Asbestos and hazardous materials in industrial upgrades and make-goods

By Brenscot Builders | Last reviewed September 2026

Not every project is a new building on a clear site. Owners and tenants also extend older warehouses, refit offices, widen doors, replace roofs and carry out make-good works at the end of a lease. In older industrial buildings, asbestos and other hazardous materials can sit undisturbed for decades until someone cuts, drills or demolishes.

This article explains what Queensland law requires and how to build it into a project. It is not a guide to handling asbestos. That work belongs to trained and licensed people.

The short answer

If the building was constructed before 1990, assume it contains asbestos until a competent person shows otherwise. Queensland law requires an asbestos register for most workplaces, and requires asbestos that is likely to be disturbed to be identified and, so far as is reasonably practicable, removed before refurbishment or demolition starts. Removal of friable asbestos, or more than 10 m2 of non-friable asbestos, must be done by a licensed removalist, followed by an independent clearance inspection.

Where asbestos is found in industrial buildings

Asbestos was widely used in building products until the late 1980s, and all forms were banned nationally from 31 December 2003. In older factories and warehouses it is commonly found in:

• Corrugated asbestos cement roof and wall sheeting, gutters and downpipes
• Flat asbestos cement sheet in offices, amenities, eaves and partitions
• Vinyl floor tiles and their adhesive
• Backing boards in old electrical switchboards
• Lagging on pipes, boilers and ovens
• Gaskets, seals and friction materials in plant
• Fire doors
• Mastics, sealants and window putty

Friable asbestos can be crumbled to powder by hand, such as lagging and sprayed insulation. It is the higher risk. Non-friable (bonded) asbestos, such as cement sheeting, is bound in a matrix and is lower risk while intact, but weathered, broken or fire-damaged sheeting can release fibres.

Asbestos cement roofs carry a second hazard. They are brittle, will not support a person's weight and are a recognised cause of fatal falls. Queensland's work health and safety regulation also prohibits using high-pressure water or compressed air on asbestos, so an asbestos cement roof must never be pressure cleaned.

What Queensland law requires

The duties are in Chapter 8 of the Work Health and Safety Regulation 2011 (Qld) and the two asbestos codes of practice.

Asbestos register and management plan. The person with management or control of a workplace must keep an asbestos register, prepared by a competent person. A register is not required only where the building was constructed after 31 December 1989 and no asbestos has been identified or is likely to be present. Where asbestos is present or assumed, a written asbestos management plan is also required. Both must be kept current and be available to workers and contractors.

Before refurbishment or demolition. The register must be reviewed before the work and given to the person doing it. Asbestos likely to be disturbed must be identified and, so far as is reasonably practicable, removed before the work starts. A standard register often covers only accessible areas, so planned works usually need a more intrusive survey of the specific areas affected, such as inside wall cavities, above ceilings and under floor coverings.

Licensed removal.

Notification. A licensed removalist must notify Workplace Health and Safety Queensland at least five days before licensed removal work starts.

Air monitoring. Required for friable (Class A) removal, carried out by an independent licensed asbestos assessor.

Clearance. After licensed removal, the area cannot be reoccupied until a clearance inspection has been done and a clearance certificate issued: by an independent licensed asbestos assessor for Class A work, and by an independent competent person for Class B work.

Disposal. Asbestos waste must be contained, transported and disposed of at a facility licensed to accept it.

Other hazardous materials

A hazardous materials survey before major works looks for more than asbestos:

