Asbestos registers in Australia: what the law requires, who keeps them, and how to keep them current

01

What an asbestos register is, and the legal requirements behind it

An asbestos register is a list of all identified or assumed asbestos in a workplace. The approved code of practice How to manage and control asbestos in the workplace, SafeWork NSW's edition of the Safe Work Australia model code (last amended December 2022), says it exists so that workers and others do not disturb asbestos by accident.

The duty is in Part 8.3 of the model regulations, reproduced in the Work Health and Safety Regulations 2011 (Cth) (compilation 28, 25 March 2025); every Australian state and territory except Victoria has adopted its own version, with closely corresponding numbers. It starts with identification. Regulation 422 says: "A person with management or control of a workplace must ensure, so far as is reasonably practicable, that all asbestos or ACM at the workplace is identified by a competent person." Material a competent person reasonably believes is asbestos, and inaccessible areas likely to contain it, must be assumed to be asbestos.

Regulation 425 then requires the register: "A person with management or control of a workplace must ensure that a register (an asbestos register) is prepared and kept at the workplace." It must be "maintained to ensure the information in the register is up to date". Under these WHS laws the register is a legal obligation, not a matter of good practice. Regulation 424 requires identified asbestos to be clearly indicated, by a label where reasonably practicable, and regulation 429 requires a written asbestos management plan wherever asbestos is identified or likely.

Victoria is different. Under the Occupational Health and Safety Regulations 2017 (Vic), as WorkSafe Victoria's Compliance code: Managing asbestos in workplaces (December 2019) explains, the person who manages or controls a workplace records identified asbestos in an asbestos register (regulation 227), and an employer at the workplace keeps an employer's asbestos register (regulation 235). Check your own jurisdiction's regulation before relying on any number or date here.

02

What an asbestos register must record

Under regulation 425(3) the register must record any asbestos or ACM identified at the workplace, or likely to be present from time to time, including the date it was identified and its location, type and condition. Where none is identified or likely, the register must say so. A register that says "none identified" still has to be kept and reviewed.

The code says a comprehensive register may also include asbestos assumed to be present, analysis results, the dates of identification, inaccessible areas and past removal work, and that "It may also be useful to attach photographs or drawings to visually show the location of the asbestos or ACM in the workplace."

An asbestos register template. Appendix D of the code is a blank template with these columns, under the workplace address and the name of the competent person:

• the date the asbestos was identified or assumed;
• the type of material, and whether identified or assumed;
• whether it is friable or non-friable;
• its condition;
• its specific location; and
• whether it is in an inaccessible area.

Appendix E fills it in. One row reads: floor tiles, identified and confirmed by testing, non-friable, "Good condition, tiles under filing cabinet starting to lift", in the main office. That is the register at its most useful: specific enough that someone standing in the room knows which tiles are meant and what to watch for.

In Victoria the register must also say whether the material is likely to be damaged or to deteriorate and, so far as possible, which activities at the workplace are likely to disturb it, and the compliance code asks for a copy of every laboratory report; there is no mandatory format. WorkSafe Victoria's guidance on asbestos registers adds tests that apply anywhere: state assumptions and limitations, name areas that could not be accessed, describe locations consistently (photos, diagrams or plans help) and keep it reflecting the building's current condition.

03

Which buildings need a register, and who is responsible

The date that matters. Regulation 425 applies to buildings whenever constructed, except where the workplace is a building constructed after 31 December 2003, no asbestos has been identified and none is likely to be present. SafeWork NSW's asbestos page puts it simply: "If your workplace was built before 31 December 2003 or if asbestos has been identified at the workplace, you must keep a register". Queensland's exemption starts earlier, for buildings constructed after 31 December 1989.

The 2003 date is when, in the code's words, "a national ban on all forms of asbestos came into effect". The code warns that newer buildings may still contain asbestos from stockpiled or recycled materials, older plant reinstated with asbestos gaskets or linings, and some imported products.

