Asbestos management

The safety of all people in schools where they might be affected by asbestos works is assured through implementation of the Ministry’s Asbestos Management Process. This process should be used in conjunction with the Health and Safety at Work Act 2015, Health and Safety at Work (Asbestos) Regulations 2016 and WorkSafe NZ Approved Codes of Practice.

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Managing Asbestos in the Education Sector

Building materials containing asbestos were in widespread use in New Zealand and overseas until the 1980s because of its fire-resistant properties. Given the age of the school portfolio, asbestos or asbestos-containing materials (ACMs) might be present in many schools.

The management of asbestos in schools will involve two types of situations:

  • Business-As-Usual, meaning the ongoing maintenance and operation of the school, which is the responsibility of the Board of Trustees. From time to time, this may also involve the management of refurbishment projects where asbestos may be present; and
  • Refurbishment and demolition projects undertaken by the Ministry in schools. These projects are led by the Ministry and usually involve establishing a construction site within a school boundary. In these situations, a main construction contractor is engaged and has the responsibility for managing the construction site and coordinating works within the operational school environment.

Whichever situation, it is important that the parties involved (PCBU's - Person Conducting a Business or Undertaking) consult, coordinate and cooperate where they share duties on the same matter to ensure the work is conducted safely for all involved. This is important especially when undertaking any work involving asbestos. The health and safety of staff and students is our top priority.

To ensure people are not exposed to the risk of airborne asbestos fibres, and to assist PCBUs involved (contractors, Boards of Trustees, and the Ministry) in meeting their obligations under the Health and Safety at Work (Asbestos) Regulations ("the Regulations") the Ministry has prepared guidance to assist asbestos management in schools.

School's health and safety responsibilities

The management of asbestos is specifically provided for in the Health and Safety at Work (Asbestos) Regulations 2016. The Regulations focus on duties to prevent exposure to airborne respirable asbestos fibres. As the PCBU with management and control of the workplace (school), Boards of trustees have a responsibility for managing asbestos in their schools, like any other hazards or risks.

Where School Boards undertake management of refurbishment projects that may involve asbestos, the processes listed under 'Project-Related Management of Asbestos' are recommended for use.

Asbestos Risks

The Health and Safety at Work (Asbestos) Regulations prescribe a number of duties for the management of asbestos. An underlying requirement (regulation 9) is that the person conducting a business or undertaking (PCBU) with management or control of the workplace must ensure that:

  • Exposure of a person to airborne asbestos is eliminated so far as is reasonably practicable; and
  • If it is not reasonably practicable to eliminate exposure, to minimise that exposure.

The Health and Safety at Work Act 2015 requires PCBU's to either eliminate risks to health and safety, or if it is not reasonably practicable, to minimise the risks.

If asbestos or ACM is in good condition and undisturbed, it is unlikely that airborne asbestos fibres will be released. In this situation, the risk to health is low. It is usually safer to leave it and review its condition over time. However, if the asbestos or ACM deteriorates, is disturbed, or if Asbestos Containing Dust (ACD) is present, there is an increased likelihood airborne asbestos will be released.

The workplace PCBU or a PCBU carrying out work involving asbestos should decide if there is a risk of exposure to airborne asbestos.
Things to consider include:
• the asbestos or ACM’s condition
• whether it is likely to be damaged or will deteriorate
• the potential quantity of airborne asbestos fibres that could be released, based on its existing condition
• whether it is likely to be disturbed through routine work
• whether it is in an area where workers are exposed to the material
• potential exposure routes
• maximum potential human exposure periods.

Visually inspecting the asbestos, its location and understanding the work practices will help with this determination.

The following checklist outlines the actions you should take as a minimum to meet the requirements of Regulation 9:

Risk Register

  • To ensure that any potential risks arising from asbestos are managed, it is important that details are included on the school’s hazard and risk register and the information is maintained and updated.
  • The risk register should detail whether any asbestos or ACM has been identified or assumed and if so, it should refer to an Asbestos Management Plan which will contain detailed information about the location, condition, quantity and monitoring plan for asbestos or ACM. Ensure you monitor the works or area regularly and have a process in place in case unexpected asbestos is found.
  • The risk register should be provided to any contractors undertaking work within schools.

