Why surveys matter
Before you can manage asbestos, you need to know if it's there and where it is. That's the starting point for everything else: the register, the management plan, decisions about removal or encapsulation, and safe work practices for contractors.
The Health and Safety at Work (Asbestos) Regulations 2016 place a clear duty on PCBUs to identify asbestos in their workplaces. A survey carried out by a qualified asbestos surveyor is the standard way to meet that duty.
The PCBU's duty to identify
Under regulation 10, a PCBU with management or control of a workplace must ensure, so far as is reasonably practicable, that all asbestos or ACMs at the workplace are identified. This applies whenever the PCBU knows, or ought reasonably to know, that there's a risk of exposure to airborne asbestos fibres.
If your building was constructed or refurbished before 2000, you should assume that risk exists. You can't simply say "we didn't know" if the building's age makes it likely that asbestos materials were used.
Where there's uncertainty about whether a material contains asbestos, you have two options: assume it does and manage it accordingly, or have a sample analysed by an IANZ-accredited laboratory (regulation 11). If you assume it contains asbestos, it's treated as identified for the purposes of the regulations.
Types of surveys
WorkSafe's guidance distinguishes between two main types of asbestos survey, each serving a different purpose.
Management survey
A management survey identifies asbestos materials that could be disturbed during normal occupation and routine maintenance. It assesses the condition of those materials and the risk they present. This is the survey that feeds into your asbestos register and management plan. For most commercial buildings, this is the starting point.
A management survey involves a systematic inspection of accessible areas, sampling of suspect materials, and an assessment of the condition and likelihood of disturbance for each item found. Our step-by-step survey walkthrough explains what to expect on the day. It won't involve breaking into sealed areas or causing significant damage to finishes.
Refurbishment and demolition survey
Before any refurbishment or demolition work, a more thorough survey is needed. This type of survey is designed to find all asbestos in the areas where work will take place, including behind walls, above ceilings, and in other concealed spaces. It's more intrusive than a management survey and may involve some destructive inspection.
The regulations require that asbestos is identified before any work that might disturb it. If you're planning a fit-out, renovation, or demolition, a refurbishment and demolition survey in the affected areas is effectively mandatory.
Who can conduct a survey?
The Asbestos Regulations don't prescribe a specific licence type for surveyors in the same way they do for removalists and assessors. However, WorkSafe's good practice guidelines are clear that surveys should be carried out by a competent person with relevant training, experience, and qualifications.
In practice, this means engaging a qualified asbestos surveyor. Look for someone with recognised asbestos survey qualifications, practical experience in NZ buildings, and the ability to arrange IANZ-accredited laboratory analysis for any samples taken.
What happens after a survey?
Once the survey is complete, the results feed into several obligations:
- The findings must be recorded in an asbestos register, which lists the location, type, and condition of all identified or assumed ACMs. If you're not sure how to interpret the results, see our guide on how to read an asbestos survey report
- The presence and location of asbestos must be clearly indicated at the workplace (regulation 12), whether through labels, signage, or marked plans
- An asbestos management plan must be prepared or updated to reflect the survey findings (regulation 13)
- If asbestos is found in poor condition or in locations where it's likely to be disturbed, you'll need to decide on control measures. That could range from sealing and monitoring to removal by a licensed removalist
The survey report itself is a point-in-time document. Conditions change. Materials deteriorate. Renovations happen. That's why the management plan needs periodic review and why re-inspection of known ACMs should be part of your ongoing maintenance programme.
Common mistakes
A few things that catch facility managers out:
- Relying on a survey that's years old without any re-inspection. The condition of materials changes over time.
- Getting a management survey when you actually need a refurbishment and demolition survey. If contractors are going to break into walls or ceilings, the management survey alone won't be enough.
- Not surveying areas before minor works. Even small maintenance jobs can disturb ACMs if no one has checked what's there.
- Forgetting to update the register and management plan after the survey is done.
Sources
- Health and Safety at Work (Asbestos) Regulations 2016, reg 10 (Duty to ensure asbestos identified at workplace)
- Health and Safety at Work (Asbestos) Regulations 2016, reg 11 (Sample analysis)
- Health and Safety at Work (Asbestos) Regulations 2016, reg 12 (Duty to ensure presence and location of asbestos indicated)
- Health and Safety at Work (Asbestos) Regulations 2016, reg 13 (Duty to prepare asbestos management plan)
- WorkSafe New Zealand, Conducting Asbestos Surveys: Good Practice Guidelines for Asbestos Surveyors