A survey report filed in an office does not stop an electrician drilling into an asbestos-containing panel. Owners, landlords, tenants and others responsible for non-domestic premises need a live asbestos management plan that reaches maintenance decisions before work begins.
Identify who holds the duty for each part of the premises
Regulation 4 of the Control of Asbestos Regulations 2012 applies to non-domestic premises. The dutyholder is every person responsible, through a contract or tenancy, for maintenance or repair of the premises or access to them. Where there is no contract or tenancy, the duty falls on the person controlling that part of the premises. Responsibility may therefore be shared.
Do not assume that ownership settles the question. A lease may place internal repairs on a tenant while the landlord retains the roof, plant room and common areas. A managing agent may perform tasks without removing the legal responsibilities of the parties. Map the building by area and record who can authorise work, maintain the register and control contractors.
The duty also covers common parts of multi-occupancy domestic buildings, such as corridors, lifts, stairwells and shared roof spaces. It does not apply to the private domestic areas themselves, although employers arranging work in homes still have duties to prevent worker exposure.
Control of Asbestos Regulations 2012, regulation 4 ↗ · HSE: actions for building owners, landlords and employers ↗
Find known and presumed asbestos and create a live register
Dutyholders must take reasonable steps to determine whether asbestos-containing materials, or ACMs, are present and, if so, their location and condition. They must presume that material contains asbestos unless there is strong evidence that it does not. Age records, plans and previous surveys can help, but they must be checked against the actual premises.
Buildings constructed or refurbished before 2000 may contain asbestos. A later construction date can be useful evidence, provided records are reliable and later-installed reclaimed materials or older retained structures have been considered. Visual inspection alone cannot confirm that a suspect material is asbestos-free; confirmation requires competent sampling and analysis.
The register should show all known and presumed ACMs, type, quantity, location, condition, inspection dates, fibre-release potential and likelihood of disturbance. Clearly mark areas that were not accessed and manage them as presumed asbestos until suitable investigation resolves the uncertainty.
Treat the register as a live operational record. Update it after condition checks, sampling, repair, encapsulation or removal, and whenever a room use or maintenance programme changes the likelihood of disturbance.
HSE: make an asbestos register and assess risk ↗ · Related guide: making risk assessments work in practice →
Choose the survey that matches the work
A management survey supports normal occupation and routine maintenance. It should locate ACMs that could be disturbed during foreseeable use, cleaning and maintenance and provide information for the register and management plan. Restrictions and inaccessible areas reduce its value and must be explicit.
A management survey is not enough for work that will open up the building fabric. Before refurbishment or demolition, a competent surveyor must complete a refurbishment or demolition survey covering the precise work area. It uses intrusive investigation to find hidden ACMs and the area must be vacated during the survey. The scope should match the drawings and proposed methods, not a generic building description.
Give the surveyor accurate plans, access and details of planned work. Check that room references, photographs and plans are usable and that exclusions are understood. HSE strongly recommends using a UKAS-accredited asbestos surveying organisation; the dutyholder must still be satisfied that the survey is adequate for its intended purpose.
Turn the register into an asbestos management plan
The register identifies the hazard; the management plan explains how the risk will be controlled. It should be site-specific, easy to find and written or electronic. Name the responsible person and deputy, attach the current register and site plan, set condition-monitoring dates, describe how information reaches workers, and state the controls that prevent accidental disturbance.
Prioritise damaged materials and those likely to be hit, cut or accessed. ACMs in good condition and unlikely to be disturbed can usually remain in place with suitable protection and monitoring. Removal is not automatically safer. Damaged ACMs may need repair, sealing, enclosure or removal by an appropriate contractor after competent assessment.
Set clear owners and completion dates for every action. Include arrangements for labels where suitable, access restrictions, permits, contractor handover and hand-back, changes to services, and emergency response. A score without a decision, owner and deadline is not a control plan.
Put asbestos information in front of people before work starts
Provide relevant register and management-plan information to employees, contractors and anyone liable to disturb ACMs. For planned work, do this early enough to influence quotation, survey scope and method—not when the contractor arrives with tools. The information must cover the actual route, void, wall, ceiling or plant area involved.
Use a controlled work-order or permit process. Confirm that the register has been checked, the information covers the work area, any intrusive survey is complete, and the contractor's competence, risk assessment and plan of work match the task. Asbestos-awareness training helps people avoid accidental disturbance; it does not qualify them to work on asbestos.
Some lower-risk asbestos work is non-licensed, but it still requires task-specific risk assessment, a plan, controls, appropriate training and waste arrangements. Higher-risk work must be completed by an HSE-licensed contractor. If the material or work category is uncertain, stop and obtain competent advice before proceeding.
HSE: provide information to anyone who might disturb asbestos ↗ · Related guide: COSHH assessments and safety data sheets →
Check the information before maintenance reaches the building fabric.
HR + SAFETY can review dutyholder roles, registers, management plans and contractor controls, and coordinate competent survey input where the existing information does not cover the task.
Discuss an asbestos management-plan reviewPlan for damage, discovery and changing conditions
The plan must include emergency procedures for accidental disturbance. If a worker finds a suspect material or damages a known ACM, stop work, keep people out, prevent further spread and contact the person responsible for the asbestos plan. Do not dry sweep debris or use an ordinary vacuum cleaner. Obtain competent advice on isolation, decontamination, sampling and whether licensed work is required.
Record what happened and review whether anyone may have been exposed. Update the register, work controls and relevant risk assessments, and investigate why the information or permission system failed. Preserve clear facts for any required health, incident or contractor records.
Monitor ACM condition at the frequency set by risk. HSE advises updating the register at least annually and sooner when risk changes. The Regulations require the management plan to be reviewed and revised at regular intervals and whenever there is reason to suspect it is no longer valid or there has been a significant change. Work affecting ACMs, new survey information, damage and changes in responsible staff are immediate review triggers.
HSE: worker guidance on discovering or disturbing asbestos ↗ · Related guide: workplace investigation process →
Ten-point asbestos management plan checklist
Test the system using tomorrow's maintenance job. Can the person authorising it identify the dutyholder, open the current register, confirm that the work area was inspected and show the contractor what must not be disturbed? If not, the plan is not yet controlling the risk.
- Map repair, maintenance and control responsibilities by building area.
- Confirm construction and refurbishment history without relying on age alone.
- Arrange a competent management survey where information is insufficient.
- Record known, presumed and inaccessible ACM locations in the register.
- Assess both material condition and the real likelihood of disturbance.
- Assign named owners, deputies, priorities and completion dates.
- Use an intrusive refurbishment or demolition survey before relevant work.
- Give workers and contractors usable information before they start.
- Maintain a practical stop-work and accidental-disturbance procedure.
- Inspect, review and update the register and plan when conditions change.
The duty to manage is an active building-control process, not a survey purchase. Establish responsibility, maintain a current register, select the right survey before intrusive work, control contractors and update the plan whenever condition or use changes.
This guide provides general information for UK employers. It is not legal advice and should not replace advice based on the facts of a specific matter.