Asbestos inventory: the 24-month review and the 6-year AIA endorsement

2 hours ago

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Short answer: review it at least every 24 months, and have it endorsed by an approved inspection authority at least every six years. Under the Asbestos Abatement Regulations, 2020, a competent person must review and, if necessary, revise your inventory of asbestos in place at intervals not exceeding 24 months. An approved inspection authority (AIA) must review and endorse the inventory and the asbestos risk assessment at intervals not exceeding six years, unless an AIA did that work in the first place.

The regulations were published as Government Notice R. 1196 in Government Gazette 43893 on 10 November 2020 and took effect on publication. Regulation 3 (identifying asbestos) and regulation 20 (labelling and signage) took effect 18 months later, on 10 May 2022. They replaced the Asbestos Regulations, 2001.

What the inventory must contain

Every employer and self-employed person must, as far as is reasonably practicable, have all asbestos-containing materials at the workplace identified by a competent person (regulation 3). A competent person must then enter every material identified as, or assumed to be, asbestos-containing into an inventory kept at the workplace or premises (regulation 4(1)). For each item, the inventory must record, as far as is reasonably practicable (regulation 4(3)):

When: the date on which the material was identified.
What: a description of the material, its quantity and its extent of deterioration.
Where: its location, as detailed on a floor plan.
Labelling: confirmation that it is labelled or signposted as regulation 20 requires.
Risk: the risk categorisation from the asbestos risk assessment.
Exposure: a description of the potential exposure scenarios.

If no asbestos is identified, a competent person must confirm the asbestos-free status of the workplace in writing. This does not apply to structures whose construction started at least three years after the 2008 national asbestos ban was promulgated; where asbestos is found in South African buildings explains why that date matters.

The 24-month review and the six-year endorsement

Inventory review (regulation 4(4)): a competent person must review and, if necessary, revise the inventory at intervals not exceeding 24 months.
Asbestos risk assessment (regulation 5(1)): carried out immediately by a competent person once asbestos is identified, then at intervals not exceeding 24 months. Health and safety representatives or the health and safety committee must be consulted first (regulation 5(2)).
AIA review and endorsement (regulation 5(7)): an approved inspection authority must review and endorse both the inventory and the risk assessment at intervals not exceeding six years. This is not required if the work was carried out by an approved inspection authority.
Asbestos management plan (regulation 6(3)): reviewed and, if necessary, revised at intervals not exceeding eight years, or sooner if the information in it changes.
Records (regulation 23): keep inventories, risk assessments and the related asbestos records for at least 50 years.

Here, a competent person has the knowledge, training, experience and, where applicable, qualifications specific to asbestos work, and is familiar with the Occupational Health and Safety Act and its regulations (regulation 1).

When you can't wait 24 months

Regulation 4(5) says the inventory should be revised more often when:

New finds: further asbestos-containing material is identified.
Changed condition: material has deteriorated significantly, or has been removed, damaged, sealed, coated or encapsulated.

Planned work is another trigger. Before removal or repair, the inventory must be detailed enough for that work (regulation 4(6)). If material you intend to remove or repair is not in it, the inventory must be reviewed and updated (regulation 11(2)(b)).

Who must see the inventory

The inventory is a working document, not a file for the auditor. Regulation 4(7) requires a copy, or the relevant part, to be:

given to the contractors and the AIA before asbestos removal or repair work starts;
readily accessible to employees and health and safety representatives at the workplace; and
provided to the new owner if ownership of the premises is transferred.

Whoever authorises work that could expose people to airborne asbestos must also receive a copy and use it to identify the job's exposure scenarios and recommended controls. The employer must make sure those controls are implemented (regulation 4(9)).

A quick self-check

Find the date of the last inventory review. If it is approaching 24 months, book the next one now.
Check when an AIA last reviewed and endorsed the inventory and risk assessment. Unless an AIA compiled them, that endorsement is due at least every six years.
Walk the site with the floor plan. Is each listed item still there, in the recorded condition, and labelled?
List what has changed since the last review: new finds, damage, repairs, removal or encapsulation.
Confirm that employees and health and safety representatives can get to a copy at the workplace.
Make sure contractors receive the relevant part of the inventory before they start work.

How Qualitas can help

Qualitas Occupational Consulting is a Department of Employment and Labour Approved Inspection Authority and a SANAS-accredited (ISO/IEC 17020) inspection body for asbestos, lead, noise and hazardous chemical agents. Our asbestos surveys and inventories inspect your buildings for asbestos-containing materials, assess their condition and exposure risk, and compile the inventory in a report written for management, SHEQ teams and auditors. Because we are an approved inspection authority, an inventory and risk assessment we compile do not need a separate six-yearly AIA endorsement under regulation 5(7).

Planning building work? Read Renovating an older building? Check for asbestos first before the contractors arrive.

Not sure what your site needs? Start with our free Compliance Gap Analysis, request a quote, or call or WhatsApp 082 649 6599.

This article summarises the Asbestos Abatement Regulations, 2020 (Government Notice R. 1196, Government Gazette 43893, 10 November 2020) for general guidance. It is not legal advice; refer to the regulations, as amended, for the full requirements.

Christo de Wet is a SAIOH-registered occupational hygienist with 15 years' experience and the founder of Qualitas Occupational Consulting.