Asbestos · Mandatory · Pre-Construction

Asbestos Refurbishment and Demolition Survey

The Refurbishment and Demolition Survey is required before any intrusive or destructive work in a building. It is more invasive than a management survey, accessing areas behind walls, above ceilings, and within floor voids. The survey must locate all ACMs in the area of work so they can be removed before construction begins.

Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. CAR 2012 Reg 7 remains current with no amendments enacted as of 29 March 2026. Next scheduled review: 29 March 2027.

Legal basis	Control of Asbestos Regulations 2012 (CAR 2012), Regulation 7 — prohibition on work on asbestos and Regulation 5 — identification of the presence of asbestos. 76% of HSE enforcement notices under CAR 2012 relate to failures in asbestos identification before work begins.
Survey type	Type 2 refurbishment and demolition (R&D) survey (formerly Type 3 under MDHS 100). Fully intrusive, involving destructive inspection to access all areas that will be affected by the proposed refurbishment or demolition work.
Who commissions	The client under CDM 2015 has the duty to commission the R&D survey as part of providing pre-construction information. The survey must be commissioned before design work is finalised and before any contractor begins intrusive work on site.
Scope	The scope of the R&D survey must match the full extent of the proposed works. Every area, element, void, and service route that will be disturbed by the refurbishment or demolition must be surveyed. A partial survey covering only some areas is not compliant.
Pre-construction information	CDM 2015 Regulation 4 requires the client to provide pre-construction information to every designer and contractor. The R&D survey report is mandatory pre-construction information for any project involving refurbishment or demolition of a building that may contain asbestos.

1. Why the R&D Survey Is Different and Mandatory

The Refurbishment and Demolition (R&D) survey is fundamentally different from a management survey. A management survey is non-intrusive — it identifies ACMs that are accessible during normal building use, for the purpose of ongoing management. An R&D survey is fully intrusive. It involves destructive inspection of the building fabric to locate all ACMs within the areas that will be disturbed by the proposed refurbishment or demolition work. This includes breaking through walls, lifting floors, opening up ceiling voids, accessing risers, and inspecting behind fixed plant and equipment.

The R&D survey is mandatory under Regulation 7 of the Control of Asbestos Regulations 2012 (CAR 2012). No refurbishment or demolition work may begin on any building that may contain asbestos until an R&D survey has been completed and all identified ACMs have been removed or made safe. The obligation is absolute — there is no exemption based on the age of the building, the size of the project, or the type of work. If the building was constructed or refurbished before the year 2000, it may contain asbestos, and an R&D survey is required.

The R&D survey exists because asbestos-containing materials are frequently concealed within the building fabric in locations that a management survey cannot access. Asbestos insulation board behind wall linings, asbestos rope seals within pipe joints, sprayed asbestos coatings within structural cavities, asbestos cement sheets behind cladding, and asbestos debris in floor voids are all commonly found during R&D surveys but would not be identified by a management survey. Refurbishment or demolition work that disturbs these concealed ACMs without prior identification causes uncontrolled fibre release — exposing workers and building occupants to potentially lethal asbestos fibres.

The consequences of starting refurbishment or demolition without an R&D survey are severe. Uncontrolled fibre release typically results in immediate site shutdown, evacuation, decontamination of the affected area (which may extend to the entire building), environmental clean-up, personal decontamination of exposed workers, medical surveillance, regulatory investigation, and potential prosecution. The financial cost of remediation after an uncontrolled release routinely exceeds the cost of the original refurbishment project.

76% of enforcement notices relate to identification failures

HSE data shows that 54 out of 71 enforcement notices issued under CAR 2012 were for breaches of Regulation 5 — the duty to identify asbestos before work begins. The most common scenario is refurbishment or demolition work that started without an R&D survey, or with an R&D survey that did not cover the full scope of the works. This is the single most common and most serious asbestos compliance failure in UK construction, and it is the area where HSE enforcement is most active.

2. Scope, Timing, and the CDM Link

The R&D survey must be scoped to match the full extent of the proposed works. Every area, element, void, cavity, service route, and building component that will be disturbed, removed, or demolished must be included within the survey scope. The timing of the survey is critical — it must be completed before the main construction works begin, and ideally before design work is finalised so that the design can take account of the ACMs identified. The following table sets out the key requirements for scope, timing, and the link to CDM 2015.

