Short answer: if the job is Type 2 or Type 3 asbestos work, the law requires an Approved Inspection Authority (AIA). The size of the job is not the test on its own. A small removal only avoids an AIA if it meets every condition for Type 1 work.
You may have heard that “anything under 10 square metres doesn’t need an AIA”. That is close, but not what the regulations say. Here is how it actually works.
What an AIA does on an asbestos job
An Approved Inspection Authority is an independent inspection body approved by the Department of Employment and Labour. The AIA does not remove anything. It checks the people who do. On Type 2 and Type 3 work, the Asbestos Abatement Regulations 2020 (as amended) require the AIA to:
- compile the plan of work with the registered contractor and submit it to the Department at least seven days before work starts (regulation 13(c) and 13(d))
- inspect the site to check the plan and the regulations are followed, and stop the work if it becomes unsafe (regulation 13(h) and 13(i))
- carry out air monitoring during the work, including environmental monitoring around the site (regulation 13(j), 16(1) and 16(3))
- do the final clearance once the work is done: a visual inspection, air sampling, and a check that all the waste has gone (regulation 22)
At the end, you as the client must get an asbestos clearance certificate from the AIA (regulation 11(3)). It records the clearance assessment and whether the work area met the applicable clearance requirements at that time.
The three types of asbestos work
The regulations sort asbestos work into three types. The type decides whether an AIA is needed.
Type 1: small, once-off, low-risk work
Type 1 is limited to two things (regulation 1):
- painting asbestos cement without any surface preparation, in a way that does not release fibres, or
- removing less than 10 m² of asbestos cement products (such as roof sheets, gutters and pipes) or asbestos insulating board, subject to the once-off condition below
Type 1 work does not need an AIA appointment.
Type 2: asbestos cement and insulating board
Type 2 covers removing asbestos cement products or asbestos insulating board, and repairing or sealing asbestos cement without surface preparation. It has to be done by a contractor registered for Type 2 work. Most Cape Town homes with asbestos have exactly this: old roof sheets, ceilings, gutters, downpipes and boundary panels.
Type 3: everything else
Type 3 covers the removal, repair or sealing of any other asbestos material, such as pipe lagging or sprayed coatings. It needs a Type 3 registered contractor.
So when is an AIA required?
Regulation 11(2)(d) is clear: anyone planning Type 2 or Type 3 work must appoint an AIA in writing. There is no size limit on that rule. A 3 m² job can still need an AIA, and here is why.
The 10 m² rule has conditions
A job only escapes the AIA requirement if it is Type 1, and a removal is only Type 1 if all three of these are true:
- The material is right. It must be asbestos cement or asbestos insulating board. Other asbestos materials are Type 3 at any size.
- The area is under 10 m². Less than 10, so exactly 10 m² is already Type 2.
- It is once-off. Removal work may not be repeated on the same site within six months.
Type 1 is not a free pass
Even when no AIA is needed, Type 1 work still has rules. The Department must be notified in writing at least seven days before work starts (regulation 10(1)). There must also be an inventory of the asbestos, a risk assessment, a written safe work procedure, and proper information and training for anyone exposed (regulation 11(1)).
When nobody is sure which type it is
If there is doubt about whether a job is Type 1, 2 or 3, the regulations do not let the contractor simply decide. Regulation 14 says an AIA must make the decision, or the matter goes to the chief inspector. The disputed work must stop until there is a written decision. And if nobody knows whether a material contains asbestos at all, it must be treated as asbestos or sent to a lab for testing (regulation 3(b)).
Quick guide: do I need an AIA?
| Your situation | Type of work | AIA needed? |
|---|---|---|
| Painting intact asbestos cement sheets, no sanding or scraping | Type 1 | No |
| Qualifying Type 1 removal of less than 10 m² of asbestos cement or insulating board | Type 1 | No, but notification and safe-work rules still apply |
| Removal of 10 m² or more of asbestos cement or insulating board, such as a house or garage roof | Type 2 | Yes |
| Repairing or sealing asbestos cement sheets | Type 2 | Yes |
| Pipe lagging, sprayed coatings or other asbestos materials, any size | Type 3 | Yes, plus a Type 3 contractor |
| Not sure which type applies | To be decided | An AIA or the chief inspector decides first (regulation 14) |
Who appoints the AIA, and who pays?
