Asbestos Management Plan

The Asbestos Management Plan: A Working Document

An asbestos management plan is the central document through which the person responsible for a building, known as the duty holder, records, controls and manages the risks posed by asbestos-containing materials (ACMs) on their premises.

It sets out where asbestos has been found or is presumed to be present, what risk those materials pose to the building occupants, what action will be taken in response, and who is responsible for carrying out and overseeing those actions.

An asbestos management plan is not simply a site-specific survey summary. It is a working document: one that must be kept up to date as conditions change, reviewed at least once every 12 months and consulted before any work that could disturb the fabric of the building is authorised.

Itsits at the centre of the organisation’s asbestos management process and provides the practical framework through which legal compliance is maintained on an ongoing basis. 

Why Asbestos is Still a Serious Concern

Asbestos is a naturally occurring fibrous mineral that was used extensively in the UK construction industry for much of the twentieth century, valued for its strength, fire resistance, insulation properties and durability. Its use in new construction was not fully banned until 1999.

As a result, it remains present in a very large proportion of non-domestic properties and some residential properties built before that date.

When asbestos-containing materials are in good condition and left undisturbed, the risk to health is generally low. The hazard arises when ACMs are damaged, deteriorated or disturbed, for example during maintenance work, refurbishment or demolition, causing microscopic fibres to become airborne.

When these fibres are inhaled, they can lodge in the lungs and, over time, cause serious and often fatal diseases including mesothelioma, lung cancer and asbestosis.

These conditions have long latency periods of 20 to 50 years, meaning that the health consequences of past exposures continue to be felt decades after the original contact.

The scale of the ongoing public health burden associated with asbestos is significant. Data published by the Health and Safety Executive in July 2024 recorded 2,257 mesothelioma deaths in Great Britain in 2022, with a similar number of asbestos-related lung cancer deaths in the same year. Asbestos-related disease remains the single largest cause of work-related deaths in Great Britain.

The duty to manage asbestos is not a historical obligation that applies only to old or derelict buildings. Maintenance workers, electricians, plumbers, joiners and other tradespeople who regularly work in buildings built before 2000 are among those most at risk of encountering disturbed ACMs.

The asbestos management plan is the mechanism through which that risk is identified and controlled before anyone starts work.

The Legal Duty to Manage Asbestos

The legal requirement to have an asbestos management plan in place is set out in Regulation 4 of the Control of Asbestos Regulations 2012 (CAR 2012), known as the Duty to Manage Asbestos.

This duty applies to non-domestic property and to the common parts of multi-occupancy residential buildings; for example, hallways, stairwells, plant rooms, lift shafts and roof spaces shared by the building occupants. It does not apply to individual private homes.

The Duty to Manage requires the duty holder, or person responsible, to take reasonable steps to determine whether there is asbestos present in the premises and, if there is or may be, to assess the risk posed by accidental disturbance.

The duty holder’s job role involves preparing and implementing a written asbestos management plan, keeping the plan under review and providing information about the location and condition of ACMs to anyone likely to disturb asbestos.

The Duty to Manage is not a duty to survey every building comprehensively, nor is it a duty to remove all asbestos found.

The HSE is explicit on this point: where asbestos-containing materials acms are in good condition and are unlikely to be disturbed, leaving them in place and managing them carefully, preventing exposure, is often the safest course of action.

The overall framework for asbestos management is set out in the HSE’s Approved Code of Practice L143, Managing and Working with Asbestos, which consolidates the statutory guidance for both non-domestic premises and those carrying out work with asbestos-containing materials to prevent exposure.

The HSE also publishes a blank asbestos management plan template on its website, which provides a starting structure for duty holders, though the plan itself must reflect the specific circumstances and asbestos-containing materials profile of the individual building.

Compliance with the Duty to Manage is monitored and enforced by the Health and Safety Executive, or by local authorities in certain types of premises.

In January 2024, the HSE launched its Asbestos: Your Duty campaign, specifically targeting duty holders of non-domestic property and reinforcing the legal obligations that apply to them. Enforcement action for non-compliance with CAR 2012 has increased in frequency since the campaign launched.

