Health & Safety

Asbestos surveys: which one you need before work starts

4 min read

The short answer

There are two survey types under HSG264. A management survey locates asbestos that might be disturbed during normal occupation and is for managing a building in use. A refurbishment and demolition survey is fully intrusive, covers the areas the work will reach, and is required before any refurbishment, demolition or work that will disturb the fabric. Regulation 5 of the Control of Asbestos Regulations 2012 requires a suitable and sufficient assessment of whether asbestos is present before work starts. Any building constructed or refurbished before the 1999 ban is a candidate, and 2000 is a rule of thumb rather than a safe cut-off.

At a glance

Regulation
Control of Asbestos Regulations 2012, reg 5
Guidance
HSG264
Management survey
For a building in normal use
R&D survey
Before refurbishment or demolition; intrusive
Who arranges it
The client, before work starts
UK ban
All asbestos banned from 1999
Licensed work
Sprayed coatings, lagging, most AIB
Notifiable non-licensed
Notified, recorded, medicals required

Which survey does the work need?

Management surveyRefurbishment & demolition
PurposeManage asbestos during occupationLocate everything before work disturbs it
Intrusive?MinimallyYes, fully
Covers voids and fabric?NoYes
Area normally vacated?NoYes
Sufficient before refurbishment?NoYes

A management survey in the building file is not authority to start stripping out. It was never designed to find what is inside a wall.

The R&D survey is destructive by design. Floors come up, ceilings come down, ducts and risers are opened. That is why the area is normally vacated, and why arranging it late is the reason so many projects stop in week one.

Whose job is it to arrange?

The client’s. Regulation 5 places the duty on whoever is carrying out or commissioning the work to ensure a suitable and sufficient assessment is made before it starts, and under CDM 2015 the client must provide pre-construction information, which includes the asbestos survey.

On a domestic project the client duties transfer to the contractor or principal contractor, so a builder taking on a 1960s house cannot rely on the homeowner having thought about it. See when CDM applies.

NoteA contractor who starts without the survey is unlikely to escape liability by pointing at the client. The duty to assess before disturbing the fabric sits with whoever is doing the disturbing.

What if asbestos is found?

The work splits into three categories, and the category decides who may do it.

  1. 01Licensed work. Sprayed coatings, lagging, and most work with asbestos insulating board. Only an HSE-licensed contractor may do it, with 14 days’ notice to the enforcing authority.
  2. 02Notifiable non-licensed work (NNLW). Lower risk but still notified to the enforcing authority, with health records kept and medical surveillance required.
  3. 03Non-licensed work. Asbestos cement, textured coatings, bitumen products. No licence and no notification, but training, controls and safe disposal still apply.

Every category requires training appropriate to the work. Even the lowest tier is not something to hand to whoever is nearest.

What does the 2000 date actually mean?

The UK banned blue and brown asbestos in 1985 and white asbestos in 1999. Buildings finished after 2000 are unlikely to contain asbestos in their original fabric, and that is the origin of the rule of thumb.

It is not a safe cut-off, for two reasons. Stock already held could legally be used up after the ban date, and any refurbishment carried out before 1999 may have introduced materials into a building that is itself newer than the work being disturbed.

The question is not how old the building is. It is when the part you are about to disturb was last worked on.

What should the survey report give you?

  • A register of materials found, with location, type, condition and extent.
  • Photographs and floor plans marking each identified item.
  • Sample analysis results from an accredited laboratory.
  • Areas not accessed, listed explicitly, with the reason.
  • A material assessment score for each item.
  • Recommendations for removal, encapsulation or management.

The list of areas not accessed is the part to read first. It defines the limits of what the survey proves, and work in an unsurveyed void is work with no assessment behind it.

Questions

Frequently asked

Do I need an asbestos survey for a domestic property?

The duty to manage under regulation 4 does not apply to domestic dwellings, but the duty to assess before disturbing materials does. A contractor refurbishing a pre-2000 house needs to know what is there before starting.

Is a management survey enough before refurbishment?

No. A management survey is for a building in normal use and does not open up the fabric. Refurbishment or demolition needs a refurbishment and demolition survey covering the areas the work will reach.

How long is an asbestos survey valid?

There is no expiry, but the register should be reviewed at least annually and after any work that could have disturbed or introduced materials. A survey that predates a refurbishment no longer describes the building.

What happens if asbestos is found unexpectedly?

Stop work immediately, prevent access, and do not disturb it further. Have it sampled by a competent analyst, then decide on the category of work required. Carrying on and hoping is how a small exposure becomes a reportable one.

Who can carry out an asbestos survey?

A competent surveyor, in practice one accredited to ISO 17020 or employed by an accredited organisation. Sample analysis must be done by a laboratory accredited to ISO 17025.

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