Type 3 Asbestos Work in Ontario: Notice Requirements and What They Do to Your Schedule
If a designated substances survey comes back with friable asbestos in the area you are renovating or demolishing, the next question decides your schedule: is this a Type 3 operation? Type 3 work carries an advance notice obligation and the most demanding controls in the regulation, and owners routinely find out about it a week before they wanted crews on site.
Here is the practical version, from a contractor's side of the table.
What makes an operation Type 3
Ontario Regulation 278/05 classifies asbestos work as Type 1, Type 2 or Type 3 based on what is being disturbed and how 1. Type 3 operations include:
- Removing or disturbing more than one square metre of friable asbestos-containing material during repair, alteration, maintenance or demolition of all or part of a building
- Spray application of a sealant to friable asbestos-containing material
- Cleaning or removing air handling equipment, including rigid ducting, in a building with sprayed fireproofing that is asbestos-containing
- Repairing, altering or demolishing a kiln, metallurgical furnace or similar structure made partly of asbestos-containing refractory materials
- Breaking, cutting, drilling, abrading, grinding, sanding or vibrating non-friable asbestos-containing material using power tools not attached to HEPA-filtered dust collection
- Repairing, altering or demolishing a building where asbestos was used in manufacturing products, unless it was cleaned up and removed before March 16, 1986
Two details that catch people out. First, area is counted as the total worked on consecutively in a room or enclosed area — you cannot split a 5 m² removal into five 1 m² jobs to stay under the threshold. Second, one square metre is not much friable material. Pipe insulation along a mechanical run, or sprayed fireproofing above a ceiling on a commercial floor, gets past it quickly.
The notice itself
Before a Type 3 operation begins, the constructor on a project — or the employer, in other cases — must notify an inspector at the Ministry office nearest the workplace, both orally and in writing 1. The same requirement applies to one particular Type 2 operation: removal of one square metre or more of insulation.
The written notice has to set out:
- The name and address of whoever is giving the notice
- The name and address of the owner of the place where the work will be carried out
- The address or a description of the place, precise enough for an inspector to find it
- A description of the work
- The starting date and expected duration
- The name and address of the supervisor in charge
Ontario also runs an online work-notice service, which is where notices of asbestos removal work are filed 3.
The part owners actually care about: the timeline
The regulation frames the obligation as before commencing rather than as a fixed number of days. That sounds flexible and is not, for one practical reason: the notice has to state a start date and a supervisor, which means the contractor, the enclosure plan, the schedule and the supervision all have to be settled before the notice can be honest. That is the real lead time, and it is measured in weeks, not days, on most commercial jobs.
What sits ahead of the start date on a typical GTA project:
- Designated substances survey. The owner's obligation under the Occupational Health and Safety Act, before tendering the work. Everything downstream waits on it.
- Classification and method. Whether the work is Type 1, 2 or 3, and the enclosure, procedures and controls that go with it.
- Contractor award and supervision named. The notice needs a supervisor in charge.
- Notice to the Ministry, orally and in writing. Also a Notice of Project where the construction project requires one.
- Enclosure built, work performed, area cleared. Then, and only then, the strip-out and construction behind it.
The sequencing mistake we see most often is tendering demolition or renovation first and treating abatement as something to sort out later. The survey then lands mid-project, the work turns out to be Type 3, and a job that was three weeks from handover stops while a notice goes in and an enclosure gets built.
What discovery mid-project actually costs
If asbestos-containing material shows up after work has started — behind a wall, above a ceiling, inside a mechanical chase — the affected work stops. The area is secured, the material is examined, the operation is classified, and if it lands in Type 3 the notice goes in before work resumes.
None of that is negotiable, and none of it is fast. The cost is the standing time and the re-mobilisation, not the abatement itself. Where a survey exists and the scope is priced against it, the same removal is a scheduled line item.
