Asbestos · Mandatory · Pre-Construction

Asbestos Removal Plan

The Asbestos Removal Plan details the methodology for safely removing asbestos-containing materials, including enclosure design, negative pressure units, decontamination facilities, waste routes, and air monitoring arrangements. Licensed removal work requires a 14-day notification to HSE. The plan must be prepared by a licensed asbestos removal contractor and agreed before work starts.

Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. CAR 2012 / Licensed Work 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 requires a written plan of work to be prepared before any work with asbestos-containing materials (ACMs) begins. The plan must set out the methods, controls, and procedures to be followed throughout the removal.
Licensed work	Work on asbestos insulation, asbestos insulation board (AIB), and asbestos coatings requires an Asbestos Contractor Licence (ACL) issued by the HSE. The licensed asbestos removal contractor (LARC) must hold a current licence, which is publicly verifiable on the HSE website. Using an unlicensed contractor for licensed work is a criminal offence.
NNLW	Notifiable non-licensed work (NNLW) requires online notification to HSE before work starts. No licence is required, but operatives must hold appropriate training, medical examinations must be carried out every 3 years, and a written record of work must be kept for 40 years.
Plan contents	The plan of work must include: description of the work and site, identification and type of ACM, removal method, enclosure design, decontamination unit layout, RPE specification, PPE requirements, waste management procedures, emergency arrangements, air monitoring strategy, and named supervisor.
Enclosure	For licensed removal, a full enclosure is typically required. The enclosure must maintain a negative pressure differential of at least 5 Pascals (measured by a negative pressure unit, NPU). Smoke testing must be carried out before work begins to verify the enclosure is airtight. A 3-stage decontamination unit (DCU) must be attached to the enclosure, comprising a dirty end, shower, and clean end.

1. The Plan of Work Legal Requirement for All Asbestos Removal

CAR 2012 Regulation 7 requires that no work with asbestos-containing materials shall be carried out unless a written plan of work has been prepared. This applies to all categories of asbestos work — licensed, notifiable non-licensed (NNLW), and non-licensed. The plan must detail the nature and probable duration of the work, the location, the methods to be used, the measures to prevent or reduce exposure, and the equipment to be used for protection and decontamination. The plan must be prepared before any work begins and must be kept available on site throughout the work.

For licensed asbestos removal, the plan of work is prepared by the licensed asbestos removal contractor (LARC). It must be site-specific — developed for the particular building, the specific ACMs to be removed, and the actual conditions on site. The plan must be based on the findings of a Refurbishment and Demolition (R&D) survey or, where appropriate, a management survey. The LARC must carry out a site visit before preparing the plan to verify the survey findings and assess practical considerations such as access, enclosure design, decontamination unit positioning, waste route, and proximity to occupied areas.

For licensed work, the LARC must submit a notification to the HSE on Form ASB5 at least 14 days before work is due to start. The notification must include a copy of the plan of work. The 14-day notification period allows the HSE to review the plan, request amendments, or arrange an inspection. Work must not commence until the 14-day period has elapsed. For NNLW, notification is made online and there is no 14-day waiting period, but the plan of work must still be in place before work starts.

Using an unlicensed contractor for licensed work is a criminal offence

The Asbestos Contractor Licence (ACL) is the legal prerequisite for carrying out work on asbestos insulation, AIB, and asbestos coatings — or any asbestos work where exposure cannot be reliably controlled below the control limit. Both the contractor who carries out the work without a licence and the client who appoints them commit a criminal offence under CAR 2012. The licence status of any LARC can be verified on the HSE's public register. The Principal Contractor and client must verify the licence before appointing a LARC, retain a copy of the licence on file, and confirm that the licence covers the type of work to be carried out. A licence that has expired, been revoked, or is subject to conditions that preclude the proposed work is equivalent to no licence at all.

2. Key Elements of the Plan of Work

The plan of work must be comprehensive and site-specific. It is not acceptable to use a generic template without adapting it to the actual conditions on site. The following table sets out the key elements that a compliant plan of work must include for licensed asbestos removal. The same elements apply in principle to NNLW and non-licensed work, although the level of detail may be proportionate to the risk.