Who keeps it. The person with management or control of the workplace: in practice the property owner, a head lessee, or a managing agent or facilities manager acting for them. In the code's example, the owner of an arcade who has engaged contractors to renovate a shop for a new tenant has management and control over the workplace, is responsible for updating the register for the work, and consults other tenants who may be affected. More than one person can hold the duty, and the code says duty holders should consult, cooperate and coordinate with each other and with workers and health and safety representatives. A business working at the workplace should obtain the register and report any asbestos it finds that the register misses. A lease or facilities management contract should say who holds the register and where it is kept.

Homes and residential strata. Regulation 421(2) says regulations 425 to 430 do not apply to any part of domestic premises used only for residential purposes, and regulation 7 says a strata title body corporate responsible for common areas used only for residential purposes may be taken not to be a person conducting a business or undertaking for them, unless it employs a worker. The code adds that, as no register is required at residential premises, a business that finds asbestos there must advise the homeowner or landlord and take appropriate action in managing the risks. Mixed-use buildings, with commercial floors beside residential ones, need closer advice.

Who identifies the asbestos. The code's examples of a competent person include occupational hygienists with asbestos experience, licensed asbestos assessors and asbestos removal supervisors. Samples go to a NATA-accredited laboratory or another laboratory the regulations allow (regulation 423).

Handover. A person giving up management or control must, so far as is reasonably practicable, give the register to whoever takes over (regulation 428). Ask for it, and the management plan, at every change of owner or manager.

04

Keeping the register current, and who can see it

Under regulation 426 the register must be reviewed and, as necessary, revised when the asbestos management plan is reviewed, when further asbestos is identified, and when asbestos is removed, disturbed, sealed or enclosed; the code says this is done by the business or a competent person it engages. The plan must be reviewed "at least once every 5 years" (regulation 430), and the code says: "The register should be reviewed at least once every five years to ensure it is kept up to date." A review includes "a visual inspection of the asbestos and ACM listed to determine its condition".

Victoria's compliance code requires review "at least every five years (even if there have been no changes to any asbestos at the workplace)", and asks for each review to be documented: when, what it involved, the outcome and who did it.

Who can see it. Regulation 427 requires the register to be readily accessible to:

• a worker who has carried out, carries out or intends to carry out work at the workplace, and their health and safety representative;
• a business that has carried out, carries out or intends to carry out work there; and
• a business that has required, requires or intends to require work to be carried out there.

A business whose work involves a risk of exposure to airborne asbestos must be given a copy. In practice, readily accessible should mean that staff and contractors alike can find it on site, the cleaner, the lift technician and the after-hours electrician included.

Before demolition or refurbishment of a structure or plant from before 31 December 2003 (in Queensland, a building constructed before 31 December 1989), the register must be reviewed and, if inadequate, revised (regulation 448), and a copy given to the business doing the work before it starts (regulation 449), which must obtain one (regulation 450). Minor or routine maintenance does not count.

05

The asbestos management plan, labels and the everyday controls

Wherever asbestos is identified or likely, regulation 429 requires a written asbestos management plan, kept up to date and as accessible as the register. It must include information about:

1. the identification of asbestos, such as a reference or link to the register and the locations of signs and labels;
2. decisions, and the reasons for them, about managing it, such as safe work procedures and control measures;
3. procedures for incidents or emergencies involving asbestos; and
4. workers carrying out work involving asbestos, such as consultation, responsibilities, information and training.

Regulation 430 requires a review when the register or a control measure is reviewed, when asbestos is removed, disturbed, sealed or enclosed, when the plan is no longer adequate, when a health and safety representative asks, and at least once every 5 years.

Labels and signs. The code says labels should match the locations in the register and warning signs should comply with AS 1319-1994; where neither is reasonably practicable, a permit-to-work system can make sure tradespeople know where the asbestos is before they start.

Most asbestos is managed in place. The code says: "If asbestos or ACM is in good condition and left undisturbed, it is unlikely that airborne asbestos will be released into the air and the risk to health is extremely low. It is usually safer to leave it and review its condition over time."

