Asbestos checks before renovation or demolition in Catalonia

Before renovating, maintaining, refurbishing or demolishing a property, do not rely on the general question “Does this building contain asbestos?”. The practical issue is whether the work could disturb materials containing asbestos in the affected areas. Those areas should be checked before drilling, cutting, stripping out or demolition begins.

The correct sequence is to define the work, collect available building information and arrange a qualified examination where the evidence is insufficient. If the proposed activity involves a risk of asbestos exposure, the project must then be coordinated with a suitably registered RERA contractor and the applicable work plan. The municipal works authorisation and the occupational asbestos procedure are separate controls; neither replaces the other.

Start by defining the work and reviewing existing information

Map the intervention before commissioning contractors. Relevant activities may include opening service chases, replacing downpipes, removing suspended ceilings or old flooring, altering thermal insulation, working on roofs and tanks, or modifying historic installations. These elements do not necessarily contain asbestos, but they merit attention if the work will disturb them. “Uralita” should not be treated as an exact synonym either: it is a trade name, while fibre cement is a type of material that may or may not contain asbestos.

For certain demolition, maintenance or refurbishment work in premises built before asbestos was prohibited in Spain, companies must take measures to identify materials that may contain it. They must first seek information from the owner, other companies and relevant records. Useful evidence may include original drawings, later refurbishment projects, technical reports, inventories, photographs and services documentation. A building’s age is a warning indicator, not proof of a material’s composition. [2] [5]

• List every area that will be drilled, cut, dismantled or demolished.
• Ask the owner or community of owners for available building records.
• Review previous projects, surveys and alterations.
• Do not break or drill a suspect material to identify it informally.
• Complete the check before finalising the programme and contractor scope.

Arrange a qualified examination when records are insufficient

If the records cannot exclude asbestos or establish where it is located, a prior examination is required. Its purpose is to determine the location and extent of materials that may contain asbestos. Depending on the circumstances, this may involve documentary research, visual inspection, sampling and laboratory analysis. Discovering a suspect product during strip-out is not an acceptable substitute: it can expose workers, contaminate adjoining areas and interrupt the project. [2] [5]

Do not assume that any architect, engineer or surveyor can automatically perform this examination. The transitional rules recognise specified architecture, technical architecture, engineering, technical engineering and higher vocational qualifications, but also require at least two years of evidenced experience in asbestos work or a higher qualification specialising in industrial hygiene. Certain authorised people or entities are also covered for particular inspections. Ask for evidence of the operator’s applicable qualification and check the current BOE text before appointment, as more specific requirements may be introduced. [2] [5]

• Confirm the operator’s qualification and relevant experience.
• Define the exact rooms, elements and external areas to be examined.
• Require the location and extent of suspect materials to be recorded.
• Agree whether sampling and analysis are necessary.
• Keep other trades away from areas awaiting examination.

Integrate the findings and assign each responsibility correctly

The identification findings must be reflected in the health and safety study, the basic health and safety study or, where neither document is required, the risk assessment. A survey or identification report does not replace the technical renovation project, municipal works authorisation or asbestos work plan. The project team must connect these separate documents so that the design, preventive measures and construction sequence all address the same affected materials. [2] [5]

As an operational division of responsibilities, the client and project professional define the proposed works; the owner and participating companies provide existing information; and the qualified operator identifies and delimits potential asbestos-containing materials. The competent designer then incorporates the findings into the project and sequence. The company carrying out the asbestos activity prepares and submits the work plan, while the specialist intervention must be undertaken by a company registered with RERA, the Spanish Register of Companies with Asbestos Risk. Relevant authorised operators must handle the resulting waste. [2] [5]

• Client and designer: define the precise renovation or demolition scope.
• Qualified operator: locate and delimit potential asbestos-containing materials.
• Project professional: integrate the findings and plan the sequence.
• RERA company: prepare the work plan and perform the specialist activity.
• Authorised operators: transport and manage the asbestos waste as applicable.

Verify the RERA company, work plan and project timetable

A work plan must be prepared before each activity involving a risk of asbestos exposure. As a general rule, it must provide for asbestos removal before demolition techniques are applied, unless removal would create a greater risk. The plan covers matters including the work, material type and quantity, location, dates, personnel, methods, equipment, preventive measures, protection of third parties and environmental monitoring. The principal or contracting company must verify that its contractor or subcontractor has the corresponding approved plan. [2] [5]

The plan is submitted to the labour authority for the place where the work will occur. The statutory period for a decision and notification is 45 days; without an express decision during that period, the plan is deemed approved. This is not a promise that a particular project will be ready to start within 45 days. The start must also be notified at least seven working days beforehand, except for justified emergencies involving unplanned work. Plans submitted before Royal Decree 847/2026 entered into force continue under the previous rules until their resolution is notified. [2] [6] [8]

• Check that the contractor’s RERA registration remains valid.
• Confirm that the plan applies to the actual site and scope.
• Allow for assessment, preparation, submission and start notification.
• Do not schedule incompatible trades in an area that has not been released.
• Obtain the separate municipal works authorisation required for the project.

Assess cost and feasibility before committing to the project

A reliable cost cannot be established from floor area alone. Relevant variables include the examination and any analysis, whether the material is friable or non-friable, its quantity and location, access and working height, containment, temporary works, environmental monitoring, transport, waste treatment and replacement of the removed element. When comparing quotations, ask each contractor to price the same defined scope and state clearly which surveys, controls, access equipment, waste services and reinstatement works are included or excluded.

For a purchase, lease or renovation feasibility study, investigate potential asbestos alongside the technical design and programme. Its presence does not automatically mean that every affected element must be removed immediately, but work that could disturb it may determine the construction sequence. Retain the examination, approved plan, start notification, evidence of RERA registration, required monitoring records, waste transport and management evidence, and final project documents. Catalan Law 8/2026 creates a framework for progressive detection, management and removal, while its specific penalty regime was deferred pending implementing regulations. Check the current position with the Portal Jurídic de Catalunya and the relevant public— [1]

• Request an itemised quotation tied to the examined scope.
• Include access, containment, monitoring, waste and reinstatement where relevant.
• Coordinate specialist activities with the main contractor and other trades.
• Keep records from identification through to waste management and completion.
• Recheck the BOE, Generalitat procedure and local council requirements before starting.

Frequently asked questions

Are the asbestos examination and work plan the same document?

No. The examination identifies the location and extent of materials that may contain asbestos and informs the preventive documentation. The work plan explains how an activity involving exposure risk will be performed, including its procedures, equipment, controls and protective measures.

Does a Barcelona works permit authorise asbestos removal?

No. The municipal planning or works procedure and the occupational procedure for the asbestos work plan are separate. A municipal permit does not authorise asbestos work by itself, and approval of the work plan does not replace the municipal authorisation. Check both before fixing the start date.

How long does approval of an asbestos work plan take?

Royal Decree 847/2026 sets a 45-day period for the authority to decide and notify, with deemed approval if no express decision is issued within that period. This does not guarantee the total project duration. The programme must also account for the start notification at least seven working days in advance and any current requirements published by the Catalan labour authority.