Asbestos in soil

Why asbestos in soil can be harmful

Asbestos is a risk to health if fibres become airborne and can be inhaled. The risk from exposure to asbestos in soil can be increased by the:

• type of soil
• amount, form, product type and condition of asbestos and its form
• chance of the asbestos being disturbed and becoming airborne.

Exposure to asbestos can cause mesothelioma, asbestosis and lung cancer. Employers must protect employees and other persons from the risk of asbestos-related disease. This must be done so far as is reasonably practicable.

How soil can become contaminated with asbestos

You could find asbestos-containing materials in soil on any property. This includes businesses, schools, community land and residential sites. There are many ways asbestos can end up in soil. For example:

• Buildings that contained asbestos were demolished and the waste was not disposed of properly.
• Asbestos-contaminated soil was used as topsoil or fill material.

Visible and non-visible asbestos in soil

Asbestos in soil can be visible and non-visible.

Visible asbestos

Visible asbestos includes any material:

• you can see with the naked eye, and
• you suspect or confirm contains asbestos.

Non-visible asbestos

Non-visible asbestos refers to material that contains asbestos but the asbestos is not visible to the naked eye. Asbestos may be in the form of small particles, fibre bundles or free fibre. Just because you cannot see asbestos in soil does not mean the soil is not contaminated with asbestos. Asbestos fibres can be between 50 to 200 times thinner than human hair and invisible to the naked eye.

How to identify asbestos-contaminated soil

If you are:

• an employer, or
• a person who manages or controls a workplace

you have a duty to identify all asbestos under your management or control, including any asbestos in soil. You must do this so far as is reasonably practicable.

If you suspect there may be asbestos in soil, you must either assume there is asbestos or arrange for collection and analysis of soil samples. The analysis must be done by a company approved by the National Association of Testing Authorities (NATA).

The Victorian Environment Protection Authority (EPA) has guidance that may help with the sampling of soil potentially contaminated with asbestos. The guidance Soil sampling for waste soils is available on the EPA website. Further methods for assessing the distribution and concentration of asbestos in soil at potentially contaminated sites are provided in National Environment Protection (Assessment of Site Contamination) Measure 1999, Schedule B2, Section 11.

You may also need to notify the EPA if friable asbestos is present in the soil. Check the EPA website to see when you need to notify.

Who can help identify asbestos?

You should engage a person who has the requisite knowledge, skills and experience to collect representative samples and identify asbestos in soil. For example, an occupational hygienist with experience in identifying asbestos.

You can find occupational hygienists through:

• the Australian Institute of Occupational Hygienists, or
• a company approved by NATA for the identification of asbestos.

Unexpected asbestos finds are common, even after work has been done to identify and remove asbestos. If the remaining soil is likely to contain asbestos, employers should ensure that employees:

• know how to identify suspected asbestos in soil
• know what to do if they find asbestos or potential asbestos in soil
• understand the risks of asbestos.

Consider the site you are working on

Some sites will have a greater likelihood of asbestos-contaminated soil being present than other sites. When considering whether there is a risk of asbestos in soil at a site, think about:

• past use of the site
• any other asbestos found at the worksite or nearby
• any use of recycled soil or fill
• any demolition or renovation of buildings or structures that contained asbestos or suspected asbestos
• any damaged buildings or structures that contain asbestos or suspected asbestos
• any dumping that may have occurred
• whether there are any asbestos roofs that allow water and damaged asbestos runoff into soil
• whether there are any underground services that might contain asbestos, such as water and sewer pipes, conduits, cable troughs and old telecommunication pits
• the presence of naturally occurring asbestos.

Where friable or suspected friable asbestos-containing material is present or likely to be present, then an assessment for the presence of non-visible asbestos in the soil will be required. See information under the heading ‘Friable asbestos’.

What to do if asbestos is identified in soil

You must clearly indicate the presence and location of asbestos if:

• asbestos has been identified in soil, or
• you suspect the presence of asbestos in soil, based on the previously listed considerations.

For example, you could indicate the presence and location of asbestos on a site map.

If it is reasonably practicable, you must indicate the presence and location of asbestos by labelling, such as by using signs.

