Do I Need a Hazardous Materials Survey Before Demolition or Refurbishment in NSW?

Demolition and refurbishment can disturb building materials that have remained safely enclosed or undisturbed for decades. In older buildings, these materials may include asbestos, lead-containing paints and dust, synthetic mineral fibres, polychlorinated biphenyls and other legacy hazardous materials.

A hazardous materials survey, commonly referred to as a HAZMAT survey or hazardous building materials assessment, is used to identify these materials before they are disturbed and establish how they need to be managed during the proposed works.

In NSW, a complete HAZMAT survey is not automatically required simply because a Development Application has been lodged. However, demolition and refurbishment activities trigger specific work health and safety requirements relating to asbestos, and broader hazardous materials investigations are commonly required by project specifications, demolition contractors, certifiers, clients or conditions applying to the works.

For older or complex buildings, undertaking the assessment early can also reduce unexpected discoveries, variations and delays once demolition begins.

Is a Hazardous Materials Survey Required Before Demolition?

There is not a universal NSW requirement stating that every demolition project must have a document specifically titled a Hazardous Materials Survey or HAZMAT Report.

There are, however, specific legal duties relating to asbestos.

SafeWork NSW states that the asbestos register should be checked before demolition begins. If an asbestos register is not available, a competent person should inspect the structure for asbestos, and asbestos must be removed before demolition where required.

The current NSW Work Health and Safety Regulation 2025 contains specific provisions dealing with demolition and refurbishment, including review and provision of asbestos registers, determining the presence of asbestos and identification and removal of asbestos before demolition or refurbishment.

In practice, many projects go further than asbestos alone and undertake a broader pre-demolition hazardous materials survey to identify other hazardous building materials that may also affect demolition methodology, worker exposure, waste management and project cost.

What Is a Pre-Demolition Hazardous Materials Survey?

A pre-demolition HAZMAT survey is an assessment specifically designed around the building elements that will be disturbed during demolition.

This is important because a survey undertaken for routine management of an occupied building may not be sufficiently intrusive for demolition.

SafeWork NSW notes that a typical workplace asbestos register is developed to manage asbestos during normal use of a workplace and may not identify all asbestos that could be disturbed during demolition or refurbishment. A demolition or refurbishment survey may therefore involve more extensive sampling and investigation of materials in areas that would normally be inaccessible.

The same survey can also consider other hazardous materials such as lead and PCBs.

The level of investigation should therefore be based on the proposed works, rather than simply repeating an existing management survey.

Do I Need a HAZMAT Survey for a Development Application?

Not necessarily.

A Development Application does not automatically trigger a requirement for a HAZMAT survey simply because an application is being lodged.

The need usually arises because of what the proposed development involves.

Where a development includes demolition, substantial refurbishment, alterations to an older building or disturbance of potentially hazardous building materials, hazardous materials assessment may become relevant through:

the demolition or construction planning process; asbestos obligations under NSW WHS legislation; Council or consent requirements; certifier requirements; demolition contractor requirements; project specifications; or the need to establish removal and waste-management costs before construction begins.

NSW Planning notes that where more significant works require development consent, councils may impose asbestos-related consent conditions and certifiers have responsibilities relating to asbestos management.

For complying development involving demolition or building works, NSW planning requirements also include conditions dealing with the safe removal and disposal of asbestos. Planning NSW

So the better question is usually not:

“Does every DA need a HAZMAT report?”

It is:

“Will the proposed development disturb an existing building where asbestos or other hazardous materials may be present?”

If the answer is yes, some form of hazardous materials assessment should be considered during project planning.

What About Residential Demolition and Renovations?

Residential properties are different because they do not generally have workplace asbestos registers before works commence.

However, once a PCBU is engaged to undertake demolition or refurbishment at residential premises, the premises become a workplace for that PCBU.

SafeWork NSW's asbestos Code of Practice states that a PCBU undertaking demolition or refurbishment at residential premises must identify asbestos likely to be disturbed and ensure, so far as reasonably practicable, that it is removed before the work starts. The Code recommends a pre-demolition or pre-refurbishment survey by a competent person because residential premises are not required to maintain asbestos registers.