Download template: 

Isolate the risk:

  • If asbestos is present (and it is confirmed that the condition of the material will either pose a risk to health in its current form or if it is disturbed as a result of work about to commence), the work area should be isolated immediately and appropriate warning signage displayed until the risk has been effectively managed.

For more information about Asbestos and your health, visit the Ministry of Health website:

Identifying if asbestos is present

Regulation 10 of the Asbestos Regulations places a duty on PCBU's with management or control of a workplace, who knows or ought reasonably to know that there is a risk of exposure to respirable fibres in the workplace, to ensure, so far as is reasonably practicable, that all asbestos or asbestos containing material (ACM) giving rise to the risk at the workplace is identified.

This means you must determine whether asbestos is present in your buildings. There are a number of ways you can do this, including:

  1. If the building was built prior to 1 January 2000 it is likely to contain asbestos containing material and you could assume that your school building contains asbestos.
  2. You could follow the WorkSafe Approved Code of Practice Guidance (external link)  to identify what is likely to contain asbestos by conducting a visual inspection. This needs to be carried out by an experienced or competent person which could include your own staff who have undergone appropriate training. Staff should not damage the suspected asbestos in any way when making this determination and correct PPE should be worn.
  3. Or you can employ a qualified asbestos surveyor to assess your building.

If it is assumed that asbestos is not likely to be present, record this assumption in your risk register.

If asbestos is assumed likely or confirmed to be present, you will need to prepare an Asbestos Management Plan; or

If asbestos is assumed likely to be present, or is found to be in poor condition and there is a risk of exposure to respirable fibres, you will need to take steps to eliminate or minimise the risk. This could include removing the asbestos (elimination of the risk) or minimising the risk by encapsulation or other methods.

Asbestos Management Plan

Where asbestos has been identified or is assumed to exist in a school building or buildings, the Regulations place a duty on PCBU's to have an asbestos management plan in place.

If the condition of the identified or assumed asbestos changes then you would need to alter the Asbestos Management Plan accordingly.

An asbestos management plan sets out how the identified asbestos or asbestos-containing material will be managed.

An asbestos management plan must include information about:

  • Where the asbestos has been identified - specific location, including building element and elevation, eg. Classroom 2, Block C, external cladding, external elevations.
  • How you plan to manage the asbestos risks (remove it, encapsulate it with a false wall or paint, leave it alone as it is in good condition, etc).
  • What procedures you will follow when work is to be undertaken.
  • How you will record incidents or emergencies involving asbestos.
  • A timetable for managing asbestos exposure risks (eg. priorities and dates for removal, reviews, circumstances and activities that could affect the timing of action), which could be reviewed in, for example, 12 months, or after an incident or emergency.
  • Procedures, including a timetable for reviewing and (if necessary) revising the asbestos management plan and asbestos documentation (note at a minimum this must be every 5 years).

You do not need to engage a surveyor to prepare your asbestos management plan. You can create your own asbestos management plans as long as you follow WorkSafe NZ guidance: Asbestos Management Plans (external link) (WorkSafe website).

All asbestos management plans must be in writing. They can be in hard copy or electronic form, as long as the legally required information outlined above is included.

Download a template: Asbestos Management Plan template [DOCX, 653 KB]

Asbestos Survey Requirements

When undertaking projects and associated works which are likely to disturb or damage asbestos (i.e. demolition, refurbishment or excavation), work cannot commence until an inspection of the specific area of the building, structure or soil that will be affected has been carried out to confirm whether asbestos or asbestos-containing material (ACM) is present.

If material cannot be identified but it is reasonably believed that it is asbestos or asbestos-containing material, you can assume the presence of asbestos.

