COSHH · Mandatory · Pre-Construction

COSHH Assessment — Asbestos

This COSHH assessment specifically addresses asbestos fibre exposure during construction and refurbishment work. Asbestos is the single greatest cause of work-related deaths in the UK. It covers the three main asbestos types (chrysotile, amosite, crocidolite), control limits, decontamination procedures, and the legal requirement for licensed removal of certain asbestos-containing materials.

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

Primary legislation	Control of Asbestos Regulations 2012 (CAR 2012) — covers management of asbestos in non-domestic premises, licensed work, notifiable non-licensed work (NNLW), and non-licensed work
Survey types	Management survey (presence, location, condition of ACMs for ongoing management) and Refurbishment & Demolition (R&D) survey (intrusive, required before any refurbishment or demolition work)
Licensed work	Work on asbestos insulation, asbestos insulation board (AIB), and asbestos coatings requires an Asbestos Contractor Licence (ACL) from HSE
Control limit	0.1 fibres per cm3 over a 4-hour TWA (time-weighted average). Short-term exposure limit (STEL): 0.6 fibres per cm3 over 10 minutes.
UK deaths	Approximately 5,000 deaths per year from asbestos-related disease. 2,218 mesothelioma deaths registered in 2023. Asbestos is the single greatest cause of work-related death in the UK.

1. Why Asbestos Remains a Critical Hazard in UK Construction

Asbestos was used extensively in UK construction from the 1950s through to the mid-1980s, and was not fully banned until 1999. It was incorporated into thousands of building products — insulation boards, ceiling tiles, textured coatings (Artex), floor tiles, cement sheets, pipe lagging, gaskets, fire blankets, and sprayed coatings. Any building constructed or refurbished before the year 2000 may contain asbestos-containing materials (ACMs). Buildings constructed between 1960 and 1985 are the highest risk.

Asbestos fibres, when inhaled, cause fatal diseases including mesothelioma (an incurable cancer of the lining of the lungs or abdomen), asbestosis (progressive scarring of the lung tissue), and lung cancer. These diseases have long latency periods — typically 15 to 60 years between exposure and diagnosis. There is no cure for mesothelioma, and no safe level of exposure to asbestos fibres has been established. A single significant exposure can cause fatal disease decades later.

The Control of Asbestos Regulations 2012 (CAR 2012) impose duties on building owners and occupiers to manage asbestos in non-domestic premises, and on employers and contractors to prevent uncontrolled exposure during construction work. CAR 2012 distinguishes between three categories of asbestos work: licensed work (requiring an HSE-issued Asbestos Contractor Licence), notifiable non-licensed work (NNLW), and non-licensed work. The category determines the level of regulatory control that applies.

Never start refurbishment or demolition without an R&D survey

A Refurbishment and Demolition (R&D) survey is mandatory under CAR 2012 before any refurbishment or demolition work begins on a building that may contain asbestos. The R&D survey is intrusive — it involves destructive inspection to access all areas that will be affected by the proposed work. A management survey alone is not sufficient for refurbishment or demolition because it is non-intrusive and may not identify concealed ACMs. Starting work without an R&D survey is one of the most serious breaches of asbestos regulations and routinely results in HSE enforcement action, including prosecution.

2. Licensed vs Non-Licensed Work

CAR 2012 categorises asbestos work into three tiers based on the type of ACM, the condition of the material, and the nature of the work being carried out. The category determines the regulatory requirements — including whether an HSE licence is needed, whether notification to HSE is required, and the extent of medical surveillance and record-keeping obligations. The following table sets out the three categories.

Category	Scope	Requirements	Examples
Licensed (ACL required)	Work on asbestos insulation, asbestos insulation board (AIB), and asbestos coatings — or any work where exposure cannot be controlled below the control limit	Asbestos Contractor Licence from HSE; 14-day notification to HSE before work starts; designated asbestos analyst for air monitoring and 4-stage clearance; full medical surveillance for all operatives; plan of work; 40-year health records	Removal of pipe lagging, spray coatings, AIB panels, boiler insulation; stripping asbestos insulation from structural steelwork; removal of sprayed asbestos fire protection
Notifiable Non-Licensed Work (NNLW)	Short-duration work on certain ACMs where exposure can be controlled below the control limit — typically work of a maintenance, minor repair, or sampling nature on lower-risk ACMs	Notification to HSE via online form before work begins; medical examination for operatives every 3 years; written record of work kept for 40 years; adequate training; suitable RPE and PPE	Removal of a small number of asbestos cement sheets where not significantly degraded; drilling through AIB to install a single fixing (short-duration); sampling ACMs for analysis
Non-licensed work	Work on lower-risk ACMs (e.g. asbestos cement, textured coatings, floor tiles, bitumen products) where the material is in reasonable condition and the work is of short duration with low fibre release	No HSE notification required; no medical surveillance required; adequate training; task-specific risk assessment; suitable RPE and control measures; waste disposed of as asbestos waste	Careful removal of undamaged asbestos cement roof sheets; encapsulation of textured coatings in good condition; removal of asbestos vinyl floor tiles using non-aggressive methods

If in doubt, treat the work as licensed

The distinction between licensed, NNLW, and non-licensed work is not always straightforward. Where there is any doubt about the type of ACM, its condition, or whether exposure can be controlled below the control limit, the work must be treated as licensed until a competent assessment confirms otherwise. Incorrectly classifying licensed work as non-licensed is a criminal offence under CAR 2012 and can result in prosecution of both the contractor and the client. The HSE takes this extremely seriously because misclassification directly leads to inadequate controls and uncontrolled fibre release.