You must also determine:

1. the location of the asbestos
2. the likely source of the asbestos
3. the type of asbestos-containing material
4. whether the asbestos-containing material is friable or non-friable
5. the condition of the asbestos-containing material
6. whether the asbestos-containing material is likely to sustain damage or deterioration, and
7. so far as is possible, any activities likely to be carried out at the site that are likely to damage or disturb the asbestos.

Asbestos register

You must have an asbestos register and include information in the asbestos register if you:

• identify asbestos in soil at the site
• suspect asbestos is contained in soil at the site, based on history and other knowledge of the site.

You must include the information listed in (a) to (g) in the previous section, as well as the date of each identification.

If you do not have an asbestos register, you must:

• establish an asbestos register, and
• include this information on the register.

You must ensure the asbestos register is revised, reviewed and kept up to date.

The asbestos register must be accessible to your employees. You must also provide a copy of the asbestos register to:

• any employer at the workplace
• any person who assumes management or control of the workplace
• any asbestos removal licence holder engaged to remove the asbestos
• any person engaged to do work at the workplace that involves the risk of exposure to airborne asbestos fibres
• any person engaged to do work at the workplace who requests a copy, and
• the health and safety representative (HSR) of an affected designated work group.

More information about asbestos registers is available in the compliance code Managing asbestos in workplaces.

How to control the risk of asbestos-contaminated soil

If you are:

• an employer, or
• a person who manages or controls a workplace

you must eliminate risks associated with asbestos-contaminated soil. This includes circumstances where you are likely to disturb asbestos-contaminated soil. You must eliminate risks so far as is reasonably practicable.

To eliminate the risk associated with asbestos-contaminated soil, either:

• remove the asbestos-contaminated soil and dispose of it at an approved landfill, or
• remove the visible asbestos from the soil, or
• remove the asbestos-contaminated soil and take it to an EPA-licensed business that treats soil for reuse as fill material.

In some cases, it will cost less to remove all the asbestos-contaminated soil than to remove only the asbestos.

If it is not reasonably practicable to remove the asbestos-contaminated soil or remove the asbestos, you must reduce the risk by enclosing the asbestos-contaminated soil. Soil can be enclosed using a suitable capping layer. Check with the EPA to confirm what obligations you may have, including whether a permission is required. Capped soil containing asbestos must be recorded on the site asbestos register.

Removing asbestos

The appropriate way to remove asbestos will depend on a number of factors, including whether the asbestos is friable or non-friable.

• Friable means that when dry or as the result of a work process, asbestos may be crumbled, pulverised or reduced to a powder by hand pressure.
• Non-friable means that when dry, asbestos may not be crumbled, pulverised or reduced to powder by hand pressure.

You should consider whether there is potential for any asbestos fibres to be released into the atmosphere during removal. This will help determine the appropriate risk controls. Such controls should include, but should not be limited to, dust suppression using water sprays. The asbestos removal area must be appropriately signed and barricaded.

The EPA has requirements around how asbestos waste should be managed. More information can be found on the EPA website.

Non-friable asbestos

Methods to remove non-friable asbestos include the following:

• Remove the visible asbestos from the surface of the soil where practicable.
• Where excavated soil is identified or suspected to contain non-friable asbestos, spread the soil to a sufficient depth to allow for further inspection. You can then identify and remove any visible non-friable asbestos. Raking over the soil using hand-held tools can help identification and removal of visible non-friable asbestos.
• Using soil screening equipment. Refer to the section under the heading ‘Using soil screening equipment on soil contaminated with non-friable asbestos’.

If the soil is grossly contaminated with visible non-friable asbestos, you should remove all the contaminated soil.

Friable asbestos

Friable asbestos is more likely to release airborne asbestos fibres when disturbed. It is difficult to remove from soil. All the visibly contaminated soil must be removed and disposed of by a Class A licensed removalist. The licensed removalist will dispose of the soil after removing it.

Once this soil has been removed, a person with the requisite knowledge, skills and experience will need to determine whether there is any further soil that may be contaminated with non-visible asbestos that needs to be removed. This determination needs to include consideration of the following:

• Site-specific information that considers the history of the site with respect to asbestos. For example, previous site use and whether fill material was installed at the site.
• Whether sampling for asbestos identification in the surrounding soil needs to be undertaken.

