What does "out of date" actually mean?
An asbestos register isn't a one-and-done document. It's a living record that needs to reflect the current state of your building. If it hasn't been reviewed in the past few years, or if the building has undergone renovations, maintenance, or changes in use since the last survey, your register probably has gaps.
Legally, the register must be kept up to date. That means reviewing it whenever there's a reason to believe conditions have changed, and at regular intervals regardless.
In Australia: The WHS Regulations require the register to be reviewed when there's a change in the condition of identified materials, when asbestos is removed, disturbed, or found, or if five years have passed since the last review. See our guide to asbestos register requirements in Australia for the full legal details.
In New Zealand: The Asbestos Regulations 2016 similarly require the register to be reviewed when there's reason to believe it's no longer correct, and at least every five years.
Signs your register needs attention
Some common indicators that your register has fallen behind:
- The last survey or review date is more than five years ago
- Renovation, maintenance, or fitout work has been done since the register was created, but the register wasn't updated
- Areas of the building weren't included in the original survey (storage rooms, plant areas, roof spaces)
- Condition ratings haven't been reassessed since the original inspection
- Materials that have been removed are still listed as present
- The register doesn't cover recent additions or alterations to the building
If any of these apply, your register is overdue for an update.
Why it matters beyond compliance
An outdated register isn't just a regulatory problem. It's a safety problem. Contractors and maintenance workers rely on the register to understand what's in the building before they start work. If the register is incomplete or inaccurate, someone could unknowingly disturb asbestos-containing material. That's a health risk and a liability issue.
Steps to get your register current
1. Engage a qualified surveyor
Start by bringing in an asbestos surveyor or consultant to carry out a re-inspection. They'll compare the current state of the building against what's recorded in the existing register. This includes checking condition ratings on previously identified materials, inspecting areas that may have been missed, and looking for any new findings.
If your building has never had a formal asbestos survey (some older registers were based on assumptions rather than sampling), a full management survey with laboratory analysis will be needed.
2. Update condition assessments
Asbestos materials deteriorate over time. Something rated as "good condition" five years ago might now be showing signs of damage, weathering, or wear. The surveyor will reassess each identified material and update its condition rating. Materials that have deteriorated may need to be prioritised for removal or additional management controls.
3. Add any new findings
If the re-survey identifies materials that weren't in the original register, whether because they were missed or because they've been exposed by subsequent work, these need to be added with full details: location, material type, condition, and recommended action.
4. Remove items that no longer apply
If asbestos has been removed from certain areas since the register was created, those entries should be updated to reflect the removal. Include the date of removal, the removalist's details, and the clearance certificate reference. Don't simply delete old entries. Mark them as removed so there's a clear history.
5. Review your management plan
The register and the asbestos management plan go hand in hand. When the register changes, the management plan usually needs updating too. This covers things like inspection schedules, access procedures for areas containing asbestos, and information provided to contractors before they start work on site.
Working with a consultant
For buildings with a significant amount of asbestos, or where the register has been neglected for a long time, it's worth engaging an asbestos consultant rather than just a surveyor. A consultant can review the whole management framework, not just the register itself, and help you put a system in place so it stays current going forward.
They can also help you set up a review schedule and integrate register checks into your routine building maintenance program.
Keep it accessible
Once updated, make sure the register is readily accessible to anyone who needs it. That includes contractors, maintenance staff, and tenants. Both Australian and New Zealand regulations require that the register be available at or near the workplace and provided to anyone carrying out work that could disturb asbestos.