Friable asbestos is removed behind plastic, inside a sealed enclosure under negative pressure. Nobody outside can see what is happening. The controls either worked or they did not, and the only way to know is to measure — which is why the law inserts a licensed third party whose commercial interest is not served by the job finishing quickly.
The removalist cannot mark their own homework. That is the whole idea, and everything on this page follows from it.
What the independence test actually says
This is worth quoting exactly, because it is very widely misstated — including, in our experience, in tender documents and scopes of works written by people who should know better.
The assessor or competent person must:
- not be involved in the removal of asbestos for that specific job; and
- not be involved in a business or undertaking involved in the removal of the asbestos for that specific job.
Consistent across the 2011 model Code, the 2018 model Code and SafeWork SA’s assessor guidance.
The common misstatement, corrected
The test is often quoted as requiring the assessor to be “not connected with the removalist or the person who commissioned the removal”. That last limb does not exist. The Code does not exclude a connection with the person who commissioned the removal.
This matters practically. An asset owner may engage an assessor directly, may have a standing relationship with them, may have used them for years across a portfolio — and indeed reg 475 puts the duty to engage the assessor on the person commissioning the work, which would be an odd design if that relationship were itself disqualifying. What is excluded is a connection with the removal.
Two refinements that matter on real jobs
The test is job-specific, not relationship-specific
The words “for that specific job” appear in every version of the test. A firm is not permanently disqualified from assessing a particular removalist’s work. It is disqualified from assessing the job it worked on. An assessor who supervised the removal on Tuesday cannot clear it on Wednesday; an assessor who has never touched this job may clear it regardless of what they were doing on the removalist’s last site.
The Class B test is narrower than the Class A test
The Queensland Code of Practice sets out the two tests separately, and they are not the same.
| Class A — licensed asbestos assessor | Class B — competent person | |
|---|---|---|
| Limb 1 | Not involved in the removal of asbestos for that specific job | Not involved in the removal of the asbestos for that specific job |
| Limb 2 | Not involved in a business or undertaking involved in the removal | — no equivalent limb — |
On the Code’s wording, a competent person employed by the removal company but personally uninvolved in that particular job could issue a Class B clearance — whereas for Class A the corporate connection alone is disqualifying. That asymmetry is the clearest single expression of why Class A is the stricter regime: for friable work, being personally uninvolved is not enough.
This asymmetry rests on the Queensland Code’s wording, which we have not been able to check against the operative text of the regulation as enacted. It is a real and useful distinction, and we set it out because it explains the structure — but verify it in your own jurisdiction before relying on it to staff a job.
Exemptions exist, and they go to the regulator
The 2018 model Code contemplates rare cases where independence is not reasonably practicable — remote sites being the obvious example. In those cases a PCBU may apply to the regulator for an exemption under Part 11.2 of the WHS Regulations. The relevant point is where the decision sits: with the regulator, in advance, on an application. It is not a judgement call to be made on site on the day.
What a licensed asbestos assessor is
A licensed asbestos assessor is an individual — never a company — licensed by the regulator under reg 489. Safe Work Australia identifies three licence categories under the model regulations: Class A removalist, Class B removalist, and licensed asbestos assessor, who “can perform air monitoring, clearance inspections, and issue clearance certificates”. Reg 490 provides for mutual recognition of assessor licences across jurisdictions.
The fact that the licence attaches to a person rather than a business is not an administrative detail. The judgements an assessor makes — whether an area is free from visible contamination, whether a monitoring position is representative, whether to stop a job — are personal ones, and the licence that can be suspended for getting them wrong is a personal licence.
Qualification — reg 495(b), one of two routes
- The national unit of competency Conduct asbestos assessment associated with removal (CPCCDE5001 / CPCCBC5014A); or
- A tertiary qualification in asbestos assessment or management, occupational health and safety, industrial hygiene, science, building construction, or environmental health.
Experience — reg 495(a)
Demonstrated knowledge and skills through work experience covering: setting up air monitors; determining monitor locations; writing air monitoring reports; conducting clearance inspections; and issuing clearance certificates.
| Regulator | Minimum experience stated |
|---|---|
| SafeWork SA | Documented involvement in at least three Class A removals (friable asbestos) performed over a period of two years, with verifiable referee details |
| SafeWork NSW | Experience supervised by a licensed asbestos assessor, demonstrating involvement in at least three separate Class A jobs within the previous five years. NSW also accepts a third training pathway — Conduct air monitoring and clearance inspections for asbestos removal work — plus a Diploma-level qualification, with a minimum age of 18 |
Anyone applying should work from their own regulator’s current guidance rather than from a national summary, this one included.
Why this site is published by an assessor
Environics (QLD) Pty Ltd holds licensed asbestos assessor credentials. On any job where we monitor the air or issue the clearance, we are barred by reg 473 and reg 475 from having been involved in the removal — and barred from being part of a business that was.
That is a constraint, and it is the reason to trust what is on this site. We do not quote for removal work. We do not subcontract it, and we do not receive anything for referring it. When this site says a method is inadequate, an enclosure specification is thin or a clearance should have been refused, there is no removal contract at the other end of the opinion.
It also shapes what is not here. There is no directory of removalists, no “recommended contractors” page and no logos. Publishing one would compromise exactly the independence that makes the rest of it worth reading.
The structural point, in one sentence
The regulations do not ask you to trust the removalist — they require a separately licensed person, with their own licence to lose, to measure the result and sign for it, and that is a better design than trust.
A worked example of how the independence sits in a real contracting chain →