In brief
Under the Regulation on Health and Safety Measures in Work with Asbestos, asbestos removal is carried out by certified asbestos removal workers under the supervision of an asbestos removal expert. Before work starts, a work plan is prepared and notified to the provincial directorate; during the work, measurements are taken by accredited and authorised laboratories and the eight-hour average may not exceed 0.1 fibre/cm³. Waste is removed in labelled, sealed packages; when the job is finished, a document showing that no exposure risk remains is issued and records are kept for 40 years.
Which rules apply to asbestos removal work?
Re-roofing an old factory, replacing pipe insulation in a boiler room or demolishing a building as part of urban renewal are all jobs that may bring workers into contact with asbestos. The core legislation for this work is the Regulation on Health and Safety Measures in Work with Asbestos of 25 January 2013. Also known simply as the asbestos regulation, it applies to all work with asbestos or asbestos-containing materials where exposure to asbestos dust may occur (Art. 2). The Regulation on Health and Safety Measures in Work with Carcinogenic or Mutagenic Substances also applies to asbestos work (Art. 2/2).
The regulation makes two points clear from the outset. First, the extraction, processing, sale and import of all types of asbestos, and the production and sale of products containing asbestos, are prohibited (Art. 5); the work done today is the safe removal and disposal of asbestos already in place. Second, the provisions apply wherever the employer suspects that the structure being worked on contains asbestos (Art. 7/1). Asbestos-cement roof and facade sheets, pipe and boiler insulation, some floor tiles and gaskets are the materials most often found in older buildings.
Before removal: survey and inventory
Before starting removal, demolition, repair, maintenance or clearance work, the employer inspects the structure to identify materials that may contain asbestos and where they are (Art. 7/1). Where demolition is involved, the Regulation on the Demolition of Buildings of 13 October 2021 also comes into play:
- Before demolition begins, an inventory survey is mandatory to determine whether asbestos-containing elements are present and, if so, their type, quantity and location. Bulk sampling and analysis are carried out by a laboratory authorised by the Ministry for asbestos type identification in bulk samples (Art. 16/1).
- Asbestos-containing elements are removed before demolition, collected separately and disposed of in line with the Regulation on the Landfilling of Waste (Art. 16/1).
- Removal is carried out in accordance with TS 13895, the guide to the removal of asbestos-containing materials and asbestos disposal methods (Art. 16/2).
- Main demolition cannot begin until asbestos and similar hazardous elements have been removed and taken away (Art. 5/7).
In the refurbishment of old industrial buildings and urban renewal demolitions in Bursa and the surrounding provinces, this sequence also sets the division of work between the demolition contractor and the employer carrying out the asbestos removal: inventory first, then removal and the clearance document, and main demolition last.
Asbestos removal contractors: who can do the work?
Under Art. 8 of the regulation, asbestos removal is carried out under the supervision of an asbestos removal expert and by an asbestos removal worker. The definitions are in Art. 4:
- Asbestos removal expert: a person given responsibility by the employer who has completed the training programme set by a commission established by the Ministry, passed the examination and received a course completion certificate. Expert training is delivered by ISGUM, the Ministry's Occupational Health and Safety Research and Development Institute (Art. 19/2).
- Asbestos removal worker: a worker who has completed the training programme set by the same commission and received a course completion certificate. This training is organised by authorised institutions in line with the programme and delivered by asbestos removal experts (Art. 19/3).
Those holding a vocational qualification certificate for asbestos removal work are not additionally required to hold a course completion certificate (Art. 8/2). The regulation does not mention a separate "authorisation certificate" for the company itself; what matters is that the people doing the work hold these certificates. When choosing an asbestos removal contractor, ask for the following documents:
| Document to request | What it shows |
|---|---|
| Asbestos removal expert course completion certificate | That the work will be supervised by an expert |
| Asbestos removal worker certificate for each worker | That everyone working on site is trained |
| Work plan and notification to the provincial directorate | That the work is registered and planned |
| Accreditation and authorisation details of the measuring laboratory | That the measurements will be valid |
| Health surveillance records of the workers | That chest X-rays and lung function tests have been done |
| Waste transport and disposal documents | That the waste has been removed in line with the law |
The company carrying out the removal is often your subcontractor; as the principal employer, your responsibility continues. For this relationship, see our article on subcontractor OHS responsibility.
Asbestos removal plan and notification
Before work begins, the employer prepares a work plan and submits a notification, together with the plan, to the Provincial Directorate of the Turkish Employment Agency responsible for the workplace (Art. 9/1). The notification includes the workplace's name and address, the type and quantity of asbestos to be removed, the work to be done, the number of workers, the start date and estimated duration, and the expert and worker certificates.
The asbestos removal plan itself is based on the risk assessment and covers at least the following (Art. 9/2):
- The type and estimated duration of the work,
- The place where the work will be carried out,
- The method to be used to remove the asbestos or asbestos-containing material,
- The characteristics of the equipment to be used,
- The protection and decontamination of those doing the work,
- The protection of other persons on or near the site,
- Removal of asbestos-containing material before demolition, except where leaving it in place would pose a greater risk.