Failure to have a compliant asbestos management plan in place can result in prosecution and financial penalties. The maximum custodial sentence at a Magistrates’ Court is up to 12 months imprisonment and unlimited fines, with potentially greater penalties at Crown Court.

Who is the Duty Holder?

The duty holder is the organisation or person responsible that has clear responsibility for the maintenance or repair of the non-domestic property, either by virtue of a contract, a tenancy agreement or by virtue of having actual control over those activities where no formal agreement exists.

Where responsibility is shared, for example between a landlord and a commercial tenant, more than one person may be a duty holder, and the responsibilities of each must be clearly defined and documented.

Common duty holders include property owners and freeholders, commercial landlords, facilities managers, housing associations managing shared areas, commercial tenants with full repairing leases, and employers who occupy and maintain their own business premises.

The category is broad: schools, hospitals, care homes, offices, industrial units, retail premises, community halls and places of worship are all covered where they were built or refurbished before 2000.

The legal responsibility of the duty holder cannot be delegated. A duty holder may nominate an appointed person; an individual trained and competent to coordinate the day-to-day asbestos management activities, conduct re-inspections, update the register and ensure that contractors consult the plan before starting work.

The appointed person handles the operational tasks. The legal accountability rests with the duty holder regardless.

What Should an Asbestos Management Plan Include?

The contents of an asbestos management plan will be specific to the building and its asbestos-containing profile.

At a minimum, a compliant plan should address the following.

Policy and Responsibility

A clear statement setting out the organisation’s commitment to managing asbestos safely, identifying the duty holder by name and role, and confirming the name and responsibilities of any appointed person designated to coordinate asbestos management activities.

Where the organisation has an existing health and safety policy, the asbestos management plan should be cross-referenced within it. 

Asbestos Register

A complete and up-to-date record of all identified or presumed asbestos present in the premises, recording the location of each material, its type, extent, physical condition and risk score.

The register should be accompanied by annotated floor plans showing the location of asbestos-containing materials so that anyone working in the building can consult it quickly before starting any task that involves the building fabric.

The register must include areas that were inaccessible at the time of the survey and must be updated whenever new asbestos-containing materials are found, or existing ones are disturbed or removed.

To manage asbestos risks, asbestos records must be maintained for a minimum of 40 years.

Risk Assessment for Identified ACMs

Presumed ACMs or identified ACMs must be assessed to determine the risk posed.

The risk score is based on the material’s current physical condition, whether it is intact, damaged or severely deteriorated, the type of asbestos it contains and the likelihood of it being disturbed by routine maintenance or other activities in the area where it is located.

The risk assessment determines the priority and urgency of the action required.

Prioritised Action Plan for Preventing Exposure

Based on the risk assessment outcomes, the plan must set out what action will be taken for all identified ACMs.

High-risk materials that are damaged, deteriorating or in areas of regular human activity require prompt remedial action to reduce the risk of exposure to asbestos.

Depending on the circumstances, this may mean repair or encapsulation to stabilise the material, or licensed removal by a contractor accredited to carry out such work.

Lower-risk asbestos-containing materials acms that are in sound condition and unlikely to be disturbed may be managed in place, subject to a regular monitoring and inspection schedule.

Permit-to-Work System

The plan must include a clear process for ensuring that the asbestos register is consulted before any work that may disturb the building fabric is authorised.

A permit-to-work system requires anyone planning maintenance, alteration or repair work to check the register first.

This is one of the most critical practical requirements of the plan: it is the mechanism that protects tradespeople from unknowingly disturbing ACMs during routine tasks, risking asbestos exposure.

Communication and Training 

The plan must set out how information about asbestos in the building will be communicated to anyone who may encounter it, including maintenance staff, contractors, cleaners and other regular building users, to prevent accidental disturbance.

All relevant personnel should receive appropriate asbestos awareness training. The HSE has identified inadequate communication and training as one of the most common weaknesses in asbestos management in practice.

Emergency Procedures

A documented procedure for responding to incidents involving the disturbance of ACMs, including the steps for stopping work, containing the affected area, notifying the appropriate parties, and arranging for specialist assessment and clean-up.