The asbestos client must appoint the AIA in writing before any Type 2 or Type 3 work starts (regulations 11(2)(d) and 12(3)(f)(i)). The AIA is an independent inspection body. It is not part of the contractor’s team, and it checks the work on your behalf. You also co-sign the plan of work with the contractor and the AIA (regulation 11(2)(g)).
In practice you do not have to find an AIA yourself. When we quote a Type 2 job, we arrange an independent AIA as part of our quotation, coordinate the client’s written appointment, and show its fee as its own line. As a guide, the AIA generally costs R10,000 to R15,000 excluding VAT, depending on the size of the project. For a simple operation, site work usually takes 1 to 3 days, separate from the advance preparation and notification period, and the fee covers the administration, submitting the asbestos plan of work and all the inspections. The project-specific AIA allowance is a substantial part of the price, which is why it can make up a larger share of a smaller job’s cost.
It also explains why qualifying small jobs can cost substantially less. When a job qualifies as Type 1, there is no AIA to appoint, and the AIA is one of the biggest parts of the cost. The exact price of a small job still depends on the site, so we price those on a free visit.
To see how that works out for your roof, try our asbestos removal cost calculator.
What this means for your job
FN Building Projects is a registered asbestos contractor, registration 2026RAC/OHS-CI069 (Type 2). That covers asbestos cement and insulating board, which is most of what we see on Cape Town homes. If your job turns out to be Type 3, we will tell you before anything starts rather than take it on.
Before quoting, we check what the material is, how much there is, and whether any removal has already happened on the site. That tells us the type of work and whether an AIA is needed. In a borderline case, the AIA makes the call, not us.
For what we remove and how a job runs from start to finish, see our Type 2 asbestos removal in Cape Town service. For why doing it properly costs what it does, read why asbestos removal is so expensive and dangerous.
Planning asbestos removal in Cape Town? Book a free asbestos site visit so we can assess the scope and explain the next steps for your property.
Common questions
Do I need an AIA for asbestos removal?
Yes, for any Type 2 or Type 3 work. That includes removing 10 m² or more of asbestos cement roof sheets or insulating board, and any removal of other asbestos materials. Only small, once-off Type 1 jobs are excluded.
Is asbestos removal under 10 m² exempt from an AIA?
Only if it meets all the Type 1 conditions explained above, including the material, area and once-off requirements. If any one of those is not true, the job is Type 2 or Type 3 and needs an AIA.
Does Type 1 asbestos work need any paperwork?
Yes. Written notification to the Department at least seven days ahead, an asbestos inventory, a risk assessment and a written safe work procedure (regulations 10(1) and 11(1)).
What is an asbestos clearance certificate?
It is the AIA’s written confirmation, after an inspection and air sampling, that the work area meets the clearance standard. After Type 2 or Type 3 work, the client must obtain one (regulations 11(3) and 22). Keep it with your property records.
Who decides if my job is Type 1 or Type 2?
If there is any doubt, an AIA or the chief inspector must decide in writing, and the work stops until they do (regulation 14).
This article summarises the Asbestos Abatement Regulations 2020 as amended. It is a plain-language guide, not legal advice. Site-specific classification must follow the regulations and any applicable decision under regulation 14.
Source: Department of Employment and Labour: Asbestos Abatement Regulations.
Check the current regulations for the actual work
The July 2024 amendment to the Asbestos Abatement Regulations also addresses tools used on asbestos-containing material and installing fittings onto it. Confirm the classification, notification and inspection requirements with the appointed competent professionals before work starts. A floor-area figure alone does not determine the requirements.