This can be particularly relevant to older houses undergoing demolition, substantial extensions or major renovations.

Why Might an Existing Asbestos Register Not Be Enough?

This is one of the most important distinctions when planning demolition.

An asbestos register is generally prepared to help manage asbestos while a building is occupied and operating normally.

It may identify accessible asbestos-containing materials such as fibre cement wall and ceiling linings, vinyl flooring, electrical components or other visible building products.

But demolition can expose entirely different areas.

SafeWork NSW specifically recommends considering whether inaccessible areas are likely to contain asbestos and whether those areas will be disturbed by the proposed demolition or refurbishment.

Potential concealed locations may include wall cavities, ceiling voids, beneath floor coverings, behind fixed linings, within service risers, around pipework, inside plant and equipment or beneath other building elements.

A building can therefore have a perfectly useful asbestos register for everyday management while still requiring further intrusive investigation before demolition.

How Intrusive Should a Pre-Demolition HAZMAT Survey Be?

The survey should reflect the extent of the proposed works.

If a project involves complete demolition, more extensive access may be appropriate than for a minor refurbishment affecting only one section of a building.

Intrusive investigation may involve controlled access behind wall or ceiling linings, beneath floor finishes, within cavities or other locations that will ultimately be disturbed.

That does not mean every wall in a building needs to be destroyed during the survey.

The objective is to develop a representative and project-specific investigation that addresses the building elements likely to be affected while recognising practical constraints such as structural safety, live services, occupied areas and accessibility.

Where an area cannot be safely assessed, that limitation should be clearly documented and further investigation undertaken before the material is disturbed.

What Does a Pre-Demolition HAZMAT Survey Assess?

The exact scope depends on the building and project.

A typical assessment may consider asbestos-containing materials, including both friable and non-friable ACM; lead-based paints and potentially lead-containing settled dust; synthetic mineral fibres associated with insulation products; PCBs associated with older electrical equipment and fluorescent light fittings; and other hazardous building materials or equipment relevant to the structure.

Older industrial facilities can require a particularly broad assessment because hazardous materials may occur within plant, pipework, insulation, electrical infrastructure, coatings and successive building modifications rather than simply in conventional wall and roof materials.

The assessment should therefore be developed from the age, construction and historical use of the building together with the proposed demolition or refurbishment scope.

Why Undertake the Survey Before Demolition Tendering?

There can be a significant commercial advantage in investigating hazardous materials before demolition works are priced.

If asbestos, lead contamination or other hazardous materials are discovered only after demolition has commenced, the project may need to stop while the material is assessed, contractors are engaged and removal requirements are established.

That can lead to variations, delays and additional mobilisation.

SafeWork NSW identifies reduced cost variations and reduced likelihood of unexpectedly discovering asbestos during demolition or refurbishment as benefits of undertaking a demolition or refurbishment survey.

A good HAZMAT survey can allow the project team to define known hazardous materials before tendering so that removal requirements can be incorporated into demolition scopes and contractor pricing.

It can also identify areas where uncertainty remains so appropriate allowances can be made before works commence.

What Happens If Hazardous Materials Are Identified?

Finding hazardous materials does not necessarily prevent a development from proceeding.

The findings are used to determine the appropriate management pathway.

Materials that will not be disturbed may sometimes remain in place under appropriate management, while materials affected by demolition or refurbishment may require removal before those works commence.

For asbestos, SafeWork NSW requires asbestos likely to be disturbed by demolition or refurbishment to be identified and, so far as reasonably practicable, removed beforehand.

Depending on the material and project, the next stage may include preparation of a removal scope, engagement of appropriately licensed contractors, asbestos air monitoring, clearance inspections, occupational hygiene monitoring, waste classification or further intrusive investigation.

Internal links: naturally link asbestos air monitoring, clearance inspections and waste classification to the relevant Confluence service pages.

What If Hazardous Materials Are Found During Demolition?

