The rule is simple: survey first, demolish second
Before any building is demolished, either partially or fully, a pre-demolition asbestos survey must be carried out. This is a legal requirement in both Australia and New Zealand, and it applies to all buildings, not just those known or suspected to contain asbestos.
The survey must be completed before demolition work starts, not during, not after. Skipping or delaying this step is one of the most common ways people end up on the wrong side of asbestos regulations.
What a pre-demolition survey involves
A pre-demolition survey (sometimes called a refurbishment and demolition survey, or Type 3 survey) is more invasive than a standard management survey. The surveyor will access areas that wouldn't normally be inspected during routine management, including inside wall cavities, above ceilings, below floors, and within service risers. Our step-by-step survey walkthrough covers what to expect during this process.
The goal is to find every asbestos-containing material in the building, including materials that are hidden or enclosed. The surveyor will collect samples and have them analysed at an accredited laboratory. The resulting report lists all confirmed materials, their locations, types, and quantities.
For a standard commercial building, expect the survey to take one to several days on site, with lab results following within a few business days.
All asbestos must be removed before demolition
If the survey identifies asbestos, it must be removed before demolition begins. You cannot demolish a building with asbestos still in it. This applies to all types of asbestos-containing materials, both friable and non-friable.
Removal must be carried out by a licensed asbestos removalist.
In Australia: A Class A licence is required for friable asbestos removal. A Class B licence covers non-friable (bonded) asbestos removal over 10 square metres. Smaller quantities of non-friable asbestos can be removed by a competent person, but given the context of a demolition, a licensed removalist is almost always required.
In New Zealand: Class A licence holders can remove any type of asbestos. Class B licence holders can remove non-friable asbestos only. Unlicensed removal is only permitted in very limited circumstances that won't apply to demolition projects.
Notification requirements
Both the asbestos removal and the demolition itself typically require notification to the relevant regulator before work starts.
In Australia: Licensed asbestos removal work must be notified to the relevant state or territory WHS regulator at least five days before work begins. Demolition work also requires notification, with timeframes varying by jurisdiction. Some states require a demolition licence or permit as well.
In New Zealand: The PCBU must notify WorkSafe NZ at least five days before licensed asbestos removal work begins. Demolition notification requirements are covered under the Health and Safety at Work (General Risk and Workplace Management) Regulations.
These notifications are separate from any council or planning approvals you need for the demolition itself.
Clearance before demolition proceeds
After asbestos removal is complete, an independent asbestos assessor (not the removalist) must inspect the area and issue a clearance certificate. This confirms that all identified asbestos has been removed and the site is safe for demolition to proceed.
Don't allow the demolition contractor on site until clearance has been received. Starting demolition before clearance creates serious legal exposure and puts workers at risk.
Who is responsible for what
Responsibilities in a demolition project are often split between multiple parties, and confusion about who is responsible for the asbestos survey and removal is common.
The building owner or developer is typically responsible for commissioning the pre-demolition asbestos survey and arranging removal of any identified asbestos before the demolition contractor starts work.
The demolition contractor is responsible for ensuring they don't commence demolition until a clearance certificate has been issued. They should request a copy of the survey report and clearance certificate before starting. If they encounter any suspect material during demolition that wasn't identified in the survey, they must stop work and report it.
If you're the building owner commissioning a demolition, make sure the responsibilities are clearly defined in your contracts. Don't assume the demolition contractor will handle the asbestos side of things unless that's explicitly agreed and they hold the appropriate licences.
Build it into your timeline
The survey, removal, and clearance process adds time to your demolition schedule. For a straightforward commercial building, allow at least two to four weeks between commissioning the survey and receiving clearance. More complex buildings with significant quantities of asbestos may require longer.
The costs are real but predictable. Getting quotes for the survey and removal during the planning phase, rather than discovering asbestos after demolition has been scheduled, avoids delays and budget surprises.