A ceiling tile is damaged during an office fit-out. A contractor drills into an old wall to run new cabling. A warehouse roof starts to deteriorate after years of weather exposure. These are the moments when commercial property asbestos obligations become a practical safety issue, not just a line item in a facilities folder.
For Victorian property owners, employers, facility managers and builders, asbestos duties are about preventing exposure before work begins. The right response depends on the building’s age, the material’s condition, who controls the site and the work being planned. A clear register, sensible maintenance controls and licensed help where required can protect workers, occupants, contractors and your project timeline.
Who holds asbestos responsibilities in a commercial property?
There may be more than one duty holder at a commercial site. Under Victoria’s occupational health and safety framework, the party with management or control of the workplace has key responsibilities for asbestos risks. That may be the building owner, a tenant, a facilities manager, a principal contractor or an employer, depending on the lease and the work being carried out.
This is why assumptions cause trouble. A landlord may own the building, but a tenant arranging an internal refurbishment still needs to ensure contractors have the information required to work safely. A builder managing a demolition or renovation must also identify asbestos risks before disturbing materials. Each party needs to understand their role and communicate early.
The practical question is not simply, “Who owns the asbestos?” It is, “Who can make the site safe and provide accurate information before people start work?” If that answer is unclear, resolve it before issuing work orders or allowing trades on site.
Commercial property asbestos obligations before work starts
Many commercial and industrial buildings built before 31 December 2003 may contain asbestos-containing materials. Common examples include cement sheeting, roof and wall cladding, vinyl floor tiles, adhesives, textured coatings, electrical backing boards, pipe insulation, fire doors and eaves. Appearance alone is not enough to confirm whether a material contains asbestos.
Before refurbishment, maintenance, demolition or intrusive services work, arrange a suitable asbestos inspection or audit. The scope should match the planned work. A general management survey may help identify materials that could be disturbed during normal occupation. More invasive work usually requires a targeted refurbishment or demolition assessment, including areas concealed behind linings, ceilings, plant or flooring where reasonably accessible.
Leaving the investigation until trades are already on site can create delays, variation costs and a potential exposure incident. It also puts contractors in an unfair position. They should know what they are working around before they cut, drill, sand, remove or demolish.
The asbestos register is a working document
For applicable workplaces, an asbestos register is not paperwork to file away. It should identify known or presumed asbestos, record its location and condition, and be available to workers, contractors and others who may need it. Where asbestos has not been identified, the register should reflect the assessment made rather than giving a false sense of certainty.
The register needs review when conditions change. That includes after removal work, damage, refurbishment, a new asbestos finding or a change in the building layout. An outdated register can be as risky as having none, particularly where new contractors rely on it to plan work.
A practical register should be easy to use on site. Include clear location descriptions, photographs where useful, material condition and any control measures. “Asbestos in plant room” is not enough for a contractor trying to locate a cable route or service a unit. Accurate records save time and reduce uncertainty.
A management plan turns records into action
Where asbestos is identified or presumed, a site-specific asbestos management plan helps set out how it will be controlled. It should cover who is responsible for managing the material, how its condition will be monitored, how workers and contractors will be informed, and what happens if damage or disturbance occurs.
Not every asbestos-containing material needs immediate removal. Intact, non-friable asbestos cement sheeting in good condition may often be managed safely in place. Removal may be the better option where material is deteriorating, likely to be disturbed repeatedly, located in a high-traffic area or standing in the way of planned construction work.
The decision should be based on risk, not fear or convenience alone. Good management can be appropriate, but it requires ongoing inspection and clear controls. A damaged sheet in a loading area or a crumbling insulation material near plant servicing is a very different risk from a sealed, undisturbed panel in an inaccessible location.
Controlling asbestos during maintenance and renovations
Routine maintenance is one of the most common causes of accidental disturbance. Installing data points, repairing a leak, replacing lights, servicing mechanical plant and upgrading fire systems can all involve hidden asbestos-containing materials.
Before approving works, provide contractors with relevant asbestos information and require them to confirm their proposed method. If material could be disturbed, stop and seek competent advice. Do not allow workers to rely on visual judgement, and do not treat “minor works” as automatically low risk.
For larger projects, asbestos should be addressed during planning and tendering, not after demolition crews arrive. The project team should allow enough time for surveying, laboratory analysis where required, removal, waste disposal, clearance and documentation. Fast turnaround is valuable, but rushed decisions around asbestos are rarely economical.
A sensible pre-start process should cover four points:
- confirm the current asbestos register and whether the proposed work reaches concealed areas;
- identify whether testing, a further audit or removal is required before work begins;
- give contractors the relevant asbestos information and site controls; and
- retain records of removal, clearance and any register updates.
This process is especially useful for multi-tenanted offices, schools, retail centres, factories and government buildings, where several contractors and occupants may be affected by the same works.
When licensed asbestos removal is required
Asbestos removal in Victoria is regulated, and the licence class matters. Friable asbestos, which can be crumbled or reduced to powder by hand pressure when dry, presents a higher exposure risk and requires a Class A licensed asbestos removalist. Non-friable asbestos removal may require a Class B licensed removalist where the amount and type of work meet regulatory thresholds.
There are limited circumstances in which small amounts of non-friable asbestos can be removed without a licence, but commercial property managers should not treat that as a shortcut. The material still needs to be handled safely, workers need suitable training and controls, and disposal must be lawful. If the material is damaged, difficult to access, overhead, mixed with other demolition waste or likely to create dust, licensed removal is the sensible course.
Removal should include proper isolation, warning signage, controlled work methods, decontamination arrangements and compliant asbestos waste handling. Waste must be packaged, labelled and taken to an approved disposal facility. Putting suspect material into general building rubbish is unacceptable and can expose your business to significant clean-up costs.
For certain removal work, independent clearance inspection and certification are required before the area is returned to normal use. Even where a formal clearance is not prescribed, a documented post-removal inspection gives property managers confidence that the work area has been left clean and safe.
What to do if asbestos is damaged or discovered unexpectedly
If suspected asbestos is damaged during works, stop work immediately. Keep people away from the area, prevent further disturbance and restrict access. Do not sweep, vacuum with a standard commercial vacuum or attempt to clean debris using compressed air.
The next step is to arrange competent assessment. Depending on the situation, this may involve sampling, air monitoring, a clean-up plan and licensed removal. The response should be proportionate to the material, extent of disturbance and likelihood of exposure, but it should never be improvised by untrained workers.
Document what happened, who was present and the controls put in place. This information helps manage the immediate issue and improves future planning. It may also be relevant to your duties under Victorian health and safety laws, lease requirements and contractor management processes.
Keep compliance practical, not performative
The strongest asbestos systems are the ones people actually use. A current register that contractors can access, a clear approval process for intrusive work and a reliable specialist on call will do more for site safety than a lengthy plan nobody reads.
Asbestos Audits Australia assists commercial clients across Melbourne and Victoria with asbestos audits, removal and practical advice for planned works and unexpected discoveries. When the building is older, the records are incomplete or the scope is changing, getting a professional assessment early gives you a clearer path forward and helps keep people safe.

