Who must keep an asbestos register at a Victorian workplace?

A Victorian person with management or control of a workplace, or an employer with relevant management or control, must identify asbestos under their control so far as reasonably practicable and maintain an up-to-date register where it is present or assumed to be present. The register must show enough about its location and condition for workers and contractors to avoid disturbing it. WorkSafe Victoria's current asbestos-management guidance says it must be reviewed when the asbestos condition changes or it is removed, enclosed or sealed, and in any event reviewed every five years and revised if necessary.

This is a Victorian workplace management task under the Occupational Health and Safety Act 2004 and Occupational Health and Safety Regulations 2017. The existing Complys national asbestos-removal guide owns removal licence classes and regulator notifications. A register is different: it tells people where asbestos is, what condition it is in and which work may disturb it before a removal job is considered. Victoria's duties should not be replaced with a model-WHS template from another state without checking the local rule.

Establish who manages or controls the workplace

The responsible person is not always the tenant who occupies the space. WorkSafe says management or control may sit with an owner, employer, property manager or another person who can decide and implement changes to a structure, premises or plant. In a leased warehouse, the building owner may control the roof and fixed services while the tenant controls an older machine with asbestos-containing brakes. Both must examine their actual sphere of control. A clause in a lease can help allocate practical information-sharing, but it cannot simply erase a statutory duty.

Create a responsibility map. Who can access and arrange a survey of the ceiling, pipe lagging, plant room, service risers or soil? Who can isolate or label damaged material? Who commissions maintenance and refurbishment? Who holds the survey and updates the register? If the answer is split, arrange a reliable exchange of information. A contractor arriving at a site needs one usable picture, not an argument about who owns the PDF.

Example: owner and tenant at a mixed-use building

A property owner controls an older service riser; a tenant runs a workshop with legacy machinery. The owner may need to identify and register asbestos in the riser, while the employer must manage any asbestos-containing machine under its control. If a contractor will drill through the riser wall to connect new services, the owner's register must reach the contractor and the tenant before work. If the tenant's machine is being moved, the employer must identify the plant hazard. Neither party should assume the other's file covers every location.

Identify actual and reasonably suspected asbestos

WorkSafe's management guidance says the duty includes asbestos in buildings, structures, ships, plant and other workplace locations such as soil. Use plans, construction dates, past surveys, maintenance records and a competent inspection to identify likely materials. Access limitations matter: a sealed riser or inaccessible void can contain asbestos that cannot safely be sampled during routine occupation. WorkSafe says where uncertainty on reasonable grounds remains, or an inaccessible area is likely to contain asbestos, the duty holder must assume it is present or arrange analysis by a NATA or similarly approved laboratory.

Do not ask a maintenance worker to break suspect material for an informal visual test. Fibre risk can be created by the identification attempt. Use a competent assessor, a controlled sampling method and an appropriately accredited laboratory where analysis is needed. “Not visible” is not proof that a void, plant gasket or soil is asbestos-free. Record the assumption explicitly so the next person does not interpret a blank map as a negative result.

The WorkSafe 2026 safety alert followed cases where employees disturbed friable asbestos without knowing it was present. The alert reinforces that the register is an operational safety tool. A survey stored in a distant email account has limited value if the people planning work cannot find it.

What should the register contain?

WorkSafe Victoria lists the asbestos location, type of asbestos-containing material (ACM), whether it is friable or non-friable, condition and work activities that could damage or deteriorate it. Its 2026 alert also identifies likely sources of loose asbestos, inaccessible areas likely to contain it and whether ACM may sustain damage. A practical record gives an unambiguous room, elevation or asset ID; a plan or photograph; the survey date and assessor; sample results or the basis of an assumption; condition; exposure potential; interim control; responsible person; and next review.

Use a map that a contractor can reconcile with the real site. “Level 2, asbestos present” is too vague if three ceiling zones have different materials and access points. For plant, identify the particular item and component rather than saying “old machinery”. Make revisions visible so workers can distinguish an outdated plan from the current register. Where sensitive information such as worker exposure or medical results exists, keep it separately with access controls; it is not a register field.

A negative survey must also have scope. It may say no asbestos was found in rooms inspected, while excluding concealed voids or soil. Do not convert a limited refurbishment survey into a whole-building “asbestos-free certificate”. Review the surveyor's limitations and sample locations before authorising work beyond the inspection scope.

Label and control, rather than only recording

Once asbestos is identified, the person with control must clearly indicate its presence and location so far as reasonably practicable, using labelling where that is practicable. See WorkSafe's labelling guide. Labels should make people consult the register before work; they should not be placed in a way that requires drilling or disturbing material. Access controls, maintenance restrictions and permit-to-work procedures may be needed for inaccessible or fragile areas.