Requirement	Detail
When commissioned	The R&D survey must be commissioned early enough to allow results to inform design decisions and construction planning. The survey should be completed before principal contractor appointment where possible, and must be completed before any intrusive work begins on site. Late commissioning is a common cause of project delays.
Full scope	The survey scope must cover every area that will be disturbed by the proposed works. This includes not only the primary work area but also adjacent areas where services will be rerouted, access routes where temporary works may disturb building fabric, and areas where enabling works (such as soft strip or removal of fixtures) will take place. If the scope of works changes after the survey, the survey must be updated to cover the additional areas.
Vacant areas	The R&D survey is intrusive and disruptive. It involves breaking through building elements to access concealed areas. For this reason, the building or the areas to be surveyed should ideally be vacated before the survey takes place. Where the building remains occupied, the surveyor must be able to access all areas within the works scope without restriction. Any area that cannot be accessed must be recorded as a limitation, and asbestos must be presumed present in that area until a further survey is carried out.
CDM obligation	Under CDM 2015 Regulation 4, the client has a duty to provide pre-construction information to every designer and contractor appointed to the project. The R&D survey report is mandatory pre-construction information for any project that involves refurbishment or demolition of a building that may contain asbestos. The client must ensure the survey is commissioned, completed, and provided to the project team before work begins. This duty is non-delegable.
Results action	Where the R&D survey identifies ACMs, those ACMs must be removed by a competent contractor (licensed if the ACM type requires it) before the main refurbishment or demolition work begins. A four-stage clearance certificate must be obtained for each area from which licensed asbestos has been removed, confirming the area is safe for reoccupation and for follow-on work to proceed. Only after clearance is confirmed can the main construction works commence in that area.
Updated surveys	If the scope of the refurbishment or demolition project changes after the R&D survey has been completed, the survey must be updated to cover the additional areas. A survey that was scoped for a partial refurbishment does not cover a full demolition. Similarly, if unexpected ACMs are discovered during the works (despite the survey), work must stop immediately and the survey must be revisited. The R&D survey is not a one-time event — it must remain current and complete for the full scope of the works at all times.

3. Common Mistakes

Starting refurbishment or demolition before the R&D survey is complete

This is the most serious and most common asbestos compliance failure in UK construction. The R&D survey must be completed and all identified ACMs removed before any intrusive work begins. Starting work before the survey is complete — even enabling works, soft strip, or preliminary demolition — risks disturbing concealed ACMs and causing uncontrolled fibre release. HSE treats this as a critical breach and enforcement action (including prosecution) is the normal response. Project pressure and programme constraints are never an acceptable reason for starting work without a completed R&D survey.

Scoping the survey too narrowly

The R&D survey must cover every area that will be disturbed by the proposed works. A common mistake is to scope the survey to cover only the primary work area while omitting adjacent areas, service routes, access corridors, or areas where enabling works will take place. If any area that will be disturbed is not covered by the survey, ACMs in that area will not be identified. When workers subsequently disturb those areas, uncontrolled fibre release occurs. The survey scope must be defined in consultation with the designer and principal contractor to ensure it captures the full extent of disturbance.

Assuming a partial or previous survey covers the whole building

An R&D survey carried out for a previous project covers only the areas that were within scope for that project. It cannot be relied upon for a different project with a different scope of works. Similarly, a management survey — regardless of how recent or comprehensive — is not a substitute for an R&D survey because it does not access concealed areas. Each refurbishment or demolition project must have its own R&D survey scoped specifically for the works proposed. Relying on a previous survey for a different project is a breach of CAR 2012.

Not providing the R&D survey report to all contractors

The R&D survey report is pre-construction information under CDM 2015. The client must provide it to every designer and contractor working on the project — not only the principal contractor but also every sub-contractor, specialist, and trade contractor whose work may involve disturbing building fabric. Failing to provide the report means contractors cannot assess asbestos risks, cannot plan their work safely, and may inadvertently disturb ACMs that remain in the building (for example, in areas outside the removal scope or where ACMs were identified as manageable in situ).

Using a surveyor not qualified or accredited for R&D survey work

An R&D survey requires a higher level of competence than a management survey because it involves intrusive, destructive inspection and the identification of concealed ACMs. The surveyor must hold the BOHS P402 qualification (or equivalent) and must be employed by a UKAS-accredited organisation. The surveyor must also have specific experience of R&D survey work, including knowledge of where ACMs are typically concealed in different building types and construction eras. Using an unqualified or inexperienced surveyor increases the risk that concealed ACMs will be missed, which directly leads to uncontrolled exposure during the works.