Element	Detail Required
Site details	Full address, building name, floor and room references, site plan showing the location of ACMs to be removed relative to the building layout, access points, occupied areas, and exclusion zones. Contact details for the site manager, Principal Contractor, and client representative.
ACM description	Identification of each ACM to be removed, including the type of asbestos (chrysotile, amosite, crocidolite), the product type (insulation, coating, board, cement), the location within the building, the quantity (area or linear metres), and the condition (intact, damaged, friable). This must be based on the R&D survey and verified by the LARC during their site visit.
Removal method	The specific method to be used for each ACM — for example, controlled wet stripping, wrap-and-cut for pipe lagging, intact panel removal for AIB, or glove bag technique for small-scale pipe insulation. The plan must explain why the chosen method is appropriate for the ACM type and condition, and how fibre release will be minimised.
Enclosure design	For licensed removal, details of the enclosure including dimensions, materials (polythene sheeting specification), airlocks, viewing panels, negative pressure unit (NPU) capacity and location, shadow monitoring positions, and smoke test methodology. The enclosure must maintain a negative pressure differential of at least 5 Pascals throughout the work.
Decontamination	The 3-stage decontamination unit (DCU) layout and specification: dirty end (for removal of disposable overalls), shower stage (with adequate water supply and drainage), and clean end (for putting on clean clothing). The DCU must be attached to the enclosure and provide the only personnel access route. Transit route for waste bags from the enclosure to the waste skip must also be defined.
RPE specification	The type of respiratory protective equipment (RPE) to be used by each category of worker, with assigned protection factors (APF) appropriate to the expected fibre concentrations. For licensed removal within a full enclosure, powered air-purifying respirators (PAPR) with P3 filters (APF 40) or full-face negative-pressure respirators with P3 filters (APF 40) are the minimum standard. RPE must be face-fit tested for each operative.
PPE	Specification of personal protective equipment including disposable Type 5/6 coveralls, boot covers or dedicated work boots, gloves, and eye protection where required. PPE must be treated as contaminated waste after each session and disposed of through the DCU dirty end.
Air monitoring	The air monitoring strategy including the type of monitoring (personal, static background, perimeter), the sampling locations, the frequency, and the identity of the UKAS-accredited analyst. For licensed removal, air monitoring is mandatory throughout the work and during the 4-stage clearance process. The analyst must be independent of the LARC.
Waste management	Procedures for double-bagging asbestos waste in red-striped asbestos waste bags, sealing and labelling, transit from the enclosure to the designated waste storage area, and collection by a carrier registered with the Environment Agency for hazardous waste. Consignment notes must be completed for each waste collection. The waste must be disposed of at a licensed hazardous waste facility.
Emergency procedures	Procedures for unplanned fibre release, enclosure failure (NPU breakdown, sheeting breach), discovery of additional ACMs not identified in the survey, operative illness or injury within the enclosure, and fire. Emergency contact numbers for the LARC supervisor, site manager, emergency services, and the HSE must be included.
Supervisor details	The name, qualifications, and experience of the LARC supervisor who will be present on site throughout the removal work. The supervisor must hold a valid Certificate of Competence in Asbestos (CCA) or equivalent, and must have direct operational responsibility for the removal. The plan must also name the contracts manager responsible for the overall project.

3. Common Mistakes

Using a generic template without site-specific content

The plan of work must be site-specific. A generic template that has not been adapted to the actual ACMs, building layout, enclosure requirements, and site conditions is non-compliant. The HSE will examine whether the plan addresses the specific risks on this site, not whether a plan exists in general terms. Common indicators of a generic plan include references to ACM types not present on site, generic enclosure dimensions that do not match the actual work area, and a lack of site-specific floor plans or photographs. The LARC must conduct a site visit before preparing the plan, and the plan must demonstrate that it has been informed by the survey findings and the site visit observations.

Not checking the contractor licence before work begins

The Principal Contractor and client have a duty to verify that the LARC holds a current, valid Asbestos Contractor Licence before appointing them. The licence must be checked on the HSE's public register, not simply accepted as a photocopy from the contractor. Licences can expire, be revoked, or be subject to conditions that restrict the type of work the contractor can carry out. Appointing an unlicensed contractor for licensed work makes both the contractor and the appointing party liable for a criminal offence under CAR 2012. The licence verification should be documented and retained on the project file.

Failing to submit ASB5 notification 14 days before licensed work starts

For licensed asbestos removal, the LARC must submit Form ASB5 to the HSE at least 14 days before work is due to start. The 14-day notification period is a legal requirement that allows the HSE to review the plan of work and, if necessary, arrange an inspection or request amendments. Starting licensed removal before the 14-day period has elapsed is a breach of CAR 2012. The Principal Contractor should verify that the ASB5 has been submitted and confirm the date after which work may legally commence. The ASB5 submission date should be recorded on the project programme.

Not keeping the plan of work on site during the removal

The plan of work must be available on site throughout the removal. It is not sufficient for the plan to exist only in the LARC's head office or on a shared drive. The site copy must be the current version, including any amendments made after the initial submission. The HSE inspector will expect to see the plan on site during any visit and will compare the actual working methods, enclosure, equipment, and PPE against the plan. Discrepancies between the plan and the actual work in progress will result in enforcement action.