During the work: measurement, limit value and protection
The eight-hour time-weighted average concentration of airborne asbestos to which workers are exposed may not exceed 0.1 fibre/cm³ (Art. 11). Measurement and sampling are carried out by laboratories accredited and authorised by the Directorate General of Occupational Health and Safety, in a way that reflects each worker's personal exposure (Art. 10). We plan measurements with authorised laboratories and feed the results into the risk assessment; the general framework is covered in our article on workplaces where exposure monitoring is mandatory.
To keep exposure below the limit value, the regulation lists these measures:
- The work is done with as few workers as possible; the work system is enclosed so that no dust is released, or where that is not possible, the spread of dust is prevented (Art. 12).
- The asbestos area is marked, warning signs are posted and unauthorised entry is prevented; smoking is prohibited and eating and drinking areas are located away from contamination risk (Art. 14/1-a).
- Suitable respiratory protection and protective clothing are provided. PPE is not taken off site; protective clothing is cleaned at the workplace and only taken out in closed containers; workers are provided with showers (Art. 14/1-b). The cost of these measures cannot be passed on to workers.
- If the limit value is exceeded, the cause is investigated, work in the affected area stops until measures are taken, and the measurement is repeated. Where compliance can only be achieved with respiratory protection, the maximum time each worker may work while wearing it is set in advance (Art. 13).
Our article on FFP1, FFP2 and FFP3 masks is a general starting point for choosing respiratory protection; in asbestos work, the type of protection is determined by the risk assessment and the removal plan.
Asbestos waste management
Asbestos-containing waste is collected immediately, labelled to show that it contains asbestos using the markings set out in environmental legislation, removed from the workplace as soon as possible in sealed packaging, and disposed of in line with the law (Art. 12/1-ç, d). Dust-releasing asbestos materials are transported in sealed packaging and stored separately from other materials. In demolition work, asbestos waste is collected separately and disposed of in line with landfill legislation. Asbestos waste must not be mixed into rubble skips; setting up a separate, lockable temporary storage point on site is the easiest way to prevent mixing.
When the work is finished: clearance document, health surveillance and records
When removal is complete, the employer arranges for a document stating that no risk of exposure to asbestos dust remains at the workplace and containing the measurement results. This document is issued by an accredited and authorised laboratory and submitted to the provincial directorate (Art. 9/3–4).
Health surveillance is carried out in line with Art. 16 and Annex I of the regulation:
- The general health of a person doing this work for the first time is assessed by the workplace physician before work begins.
- The examination includes a physical examination focusing on the respiratory system, a standard or digital chest X-ray and a lung function test.
- The chest X-ray is repeated at intervals set by the physician; this interval may not exceed 2 years.
- The physician may decide how long health surveillance should continue after exposure ends.
Records are kept for at least 40 years after exposure ends; if the workplace closes, they are handed over to the provincial directorate of the Social Security Institution (SGK) (Art. 17). In the list of occupational diseases, asbestosis appears under heading C-1b; mesothelioma of the pleura and peritoneum is listed among its manifestations, "construction and demolition work involving asbestos-containing materials in buildings" is listed among the hazardous jobs, and the liability period is 10 years. See our articles on the list of occupational diseases and, for general dust rules, the Regulation on Dust Control.
For assessing asbestos risk in construction and demolition projects and checking the removal contractor's documents, see our risk assessment service; for chest X-ray and lung function test follow-up of workers, see our health surveillance service; and for the other risks in the sector, see our construction page.
Frequently Asked Questions
Can our own maintenance team remove asbestos roof sheets?
Removal work within the scope of the regulation is carried out under the supervision of an asbestos removal expert by people holding an asbestos removal worker certificate. It is contrary to the regulation for a maintenance team without these certificates to remove asbestos-containing material by breaking or cutting it.
Where is the asbestos removal plan notified?
Under Art. 9 of the regulation, the work plan is submitted with the notification to the Provincial Directorate of the Turkish Employment Agency responsible for the workplace before work begins. When the work is finished, the document showing that no exposure risk remains is also submitted to the same directorate.
What is the asbestos limit value?
The eight-hour time-weighted average concentration of airborne asbestos to which a worker is exposed may not exceed 0.1 fibre/cm³. Measurements are taken by accredited and authorised laboratories based on personal exposure.
How long are records of asbestos removal workers kept?
Records showing the work done by workers, their working hours and exposure levels are kept for at least 40 years after exposure ends.
A risk assessment that identifies and scores hazards on site, links each measure to an owner and a date, and has a clear renewal schedule.
Bursa SİSTEMER OSGB Technical Team — written from the field experience of our OHS specialists and workplace physicians. Legal information is valid as of the publication/update date; contact us for an assessment specific to your business.