The plan should be clear about who has authority to authorise a return to work in the affected area and on what basis.

Review Schedule 

A confirmed timetable for reviewing the plan and the asbestos register, with a minimum frequency of once every 12 months.

The plan must also be reviewed immediately if an ACM is damaged or disturbed, if remedial works are carried out, or if there is a change in duty holder or in the occupancy or use of the building.

The Two Types of Asbestos Survey

An asbestos management plan must be based on an appropriate asbestos survey.

There are two recognised types of survey, and the choice between them depends on the purpose for which the information is needed.

An asbestos management survey is the standard survey for buildings where no major refurbishment or demolition is planned. It is designed to locate as far as reasonably practicable all ACMs likely to be disturbed during normal occupation and routine maintenance of the building.

It involves a visual inspection and minor intrusive investigation in accessible areas. The results inform the asbestos register and provide the baseline for the management plan.

A refurbishment and demolition survey is required before any significant work that will disturb asbestos in the fabric of the building, including refurbishment, conversion, extension or demolition.

It is a more thorough and intrusive investigation, designed to locate all ACMs that may be affected by the planned work, including asbestos present in concealed areas that would not be accessed during normal occupation.

Licensed removal of any relevant asbestos-containing materials acms must be carried out before the proposed work can begin.

Failure to commission a refurbishment and demolition survey before starting work is the single most common breach of CAR 2012: in the year from June 2023 to May 2024, it accounted for 76% of all enforcement notices issued under the regulations.

Both types of survey should be carried out by a suitably qualified and competent asbestos surveyor. UKAS-accredited surveying organisations are recognised as meeting the required standard of competence.

Managing Asbestos and Development

For developers and housing providers, asbestos is a consideration that arises most commonly in the context of refurbishment, conversion, change of use and demolition projects involving buildings constructed before 2000.

Discovering asbestos during a project that has already started is significantly more disruptive and expensive than identifying it in advance.

A refurbishment and demolition survey commissioned before work begins, followed by a management plan and a licensed removal programme where necessary, is the most effective way to protect the programme and manage the costs associated with asbestos.

Local planning authorities may impose conditions on planning permissions for refurbishment or demolition projects requiring evidence that asbestos has been properly identified and managed.

Building regulations requirements and CDM (Construction Design and Management) Regulations 2015 duties also apply to projects where asbestos is or may be present. 

Where a development project involves the sale or letting of an existing building, the asbestos register and management plan should be made available to the purchaser or incoming tenant as part of the due diligence process.

Potential buyers and occupiers have a legitimate interest in knowing whether asbestos is present and how it is being managed.

The HSE Asbestos Management Plan Template 

The HSE publishes a blank asbestos management plan template on its website as a free download.

HSE guidance in the template provides a starting framework covering the key elements a compliant plan should address: policy and responsibility, the asbestos register, risk assessment outputs, the action plan, communication arrangements and the review schedule.

The template is a useful starting point, but it does not remove the need for a competent person to complete the plan.

The risk assessments underpinning the action plan require professional judgement from a competent asbestos surveyor, and the plan as a whole must be tailored to the specific conditions of the individual building to ensure it is properly managed.

A template completed without adequate survey information or professional input is unlikely to satisfy the requirements of the regulations in practice.

How to Obtain an Asbestos Management Plan

The starting point is to identify a suitably qualified asbestos surveying organisation that can provide the asbestos information you need, carry out the appropriate type of survey, assess the risk from any ACMs identified, and produce the management plan and register.

The surveyor should hold relevant qualifications, and the organisation should ideally hold UKAS accreditation for asbestos surveying.

We connect developers, housing providers, landlords and building owners with experienced asbestos consultants who can carry out the surveys, risk assessments and management planning needed to keep their buildings legally compliant and building occupants and workers safe.

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Fill in the form at the top of this page, and we will connect you with an expert who can assess your building, manage asbestos in compliance with CAR 2012, and ensure you have a legally compliant plan in place to protect building occupants, your workers and your organisation.