Not updating the plan when conditions change

The plan of work is a living document. If conditions change during the removal — for example, additional ACMs are discovered, the extent of contamination is greater than expected, the enclosure design needs to be modified, or the removal method needs to be changed — the plan must be updated before work continues. Continuing to work under an outdated plan that no longer reflects the actual conditions is a breach of CAR 2012 Regulation 7. The amendment must be documented, and the HSE notification updated where the change is material to the scope of work.

4. Related Documents

Document	Relationship
D1 — Asbestos Management Survey	The management survey identifies the presence, location, and condition of ACMs for ongoing management. It informs the plan of work where removal is required for management purposes but is not sufficient for refurbishment or demolition — an R&D survey is required in those cases.
D2 — Asbestos Refurbishment and Demolition Survey	The R&D survey is the intrusive survey that identifies all ACMs that will be disturbed by the proposed works. The plan of work must be based on the R&D survey findings. If the plan refers to ACMs not identified in the survey, or the survey identifies ACMs not addressed in the plan, both documents must be reconciled before work begins.
D3 — Asbestos Register	The register must be updated following removal to reflect the changed status of each ACM — recording the date of removal, the LARC who carried out the work, and the clearance certificate reference. Failure to update the register after removal creates a risk that future occupants or contractors will not have accurate information about remaining ACMs.
D4 — Asbestos Management Plan	The management plan provides the overall framework for managing ACMs in the building. The removal plan is an action arising from the management plan where the management action for a specific ACM is "remove" rather than "monitor" or "encapsulate".
C10 — COSHH Assessment: Asbestos	The COSHH assessment for asbestos sets out the health risks, control measures, exposure limits, RPE requirements, and monitoring arrangements. The plan of work must be consistent with the COSHH assessment, and the RPE specification in the plan must meet the protection factors required by the assessment.
B15 — RAMS: Demolition	The demolition method statement must confirm that all ACMs have been removed before mechanical demolition begins. The plan of work governs the removal phase, and the demolition RAMS governs the demolition phase. The two documents must be sequenced so that removal is completed and cleared before demolition starts.

5. Frequently Asked Questions

What is the difference between licensed, NNLW, and non-licensed asbestos work?▾

Licensed work covers asbestos insulation, asbestos insulation board (AIB), and asbestos coatings, or any work where exposure cannot be reliably controlled below the control limit (0.1 fibres per cm3 over a 4-hour TWA). It requires an HSE-issued Asbestos Contractor Licence, 14-day ASB5 notification, full medical surveillance, a designated UKAS-accredited analyst, and 40-year health records. NNLW covers short-duration work on certain ACMs where exposure can be controlled below the control limit — typically maintenance or minor repair work. It requires online notification to HSE (no 14-day wait), medical examinations every 3 years, and 40-year work records. Non-licensed work covers lower-risk ACMs (asbestos cement, floor tiles, textured coatings) in reasonable condition with low fibre release. No notification or medical surveillance is required, but a written plan of work, adequate training, and appropriate RPE are still mandatory.

Who is responsible for submitting the ASB5 notification to the HSE?▾

The licensed asbestos removal contractor (LARC) is responsible for submitting the ASB5 notification to the HSE. However, the Principal Contractor and client should verify that the notification has been submitted and should record the submission date and the earliest date on which work may legally commence. The ASB5 must be submitted at least 14 days before the planned start date. If the scope of work changes materially after the ASB5 has been submitted, a revised notification may be required. The LARC should provide the PC with a copy of the submitted ASB5 and the HSE acknowledgement.

How should asbestos removal be programmed within the overall construction programme?▾

Asbestos removal must be completed before any other construction work begins in the affected area. This means the removal must be programmed as an early activity, with adequate time for: the R&D survey, LARC appointment and plan of work preparation, 14-day ASB5 notification period, the removal itself, the 4-stage clearance process, and the issue of the Certificate for Reoccupation (CfR). Only after the CfR has been issued can other construction trades access the area. The programme must account for the possibility that additional ACMs may be discovered during removal, requiring amendment to the plan and potentially extending the removal period. On refurbishment projects, asbestos removal is commonly on the critical path and any delay will affect the overall programme.

What RPE is required for licensed asbestos removal?▾

For licensed asbestos removal within a full enclosure, the minimum RPE standard is a powered air-purifying respirator (PAPR) with P3 particulate filters, providing an assigned protection factor (APF) of 40, or a full-face negative-pressure respirator with P3 filters (also APF 40). For higher-risk work — such as removal of sprayed coatings or heavily degraded lagging where very high fibre concentrations are expected — airline-fed breathing apparatus may be required, providing an APF of up to 2,000. All RPE must be CE-marked, face-fit tested for each individual operative (using either qualitative or quantitative methods), and maintained and inspected in accordance with the manufacturer's instructions. The RPE specification must be recorded in the plan of work and must be consistent with the expected fibre concentrations as assessed in the COSHH assessment.

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