On 3 August 2026 the Board of the Faculty of Asbestos Management of Australia & New Zealand (FAMANZ) published From Regulation to Assurance, a ten-year review of how well public-sector asbestos management systems have matured in New Zealand. It was timed to land just before the tenth anniversary of the Health and Safety at Work (Asbestos) Regulations 2016.
The whole report is worth reading. The reason it matters on this side of the Tasman sits in the recommendations: FAMANZ intends to adapt the same maturity framework for an Australian workstream. The questions it put to New Zealand agencies are questions Australian duty holders should expect from their own boards, their insurers, and eventually a regulator or a journalist with an information request.
The five questions
FAMANZ issued information requests to Crown agencies, national entities and local authorities with significant property responsibilities, using the Official Information Act 1982 and the Local Government Official Information and Meetings Act 1987. It asked five things:
- How many buildings do you own or manage?
- How many were constructed before 1 January 2000?
- How many have a current Asbestos Management Plan?
- How often are those AMPs reviewed and updated?
- What percentage were updated in the last 12 months?
None of these are trick questions. None need a site visit, a survey, or a technical judgement. A facilities director should be able to pull the answers from an asset register in an afternoon.
Which is why FAMANZ treats the ability to answer them as an assurance indicator in itself. As the report puts it: "the best evidence of maturity was not perfection. It was visibility."
What the responses showed
The picture is uneven rather than uniformly poor, and FAMANZ is careful to say this is not a compliance audit, a league table, or a finding that any agency has breached its duties. Some of the individual responses still make for uncomfortable reading.
New Zealand's Ministry of Education confirmed responsibility for 33,755 buildings, 25,500 of them built before 2000. That is one of the largest and most asbestos-relevant public property portfolios in the country. The Ministry then advised that it does not centrally hold data allowing it to confirm AMP coverage, review frequency or update status across any of it. Parts of the request were refused on the basis that the information is not held. The Ministry's position is that schools are the primary PCBU and manage AMPs on a site-wide basis, which is a defensible operating model. It also leaves the Crown asset owner unable to see the state of its own estate.
Health New Zealand | Te Whatu Ora reported around 1,200 owned buildings plus roughly 750 leased premises. Fourteen of 19 districts had AMPs. Five had none. Five districts, or 26 percent, had updated AMPs in the previous 12 months. To its credit Health NZ was candid about the legacy inconsistency and described a national improvement programme, including a National Asbestos Management Group and a national AMP stocktake.
New Zealand Police owns 542 buildings, 514 of them pre-2000, with asbestos known or presumed at 426 sites. Police aims to refresh AMPs every five years and confirmed it is currently behind schedule, while completing 32 management surveys in the previous year.
Kāinga Ora manages 77,402 properties, 49,963 of them pre-2000, and holds no property-level AMP for residential homes at all. It runs a presumption-based operational model instead: pre-2000 homes are assumed to contain ACM unless records say otherwise, backed by work-order hazard alerts, contractor training and sampling before disturbance. FAMANZ accepts this as reasonable for a residential portfolio of that size, while pointing out that the model depends entirely on maintenance contractors applying the presumption consistently, every time.
The response FAMANZ rated highest came from the New Zealand Defence Force. NZDF reported around 7,200 in-use structures, 4,270 built before 2000, all covered by an estate-level Defence Estate Asbestos Management Plan. It then broke the number down: roughly 2,600 pre-2000 structures with management surveys, around 590 with other asbestos information only, and around 1,080 where asbestos remains assumed present. It also reported 739 asbestos register records added in the previous 12 months across 630 structures or sites.
NZDF did not claim its estate was fully surveyed. It quantified what it did not know. That is why FAMANZ classed it as stronger assurance while placing much better-resourced agencies below it.
Then there is the finding that will get quoted. WorkSafe New Zealand's own initial response identified that the national health and safety regulator needed to improve its internal property schedules, AMP expiry tracking, landlord-held information and intranet access to AMPs. FAMANZ makes the point generously: the significance is not to single WorkSafe out, but to show that knowing the law is not the same as running a system.
