The asbestos removal control plan is the document that decides how a removal will actually be done, written before anything is disturbed. It is required by model reg 464, must be kept and made available under reg 465, and is almost always the first document an inspector asks to see.
An asbestos removal control plan is a document that identifies the specific control measures a licence holder will use to ensure workers and other persons are not at risk when asbestos removal work is being conducted. It is similar to a job safety analysis (JSA) but is focused on the specific control measures necessary to minimise any risk from exposure to asbestos.
Model Code of Practice, How to safely remove asbestos, §3.5
Who prepares it, when, and who gets it
| Who must prepare it | The licensed asbestos removalist — not the client, not the builder, not the assessor |
| When it is required | For any licensed asbestos removal work commissioned — that is, Class A or Class B. It is not mandatory for unlicensed work, though the Code encourages preparing one voluntarily, and it is good practice |
| When it must exist | Before the work commences. A plan written after the fact is not a plan |
| Consultation | Prepared in consultation with the commissioning party, workplace management and workers, so far as is reasonably practicable |
| Who gets a copy | The person who commissioned the work |
| Where it is kept (reg 465) | At the workplace until the removal work is complete, readily accessible on site to other PCBUs, workers and their representatives, and to occupants where the premises are residential; and available for inspection under the WHS Act |
| Retention | Until the work is complete — but if a notifiable incident occurs in connection with the work, for at least two years after the incident |
The Code allows the structure of a control plan to be generic, but each plan must address the specific requirements for each job. A template is fine. A template submitted unchanged is not a control plan — it is stationery.
The two mandatory elements
The regulation itself is short. Reg 464 requires the plan to include details of:
- How the asbestos removal will be carried out, including the method to be used and the tools, equipment and personal protective equipment to be used; and
- The asbestos to be removed, including the location, type and condition of the asbestos.
The Code adds: “You should also attach specifications or drawings that are relevant to the asbestos removal work, to the asbestos removal control plan to provide additional information about the asbestos.”
That is the whole of the mandatory statutory content, and its brevity is deliberate. The regulation sets a floor of two elements. The Code of Practice, at Appendix B, builds a comprehensive plan on top of that floor — and it is Appendix B, not reg 464, that a competent plan is actually measured against.
Appendix B — the full contents matrix
Reproduced from the model Code of Practice How to safely remove asbestos (July 2020 edition), Appendix B. In this edition the appendix is not a bullet list but a four-column Yes/No matrix, splitting the answer by whether the work is on buildings and structures or on plant and equipment, and whether the material is friable or non-friable.
Read down the column that matches your job. The four columns are the reason a single generic template rarely survives contact with a real scope: an enclosure line that is “Yes” for friable work is “No” for non-friable, and a plant job and a building job diverge on temporary facilities.