The person procured to conduct asbestos surveys must be suitably qualified/certified to undertake asbestos sampling, testing and/or a survey report based on the work involved. See: Asbestos Surveyor Competencies (external link) (Worksafe website)

The surveyor should be briefed with a complete overview of the scope of work to be undertaken as part of the main project. Testing must be analysed by an accredited laboratory.

The person doing the inspection must use appropriate Respiratory Protective Equipment (RPE) as a minimum.

Consider how to provide and manage access to subfloor and ceiling spaces, particularly for buildings which are still in use.

When commissioning an asbestos survey, ensure that the correct type of survey is conducted.

Further information about different types of surveys can be found in the Full Asbestos Management Process [PDF, 174 KB].

Project-related Management of Asbestos

When managing projects where asbestos is present, or might be present, it is important that the risks be assessed as this will help determine the best control methods to ensure health and safety.

Asbestos risks need to be managed in a consistent way during all property projects within schools.

If you are managing or involved in a project you must ensure the following steps are followed:

  1. For any refurbishment or demolition works, you must have a Refurbishment and Demolition Survey of affected areas undertaken by a Competent Person (https://worksafe.govt.nz/topic-and-industry/asbestos/working-with-asbestos/key-duties-for-surveyors-and-assessors/ (external link) ). The Survey will detail the presence of any ACM and outline recommendations for managing the asbestos;
  2. If ACM is assumed, or identified by survey, you must ensure an Asbestos Management Plan is in place covering:
  3. If step #1 above does not identify or assume the presence of asbestos, proceed, but have arrangements in place in case asbestos is found or suspected as the work progresses, 
  4. If asbestos is found, and needs to be removed, engage a licensed asbestos removalist and have them prepare an Asbestos Removal Control Plan, 
  5. Notify WorkSafe NZ of the asbestos work at least 5 days before removal works are due to commence,
  6. Ensure boundary Air Monitoring is in place at all stages of the work to ensure there are no airborne fibres, 
  7. Consult, inform and coordinate at all stages of works with other PCBUs with shared duties on the project e.g. schools, contractors and project managers. 
  8. Ensure reasonable notice is given,
  9. Consult all persons who may be affected by the works, or who are considered within the immediate vicinity i.e. school community of parents and teachers, and neighbouring properties (residential and commercial), 
  10. Engage an independent Asbestos Assessor to conduct a clearance inspection following removal to confirm that the area is safe for re-occupation,
  11. If the project is a Ministry Led Project, provide the Asbestos Removal Control Plan to EIS H&S Team for approval before starting work.

Ministry Led Construction Projects

At times, the Ministry will manage Contracts for school property projects which may involve demolition or major refurbishment works.  The Ministry’s Asbestos Management Process is designed to ensure the safety of all people who may be affected by asbestos works - including pupils, teachers, contractors, visitors and neighbours.  It is mandatory for Ministry Led projects, and recommended for School Board projects.

The process reflects good practice and ensures compliance with the Regulations and should be followed by schools and Boards when managing asbestos in schools.

For Ministry-run construction projects, the Education Infrastructure Service will work with the school to identify and manage the presence of asbestos before and during the project.

Method for Transporting Buildings Containing Asbestos

The Health and Safety at Work (Asbestos) Regulations 2016 (the regulations) prohibit PCBUs from carrying out work involving asbestos, or from directing or allowing a worker to carry out work involving asbestos, unless the work is carried out in accordance with the regulations, is a response to an emergency, or the work is carried out in accordance with a method approved by WorkSafe NZ.

From time to time, the Ministry will move buildings from one location to another. Sometimes, these buildings may contain asbestos or Asbestos Containing Materials (ACM's). Buildings may be transported with asbestos provided that all known or presumed ACM’s that are likely to be damaged or disturbed during the transportation are removed or secured before transportation so that no asbestos fibres are released during transportation.

