Project Management
How conflicts of interest affect asbestos project managers. Incompatibilities, regulations, documented fraud cases, and how to protect yourself.
What a Project Manager Does
An asbestos project manager plans, coordinates, and supervises the entire asbestos management project from start to finish. They draft removal specifications, run the contractor selection process, supervise on-site execution, verify regulatory compliance, coordinate between the building owner, removal contractor, air monitoring firm, and laboratory, and ensure all documentation is complete. The project manager is the building owner's representative on-site -- the person who ensures the removal contractor does the work correctly.
The Main Conflict of Interest
When the project manager has a financial connection to the removal contractor, the supervision function is neutralized. The entity that should catch problems becomes the entity that hides them.
- Favouring a specific removal contractor during the selection process, steering the contract to a partner company
- Being less rigorous in supervising a commercial partner than they would be with an unrelated contractor
- Accepting deviations from the removal plan (e.g., inadequate containment, skipped decontamination steps) that they would not tolerate from an independent contractor
- Approving variation orders and cost increases that benefit the partner contractor but are not justified by site conditions
- Failing to report safety violations or regulatory non-compliance to protect the commercial relationship
The Rule
The project manager supervises. They do not physically execute removal work, they do not hold a financial interest in the removal company, and they do not receive payments or incentives from the contractor they are supposed to supervise. The project manager's loyalty must be entirely to the building owner.
Incompatibilities with Other Roles
The following table shows which roles are incompatible with the Project Management role on the same project.
| Role | Compatibility |
|---|---|
| Survey | Compatible |
| Laboratory | Compatible |
| Removal | Incompatible |
| Air Monitoring | Compatible |
| Consulting | Compatible |
| Waste Mgmt | Compatible |
| Training | Compatible |
Regulation by Country
How different jurisdictions regulate project management independence.
| Country | Regulation | Requirement for this role |
|---|---|---|
| France | Code du Travail, Maîtrise d'œuvre regulations | The maître d'œuvre (project manager) must be independent of the removal company. Cannot hold financial interest in the executing firms. |
| United Kingdom | CDM Regulations 2015, HSG247 | The project manager / principal designer has duties to ensure competence and independence of the removal contractor's supervision. |
| United States | EPA project monitor requirements, state regulations | Several states require independent project monitors for large asbestos abatement projects. The monitor must not be employed by the abatement contractor. |
Documented Cases of Fraud
Cases where the failure of independent project oversight led to fraud.
Landell Environmental
United States · 2000s
Landell served as the project monitor -- the third-party control entity responsible for overseeing the removal contractor's work. Instead of providing independent oversight, Landell colluded with the removal company. The monitor allowed irregular removal practices, did not perform required air monitoring, falsified monitoring records, and did not conduct proper final air clearances. The entire third-party monitoring system failed because the monitor was not independent.
Prosecution by the Department of Justice, Environment and Natural Resources Division (ENRD). The case demonstrates the catastrophic failure that occurs when the project monitor colludes with the removal contractor.
Red Flags for Building Owners
- The project manager recommends a single removal contractor without running a competitive process
- The project manager and the removal contractor have worked together on every recent project -- suggesting a standing commercial arrangement
- The project manager is reluctant to document deviations from the removal plan or issue non-compliance notices
- The project manager approves all variation orders submitted by the contractor without questioning scope or cost
- The project manager discourages the building owner from visiting the site during works or attending progress meetings
- The project management firm is a subsidiary, sister company, or frequent subcontractor of the removal company
How to Protect Yourself
- Ask the project manager directly: "Do you have any commercial relationship with the removal contractors you will be supervising?" Require a written declaration.
- Contract the project manager independently. They must report to you, not to the removal contractor.
- Attend site visits and progress meetings. Your presence increases accountability.
- Request copies of all site diaries, non-compliance notices, and variation orders. An independent project manager will document problems, not hide them.
- If the project manager consistently avoids issuing non-compliance notices to a contractor, consider replacing them.
- For large projects, consider engaging an independent clerk of works in addition to the project manager for additional oversight.