4. Related Documents

Document	Relationship
D1 — Asbestos Management Survey	The management survey identifies accessible ACMs for ongoing management. It provides baseline information but is not sufficient for refurbishment or demolition. The R&D survey builds on the management survey findings by accessing concealed areas that the management survey could not reach. Both surveys may be needed — the management survey for occupied areas and the R&D survey for areas to be disturbed by the works.
D3 — Asbestos Register	The asbestos register must be updated with the findings of the R&D survey. Any additional ACMs identified by the R&D survey must be added to the register, and the register must record the actions taken (removal, encapsulation, or management in situ). After removal, the register must be updated to record the clearance certificate reference and the date of removal.
D4 — Asbestos Management Plan	Where the R&D survey identifies ACMs that will be managed in situ (for example, in areas outside the works scope), the management plan must be updated to include these ACMs. The plan must also describe how asbestos risks will be managed during the construction phase, including contractor information procedures and emergency arrangements.
D6 — Asbestos Removal Plan	Where the R&D survey identifies ACMs that require removal before the main works can proceed, the removal plan is produced by the licensed removal contractor. The removal plan must be directly based on the R&D survey findings and must address every ACM identified for removal, including the method, sequence, containment, air monitoring, and clearance procedures.
C10 — COSHH Assessment: Asbestos	The COSHH assessment for asbestos exposure during the construction works must be based on the R&D survey findings. The assessment identifies the specific ACMs that workers may encounter, the exposure risks, and the control measures required. Without the R&D survey data, the COSHH assessment cannot be completed accurately.
B15 — RAMS: Demolition	The demolition RAMS must confirm that the R&D survey has been completed, that all ACMs within the demolition scope have been removed, and that four-stage clearance certificates have been obtained for all licensed removal areas. The RAMS must cross-reference the R&D survey report and the clearance certificates by reference number and date.

5. Frequently Asked Questions

What is the difference between a management survey and an R&D survey?▾

A management survey is non-intrusive. It identifies ACMs that are accessible during normal building occupancy for the purpose of ongoing management — monitoring, labelling, and avoiding disturbance. An R&D survey is fully intrusive. It involves destructive inspection — breaking through walls, lifting floors, opening voids — to identify all ACMs within the areas that will be disturbed by proposed refurbishment or demolition work. The management survey tells you what asbestos is accessible in the building. The R&D survey tells you what asbestos is present — including concealed materials — in the specific areas where intrusive work will take place. A management survey is never sufficient for refurbishment or demolition.

Who can commission an R&D survey?▾

Under CDM 2015, the client has the duty to provide pre-construction information, which includes the R&D survey report. The client should commission the R&D survey directly, although in practice this is often arranged through the principal designer or project manager acting on the client's behalf. Regardless of who arranges the survey, the client retains the legal duty to ensure it is carried out, that it covers the full scope of the works, and that the results are provided to all designers and contractors. The survey must be carried out by a UKAS-accredited surveying organisation with P402-qualified surveyors.

Does the R&D survey need to cover the whole building or just the works area?▾

The R&D survey must cover every area that will be disturbed by the proposed works. This includes the primary work area, adjacent areas where services will be rerouted, access routes where building fabric may be disturbed, areas where enabling works will take place, and any area where the proposed works could cause vibration, dust, or other disturbance to concealed ACMs. For full demolition, the entire building must be surveyed. For partial refurbishment, the survey must cover all affected areas. If the scope of works changes after the survey, the survey must be updated to cover the additional areas before work proceeds in those areas.

What happens if asbestos is found during works despite an R&D survey?▾

If suspect ACMs are discovered during construction work despite a completed R&D survey, all work in the affected area must stop immediately. The area must be sealed off and access restricted. The asbestos surveyor must be recalled to inspect the material, take samples if necessary, and update the survey report. If asbestos is confirmed, it must be removed by a competent contractor (licensed if the ACM type requires it) before work in that area can resume. A clearance certificate must be obtained. The discovery should also trigger a review of whether the original survey scope was adequate and whether other areas may also contain unidentified ACMs. The incident must be reported to the principal contractor and the client.

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