removal control plan for any licensed asbestos removal work. This is a legal requirement regardless of the size or scope of the removal project.

According to Workplace Health and Safety Queensland (WHSQ), an asbestos removal control plan must include:

  • Details of how the asbestos removal will be carried out, including the method, tools, and equipment to be used
  • The personal protective equipment (PPE) required for the job
  • Details of the asbestos to be removed, including its location, type, and condition
  • Procedures for decontamination and waste disposal
  • Notification requirements for WHSQ, where applicable

When is each document required?

As a general guide:

  • Asbestos management plan: Required on an ongoing basis for any workplace with identified or assumed asbestos, updated and reviewed regularly.
  • Asbestos removal control plan: Required each time licensed asbestos removal work is performed, prepared before work begins and specific to that job.

Key components of an industrial asbestos management plan

For large industrial facilities, asbestos management plans carry additional complexity. Industrial sites often have higher volumes of contractors, ageing infrastructure, and a greater diversity of ACMs. Here are some key considerations specific to industrial asbestos management:

Comprehensive site mapping

Industrial facilities can be sprawling, with asbestos present in plant rooms, pipe lagging, roof sheeting, fire doors, and other hard-to-access areas. A thorough asbestos survey is essential before the management plan is prepared.

Contractor management protocols

Industrial sites often engage numerous contractors for maintenance and shutdown works. Your asbestos management plan should include clear protocols for briefing contractors on asbestos risks, providing access to the asbestos register, and ensuring they understand their obligations before work begins.

Regular review and updates

Your plan needs to be reviewed at a minimum of once every five years. However, for active industrial sites, more frequent reviews are strongly recommended. Significant changes to the site, such as renovations, equipment upgrades, or storm and fire damage, should prompt an immediate review and update of both the asbestos register and the management plan.

Asbestos awareness training

All workers on industrial sites where asbestos is present must receive asbestos awareness training. This training should be documented and refreshed regularly, with records maintained as part of the management plan.

Common mistakes in asbestos safety management plans

How do you ensure you have an effective plan with all the right control measures? Here are some common mistakes that companies and site owners make when preparing their asbestos management plans.

Accessibility issues

When there are emergencies involving asbestos, everyone must know their best course of action. Your asbestos management plan is of no use if staff cannot access it in an emergency. Workers need to know where the plan is and what it contains. Include asbestos management information in onboarding sessions for all relevant contractors and ensure the plan is available in a physical or digital location accessible to everyone on site.

Incomplete documentation

It is your responsibility as the site owner or operator to maintain the most complete records possible. This means recording both known and assumed asbestos, regardless of where it is within the structure. Some asbestos management plans fail to declare all asbestos or asbestos-containing materials by omitting asbestos in inaccessible areas. While the areas may be inaccessible to workers, it doesn’t mean that the asbestos fibres can’t be disturbed as a result of planned works, workplace accidents, or natural disasters. To appropriately control asbestos risks, it’s essential that all locations of asbestos or suspected asbestos are recorded.

Failing to update the asbestos register

Asbestos safety management plans aren’t a set-and-forget document: they must be maintained and updated so that appropriate control measures can be upheld and your site’s safety can be protected. Any factors that might cause disturbance to your identified asbestos needs to be recorded, and further testing needs to be prompted. Damaging winds and rains, as well as fires, can release airborne asbestos fibres: this should trigger additional testing to ensure you’re adequately managing risks. Accuracy in your asbestos safety management plan must be a priority, especially for large industrial sites with high volumes of contractors. Your control measures, procedures, and plan need to stand up to scrutiny and take the form of genuinely useful documents.

“With over 27 years of experience in asbestos removal across South East Queensland, we see firsthand the gaps that can exist in industrial asbestos management plans — from incomplete registers to outdated removal protocols. Getting your documentation right is not just a legal box-tick; it is the foundation of a safe site. Our A-Class licensed team works with facility managers, builders, and business owners to prepare management plans and removal control plans that are accurate, compliant, and practical for day-to-day operations.” — HM Group

How HM Group Can Help

Preparing and maintaining a compliant asbestos management plan for an industrial facility in Queensland requires specialist knowledge, up-to-date regulatory expertise, and practical experience on complex sites. HM Group brings all three.

HM Group works with builders, facility managers, insurers, and business owners across South East Queensland to prepare and review asbestos management plans and asbestos removal control plans that are fully compliant with the Work Health and Safety Act 2011 (QLD), the Work Health and Safety Regulation 2011 (QLD), and the How to Manage and Control Asbestos in the Workplace Code of Practice 2021.

Our industrial asbestos removal services include end-to-end support: from initial site assessments and asbestos surveys through to the preparation of management plans, the conduct of licensed removal work with full asbestos removal control plans, and post-removal clearance certification.

We manage projects of all scales — from single-building commercial sites to large multi-site industrial facilities — with multiple crews and subcontractors servicing all of South East Queensland.

Get Your Asbestos Management Plan Right — Contact HM Group Today

If your industrial facility in Queensland has identified or assumed asbestos, or if your current asbestos management plan is due for a review, don’t leave compliance to chance. The consequences of inadequate documentation — for your workers’ health, your legal obligations, and your business — are too significant to overlook.

HM Group’s A-Class licensed team is ready to help. Whether you need a new asbestos management plan prepared, an existing plan reviewed and updated, or a full asbestos removal control plan prepared ahead of scheduled removal works, we offer fast, professional, and competitively priced services across Brisbane and South East Queensland.

Call us on 1300 10 11 44 or contact HM Group online to discuss your asbestos management requirements. Our experienced consultants are available to provide obligation-free advice and help you meet your legal obligations with confidence.