| Item | Buildings & structures | Plant & equipment | ||
|---|---|---|---|---|
| Friable | Non-friable | Friable | Non-friable | |
| Notification | ||||
| Notification requirements have been met and required documentation will be on site (e.g. removal licence, control plan, training records) | Yes | Yes | Yes | Yes |
| Identification | ||||
| Details of asbestos to be removed identified (e.g. the locations, whether asbestos is friable or non-friable, its type, condition and the quantity being removed) | Yes | Yes | Yes | Yes |
| Preparation | ||||
| Consult with relevant parties (health and safety representative; workers; person who commissioned the removal work, licensed asbestos assessors) | Yes | Yes | Yes | Yes |
| Assigned responsibilities for the removal | Yes | Yes | Yes | Yes |
| Program commencement and completion dates | Yes | Yes | Yes | Yes |
| Emergency plans | Yes | Yes | Yes | Yes |
| Asbestos removal boundaries, including the type and extent of isolation required and the location of any signs and barriers | Yes | Yes | Yes | Yes |
| Control of other hazards including electrical and lighting installations | Yes | Yes | Yes | Yes |
| PPE to be used, including RPE, identified | Yes | Yes | Yes | Yes |
| Removal | ||||
| Details of air-monitoring program / control and clearance | Yes | No | Yes | No |
| Waste storage and disposal program | Yes | Yes | Yes | Yes |
| Method for removing the asbestos (wet and dry methods) | Yes | Yes | Yes | Yes |
| Asbestos removal equipment (e.g. spray equipment, HEPA-filtered H-Class industrial vacuum cleaners, cutting tools) | Yes | Yes | Yes | Yes |
| Details of required enclosures, including their size, shape, structure, etc., smoke testing of enclosures and the location of negative pressure exhaust units | Yes | No | Yes | No |
| Details on temporary buildings required by the asbestos removalist (e.g. decontamination units) including details on water, lighting and power requirements, negative pressure exhaust units and the locations of decontamination units | Yes | May be required depending on the job | Yes | May be required depending on the job |
| Other risk control measures to prevent the release of airborne asbestos fibres from the asbestos removal work area | Yes | Yes | Yes | Yes |
| Decontamination | ||||
| Detailed procedures for workplace decontamination, the decontamination of tools and equipment, personal decontamination and the decontamination of non-disposable PPE and RPE | Yes | Yes | Yes | Yes |
| Waste disposal | ||||
| Method of disposing of asbestos wastes, including the disposal of protective clothing | Yes | Yes | Yes | Yes |
| Method of disposing of asbestos wastes, including the structures used to enclose the removal area | Yes | No | Yes | Yes |
| Clearance and air monitoring | ||||
| Name of the independent licensed asbestos assessor or competent person engaged to conduct air monitoring (if any) | Yes | No | Yes | No |
| Consultation | ||||
| Consult with any people who may be affected by the removal work, including neighbours | Yes | Yes | Yes | Yes |
Appendix B appears at different page numbers across editions: model Code (July 2020) p.72; South Australia (February 2024) p.74; New South Wales p.73; Queensland (2021) around p.70. Western Australia has not adopted the model code and publishes its own, dated 14 July 2022.
Why it matters
The safety case
- It forces the method decision before the site is disturbed — wet or dry, enclosure or glove bag, which tools — rather than improvising once fibres are already mobile.
- It is the vehicle for consultation. The commissioning party, site management, workers and residential occupants all get sight of it before work starts.
- It makes the plan contestable in advance. Because it must be readily accessible on site, a health and safety representative, a builder or a homeowner can read it and challenge it while changing it is still cheap.
- It ties together emergency procedures, decontamination and waste — the three areas where asbestos jobs most often go wrong after the removal itself has gone fine.
- For Class A work, it is the document against which the independent assessor’s air monitoring and clearance are effectively benchmarked. If the plan says three negative pressure units and a three-stage decontamination unit, that is what should be there.
The legal case
- Preparing it is a standalone duty. Failing to prepare one is an offence whether or not anybody was exposed to anything.
- The requirement to retain it for two years after a notifiable incident tells you its evidentiary purpose: it is the primary record of what was planned, against which what happened will be compared.
- Being available for inspection under the WHS Act makes it the first document an inspector asks for, and the quality of it sets the tone for everything that follows.
- It is direct evidence of whether the PCBU discharged the duty to eliminate or minimise risk so far as is reasonably practicable — the central question in any Category 1, 2 or 3 prosecution.
The test we apply when we read one
Could a competent removalist who has never seen this site execute this job from this document, and could an inspector standing on site tell whether they had? A control plan that describes the boundary, the enclosure, the negative pressure arrangement, the decontamination route, the waste path and the monitoring positions with enough specificity to be checked is doing its job. One that says “asbestos will be removed using wet methods and appropriate PPE” is not, however many pages it runs to.
Control plan or safe work method statement?
They are separate documents under separate provisions, and on a licensed removal job both are usually required. The confusion is common enough to be worth setting out plainly.