If sampling is undertaken and identifies asbestos, then an assessment needs to be performed to determine whether further soil must be removed. The assessment should be based on appropriate standards. For example, to determine that the soil does not contain more than trace levels of asbestos, use Australian Standards:

• AS 5370-2024, Sampling and qualitative identification of asbestos in bulk materials
• AS 4964-2004, Method for the qualitative identification of asbestos in bulk samples.

If samples are determined to contain greater than trace analysis levels using an appropriate standard, then soil should be prioritised for disposal as asbestos-contaminated waste.

A person who has the requisite knowledge, skills and experience may determine via a risk assessment that the soil can be reused.

Enclose the asbestos-contaminated soil

If it is not reasonably practicable to remove the asbestos-contaminated soil or remove the asbestos from the soil, you should enclose or cap the soil after removing visible non-friable surface-level asbestos. Obtain a clearance certificate where required.

You can enclose the asbestos-contaminated soil using a suitable capping layer. Suitable capping layers include:

• hardstand
• paved
• clean soil
• clean fill material.

You can also use a marker layer. You should do a risk assessment to determine the type of capping layer to use and the depth of the layer.

Disturbing the asbestos during capping can create a risk of exposure to airborne asbestos.

You must record any enclosed or capped soil on the asbestos register. The register should contain clear and detailed information about the asbestos-contaminated soil. This activity may require notification to the EPA or require EPA permissions.

Risk assessments for reuse

Risk assessments need to consider whether exposure of any persons engaged with handling the soil, as part of its reuse at any point in time, is likely to exceed the asbestos occupational exposure standard. If this is the case, the soil needs to be disposed of as asbestos-contaminated waste.

The risk assessment needs to consider, but is not limited to:

• soil type, for example, clay, sandy
• extent of asbestos sampling, based on identified visible friable asbestos and site history
• nature of asbestos detected, for example, whether it is present as asbestos-containing material fragments or fibre bundles that are not visible to the naked eye
• free fibre detection
• partial removal and further sampling
• likely levels of exposure of persons during any reuse and end-use.

When removing soil containing friable asbestos outdoors, air monitoring is required if the work constitutes a risk to other people. For more information about air monitoring, see the compliance code Removing asbestos in workplaces.

The EPA also regulates the management of asbestos. More information can be found on the EPA website.

Asbestos in soil flowchart

WorkSafe has a flowchart that suggests a process to manage and control risks from asbestos in soil. The flowchart is designed for a technical audience with the requisite knowledge to understand the process to assess and test for asbestos in soil.

Using excavators to remove asbestos-contaminated soil

You can use an excavator to remove asbestos-contaminated soil. Note that the person operating the excavator is removing asbestos. Depending on the type of asbestos being removed, the excavator operator must be either:

• a Class A or Class B asbestos removal licence holder, or
• an employee of a Class A or Class B asbestos removal licence holder, or
• an independent contractor engaged by a Class A asbestos removal licence holder.

If the excavator operator is an employee of a Class A or Class B asbestos removal licence holder, they must be provided with appropriate:

• training
• PPC and RPE, and
• health monitoring.

For more information about the requirements for asbestos removal work, see the compliance code Removing asbestos in workplaces.

If you use an excavator to remove asbestos-contaminated soil, you need to decontaminate the cabin and exterior before you remove the excavator from the area. You should also consider whether the cabin needs air filtration. The type of air filtration in the cabin will have an impact on the type of PPC and RPE you need. MERV 16+ or H13 HEPA-grade filters are recommended.

Engaging independent excavator operators

Independent excavator operators must only operate the excavator. They cannot do any other form of asbestos removal work. For example, they cannot:

• assist in removing asbestos using hand tools, or
• spray water for dust suppression.

The excavator operator must be:

• engaged by a person who holds a Class A asbestos removal licence, and
• directly supervised by the appointed asbestos removal supervisor at all times during the removal work.

Medical examinations

Excavator operators must have a medical examination before they start asbestos removal work. The asbestos removal licence holder must arrange the examination.