Sequence it once, properly
The way to keep a date is to run the survey, the abatement and the work behind it as one sequence under one contract. We handle commercial asbestos abatement and the commercial demolition that follows it, which means the classification, the notice, the enclosure and the strip-out sit with the same project manager rather than being relayed between two contractors with different schedules.
If your building predates 1990, start with what owners of pre-1990 commercial buildings need to know about asbestos.
Request a quote. Send us the survey and the scope or call (647) 963-4310.
Related reading
Frequently asked questions
When is commercial asbestos work a Type 3 operation in Ontario?
Ontario Regulation 278/05 classifies the work by what is being disturbed and how. This article lists Type 3 as removing or disturbing more than one square metre of friable asbestos-containing material during repair, alteration, maintenance or demolition; spray-applying a sealant to friable material; cleaning or removing air-handling equipment, including rigid ducting, in a building with sprayed fireproofing that contains asbestos; repairing, altering or demolishing a kiln, metallurgical furnace or similar structure made partly of asbestos-containing refractory materials; using power tools that are not attached to HEPA-filtered dust collection to break, cut, drill, abrade, grind, sand or vibrate non-friable material; and repairing, altering or demolishing a building where asbestos was used to manufacture products, unless it was cleaned up and removed before March 16, 1986.
Can a commercial removal be split into smaller jobs to stay under one square metre?
No. The article says area is counted as the total worked on consecutively in a room or enclosed area. You cannot split a 5 square metre removal into five 1 square metre jobs to stay under the threshold. One square metre is not much friable material: pipe insulation along a mechanical run, or sprayed fireproofing above a ceiling on a commercial floor, gets past it quickly.
Who has to give the Type 3 notice, and how?
Before a Type 3 operation begins, the constructor on a project, or the employer in other cases, must notify an inspector at the Ministry office nearest the workplace, both orally and in writing. The same requirement applies to one particular Type 2 operation: removal of one square metre or more of insulation. Ontario also runs an online work-notice service where notices of asbestos removal work are filed.
What does the written notice have to include?
The name and address of whoever is giving the notice, the name and address of the owner of the place where the work will be carried out, an address or description precise enough for an inspector to find it, a description of the work, the starting date and expected duration, and the name and address of the supervisor in charge.
Is the Type 3 notice a fixed number of days before the start?
No. The regulation frames the obligation as before commencing, not as a fixed number of days. That sounds flexible and is not, because the notice has to state a start date and a supervisor. The contractor, the enclosure plan, the schedule and the supervision all have to be settled before the notice can be honest. On most commercial jobs that lead time is measured in weeks, not days.
What has to happen before a Type 3 commercial start date?
The designated substances survey, which is the owner's obligation under the Occupational Health and Safety Act before tendering. Then classification and method. Then contractor award with a supervisor named, because the notice needs a supervisor in charge. Then notice to the Ministry, orally and in writing, and a Notice of Project where the construction project requires one. Then the enclosure is built, the work is performed and the area is cleared. Only then does the strip-out and the construction behind it proceed.
What happens if Type 3 asbestos is found after commercial work has started?
The affected work stops. The area is secured, the material is examined and the operation is classified. If it lands in Type 3, the notice goes in before work resumes. The cost this article describes is standing time and re-mobilisation, not a unit price for the abatement. The usual sequencing mistake is tendering demolition or renovation first and treating abatement as something to sort out later, so a job that was three weeks from handover stops while a notice goes in and an enclosure gets built.
Can the notice, the enclosure and the strip-out sit on one commercial contract?
Yes. Sofisa handles commercial asbestos abatement and the commercial demolition that follows, so the classification, the notice, the enclosure and the strip-out sit with the same project manager rather than two contractors on different schedules. If the building predates 1990, start from the survey rather than from the demolition tender. This page is a contractor's scheduling note, not legal advice. Call (647) 963-4310.
Planning a commercial project in the GTA?
Sofisa delivers demolition, abatement, fit-outs and renovations under one contract with senior site supervision. We'll walk the site and come back with a fixed-scope number.