Asbestos removal is high risk construction work. Model reg 291 (“Meaning of high risk construction work”) captures work that involves, or is likely to involve, disturbing asbestos. That triggers the SWMS provisions at regs 299–302, quite separately from the ARCP duty at reg 464.
| Asbestos removal control plan | Safe work method statement | |
|---|---|---|
| Model regs | 464, 465 | 291, 299–302 |
| Trigger | Licensed asbestos removal work | Any construction work disturbing asbestos, licensed or not |
| Focus | Asbestos-specific controls, from setup through to clearance | All high risk construction work hazards on the activity |
| Prepared by | The licensed asbestos removalist | The PCBU carrying out the high risk construction work |
| Copy to | The person who commissioned the work | The principal contractor (reg 301) |
| Retention | Until the work is complete; two years after a notifiable incident | |
A SWMS must identify the work that is high risk construction work, specify the hazards and the risks to health and safety, describe the control measures, and describe how those measures are to be implemented, monitored and reviewed. It must exist before the high risk construction work starts and be prepared in consultation with affected workers.
The non-obvious consequence
An unlicensed removal of, say, 6 m² of fibro sheeting needs no control plan but still needs a SWMS — because disturbing asbestos is high risk construction work regardless of quantity. Small jobs routinely get this backwards, producing neither document on the assumption that being under the threshold means being outside the paperwork.
A note on sourcing: the asbestos Code of Practice does not itself discuss SWMS. The link above comes from reading the asbestos Code and the Construction Work Code together, which is what the regulations require in practice, but it is an inference from two Codes rather than a single stated rule.
Notification, signage and access
The control plan sits inside a cluster of duties that all bite before or at the start of the work.
Notification — five days (reg 466)
A licensed asbestos removalist must notify the regulator in writing at least five days before licensed removal work commences. Queensland, New South Wales and Western Australia all state the same period; Queensland uses Form 65.
For emergencies, Queensland requires immediate telephone notification followed by written notice within 24 hours. The events requiring immediate phone notice on 1300 362 128 are: an emergency removal following a sudden and unexpected event that may expose people to respirable fibres, or an unexpected breakdown needing immediate rectification; fibre levels above 0.02 fibres/mL during Class A work; and emergency demolition where a structure containing asbestos is structurally unsound or collapse is imminent. Queensland’s class exemption covers removal necessary because of flooding or severe weather — work done months after such an event does not qualify.
Two related duties: reg 467 requires the licensed removalist to tell certain people about the intended work, and reg 468 requires the person with management or control of the workplace to do the same. Between them that covers workers, occupiers, owners, the person who commissioned the work, and operators of nearby businesses.
Signage and barricades (reg 469)
Signs must be placed to inform people nearby that asbestos removal work is taking place, positioned at all of the main entry points to the work area, and must comply with AS 1319:1994 Safety signs for the occupational environment. On barricading, the Code distinguishes by material: for friable asbestos, solid barricades should be used; for non-friable work of short duration, PVC barrier tape may be appropriate. Distance should account for whether the material is friable and for the activity around the removal area.
Limiting access (reg 470)
Access is limited to workers engaged in the removal work, other people associated with it, and people allowed to be there under the regulations or another law. Everyone with access must comply with any direction given by the licensed asbestos removalist.
Decontamination and waste (regs 471, 472)
Decontamination facilities must be available for the work area, any plant used in it, and the workers. Asbestos waste must be contained and labelled in accordance with the GHS before it leaves the removal area, and disposed of as soon as practicable at a site authorised to accept asbestos waste. Contaminated disposable PPE must be sealed and labelled in a container before being removed from the work area. Parallel provisions for asbestos-related work sit at regs 483 and 484.
Transport and disposal are also governed by environmental law rather than WHS law alone. In Queensland that means the Environmental Protection Act 1994, the Environmental Protection Regulation 2019 and the Environmental Protection (Waste Management) Regulation 2000, which between them regulate waste transport, disposal facility licensing and contaminated land notification.