Asbestos register basics: what general contractors actually need on file

If a project was built before 2004 — or nobody actually knows when it was built — Australian construction work on it carries a real chance of disturbing asbestos-containing material. That’s not a renovation-specific quirk; it applies to any refurbishment, demolition, or even routine maintenance on an older structure. A new build on a vacant block doesn’t need this at all. An older building with an unclear paper trail does, and it needs it before anyone starts cutting into a wall.

What actually has to be recorded, and by when

In most Australian states, this sits under the model WHS Regulations’ asbestos chapter (Part 8.2, regulations 425–426): regulation 425 puts the duty on the person with management or control of a workplace to identify asbestos or assume it’s present and keep an asbestos register recording what was found and where, and regulation 426 is what actually requires that register to be reviewed — at least every five years, and again whenever remediation work changes what’s actually there. Victoria and WA run their own OHS/WHS regimes rather than the harmonised model laws, with equivalent obligations under different section numbers — worth checking against your specific state rather than assuming the exact clause number carries over.

What matters in practice is less the citation and more the substance: the register has to name the material, its condition and location, and it has to be current — not a document that was accurate the day it was written and never touched again.

Where this actually goes wrong

The most common failure isn’t a missing register — it’s a stale one. A register gets produced once at the start of a job, remediation work happens six months later, and nobody circles back to update it, so the document on file no longer reflects the building it’s describing. A close second is provenance: a register that’s been forwarded, re-scanned, or summarised by someone other than the licensed assessor who actually produced it. By the time it’s a third-generation photocopy sitting in someone’s inbox, there’s no way to be confident it’s the real thing, or the current version of it.

The third, more mundane failure is simply access — the register exists somewhere, but not in a form anyone on site can actually pull up when a regulator or a worker asks to see it.

Where the register should come from

The assessment itself has to come from a licensed asbestos assessor — that’s not something a general contractor can produce or verify on their own. The part a GC does control is how that document gets from the assessor onto the project file: relayed through email and re-uploaded by someone else introduces exactly the kind of provenance gap described above, where what’s on file may not be what the assessor actually wrote.

How Novato handles this

Novato flags a project as needing a register automatically — any project built before 2004, or where the construction year isn’t recorded, gets flagged without anyone having to remember the cutoff. From there, Novato lets you invite the licensed assessor directly: they get a token-based link with no login required and upload the register themselves, so what ends up on file is exactly what they produced, not a forwarded copy. The register sits against the project with its own next-review date tracked alongside it, the same way a licence expiry is tracked — not a one-off upload that quietly goes stale. (Asbestos removal and assessor licensing itself is also checked per state — see how that’s tracked for projects in NSW, for example.)