Risk Assessments · Mandatory · Pre-Construction
RAMS — Refurbishment and Strip Out
This RAMS covers internal strip-out and refurbishment works in existing buildings. It addresses hidden hazards including asbestos, lead paint, structural instability, and live services behind walls and ceilings. Pre-start surveys, phased isolation of services, and asbestos refurbishment surveys are mandatory before any intrusive work commences.
Last reviewed: 29 March 2026 — This guide reflects UK law as of this date. MHSWR 1999 / CDM 2015 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) + Control of Lead at Work Regulations 2002 (CLAW 2002) + COSHH 2002 + CDM 2015 |
| Asbestos survey | Refurbishment and Demolition (R&D) survey mandatory before any refurbishment or strip-out work under CAR 2012 Regulation 5 |
| Management survey | Assesses condition and manages ACMs in situ during normal occupation — does not cover hidden or concealed materials |
| R&D survey | Intrusive survey identifying all ACMs in the area to be disturbed — required before any refurbishment or strip-out work begins |
| Licensed removal | Required for higher-risk asbestos work (e.g. sprayed coatings, lagging, AIB in poor condition) — HSE-licensed contractor only |
| Enforcing authority | Health and Safety Executive (HSE) |
1. What It Covers
Refurbishment and strip-out RAMS address the specific hazards associated with the removal and alteration of existing building fabric. This category of work is distinct from new-build construction because it involves disturbing materials that may contain asbestos, lead, or other hazardous substances. Any building constructed before 2000 may contain asbestos-containing materials (ACMs), and many buildings constructed before 1980 contain lead paint. The consequences of disturbing these materials without proper controls are severe — asbestos exposure causes mesothelioma, a fatal cancer with no cure, and is the single largest cause of work-related death in the UK.
CAR 2012 imposes a duty to manage asbestos in non-domestic premises and requires a Refurbishment and Demolition (R&D) survey before any refurbishment or strip-out work. This is distinct from a management survey, which assesses ACMs during normal occupation but does not cover hidden or concealed materials that will be disturbed during refurbishment. CLAW 2002 controls lead exposure, COSHH 2002 covers all other hazardous substances, and CDM 2015 places duties on all duty holders to manage the risks associated with the work.
“An employer must not undertake work in demolition, maintenance, or any other work which exposes or is liable to expose employees to asbestos...unless...a suitable and sufficient assessment has been made as to whether asbestos...is or is liable to be present.”— CAR 2012 Regulation 5
Sohan Group prosecution — March 2026
In March 2026, the Sohan Group was prosecuted following the uncontrolled disturbance of asbestos insulating board during a strip-out contract on a 1970s office building. The investigation found that only a management survey had been carried out — not an R&D survey — and that operatives had removed ceiling tiles and partition walls without any asbestos controls in place. Fibre levels in the work area exceeded the control limit by a factor of 15. The court heard that the contractor had relied on the building owner’s existing asbestos register, which was based on a management survey that explicitly stated it did not cover concealed materials. The case demonstrates that a management survey is not a substitute for an R&D survey when refurbishment or strip-out work is planned.
R&D survey vs management survey — the critical distinction
A management survey identifies ACMs that could be disturbed during normal occupation, use, and maintenance. It is a condition assessment of known or reasonably assumed ACMs, and it does not involve destructive inspection of concealed areas. An R&D survey is an intrusive, destructive survey that aims to identify all ACMs in the area where refurbishment or demolition will take place — including behind walls, above ceilings, under floors, and within service risers. An R&D survey is mandatory before any refurbishment or strip-out work begins. The two surveys serve different purposes and one cannot substitute for the other.
2. Asbestos Work Classification
CAR 2012 classifies asbestos work into three tiers based on the type of material, its condition, and the nature of the work being carried out. The tier determines who can carry out the work, what controls are required, and whether HSE notification is needed. Correct classification is critical — carrying out licensed work without a licence is a criminal offence.
| Tier | Material / work type | Who can do the work | HSE notification | Key controls |
|---|---|---|---|---|
| Licensed | Sprayed asbestos coatings, asbestos lagging, asbestos insulating board (AIB) in poor condition, any work where exposure exceeds the control limit or where the work is not short duration | HSE-licensed asbestos removal contractor only | 14-day notification to HSE mandatory before work commences | Full enclosure, negative pressure unit (NPU), decontamination unit, air monitoring, 4-stage clearance, personal exposure monitoring, health surveillance |
| Notifiable Non-Licensed Work (NNLW) | AIB in reasonable condition (short-duration work), textured coatings containing asbestos, asbestos cement that is weathered or damaged | Competent contractor (not required to hold HSE licence, but must be trained and competent) | Brief online notification to HSE required before work commences | Controlled wetting, local exhaust ventilation or H-type vacuum, RPE (minimum FFP3), designated waste bags, personal exposure monitoring recommended, health surveillance |
| Non-licensed | Asbestos cement in good condition, asbestos textured coatings (Artex) undamaged, asbestos gaskets and seals, short-duration minor work on low-risk ACMs | Any competent contractor with asbestos awareness and task-specific training | No notification required | Controlled wetting, H-type vacuum, appropriate RPE, double-bagged waste, decontamination procedures |
3. Hazardous Materials
Asbestos is the highest-profile hazardous material in refurbishment, but it is not the only one. The following table identifies the principal hazardous materials commonly encountered during strip-out and refurbishment work, together with the applicable regulations and the controls required.