The WorkSafe NZ approved method should be followed when transporting buildings which may contain asbestos or Asbestos Containing Materials. The PCBU who carries out building transportation must ensure that:

  1. Before transportation, any known or presumed Asbestos Containing Material (ACM's) are identified and recorded, and that this record is provided to all PCBUs and workers carrying out the work to which this approved method applies; and
  2. All known or presumed ACM's that are likely to be damaged or disturbed during the transportation are removed before transportation, so far as is reasonably practicable; and 
  3. All Asbestos removal work is conducted in accordance with the requirements of the Health and Safety at Work Act 2016 (the Act) and the Health and Safety at Work (Asbestos) Regulations 2016; and 
  4. Any damaged components of the building that are known or presumed ACM's are secured so that during transportation no asbestos fibres are released, as far as is reasonably practicable. For example, damaged ACM's such as sheeting or cladding must be supported, sealed or removed; and 
  5. If transportation takes more than one day, the building is inspected for any possible damaged whenever it is parked; and 
  6. If inspection indicates that the building has been damaged and there is a risk of asbestos fibres being released, that the ACM's are re-secured in accordance with (4) above; and 
  7. If transportation occurs off-road or over uneven surfaces that are likely to loosen ACM's, that inspection and controls are carried out at a frequency to ensure, so far as is reasonably practicable, that no asbestos fibres are released; and 
  8. The building is inspected to check whether it has been damaged once it reaches its intended site.

A PCBU who carries out building transportation must be prepared to immediately respond to and resolve any event which could reasonably occur that may result in the release of asbestos fibres.

A PCBU who carries out building transportation must ensure that ACM that has been dislodged from the building during transportation is not reinstalled.

A PCBU must comply with all relevant requirements of the Act and the regulations when carrying out, or directing or allowing a worker to carry out, work to which this approved method applies, whether or not those requirements are referred to in this approved method. This includes, for example, requirements relating to demolition or refurbishment of a structure set out in subpart 4 of Part 4 of the regulations.

Removing Asbestos

When you commission asbestos removal, as a PCBU, you must ensure that the asbestos removal work is carried out by a licensed asbestos remover. The licensed asbestos remover you commission must prepare an "Asbestos Removal Control Plan”.

For all Ministry-led projects, no matter the size or nature of removal, Asbestos Removal Control Plans must be provided to the EIS Health and Safety team for review and agreement prior to works commencing.

Air Monitoring

The Ministry follows good practice for all removals and enforces air monitoring on all Ministry-led projects, no matter the size or class of removal. It is recommended that Boards of Trustees follow Ministry processes in relation to air monitoring.

Communication and Consultation

It is important to communicate to everyone who may be affected by the works. This includes:

  • The PCBU workers and any other people at the workplace.
  • The person who commissioned the asbestos removal work.
  • Any person at or in the immediate vicinity of the workplace (i.e. neighbours along boundary fences).
  • Anyone occupying premises in the immediate vicinity of the workplace (i.e. after school care programmes).

Communications must clearly state:

  1. Why the work is being undertaken
  2. What is involved with the work
  3. When it will start and finish
  4. The safeguards that will be in place during the works.

Use the Communications Guidance to help communicate clearly with your community:

Obtain a Clearance Certificate and update the Risk Register

When any asbestos removal work is finished, as a PCBU, you must ensure necessary clearances from an independent asbestos assessor are obtained before anyone not directly involved in the asbestos work can re-occupy the area.

You should also update the school’s asbestos information (both school and Ministry records), the risk register for the site (if applicable) and the more general risk register for the school.

Paying for asbestos management

The cost of managing or removing asbestos safely forms part of the project costs. If this causes a major overrun in a project budget, help may be available and you should speak to your School Property Advisor

See: Budget Plus and Unforeseen Work funding for school property work

Frequently asked questions and further information

To help schools and boards manage their risks (and to meet the requirements of the Health and Safety at Work Act 2015 (external link) ), the 11 key components of an effective health and safety system for schools is outlined:

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