Do You Have a Plan? When an Asbestos Management Plan is Required

Article by: Ashley Miller, M.Sc., EPt

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Many businesses operate out of buildings that were constructed during the time that asbestos was frequently used for everything from room finishes (plaster, drywall, vinyl flooring, texture coat, etc.) to various forms of insulation (pipe wrap, attic, electrical, subflooring, heat shields, etc.).  It is the responsibility of the building owner to know if their building has asbestos-containing materials (ACMs).

Sections 8 and 10 of Ontario Regulation 278/05 – Asbestos on construction projects and in buildings and repair operations – details the full responsibilities of building owners in managing asbestos in their buildings

If an owner knows or ought reasonably to know that their building contains asbestos, they must implement an Asbestos Management Program (AMP).

An AMP is designed to ensure that those who occupy the building have information about asbestos that they could be exposed to. This includes tenants, in-house employees, contracted workers, etc. 

An Asbestos Management Plan is a critical document designed to register and detail how asbestos will be managed in a property and what activities will be implemented to ensure people remain safe from asbestos exposure.

An AMP is made up of five basic components:

  1. Creating an Asbestos Record

This in an inventory of the types and locations of known and presumed asbestos-containing materials within the building. The record should be updated after any renovation or asbestos testing. Materials that have not been tested for asbestos should be presumed to contain it until testing determines otherwise. The inventory should also give the condition of the material. Is it intact, or is it damaged and in need of replacement or encapsulation? The record should include a detailed description and amount of the material.

  • Inspection of Materials

A visual inspection of the building is conducted once a year to monitor the condition of any ACM or presumed ACM. The visual assessment includes an evaluation of the hazards associated with the material. Degradation of materials resulting from water damage, or normal wear and tear can result in the release of asbestos fibres. The assessment will determine:

  • The condition of the material
  • The accessibility of the material
  • The level of activity in the area of the material
  • The friability of the material
  • The asbestos content/type of the material

The asbestos record is updated after every inspection and renovation that occurs.

  • Notification of Occupiers & Employees

Occupiers and employees (including contracted workers) must be given written notice that there is asbestos in the building. Having a written AMP available at the building is paramount for employee and occupant safety. Maintenance workers can easily consult the AMP to see if any materials they may need to disturb are asbestos-containing and take the proper precautions for protecting themselves. For example, a maintenance worker may need to remove ceiling tiles to address a problem in the ceiling space. Knowing whether or not those ceiling tiles contain asbestos will inform whether the worker needs to wear a respirator, or seek another way to access the space.

Similarly, tenants need to know if there is asbestos within the dwelling. Small home repairs, renovations, or small daily disturbances still have the potential to release asbestos fibres. No amount of asbestos exposure is considered safe and people should always take precaution to avoid inhaling toxic dust.

  • Worker Training

Employees who will be working with or near ACM must be properly trained. At a minimum this must include:

  • the hazards of asbestos exposure;
  • the use, care and disposal of personal protective clothing and equipment;
  • personal hygiene; and,
  • the measures and procedures required by the Regulation.

Asbestos awareness classes are an easy way to ensure that your employees stay safe in the workplace.

  • Clean-up of Material

In the event that ACM or presumed ACM is disturbed or assessed to be in poor condition, it is the owner’s responsibility to have the material properly remediated by repairing, sealing, removing or permanently enclosing it. In the case of presumed ACM, the owner has the option of having a qualified person test the material for asbestos or proceeding with remediation assuming it is ACM.

Having a comprehensive Asbestos Management Plan is an integral part of complying with Ontario’s Health and Safety Regulations. Having an AMP in place can reduce the time it takes to respond to emergencies (water losses, clean-up of fallen materials, etc.) and keep first-responders safe. An AMP is more than a single use document; it is a comprehensive plan that needs monitoring and maintenance while ACMs are present in your building.

If you suspect your building has asbestos-containing materials and need an AMP or survey completed, contact Roar Engineering. We have the expertise to create a comprehensive asbestos management plan for your building, complete an asbestos survey or inspection, and provide you with the protocols required to safely remove asbestos and other Designated Substances.


Ontario Regulation 278/05 – Asbestos on construction projects and in buildings and repair operations

Ireton, J. (2016). ‘Federal government still using asbestos in new construction’, CBC News,  2 February:

Lum, F. (2014). “Pipes with asbestos still used in new buildings’, The Globe and Mail, 27 June: Povtak, T. (2018). ‘Canada announces asbestos ban with exemptions’,, 22 October:

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