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 of asbestos, and
- 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.
This guidance only relates to visible asbestos in soil
It does not cover non-visible or microscopic asbestos in soil. Visible asbestos includes any material:
- you suspect or confirm to contain asbestos, and
- you can see with the naked eye.
How soil can become contaminated with asbestos
You could find visible asbestos 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.
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 analysis of a sample of the soil. The analysis must be done by a company approved by the National Association of Testing Authorities for the identification of asbestos. You should engage a person who has the requisite knowledge, skills and experience to 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 the National Association of Testing Authorities for the identification of asbestos.
Unexpected asbestos finds are common even after work has been done to identify and remove asbestos. If there is a chance of buried asbestos at a site, employers should ensure that employees:
- know how to recognise asbestos in soil
- know what to do if they find asbestos, or potential asbestos in soil
- understand the risks of asbestos.
Consider the history of the site you are working on
Some sites will have a greater risk of asbestos contaminated soil. When considering if there is a risk of asbestos in soil at a site, think about:
- any other visible 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
- if there are any asbestos roofs that would allow water and damaged asbestos runoff into soil
- if there are any underground services that might contain asbestos
- the presence of naturally occurring asbestos.
What to do if you identify asbestos in soil
If asbestos has been identified in soil, you must ensure the presence and location of the asbestos is clearly indicated. For example, on a site map. If it is reasonably practicable you must indicate this by labelling. For example, using signage.
You must also determine:
- the location of the asbestos
- the likely source of the asbestos
- the type of asbestos-containing material
- whether the asbestos-containing material is friable or non-friable
- the condition of the asbestos-containing material
- whether the asbestos-containing material is likely to sustain damage or deterioration, and
- 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 include information in the asbestos register if you:
- identify visible asbestos in soil at the site
- suspect visible asbestos is contained in soil at the site.
You must include the information listed in (a) – (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 of 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 HSR of an affected designated work group.
More information about asbestos registers is available in the Managing asbestos in workplaces compliance code.
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 the risk associated with asbestos contaminated soil. You must do this so far as is reasonably practicable.
To eliminate the risk of asbestos contaminated soil either:
- remove all the asbestos contaminated soil and dispose of it at an approved landfill, or
- remove all the visible asbestos from the soil.
In some cases, it will cost less to remove all the asbestos contaminated soil than to remove only the visible asbestos.
If it is not reasonably practicable to do either of these, you must reduce the risk by enclosing the asbestos contaminated soil. Soil can be enclosed using a suitable capping layer.
Strict safety requirements apply to asbestos removal work
A licenced asbestos removalist must perform most asbestos removal work. The licenced removalist must have training in how to remove asbestos safely.
You can remove limited amounts of asbestos containing material without a licence. This is only permitted if the:
- asbestos is non-friable, and
- area of asbestos to be removed does not exceed 10 square metres in total, and
- total time to remove the asbestos does not exceed 1 hour over a 7-day period.
Specific health and safety requirements apply if removing asbestos without a licence. These include ensuring people doing the work are:
- trained to remove asbestos safely
- provided with appropriate and suitable personal protective clothing and respiratory protective equipment.
More information about limited asbestos removal is available in:
Remove the visible asbestos
The appropriate way to remove visible asbestos will depend on a number of factors, including whether it is friable or non-friable.
- Friable means when dry, or as the result of a work process, may be crumbled, pulverised, or reduced to a powder by hand pressure.
- Non-friable means, when dry 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.
Friable asbestos
It is often very difficult to remove friable asbestos from soil. You will likely need to remove all the contaminated soil. A Class A licenced removalist must do this. The licenced removalist will dispose of the soil after removing it.
When removing soil containing friable asbestos, air monitoring may be required. For more information about air monitoring, see the Removing asbestos in workplaces compliance code.
Non-friable asbestos
To remove non-friable asbestos first spread the soil out. Spread the soil to a sufficient depth to allow for inspection. You can then identify and remove any visible asbestos. Raking over the soil can help identification and removal.
If the soil is grossly contaminated with non-friable asbestos, you should remove all the contaminated soil.
Enclose the asbestos contaminated soil
If it is not reasonably practicable to remove the asbestos contaminated soil or remove the visible asbestos from the soil, you should enclose or cap the soil.
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 it.
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.
Using excavators to remove asbestos contaminated soil
You can use an excavator to remove asbestos contaminated soil. 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
- personal protective clothing (PPC) and respiratory protective equipment (RPE), and
- health monitoring.
For more information about the requirements for asbestos removal work, see the Removing asbestos in workplaces compliance code.
If you use an excavator to remove asbestos contaminated soil, you need to decontaminate the cabin and exterior before you remove it from the area. You should also consider if 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 at all times during the removal work by the appointed asbestos removal supervisor.
Medical examinations
Excavator operators must have a medical examination before they start asbestos removal work. The asbestos removal licence holder must arrange this. The examination must be done by a registered medical practitioner.
Information, instruction and training
Excavator operators must receive information, instruction, and training before they start work. 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
- use of excavator onsite and controls to prevent airborne asbestos fibres
- decontamination of plant and equipment.
A competent person with relevant knowledge and skills should provide the training. For example:
- a registered training organisation who 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 the same training as the excavator operator.
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:
- if 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.
- if 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:
- 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 if 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 5mm 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 re-occupied.
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, a visual inspection must be conducted by an independent person. 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
- area did not exceed 10 square meters in total.
The independent person must be able to visually inspect all the screened soil. This allows them to determine if 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 there is no visible asbestos residue remaining as a result of the asbestos removal work in the:
- area where the asbestos was removed, and
- 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 re-occupied.
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 meters in total.
For more information about clearance certificates, see the Removing asbestos in the workplace compliance code.
Re-using soil after removing visible asbestos
The re-use of asbestos contaminated soil is prohibited. You need a clearance certificate before you can re-use soil that contained visible asbestos.
If a clearance certificate has been issued, you must still visually inspect the soil before:
- supplying
- storing
- transporting
- selling
- using, or
- re-using.
If visible asbestos is found, it must be removed.
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.
- Signage that makes clear that the soil contains, or is likely to contain, asbestos.
- Marking the soil with asbestos warning tape.
Transporting asbestos contaminated soil
You can only transport asbestos contaminated soil to:
- dispose of it at an EPA licensed landfill, or
- remove visible asbestos and dispose of the asbestos at an EPA licenced landfill.
Before you package the soil for transport, it must be damp. 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 soil using double lined plastic which 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, they need to be cleaned before they leave the site.
The EPA regulates the transport of asbestos waste. For more information, see the EPA website.
Disposing of asbestos
Asbestos-containing material, asbestos contaminated soil and asbestos waste must be disposed of in accordance with EPA requirements. For more information about disposal of asbestos visit the EPA website.