| Material | Where found | Applicable regulations | Controls |
|---|---|---|---|
| Asbestos (all types) | Insulation, ceiling tiles, floor tiles, textured coatings, gaskets, pipe lagging, roof sheets, fire doors | CAR 2012 | R&D survey, licensed/NNLW/non-licensed removal as classified, air monitoring, health surveillance, waste disposal to licensed tip |
| Lead paint | Pre-1980 buildings: window frames, doors, skirting, radiators, structural steelwork | CLAW 2002 | Blood lead level monitoring, wet removal methods, H-type vacuum, RPE (minimum APF 20), biological monitoring, health surveillance |
| Respirable crystalline silica (RCS) | Cutting, drilling, or grinding concrete, brick, stone, morite, and tiles | COSHH 2002 | Water suppression, on-tool extraction, RPE (minimum FFP3), exposure monitoring, health surveillance, WEL 0.1 mg/m3 |
| Man-made mineral fibres (MMMF) | Glass wool, rock wool, slag wool insulation in walls, lofts, pipe lagging, ductwork | COSHH 2002 | Minimise disturbance, RPE (minimum FFP2), disposable coveralls, dampening, H-type vacuum for cleanup |
| Refrigerants (CFCs/HCFCs/HFCs) | Air conditioning systems, chillers, refrigeration plant | F-Gas Regulations 2015 + Ozone-Depleting Substances Regulation | Recovery by certified F-Gas engineer before decommissioning, no venting to atmosphere, waste transfer notes, equipment decommissioned before strip-out |
| Fluorescent tubes and discharge lamps | All buildings with fluorescent lighting | Hazardous Waste Regulations 2005 + WEEE Regulations | Intact removal and segregation, storage in purpose-made containers, disposal via licensed hazardous waste contractor, mercury content requires specialist handling |
4. Common Mistakes
Relying on a management survey instead of an R&D survey
A management survey identifies ACMs during normal building occupation. It does not cover concealed materials that will be disturbed during refurbishment or strip-out. An R&D survey is intrusive and specifically designed to find all ACMs in the area to be worked on. Starting strip-out work based on a management survey alone is a breach of CAR 2012 Regulation 5 and was the primary failing in the Sohan Group prosecution. The RAMS must confirm that an R&D survey has been completed for the specific work area.
No pre-strip-out soft strip sequence
Refurbishment and strip-out work must follow a planned sequence: hazardous materials removal first (asbestos, lead paint, refrigerants), then soft strip (non-structural elements), then hard strip (structural elements where applicable). Beginning general strip-out before hazardous materials have been identified, assessed and removed is the most common cause of uncontrolled asbestos exposure on refurbishment projects.
Failing to isolate services before strip-out begins
Live electrical circuits, pressurised water and gas supplies, and active drainage systems must be identified, isolated, and confirmed dead before strip-out work commences. Many refurbishment projects involve buildings where services have been modified over decades in ways that do not match record drawings. A physical trace and isolation by a competent person is required — not reliance on drawings alone.
Not classifying asbestos work into the correct tier
Under-classifying asbestos work — for example, treating NNLW as non-licensed work to avoid notification — is a criminal offence under CAR 2012. The classification depends on the material type, its condition, and the nature and duration of the work. If there is any doubt, the work should be classified at the higher tier and a licensed contractor engaged. The analyst carrying out the R&D survey should provide guidance on the appropriate classification for each ACM identified.
No COSHH assessment for non-asbestos hazardous materials
The focus on asbestos can lead to other hazardous materials being overlooked. Lead paint, RCS from concrete cutting, MMMF from insulation removal, and refrigerants from HVAC decommissioning all require separate COSHH assessments with specific exposure limits, controls and health surveillance. The RAMS must address all hazardous materials identified in the pre-refurbishment surveys, not just asbestos.
5. Frequently Asked Questions
Is an R&D survey required for every refurbishment project?▾
Yes, if the building was constructed before 2000 and the work involves disturbing the building fabric. CAR 2012 Regulation 5 requires that no work which is liable to expose employees to asbestos is undertaken until a suitable and sufficient assessment has been carried out. For refurbishment and strip-out, this means an R&D survey of the specific area to be worked on. Even if a management survey shows no ACMs in the building, an R&D survey is still required because the management survey does not cover concealed areas that the refurbishment will disturb.
Who is responsible for commissioning the R&D survey?▾
Under CDM 2015, the client has a duty to provide pre-construction information including the results of any asbestos survey. In practice, the principal contractor or the contractor carrying out the strip-out should verify that an R&D survey (not just a management survey) has been completed for their specific work area before starting. If it has not, they should refuse to commence work until it is done. The duty not to expose workers to asbestos under CAR 2012 applies to the employer — which is the contractor whose workers will carry out the strip-out.
What is the difference between licensed and notifiable non-licensed work (NNLW)?▾
Licensed work covers the highest-risk asbestos activities: removal of sprayed coatings, lagging, and asbestos insulating board in poor condition, or any work where exposure is likely to exceed the control limit or the work is not short-duration. Licensed work requires an HSE-licensed contractor and 14 days advance notification. NNLW covers work on ACMs that is lower risk but still requires notification — such as short-duration work on AIB in reasonable condition or removal of textured coatings containing asbestos. NNLW requires a brief online notification to HSE but does not require an HSE licence.
Do operatives need asbestos awareness training for strip-out work?▾
Yes. CAR 2012 Regulation 10 requires that every worker who may be exposed to asbestos during their work receives appropriate information, instruction and training. For strip-out operatives, this means asbestos awareness training as a minimum — covering the types of materials that may contain asbestos, how to recognise them, the health effects of exposure, and what to do if they suspect they have disturbed ACMs. Workers carrying out NNLW or licensed work require additional task-specific training beyond basic awareness.
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