So condition matters between formal reviews. The register records condition on the day of the survey; someone has to keep looking. A plan can set a routine visual check of known items and their labels by trained site staff, with any damage or disturbance reported straight away under the plan's incident procedure and referred to the competent person.

06

Where the asbestos register fails, and what SiteClara does about it

The asbestos register rarely fails for want of a survey. It fails in the years between. The register says "good condition" while a pallet jack has chipped the asbestos cement wall at the loading dock. Labels disappear under fresh paint in a fit-out. Asbestos is removed from a plant room and the register still lists it. The register sits in a folder in the building manager's office, and the after-hours electrician never sees the entry for the switchboard cupboard. Five years on, the competent person asks what changed and nobody can say.

SiteClara records work at the location. A printed QR poster, with an optional NFC tag behind it, sits at each place where checks are scheduled, such as a plant room, a switchboard cupboard, the loading dock or a ceiling access point near known material. Staff scan or tap on their own phone, with no app to install, and mark the scheduled check done, such as a monthly look at the listed items and their labels, with a photo when the check asks for one, or explain what stopped them. Someone who sees cracked sheeting, lifting tiles or dust below an asbestos cement roof can report it there, with a photo; the report carries the location, the time and the named person, and stays on the team's open jobs until someone closes it.

The supervisor sees the day's checks and open jobs, adds a note and approves a daily report that goes to nominated management or client contacts the next morning. Over months that gives the competent person a dated series of condition checks and photographs, location by location, to set beside the register at review.

07

Questions people ask

Can I check the asbestos register?

Yes, if you work at the workplace or your business does, will or has asked for work there: the code of practice How to manage and control asbestos in the workplace sets out regulation 427, under which the register must be readily accessible to those workers, their health and safety representatives and those businesses, and a business whose work involves a risk of exposure to airborne asbestos must be given a copy. Ask the building manager, managing agent or whoever manages or controls the workplace.

How long does an asbestos register last?

An asbestos register does not expire, but it must be kept up to date and reviewed at least once every five years, and sooner when asbestos is found, removed, disturbed, sealed or enclosed, when the management plan is reviewed, and before demolition or refurbishment. The code of practice How to manage and control asbestos in the workplace says a review should include a visual inspection of the listed material.

Who is responsible for the asbestos register?

The person with management or control of the workplace, often the building owner or whoever manages the building for them, must ensure it is prepared and kept at the workplace, reviewed, readily accessible and, so far as is reasonably practicable, handed to whoever takes over management or control, for instance when the workplace or the business is sold. The code of practice How to manage and control asbestos in the workplace sets out each of these duties, under regulations 425 to 428.

Can I check whether a material is asbestos myself?

No: SafeWork NSW's asbestos page says "The only way to be certain that something contains asbestos is to have a sample tested in a laboratory", and to treat suspected asbestos as asbestos until results confirm otherwise. It strongly recommends a licensed professional to collect samples.

08

Where to read more, and a list to take away

The duties are in Part 8.3 of the Work Health and Safety Regulations 2011 (Cth), with demolition and refurbishment in Part 8.6; each adopting jurisdiction publishes its own version, such as the Work Health and Safety Regulation 2011 (Qld). For practice, read the code of practice How to manage and control asbestos in the workplace: chapter 3 covers the register, chapter 4 the plan, and Appendices D and E a template and a worked example. In Victoria, start with WorkSafe Victoria's Compliance code: Managing asbestos in workplaces.

Before you rely on your asbestos register, check that:

• you know whether your building needs one under your jurisdiction's date, and a competent person has identified or assumed the asbestos;
• every entry gives the date, a specific location, the type, friable or non-friable, the condition and any inaccessible area, with photographs where they help;
• the register is kept on site and everyone who works there, contractors after hours included, can find it;
• a contractor whose work could disturb asbestos gets a copy before starting;
• labels and signs match the register and are still legible;
• known material is looked at between formal reviews, and damage is reported and referred to the competent person;
• the register is updated after any removal, sealing, enclosure or new find, and reviewed with the plan at least every five years;
• the register and plan are reviewed before demolition or refurbishment and handed over when the building or its management changes.