Asbestos removal licence holders must ensure they provide medical examinations in each of the following situations:

• Before a person starts asbestos removal work for the first time with that licence holder. This requirement does not apply if the person has had an appropriate medical examination within the past year.
• At intervals of not more than 2 years.
• Within 30 days after the person stops asbestos removal work. This requirement does not apply if the person has had an appropriate medical examination within the past year.

A registered medical practitioner must do the examinations.

Information, instruction and training

Excavator operators must have received information, instruction and training. At a minimum, this should cover:

• restrictions to asbestos removal areas
• PPC requirements, including cleaning, storage and performing a fit check for RPE
• personal decontamination procedures when leaving the site
• specific onsite requirements
• use of excavator onsite and controls to prevent airborne asbestos fibres, and
• decontamination of plant and equipment.

A competent person with relevant knowledge and skills should provide the training. For example:

• a registered training organisation that provides asbestos-related training, or
• an occupational hygienist.

Work requiring a spotter

In some cases, a spotter may be required for safety purposes. Spotters who are not asbestos removalists cannot do any asbestos removal work. Spotters must also:

• wear appropriate PPC and RPE, and
• receive necessary training to enable them to perform the work in a way that is safe and without risks to health.

Using soil screening equipment on soil contaminated with non-friable asbestos

Soil screening equipment can separate small pieces of non-friable asbestos from the soil. But there is also a risk that screening equipment can cause non-friable asbestos to become friable. This means asbestos fibres could be released into the air. Because of this, you need to complete a risk assessment before using any soil screening equipment. This will help you determine:

• Whether soil screening equipment should be used. Do not use soil screening equipment if it is likely to cause non-friable asbestos to become friable. Select another method to manage the asbestos-contaminated soil.
• Whether air monitoring is required when using soil screening equipment.
• What risk control measures are required when using soil screening equipment.

The risk assessment should be completed by a person with suitable knowledge and experience. If you complete a risk assessment and are still unsure of the risk, do not use the soil screening equipment.

If you do use soil screening equipment, make sure you have developed a safe system of work based on your risk assessment. The system of work should be documented in the asbestos control plan. You should remove any large obvious pieces of asbestos or other large heavy material before using screening equipment. Large or heavy materials can further degrade asbestos in the soil being screened.

When completing the risk assessment, consider the following:

• What condition is the asbestos in? Could using the screening equipment result in non-friable asbestos becoming friable?
• What type of soil is it? Sandy soil is easier to screen than ‘clumpy’ soil, such as heavy clay soil. If the soil is clumpy, it may not be possible to separate asbestos pieces from the soil. In this case all the soil should be removed.
• Who will operate the soil screening equipment?
• How big does the exclusion zone need to be?
• How will you determine whether you need to do personal exposure monitoring and area monitoring?
• If needed, how will you do personal exposure monitoring and area monitoring?
• How will you provide monitoring results to workers?
• How will you stop dust from the soil blowing around? For example, use of water misting and tarps and stopping work on windy days.
• How will you identify and manage ‘hot spots’?
• What size screen will you use? You should use the smallest screen size possible. The type of soil will have an impact on the screen size you use. For example, for sandy soil, start with a 5 mm screen. If the soil is coarser, you may need to start with a larger-sized screen.
• What material is the screen made of? The material should minimise the destruction of asbestos fragments.
• What processing speed will you use?
• What is the process for investigating oversized pieces of material? Oversized pieces should not pass through the screen twice.
• What will you do if elevated airborne fibres are detected? What is the process for investigating and reviewing risk controls?
• How many operators do you need?
• How will you train those operators?
• What PPC and RPE will you need?
• How will you decontaminate the screening equipment?
• Who will issue the clearance certificate for the screening equipment?
• How will you control other safety risks, for example, plant guarding?

What to do at the end of the asbestos removal work

Once the asbestos removal work is completed, the person who commissioned the work must:

• arrange a visual inspection, and
• obtain a clearance certificate before the area can be reoccupied.

If para-occupational air monitoring was completed during removal work, the results must be readily accessible to HSRs, employees and independent contractors at the workplace.

Visual inspection

Once removal works are completed, an independent person must conduct a visual inspection. The independent person must have the requisite knowledge, skills and experience to complete the inspection. The independent person must verify that there is no visible asbestos residue remaining in the:

• area where the asbestos was removed, and
• immediate surrounding area.

