Introduction: why refurbishment carries hidden environmental risk
Refurbishment is often perceived as a lower-risk alternative to demolition and rebuild. In practice, however, it can present significant environmental and safety risks, particularly in older buildings where hazardous materials (hazmat) are disturbed during strip-out, services upgrades or structural modifications.
From our experience, hazmat refurbishment risk is rarely about whether hazardous materials exist. It is about whether they are identified early enough to be managed safely and compliantly. Asbestos, lead-based paint, polychlorinated biphenyls (PCBs) and other legacy substances are common in commercial, industrial and institutional buildings constructed or modified before modern regulatory controls were introduced.
Effective refurbishment planning therefore requires more than cosmetic design intent. It demands an informed understanding of hazardous material risks, clear pre-strip obligations, and a redevelopment strategy that integrates environmental, safety and compliance considerations from the outset.
Typical hazardous materials in refurbishment projects
The hazardous materials encountered during refurbishment depend on building age, historical use and past modifications. While every site is different, several materials consistently present risk across Australian projects.
Asbestos-containing materials
Asbestos refurbishment risk remains one of the most significant issues in existing buildings. Asbestos-containing materials (ACMs) may be present in wall and ceiling linings, vinyl flooring systems, fire doors, pipe insulation, roofing and cladding.
Refurbishment works frequently disturb ACMs that are otherwise in reasonable condition, increasing the likelihood of fibre release if controls are not properly implemented. This is particularly relevant where intrusive works extend beyond the scope of previous asbestos registers.
Lead-based paint and coatings
Lead-based paints were widely used in Australia prior to the 1970s and can still be found on structural steel, timber joinery, internal linings and external façades. Activities such as sanding, grinding or coating removal can generate lead-contaminated dust, posing risks to workers, occupants and surrounding areas.
In many refurbishment projects, lead paint and PCB assessments are undertaken together, particularly where multiple legacy contaminants may be present.
PCBs and other legacy substances
PCBs may be encountered in older electrical equipment, light fittings, transformers, capacitors and some sealants. Although less common than asbestos or lead, PCBs present higher toxicity risks and require specialist handling and disposal.
Other hazardous materials encountered during refurbishment may include synthetic mineral fibres, mercury-containing equipment, ozone-depleting substances in refrigeration systems, and contaminated dusts within ceiling voids or plant rooms. Understanding what may be present is critical to defining survey scope and redevelopment strategy.
Pre-strip and pre-demolition obligations
One of the most critical compliance steps in refurbishment projects is meeting pre-strip and pre-demolition requirements. These obligations exist to protect workers, occupants and the public from exposure during building works.
Purpose of a pre-demolition hazardous materials survey
A pre-demolition hazmat survey identifies hazardous materials that are likely to be disturbed during planned works. Unlike management surveys, refurbishment surveys are intrusive and targeted specifically to the scope of proposed disturbance.
For refurbishment projects, surveys must accurately reflect the areas and elements being affected, identify hazardous materials by type, condition and location, and provide sufficient information to plan safe removal or controls. Reliance on outdated or generic surveys is a common cause of non-compliance and project delay.
Regulatory expectations
In NSW and across Australia, refurbishment works are subject to workplace health and safety and environmental obligations. These generally require hazardous materials to be identified before disturbance, removed by appropriately licensed contractors, and disposed of lawfully with clear documentation.
Failure to meet these obligations can result in stop-work orders, regulatory penalties, insurance complications and reputational risk.
Timing matters
Hazardous materials surveys must be completed early enough to inform design, costing and programming. Surveys undertaken after strip-out has commenced often result in reactive controls, higher costs and increased exposure risk for workers and occupants.
.jpg)
