Hazardous Building Materials Assessment 101

If you're planning a renovation, demolition, or significant repair on a property in Canada, there's a critical step that needs to happen before work begins: a formal assessment for hazardous materials.

Miss this step and you're not looking at a minor paperwork problem. You're looking at potential worker health risks, project shutdowns, and significant liability for property owners, managers, and general contractors.

The specifics vary by province — but the requirement exists across the country.

What Is a Hazardous Materials Assessment?

A Hazardous Building Materials Assessment (HBMA) is a formal assessment of a building to identify substances that could pose a health risk if disturbed during construction, renovation, or demolition activities.

These assessments go by different names depending on where you are:

• In Ontario, they're formally called Designated Substance Surveys (DSS), governed by provincial legislation

• In British Columbia, Alberta, Quebec, and other provinces, the equivalent assessment is commonly referred to as a Hazardous Materials Assessment or Pre-Construction (Demolition/Pre-Renovation/Construction) Hazardous Building Materials Assessments

The terminology differs. The underlying obligation — to identify and manage hazardous materials before disturbing them — does not.

Regardless of province, these assessment typically identify:

• Asbestos — found in pipe and duct insulation, floor tiles, drywall compound, plaster, ceiling tiles, and more in buildings constructed before the 1990s

• Lead — common in older paints, solders, and plumbing

• Silica — present in concrete, masonry, ceramic tiles, and ceiling tiles

• Mercury — present in thermostats, fluorescent lighting, and equipment gauges/switches

• Mould — a biological hazard, usually occurs alongside water damage/staining

• Other regulated substances — including acrylonitrile, arsenic, benzene, coke oven emissions, ethylene oxide, isocyanates, and vinyl chloride depending on building type and history

The assessment identifies which substances are present, where they're located, and what condition they're in. That information then determines how the project must be managed — including whether abatement is required before work begins.

The Regulatory Landscape Across Canada

Workplace health and safety legislation in Canada is provincially administered, which means the specific regulatory framework — and the terminology — varies by jurisdiction.

Ontario has the most codified requirements under the Occupational Health and Safety Act, including:

• Ontario Health and Safety Act R.S.O. 1990 — Section 30 requires the project owner to determine whether Designated Substance Survey are present before any renovation, alteration, repair, or demolition that may disturb building materials. Applies to all project sizes.

• Ontario Regulation (O. Reg.) 490/09 — Defines Designated Substances and requires an employer to take every precaution reasonable to protect workers from exposure to Designated Substances in a workplace.

• O. Reg. 213/91 — Places additional obligations on constructors and employers on construction sites to protect workers from exposure.

British Columbia requirements fall under the Workers Compensation Act and WorkSafeBC regulations, which require hazardous materials identification and management plans before demolition or renovation activities.

Alberta operates under the Occupational Health and Safety Act and associated codes, with specific requirements around asbestos and other hazardous building materials before disturbance.

Quebec governs hazardous materials through the Act respecting occupational health and safety and associated regulations, with requirements for asbestos risk management in buildings.

Across all provinces, the common thread is this: you are required to know what's in a building before you disturb it. The regulatory mechanism differs; the obligation is universal.

If you're operating in multiple provinces — as many of our clients are — a consistent approach to hazardous materials assessment isn't just good practice, it's the only way to manage compliance risk at scale.

When Is an Assessment Required?

While the trigger points vary slightly by province, as a general rule a hazardous building materials assessment is required before:

• Any renovation, alteration, or repair of a building

• Demolition of any part of a building

• Maintenance work that may disturb building materials

This applies regardless of project size. Whether you're replacing flooring in a 1970s office building or pulling down a wall for a tenant improvement, if there's any chance hazardous materials are present, you need an assessment first.

What Happens During the Assessment?

A qualified assessor will:

1. Review available building documents (as-builts, previous assessments, renovation history)

2. Conduct a thorough visual inspection of the areas to be disturbed

3. Collect bulk samples of suspect materials for laboratory analysis

4. Produce a written report documenting findings, material locations, sample results, and recommended actions

That report becomes a critical project document. In Ontario and most other provinces, general contractors are required to disclose it to all employers on site, to contractors bidding on work, and it informs the scope of any required abatement work.

What If Hazardous Materials Are Found?

Finding a hazardous building material doesn't automatically stop a project. It means the work needs to be planned and managed appropriately.

In Ontario, asbestos disturbance is classified as Type 1, 2, or 3 work under O. Reg. 278/05, with each level dictating the required controls. Similar risk-based classification systems exist in other provinces and for other hazards like lead, silica, and mould.

Depending on findings, the project may require:

• Abatement Project Design

• Develop scopes of work and specifications

• Project Tendering and Contractor Management

• Inspection Services

• Air Monitoring

• Close-Out Reporting Summarizing the abatement project.

RiskCheck manages the full cycle — from initial assessment through abatement oversight and clearance — so property owners and general contractors aren't coordinating multiple vendors or navigating provincial regulations on their own.

Common Mistakes We See

Assuming newer buildings are clean. Asbestos was used in building materials well into the 1980s, and some products remained in use into the early 1990s. Age alone doesn't clear a property.

Starting work before the assessment is complete. This is where serious liability is created. If workers disturb asbestos or other designated substances without proper controls in place, the consequences — health, legal, and financial — are severe.

Using a non-qualified assessor. Assessment must be conducted by a qualified person. The assessment process and report must meet the applicable provincial regulatory standard to be valid.

Not disclosing results to contractors. Property owners and project managers are required to disclose assessment findings to all employers working on site. In most provinces, this is a legal obligation, not a courtesy.

Treating it as a one-province problem. If you manage properties across multiple provinces, patchwork compliance creates gaps. A consistent, national approach to hazardous materials assessment is the only way to protect your portfolio and your people.

The Bottom Line

Regardless of what province you're operating in, the obligation is the same: identify hazardous materials before you disturb them. The regulatory frameworks differ, but the risk of getting it wrong — to workers, to timelines, and to owners — is consistent across the country.

Getting an assessment done early, before contractors are mobilized and schedules are locked, is almost always the right call.

Operating in Ontario or across Canada? Contact RiskCheck to discuss your project. We provide fast turnaround with thorough documentation, and we're experienced navigating hazardous materials requirements across jurisdictions.