Unexpected hazardous materials should not simply be demolished because they were not listed in the original report.

If a previously unidentified material suspected of containing asbestos or another hazardous substance is encountered, work affecting that material should stop and the area should be assessed before disturbance continues.

This is particularly important where the original survey identified inaccessible areas or where demolition exposes previously concealed building elements.

For complex sites, an unexpected finds procedure can establish the process for isolating the area, obtaining specialist assessment and determining whether sampling, removal or other controls are required.

HAZMAT Survey vs Asbestos Survey

An asbestos survey concentrates specifically on asbestos-containing materials.

A Hazardous Materials Survey is broader.

Depending on the building, it may assess asbestos together with lead-based paint, lead dust, synthetic mineral fibres, PCBs and other legacy materials.

This distinction can become particularly important on older industrial, commercial and institutional buildings.

For example, removing asbestos may address one component of the demolition risk while deteriorated lead paint, contaminated ceiling dust or legacy electrical equipment still require separate management.

A broader HAZMAT survey allows these materials to be considered together as part of the demolition planning process.

When Should the HAZMAT Survey Be Undertaken?

Ideally, the investigation should be completed early enough to influence demolition planning and procurement.

For a redevelopment involving existing buildings, this may be during detailed design, preparation of demolition documentation or before demolition packages are issued for tender.

Undertaking it early provides time to resolve inaccessible areas, obtain laboratory results, define removal requirements and incorporate hazardous materials management into the works program.

Leaving the assessment until immediately before demolition can reduce those options and increase the likelihood that unexpected findings become a project delay rather than a manageable planning issue.

Frequently Asked Questions (FAQ):

Q: Is a hazardous materials survey mandatory before demolition in NSW?
There is no universal NSW requirement for every project to have a report specifically titled a hazardous materials survey. However, there are specific legal obligations relating to identifying and managing asbestos before demolition and refurbishment. A broader HAZMAT survey is commonly undertaken to address asbestos together with other hazardous building materials relevant to the works.

Q: Do I need a HAZMAT survey for a Development Application?
Not automatically. The requirement is generally driven by the proposed demolition or refurbishment works, applicable consent conditions, project requirements and WHS obligations rather than simply the lodgement of a DA.

Q: Is an existing asbestos register enough before demolition?
Not necessarily. SafeWork NSW notes that workplace asbestos registers may not identify all asbestos that could be disturbed during demolition or refurbishment. Further intrusive investigation may therefore be required.

Q: Does a pre-demolition HAZMAT survey need to be destructive?
It may need to include targeted intrusive investigation where hazardous materials could be concealed within building elements that will be disturbed. The required level of intrusion depends on the proposed works and access conditions.

Q: What materials are included in a HAZMAT survey?
Depending on the building, the assessment may consider asbestos, lead-based paint, lead dust, synthetic mineral fibres, PCBs and other hazardous building materials relevant to the property and proposed works.

Q: Should the survey be completed before getting demolition quotes?
Where practicable, yes. Identifying hazardous materials before tendering allows known removal requirements and remaining uncertainties to be incorporated into demolition scopes and pricing and may reduce unexpected variations during construction.

Pre-Demolition Hazardous Materials Surveys Across NSW

Confluence Environmental undertakes pre-demolition hazardous materials surveys, HAZMAT assessments and hazardous materials reporting across NSW for development, refurbishment and demolition projects.

Our team includes SafeWork NSW Licensed Asbestos Assessor capability and experience assessing residential, commercial and industrial buildings, complex former industrial facilities and multi-building redevelopment sites.

Where redevelopment also requires contaminated land assessment, Confluence can coordinate HAZMAT and contaminated land investigations through the same project team, helping reduce duplicated mobilisation and establish both above-ground and below-ground environmental constraints before works commence.

If demolition or refurbishment is proposed and you are unsure whether the existing asbestos or hazardous materials information is adequate, provide the building address, proposed works and any existing registers, plans or previous reports. We can review the information and develop an appropriate survey scope.