3. Common Mistakes

Starting refurbishment or demolition without an R&D survey

A management survey identifies ACMs for ongoing management but does not access concealed areas. An R&D survey is intrusive and identifies all ACMs that will be disturbed by the proposed work. Starting refurbishment or demolition based on a management survey alone — or with no survey at all — is the most common and most serious asbestos compliance failure. It routinely results in uncontrolled fibre release, site shutdowns, decontamination costs, and HSE prosecution. The R&D survey must be completed and all identified ACMs removed before intrusive work begins.

Assuming asbestos has already been removed from a building

Previous asbestos removal may not have been complete. Removal records may be inaccurate, incomplete, or missing. ACMs may exist in locations that were not accessed during previous surveys or removal programmes. Never assume a building is asbestos-free based on verbal assurances or historical records alone. A current R&D survey commissioned specifically for the proposed works is the only reliable basis for proceeding.

Using an unlicensed contractor for a small quantity of licensed material

The licensing requirement under CAR 2012 is determined by the type of ACM and the nature of the work, not the quantity. There is no de minimis threshold. Removing a single metre of pipe lagging requires a licensed contractor just as much as removing an entire building's worth. Using an unlicensed contractor for licensed work — regardless of quantity — is a criminal offence for both the contractor and the client who appointed them.

Not providing pre-construction information about known asbestos

CDM 2015 requires the client to provide pre-construction information, which must include the asbestos register, management survey, and any previous R&D survey reports. Failing to provide this information to designers and contractors means they cannot adequately plan for asbestos risks. The client has a non-delegable duty to make this information available — ignorance of its existence is not a defence.

Disposing of asbestos waste in general construction waste skips

All asbestos waste — including debris, contaminated PPE, plastic sheeting, and HEPA filter bags — must be double-bagged in red-striped asbestos waste bags, sealed, and labelled. It must be collected by a carrier registered with the Environment Agency for asbestos waste and disposed of at a licensed hazardous waste site. A consignment note must be completed for each collection. Mixing asbestos waste with general construction waste is an offence under both the Hazardous Waste Regulations and the Environmental Protection Act.

4. Related Documents

Document	Relationship
D1 — Asbestos Management Survey	The management survey identifies the location, extent, and condition of ACMs in the building for ongoing management purposes. It is the starting point for asbestos risk management but is not sufficient for refurbishment or demolition work — an R&D survey is required in addition.
D2 — Asbestos Refurbishment and Demolition Survey	The R&D survey is the intrusive survey required before any refurbishment or demolition work. It must be commissioned specifically for the proposed works and must cover all areas that will be disturbed. This is the survey that must be completed before this COSHH assessment can be finalised.
D3 — Asbestos Register	The asbestos register records all known ACMs in the building, their location, condition, and the management action assigned to each. It must be updated following any survey, removal, or re-inspection. The register must be made available to all contractors working on the building.
D6 — Asbestos Removal Plan	Where licensed or NNLW removal is required, the removal plan sets out the method, sequence, controls, and decontamination procedures. It must be produced by the licensed removal contractor and approved before work begins. The plan must be consistent with the findings of the R&D survey.
B15 — RAMS: Demolition	The demolition RAMS must confirm that an R&D survey has been completed and all ACMs removed before mechanical demolition begins. The demolition method statement must describe how asbestos risks have been addressed and cross-reference the asbestos removal plan and clearance certificate.

5. Frequently Asked Questions

What types of asbestos are found in UK buildings?▾

Three types of asbestos were commonly used in UK buildings. Chrysotile (white asbestos) was the most widely used, found in cement products, textured coatings, floor tiles, and gaskets. Amosite (brown asbestos) was used extensively in insulation boards, pipe lagging, and sprayed coatings. Crocidolite (blue asbestos) was the most hazardous, used in spray-applied fire protection and pipe insulation — it was the first type to be banned (1985). All three types cause fatal disease. There is no safe type of asbestos, and the same regulatory controls apply regardless of fibre type.

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

A management survey is non-intrusive. It identifies ACMs that could be disturbed during normal occupancy, maintenance, or minor repair. It assesses the condition of accessible ACMs and assigns a management action (monitor, encapsulate, or remove). An R&D survey is intrusive — it involves destructive inspection (lifting floors, opening walls, breaking into voids) to identify all ACMs in the areas that will be affected by the proposed refurbishment or demolition work. The R&D survey is required before any refurbishment or demolition and is more comprehensive and more disruptive than a management survey. A management survey alone is never sufficient for refurbishment or demolition work.

How should Artex (textured coating) be managed?▾

Artex and similar textured coatings applied before the mid-1980s frequently contain chrysotile asbestos. Where textured coatings are in good condition and will not be disturbed, they can be managed in situ — recorded on the asbestos register and monitored. Where they need to be removed or will be disturbed by other work, the coating must be sampled and analysed. If asbestos is confirmed, removal is classified as either NNLW or non-licensed work depending on the method and extent. Wet scraping with appropriate RPE and containment is the standard removal method. Dry sanding of asbestos-containing textured coatings must never be carried out under any circumstances.

When is air monitoring required during asbestos work?▾

Air monitoring is mandatory for all licensed asbestos removal work. It must be carried out by an analyst accredited by the United Kingdom Accreditation Service (UKAS). Monitoring is required during the removal work (to verify that controls are effective), during the four-stage clearance process (to confirm the area is safe for reoccupation), and at the site boundary (to confirm that fibre release has not affected the wider environment). For NNLW and non-licensed work, air monitoring is not mandatory but is strongly recommended, particularly where the effectiveness of controls is uncertain or where the work is carried out near occupied areas.

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