You are not required to conduct a visual inspection if:

• the asbestos being removed was non-friable asbestos-containing material, and
• the area did not exceed 10 square metres in total.

The independent person must be able to visually inspect all the screened soil. This allows them to determine whether there is visible asbestos present. The flow of screened soil into the inspection area needs to allow enough time for inspection. If this is not possible, the soil will need to be spread so it can be properly inspected.

The inspection must happen before the clearance certificate can be issued.

Clearance certificate

Once the asbestos is removed, the person who commissioned the removal must obtain a clearance certificate from an independent person.

The certificate must confirm that an independent person has found that, as a result of the asbestos removal work, there is no visible asbestos residue remaining in the:

• area where the asbestos was removed, or
• immediate surrounding area.

The independent person must have the requisite skills, knowledge and experience to issue a clearance certificate. A clearance certificate must be obtained before the area where the asbestos removal work was being performed is reoccupied.

If required for friable asbestos removal work, air monitoring is to be undertaken as part of the clearance certificate. For more information about air monitoring, see the compliance code Removing asbestos in workplaces.

You are not required to obtain a clearance certificate if the:

• asbestos being removed was non-friable asbestos-containing material, and
• area did not exceed 10 square metres in total.

For more information about clearance certificates, see the compliance code, Removing asbestos in the workplace.

Reusing soil after removing asbestos

You may reuse soil that previously contained asbestos, but only under specific conditions. All visible asbestos-containing material must be removed before reuse. The removal of asbestos-containing material must be done so far as is reasonably practicable. You must have a clearance certificate before you can reuse the soil.

If a clearance certificate has been issued, you must still inspect the soil before:

• supplying
• storing
• transporting
• selling
• using, or
• reusing.

If asbestos is found, it must be removed.

The employer or person with management or control of the material should check EPA requirements for the decontamination and reuse of soil that has been contaminated with asbestos.

Storing asbestos-contaminated soil for the purpose of disposal

You must dispose of asbestos-contaminated soil as soon as possible. You can only store asbestos-contaminated soil in order to dispose of it. If storing asbestos-contaminated soil, you must ensure that it is:

• stored securely, and
• identified to indicate the likely or actual presence of asbestos.

You can do this by:

• preparing an asbestos management plan
• prioritising the removal and disposal of the asbestos-contaminated soil, and
• ensuring the storage site is secure. This includes:
  • Making sure asbestos fibres cannot be released from the soil. One way of doing this is to cover the soil with plastic sheeting or a permeable textile material. For example, geofabric.
  • Signs that make clear that the soil contains or is likely to contain asbestos.
  • Marking the soil with asbestos warning tape.

Ensure that you are meeting your obligations under the Environment Protection Framework. Find more information about the removal, transport and storage of asbestos waste on the EPA website.

Transporting asbestos-contaminated soil

You can only transport asbestos-contaminated soil to:

• dispose of it at an EPA-licensed landfill, or
• remove asbestos and dispose of the asbestos at an EPA-licensed landfill, or
• remove the asbestos-contaminated soil and take it to an EPA-licensed business that treats soil for reuse as fill material.

The contaminated soil must be damp before you package it for transport. This reduces the risk of dust and fibres becoming airborne.

You must contain asbestos-contaminated soil waste. This eliminates the release of airborne fibres. You can contain the soil using double-lined plastic that is then sealed. The sealed lining must be labelled as asbestos- containing.

Vehicles on the site may be contaminated with asbestos. A competent person needs to inspect the vehicles. If needed, vehicles need to be cleaned before they leave the site.

If you are an asbestos removal licence holder performing asbestos removal work, you must ensure that the exterior of any container holding asbestos-contaminated soil waste is also decontaminated before it leaves the site.

The EPA regulates the transport of asbestos waste. All asbestos transported by businesses must be tracked in the EPA’s Waste Tracker. See the EPA website for information about how to manage asbestos waste and how to transport industrial waste.

Disposing of asbestos

Asbestos and anything containing asbestos must be appropriately disposed of in accordance with EPA requirements. Check the EPA website for information on what duties and obligations apply to you.