WorkSafe's 2026 alert describes a hierarchy: remove asbestos where reasonably practicable, enclose it if removal is not practicable, or seal it if enclosure is not practicable, with the duty to control airborne exposure. The precise control depends on material and risk. An intact, well-managed panel may remain, but its presence must be known before anyone cuts it. Damaged friable lagging may require urgent isolation and specialist removal. Use a licensed removalist when the proposed work requires one; a register is not permission for an unqualified worker to remove ACM.

Example: a contractor asked to install cable trays

An electrical contractor is told to drill into a ceiling area in an occupied Victorian workplace. Before the first hole, the site manager checks the current register and plan, explains the marked ACM and the scope of any unknown voids, and provides relevant information to the contractor. If the planned fixing location is assumed to contain asbestos, the job is redesigned or a competent investigation is arranged. Giving the contractor a generic induction tick without the location-specific register is insufficient protection.

Review every five years and when facts change

WorkSafe's register guidance says to review when the condition of asbestos changes, or it is removed, enclosed or sealed. A five-year review applies regardless of apparent change, with revision if needed. The five-year point is therefore a maximum periodic check for the register, not permission to ignore a damaged panel until the calendar date. Building works, leaks, vibration, demolition planning, a new survey or an incident should prompt an immediate reassessment of the relevant entries.

At review, verify physical location and condition, controls and labels, contractor access, survey limitations, completed removals and any new suspected ACM. Document who inspected and what changed. If a removal occurred, retain the clearance and waste records separately and update the register so a missing entry cannot be mistaken for an area never surveyed. An enclosure can reduce exposure but may conceal the material; mark that it remains beneath the enclosure.

Handover before demolition or refurbishment

WorkSafe's 2026 asbestos-register alert says the register must be reviewed before demolition or refurbishment at a workplace, revised if it lacks enough information for the person doing the work to manage asbestos risk, and provided to that person. The scope of a routine occupancy register may be too shallow for demolition behind walls or under floors. Commission a suitable pre-works assessment before the contractor starts disturbing those areas.

Handover should include the current register, survey scope and limitations, plans, controls, known inaccessible areas, material to be removed or protected, and a process for unexpected finds. Confirm receipt and understanding with the contractor and any principal contractor. If the contractor discovers suspected asbestos, stop the relevant work, isolate, inform the site controller, investigate and update the register. The handover is an active work-planning step, not a document attachment sent after the demolition crew has started.

Domestic premises have different facts. WorkSafe says an employer or self-employed person performing demolition or refurbishment at a domestic premise must identify asbestos under that person's control that is likely to be disturbed, or engage a competent person to do so. A homeowner may not have a workplace register waiting to hand over. The business still needs to assess the work and control exposure; avoid assuming that a missing register means asbestos is absent.

Who needs access and training?

WorkSafe says the register must be accessible to employees and contractors who may encounter asbestos. Supervisors, maintenance staff, cleaners, service technicians, emergency planners and project managers may each need relevant information. Explain the labelling system, how to access the latest register, activities that could disturb ACM, required controls and what to do on an unexpected find. Health and safety representatives should be involved where the OHS consultation rules require it.

Make access practical. A QR code can point to a current copy if the site has reliable connectivity and appropriate permissions, but it should not be the only route for a worker in a basement with no signal. Keep a controlled, available copy at the point where work is authorised. Prevent an old PDF being circulated after an updated survey identifies new ACM.

Frequent mistakes

• Assuming only the owner is responsible. Employer and workplace-control duties depend on actual control.
• Leaving inaccessible areas blank. Record and manage reasonably suspected ACM.
• Treating a limited survey as whole-building clearance. Respect scope and sampling limits.
• Creating a register but failing to label or share it. The operational purpose is to prevent disturbance.
• Waiting five years despite a damaged or removed material. Review when facts change.
• Forgetting the demolition/refurbishment handover. A pre-works review may reveal hidden material.
• Using a removal licence article as the entire management plan. Ongoing location, condition and access duties come first.

How can Complys support the records?

The verified Complys AU WHS compliance software supports safety records, risk assessments and review tracking. It may help organise a register file, controls and review actions if its current access and document configuration suits the site. The live product page does not establish asbestos detection, laboratory sampling, a legally complete Victorian asbestos-register template, licensed removal, clearance certification or automatic five-year legal interpretation. A competent assessor and duty holder must maintain and verify the actual register and safe-work controls.

Start with WorkSafe Victoria's current asbestos-management guidance and its 2026 register alert. Identify who controls each structure and item of plant, close survey gaps, keep the register accessible and review it before anyone drills, demolishes or refurbishes. Use software to keep the evidence available; do not let it replace inspection, communication or controls.

For the related Complys product, see Whs Compliance Software. This guide is general information, not legal advice; verify current requirements against the official sources linked above.