What Law 7/2022 requires
The fourteenth additional provision requires municipalities to prepare an inventory of installations and sites containing asbestos, together with a removal timetable. Both are public and submitted to the competent regional health, environmental and labour authorities. The law allowed one year from entry into force to prepare them; that original deadline does not restart when a municipality begins its inventory. The inventory should support planning rather than remain an unmonitored list of locations.
Identification with different levels of certainty
The Ministry of Health’s June 2024 guidance provides a non-binding method for exploration, inspection and assessment. Documentary information, suspected material and confirmed presence should be distinguished, with limitations recorded where areas could not be examined. Roof age or aerial imagery can guide investigation but should not be represented as a complete analysis of hidden or inaccessible materials. Recording uncertainty is more useful than presenting incomplete coverage as a definitive absence of asbestos.
Make priorities explicit
The law requires attention to hazardousness and exposure of vulnerable populations. Higher-risk public installations or sites must be managed before 2028; that provision does not assign the same date to every material on every property. Prioritisation considers condition, potential fibre release, accessibility and use of the location. A useful timetable identifies actions and criteria that can be reviewed when new findings or changes in use alter the assessment.
Example of a municipal facility
A sports building has a suspected asbestos roof and several uninspected areas. The inventory records location, available evidence and inspection limitations. Priority decisions require assessment of condition and potential disturbance rather than assuming that absence of planned work means absence of risk. If refurbishment is scheduled, task-specific identification must precede intervention and cover materials that may be affected, including those outside the initial visual survey.
From inventory to execution
The inventory is neither company registration in RERA nor an approved work plan. Since October 2026, affected work must consider Royal Decree 847/2026 and its transitions. Removal and waste management require the relevant occupational and environmental framework. Older occupational references in 2024 guidance must be read in light of that update. Public information should also be prepared in accordance with applicable data-protection requirements rather than disclosing unnecessary personal information with the location records.