The distinction at the centre of the report
FAMANZ frames the whole exercise around one shift. Compliance asks whether the required documents and processes exist. Assurance asks whether those documents are accurate, current, accessible, used, reviewed, governed and connected to real decisions.
The report sets it out as a set of paired questions, and they work well as a self-test. "Do we have an Asbestos Management Plan?" becomes "is the AMP current, accurate, accessible, understood and actively used before work occurs?" "Do we have an asbestos register?" becomes "is the register reliable, updated, linked to assets, and used to inform maintenance, refurbishment, demolition and contractor engagement?" "Do we review documents?" becomes "are reviews routine, evidenced, reported, and triggered by changes such as deterioration, removals or new information?" And "do we manage asbestos at site level?" becomes "can senior leaders also see the portfolio-level picture, including coverage, currency, gaps and overdue reviews?"
An AMP sitting in a folder satisfies a narrow document expectation. It provides no assurance at all if workers cannot access it, contractors are never told about it, maintenance work is not checked against it, or nobody notices the review date passed two years ago.
Why Australian duty holders should care now
The framework is coming here. FAMANZ has confirmed it is running a similar review in Australia and that the core assurance questions stay consistent across both countries. Australian agencies and councils are subject to freedom of information regimes that work much like the OIA and LGOIMA. The same five questions can be put to a state education department, a health service, a council or a housing authority, and the answers will be published.
The gaps FAMANZ found are structural rather than specific to New Zealand. Central visibility over a devolved estate. Leased and co-located premises where the asbestos information sits with a landlord. Residential portfolios too large for per-property AMPs. AMP refresh programmes quietly running behind schedule. All of those exist in Australian portfolios too. The report's fourth key finding, that leased, occupied and co-located premises are a blind spot, should be uncomfortable for any organisation that has assumed the landlord's register is somebody else's problem. Occupier PCBUs still have duties to their own workers and contractors.
And maintenance is where this stops being theoretical. FAMANZ is blunt that asbestos risk is not confined to major demolition projects. It becomes active through routine maintenance, reactive repairs, intrusive inspections, fire-door work, ceiling access, service penetrations and minor refurbishments. Mature systems put asbestos information in front of the worker before the work starts, not after something gets disturbed. If your register is technically current but a subcontractor cannot get to it at 7am on a Tuesday, you do not have assurance.
What to do with this
Run the five questions against your own portfolio this week, not as a compliance exercise but as a timing exercise. How long does it take you to produce the answers, and how much of it comes from a system rather than somebody's memory?
Then work through FAMANZ's good-practice tests. Can senior leaders identify who owns asbestos risk, how it is reported, and what is being done where gaps exist? Can you name which buildings require asbestos to be considered, presumed or ruled out? Can a tradesperson get the right asbestos information before disturbing building fabric? Can the organisation see AMP coverage, review dates, overdue actions, presumed-asbestos areas and improvement work at portfolio level?
The most useful test, and the one most commonly failed, is whether you can explain your AMP coverage rather than just report it. Which buildings have plans, which do not, and why? Post-2000 construction, no asbestos detected, asbestos removed, or coverage under a site-wide plan are all legitimate answers. FAMANZ found repeatedly that a low AMP count is not automatically a weak system. Several agencies had perfectly good reasons for buildings without plans. What separated the stronger responses was being able to account for the number.
The uncomfortable part
The report's most quotable line is also its most awkward: "New Zealand has regulated asbestos management. The next step is to assure it."
Australia is further along in its regulatory history than New Zealand. A total ban since December 2003, model WHS regulations, mandatory registers and management plans for workplaces with identified asbestos, and a National Strategic Plan now in its third phase. None of that answers the assurance question. A jurisdiction can have excellent regulations and still be unable to say how many of its public buildings have a current management plan.
Transparency about limitations, FAMANZ concluded, is a strength rather than a weakness. The agencies that scored well were not the ones claiming everything was under control. They were the ones that could say precisely what they knew, what they had presumed, what they had ruled out, and what they were still working on.
That is a low bar, and a surprisingly hard one. Worth checking which side of it you sit on before somebody else does the checking.