This is longer than our usual articles, but it was so important to make sure I covered everything. Once you start reading, you will soon get to grips about the challenging nature of Asbestos removal – Cheers, Ross.

The Project

In 2024 we were involved in a large-scale asbestos removal and demolition project in a 13 storey commercial building with an associated 5 storey car park.

The overall project included demolition of both the car park and portions of the building. The demolition contract was let to a main demolition contractor who subcontracted the asbestos removal to a specialist.

Asbestos was found in multiple locations including vinyl glue, window rope, pitted in concrete from previous demolition works, in pipework joints, in ducting etc. The removal of the asbestos was a significant operation at circa $1.5 million.

Asbestos Removal Control Plan (ARCP)

The Contractor (via the asbestos removal specialist) was required to produce an Asbestos Removal Control Plan (ARCP) which documented in detail the proposed methodology, procedures and risk mitigations to be put in place in order to carry out the asbestos removal.

The main contractor deferred largely to the specialist for the asbestos removal, which is understandable given the specialist nature of the work. Consequently however, it was apparent that their level of scrutiny of information provided was relatively low, and the asbestos removalist was pretty much left to their own devices.

We engaged with an independent expert to review the ARCP, to ensure its suitability and compliance to regulatory requirements.

Notwithstanding the acceptance of the ARCP, while works were happening on site there was a lack of clear visibility and auditing mechanism to monitor and ensure that the ARCP was being followed. When the main contractor was challenged to demonstrate that they were appropriately managing their sub-contractor’s works, or to validate the progress reports received, their common response was to state that access was not possible due to the asbestos works, or to “speak to the asbestos contractor”.    

Frustratingly, it felt like what was happening “behind the curtain” was secret and on a “need to know” basis; whilst ARCP’s (Asbestos Removal Control Plans) often include for vision panels into the asbestos removal areas for monitoring purposes these are often impractical to get to due to access constraints. Irrespective, it is difficult to assess what is actually happening through any such vision panel.

Like most project plans, ARCP’s are dynamic documents that are likely to change and evolve as the environment dictates. We found that the removalists often made good decisions to change approach as the environment dictated, but that this was not well documented or communicated by either the subcontractor or the main contractor.

As a result, this presented as an ongoing project created risk. The removalist generally struggled with turning their frequently evolving plan into writing, and often needed our help with this. Ironically, the assistance we gave to the sub-contractor (in the absence of the main contractor doing so) enabled us to better understand the process and any changes made to the ARCP.

A significant lesson learned is to ensure not only that the main contractor engages suitably qualified asbestos contractors, but that they have mechanisms in place to review and monitor the asbestos methodology; in the future we would certainly look to understand in much greater detail how the main contractor will approve and ensure compliance with the ARCP.

Clearance Certificates

In stripping asbestos from the commercial building, the plan was to clear a floor at a time working from the top down, with an independently obtained Clearance Certificate provided by the contractor for each floor as it was completed.  This was to allow the removal works to be closely followed by floor crack injection works to ensure the building’s structural integrity. The crack injection contractor was not able to progress works on a floor until independent clearance certificates had been issued.

The crack injection contractor was separately engaged by the Principal, but was identified as a Separate Contractor under the demolition contract. As such, the main contractor and their asbestos subcontractor reviewed the crack injection contractor’s methodology and safety paperwork to ensure that their works could be undertaken safely and without compromising the asbestos works.  The proposed injection methodology included floor grinding; no adverse comment was raised in regard to this by either the main contractor or the asbestos removal contractor.

Asbestos removal on the top two floors were completed, and the contractor provided Clearance Certificates accordingly, allowing the crack injection works to commence. As a matter of routine and added precaution, we arranged for some further independent asbestos testing to be undertaken across the floors that had been given a Clearance Certificate. This included testing in areas where floor grinding for the crack injection works were progressing. The tests identified asbestos contamination in some floors where grinding had taken place prior to the cracks being remediated.

Works were stopped immediately, and the apparent source of contamination was identified as the grinding that was done to expose the cracks prior to injection.

Interestingly, the Clearance Certificates identified that asbestos may still be present pitted in the concrete in the walls and ceilings, but not the floor.  When challenged, the contractor’s view was that if the independent assessor had been aware of the follow-on works, then they may have identified the possibility that it was in the floor.

Given that both the contractor and sub-contractor had reviewed the crack injection methodology and not raised any concerns, it was a disappointing outcome. As the crack injection contractor was a Separate Contractor, this resulted in a lack of clarity by the main contractor regarding their health and safety obligation.

Lessons Learned

The key learnings from the exercise were to ensure that the right people are furnished with and review all relevant information.

This includes:

• A Main Contractor’s obligation to fully understand and have in place processes to review, approve and monitor all works of their asbestos sub-contractors.
• Ensuring appropriate contractual relationships; as the crack injection contractor was a Separate Contractor, the main contractor had no direct relationship with them and a lack of clarity existed on their health and safety obligations.
• Ensuring that the contractor, if they do not have the expertise in-house, engages the services of appropriately qualified and vetted specialists, tasked with overall management of their sub-contracted asbestos removalists.
• Processes to monitor and approve any proposed change to the ARCP

Understanding the scope, limits and parameters of Clearance Certificates – obtained directly from the issuer of the Certificate  

For more information or a chat about Asbestos removal contact ross.meikle@teamprojects.nz