Asbestos in Building Dismantling
Requirements for Contractors and Those Carrying Out the Work
With the amended Hazardous Substances Ordinance (Gefahrstoffverordnung, GefStoffV) of December 2024, the risk-based measures concept for activities involving carcinogenic hazardous substances was incorporated into the ordinance. In addition, duties of cooperation and information for the party initiating the work were introduced, and new asbestos-related provisions were defined.
These regulations also have far-reaching implications for the demolition industry: before work begins, the initiator must inform the contractor of the year the structure to be demolished (in whole or in part) was built. The initiator must also inform the contractor about any existing or suspected hazardous substances.
The contractor, in turn, is required to check the initiator’s information for plausibility. The most important piece of information is the date construction began. If construction started before 31 October 1993—the date asbestos was banned in Germany—the contractor must assume the presence of asbestos and take this into account in the risk assessment. If the initiator’s information is insufficient for the risk assessment, the contractor must obtain further information. For example, the contractor may arrange a technical survey. The costs incurred for this are considered a special service.
Activities involving asbestos are prohibited. Exceptions to this prohibition are demolition, remediation, and maintenance work (ASI work). Under Section 11(2) GefStoffV, demolition means the complete removal of asbestos-containing components or materials—even on partial surfaces or in partial areas. The complete removal of asbestos-containing plaster from a wall (in whole or in part) therefore falls under demolition in the same way as the complete demolition of a reinforced-concrete structure containing asbestos-bearing spacers or wall thicknesses.
Work involving asbestos may only be carried out by specialist companies. Specialist companies have suitable safety, organizational, and personnel resources for asbestos-related work. The personnel requirements relate to the roles and the associated qualifications of employees.
The responsible person is tasked with carrying out the risk assessment and determining protective measures. The supervising person oversees the work on site and ensures protective measures are applied. Responsible and supervising persons must be competent. For work in the high-risk category, competence in accordance with Annex 3 of TRGS 519 must be demonstrated. For work in the low and medium risk categories, at least competence in accordance with Annex 4C of TRGS 519 must be demonstrated.
With GefStoffV 2024, a qualification requirement was introduced for all employees who carry out asbestos-related activities. Proof of this qualification must be provided by 05 December 2027. Completing the “Basic Knowledge Asbestos” course counts as proof. The theoretical component of this qualification can be completed via the BG BAU learning portal.
The type and scope of notification and approval also depend on the risk category to which the activities are assigned. For activities in the low and medium risk categories, a company-based notification must be submitted, observing a one-week deadline. With GefStoffV 2025, the content of the company-based notification was further differentiated: for demolition work in the low and medium risk categories, approval must be obtained from the supervisory authority. Additional information from the contractor is required for approval to be granted—for example, employees carrying out asbestos-related work must be named individually, and proof of qualification must be attached. In addition, the notification period is extended to four weeks.
For activities in the high-risk category, an object-specific notification is required. These companies also require authorization from the competent authority.
For asbestos-related work, working methods must be selected that minimize or prevent the release of asbestos fibers.
In demolition work, a distinction is necessary here: are the activities carried out indoors and limited to specific building materials? Or are they outdoor activities where removing the asbestos-containing material from a building or building section is not possible? Are blasting operations being performed?
Different demolition activities can therefore be assigned to different risk categories. The protective measures to be implemented must take this into account.
The combination of selecting working methods that minimize fiber release and thoroughly removing any remaining fibers at the end of the work reduces the risk of fiber carryover during asbestos-related activities.
Berit Schuchmann, BG BAU