• Lead paint. Common on older steelwork and timber. For house paint, the recommended maximum lead content was reduced from 50% before 1965 to 1% in 1965, 0.25% in 1992 and 0.1% in 1997. Industrial coatings on old steelwork, such as red lead primers, can contain far more. Treat old paint as lead-bearing until tested. Sanding, grinding or flame-cutting lead-painted steel creates toxic dust and fume.
• Synthetic mineral fibre (SMF). Glasswool and rockwool insulation. An irritant that needs controls when disturbed.
• PCBs. Polychlorinated biphenyls, found in old capacitors, transformers and fluorescent light fittings.
• Refrigerants. Older air-conditioning and cold room plant may contain ozone-depleting gases, which must be recovered by licensed technicians.
• Contaminated land. Former industrial uses may have contaminated the soil. Queensland's Environmental Management Register and Contaminated Land Register record land used for notifiable activities, such as fuel storage, and land known to be contaminated. A search should be part of due diligence before buying, and before any excavation.
• Silica dust. Cutting, grinding and drilling concrete, tilt panels, blocks and tiles produces respirable crystalline silica, which causes silicosis. Queensland has a code of practice for managing silica dust in construction, and strengthened regulations for processing crystalline silica materials, adopted nationally and in Queensland, took effect on 1 September 2024. Expect wet cutting, on-tool dust extraction and respiratory protection on any compliant site.

A sensible process for an upgrade

1. Check the history. Construction date, the existing asbestos register, previous removal records and the land's register status
2. Commission a survey suited to the works before pricing demolition or strip-out
3. Build the findings into the scope and programme, including removal, clearance and any temporary works
4. Use licensed removalists, and an assessor who is independent of the removalist
5. Separate the work areas and manage other trades and occupants around the removal
6. Get the clearance certificate before the next trade starts
7. Update the asbestos register for whatever remains in the building

The most expensive asbestos is the asbestos found halfway through a job. Work stops, the area may need decontamination, and the programme and cost are no longer in your control.

Leases and make-goods

Asbestos is a frequent cause of disputes at the end of a lease. Typical triggers are a make-good scope that requires removing fitout fixed to asbestos sheeting, a register that was never given to the tenant, or contractors starting strip-out without a survey. Owners should keep the register current and hand it over at the start of each lease. Tenants should ask for it before signing and before starting any fitout. Buyers should obtain the register and the records of past works as part of due diligence.

Frequently asked questions

How do I know if my warehouse contains asbestos?

You can't tell by looking. If the building dates from before 1990, assume it does until a competent person has inspected and, where needed, had samples tested by an accredited laboratory.

Is an asbestos register a legal requirement in Queensland?

Yes, for workplaces, unless the building was constructed after 31 December 1989 and no asbestos has been identified or is likely to be present.

Can I remove asbestos myself?

In a workplace, only up to 10 m2 of non-friable asbestos can be removed without a licence, and the safety requirements still apply. Anything more, or any friable asbestos, needs a licensed removalist. We recommend using a licensed removalist regardless of quantity.

Can solar panels be installed on an asbestos cement roof?

It isn't practical or safe. The sheeting is brittle, can't be walked on, and drilling it disturbs asbestos. Replace the roof first.

Who pays for asbestos removal in a leased building?

It depends on the lease. Generally the owner is responsible for the building fabric, but make-good and fitout clauses vary. Get legal advice on the specific lease.

Sources

• Work Health and Safety Regulation 2011 (Qld), Chapter 8 (asbestos), including sections 425, 429, 446, 458, 466 and 473 to 475
• How to manage and control asbestos in the workplace Code of Practice 2021; How to safely remove asbestos Code of Practice 2021; Demolition work Code of Practice 2021; Managing the risk of falls at workplaces Code of Practice 2021, WorkSafe Queensland
• Managing respirable crystalline silica dust exposure in construction and manufacturing of construction elements Code of Practice 2022, WorkSafe Queensland
• Department of Climate Change, Energy, the Environment and Water, Lead in house paint
• Queensland Government, Environmental Management Register and Contaminated Land Register; Environmental Protection Act 1994, Schedule 3

General information only

This article is general information, current as at September 2026. It is not legal or work health and safety advice, and it is not guidance on how to handle asbestos. Do not disturb suspected asbestos. Engage a licensed asbestos assessor and licensed removalist, and obtain advice specific to your building.

Planning an industrial warehouse?

Talk to Brenscot about your site or your requirements. Call 0480 800 077, email enquiries@brenscot.com.au, or start an enquiry. You can also read how we work.