The hazardous materials survey applies to every building, whatever its age

There is a belief we run into on most renovation projects that is worth correcting directly, because getting it wrong exposes the owner personally.

Owners tell us their house is too new to need a hazardous materials survey. They usually have a year in mind, generally 1990. The WorkSafeBC regulation that creates the requirement contains no building age threshold at all.

What the regulation says

Before work begins on the demolition or salvage of machinery, equipment, a building or a structure, or the renovation of a building or structure, all employers responsible for that work, and the owner, must ensure that a qualified person inspects the building and the worksite to identify the hazardous materials, if any.

Three things in that sentence deserve attention.

• Before work begins. Not during, not as the demolition uncovers something.
• Demolition, salvage, or renovation. Renovation is named alongside the others, so the duty reaches ordinary renovation work.
• All employers responsible for that work, and the owner. The owner is named, not merely implied.

The regulation puts the duty on the owner alongside the contractor. Assuming your builder has it handled does not remove your name from the provision.

Where the 1990 figure comes from

The year is not invented, it is misattributed. The City of Vancouver applies its own requirements that reference buildings constructed before 1990, and that municipal rule is what people are half-remembering.

Two consequences follow. First, in Vancouver there is a municipal layer on top of the WorkSafeBC duty, with its own forms at application and completion. Second, and more important, an owner outside Vancouver, or an owner in Vancouver with a newer building, has not escaped the WorkSafeBC requirement just because the municipal age reference does not catch them. The provincial duty has no age trigger.

What is being looked for

The regulation defines hazardous material as a hazardous substance or a material containing one, including asbestos-containing material, lead or any other heavy metal, and toxic, flammable or explosive material.

Asbestos is the one everyone knows, and in Metro Vancouver's older housing stock it turns up in more places than owners expect: insulation, flooring, texture coatings, and mechanical components. Lead appears in old paint and in plumbing. The broader categories catch things like stored chemicals and fuel in a workshop or garage.

In practice surveyors look at more than that list. What we will say precisely is that those are the categories the regulation itself names, and other substances are commonly included as a matter of professional practice rather than because the regulation enumerates them.

Who can do it, and what changed

The regulation defines a qualified person by education, training and experience with the specific materials rather than by naming a credential. That framing has been overtaken in one important respect.

Since January 1 2024, asbestos abatement work relating to buildings requires a WorkSafeBC licence, and workers require certification. The statutory definition of that work includes identifying material that is or may be asbestos-containing and collecting samples, which means the survey is itself inside the licensed regime rather than sitting outside it as preliminary work.

So who you hire matters in a way it did not a few years ago. Confirming that a firm holds the required licence, and that the individual doing the work holds current certification, is a reasonable question rather than an insult.

What a real report contains

The regulation is specific about output, and it is a useful standard for judging what you receive.

It requires sampling and identification, and a written report stating the methods used, the locations of the materials including through drawings, plans or specifications, and the approximate quantity of each.

A report that lists substances without locating them on a drawing and quantifying them is not what the regulation describes, and it is not useful to the trades who have to work around the findings. Location and quantity are what turn a survey into something a project can act on.

The provision that moves your schedule

This is the part with the largest practical effect, and the one most often discovered late.

The regulation prohibits any work that may disturb the materials until they are safely contained or removed, and requires written confirmation from a qualified person.

Read as a schedule, that is a chain of dependencies: survey, then abatement where required, then written confirmation, then the work that could have disturbed the materials. Each step waits on the one before it. There is no version where demolition proceeds in parallel while abatement is arranged.

Projects that treat the survey as paperwork to be done during mobilization discover this at the worst moment, with trades scheduled and a site that cannot be touched. It belongs in pre-construction planning alongside the items in what homeowners wish they knew before renovating.

Vancouver's additional layer

In Vancouver the municipal process runs alongside the provincial duty and requires documentation at both ends: a qualified professional declaration at application, and on completion a hazardous building materials report, an inspection report meeting WorkSafeBC requirements, and a post-abatement inspection report.

The city has also changed how this is permitted, folding salvage and abatement into the demolition permit rather than issuing a separate permit for it. Because that changed recently, confirm the current process with the city rather than working from an older description, including anything you may have done on a previous project.

How this connects to the demolition decision

For an owner weighing whether to renovate or take a house down, the survey is a cost and a schedule item on both paths, since renovation is named in the regulation alongside demolition.

What differs is scope. A full demolition surveys the whole building. A renovation surveys the area affected, which can be smaller, though a discovery in one area often raises questions about others. We walk through the broader comparison in renovate or demolish, how that decision gets made.

Frequently asked