If you are responsible for a non-domestic building constructed or refurbished before 2000, the Control of Asbestos Regulations 2012 requires you to identify, assess, and manage any asbestos-containing materials present. For most occupied premises, that obligation begins with an asbestos management survey.
The term is often used loosely — sometimes interchangeably with “asbestos survey” — which can make it difficult to know whether you have the right survey in place, or what commissioning one actually involves.
This article sets out what an asbestos management survey is, when it applies, what the process involves, and what you are required to do with the results.
What is an asbestos management survey?
Formerly known as a Type 2 survey, an asbestos management survey is the standard survey for non-domestic premises in normal use.
This type of asbestos survey’s purpose is to locate and assess asbestos-containing materials (ACMs) that could be disturbed during a building’s routine occupation, maintenance, or minor works (but not major structural works).
Asbestos management surveys are required by Regulation 4 of the Control of Asbestos Regulations 2012 (CAR 2012) and governed by the UK Health and Safety Executive (HSE)’s guidance document Asbestos: The survey guide, under the series code HSG264.
A vital detail to know about this form of asbestos survey, is its non-intrusive nature. Surveyors undertake a visual inspection of the given building’s accessible areas and take samples of suspect materials. What they don’t do is open up the building fabric (such as breaking through walls, floors, or ceilings). The samples are then subject to laboratory analysis to confirm whether they contain asbestos.
As a duty holder who commissions an asbestos management survey, you will receive:
- A detailed schedule of ACMs (or presumed ACMs) setting out the location, extent, condition, and product type
- Photographs, plans/markups, and material assessment scores (which rate the potential for asbestos fibres to be released)
- Recommendations for managing any risks identified.
This information will provide a crucial foundation for the asbestos register and asbestos management plan that are also required for many non-domestic premises in accordance with CAR 2012.
How does a management survey differ from a refurbishment or demolition survey?
It is important not to confuse these two types of asbestos survey. Contrary to widespread misconception, an asbestos management survey is not a “lesser version” of a refurbishment or demolition survey. These survey types serve different legal purposes and are not interchangeable.
So, let’s be clear about the distinctions:
- A management survey is a non-intrusive inspection for ACMs, designed for ongoing management obligations. It is arranged for occupied premises in routine occupation, focusing on materials that are likely to be disturbed during normal use of the building.
- A refurbishment or demolition (R&D) survey is required before any works that will disturb the given property’s fabric, such as refurbishment, extensions, wiring upgrades, or demolition. The survey process is more intrusive, often involving destructive sampling.
These two types of asbestos survey, then, are complementary but can’t be directly swapped for each other. For instance, having a current management survey for your building will not satisfy the requirement for an R&D survey prior to major works.
Who needs an asbestos management survey?
You will be obliged to arrange an asbestos management survey if, in line with the terms of Regulation 4 of CAR 2012, you are the duty holder for a given non-domestic premises (or the common parts of a residential building) constructed or refurbished before the year 2000.
The duty holder is typically the person or organisation with responsibility for the property’s maintenance and repair.
This commonly includes the likes of:
- Landlords and building owners
- Local authorities and housing associations (for communal areas)
- NHS estates teams and academy trusts
- Facilities management companies
- Employers occupying their own properties
Domestic structures occupied solely as homes are generally exempt from the CAR 2012, Regulation 4 requirements. However, this exemption does not extend to communal areas in residential blocks, or to commercial parts of mixed-use buildings.
In situations of shared responsibility (such as leases), it is essential to have clear written agreement on the identity of the duty holder. It is not acceptable in the eyes of the law to simply ignore responsibility, or to pass on responsibility informally.
What does an asbestos management survey involve in practice?
From the duty holder’s perspective, the process of having an asbestos management survey performed is relatively straightforward:
- Pre-survey preparation will include providing the surveyor with existing building plans and information on any previous surveys or records. It will also be necessary to make access arrangements.
- A site visit will then take place. This will entail a competent surveyor undertaking a thorough visual inspection of all accessible parts of the building, including (but not limited to) roof voids, ceiling voids, plant rooms, and service ducts.
- Samples of suspect materials will be taken, where it is safe and possible to do so in a non-intrusive manner that does not open up the fabric of the building. These samples will be sent to a laboratory for analysis.
- A survey report will then be produced. This will be a comprehensive and illustrative document comprising an ACM schedule, location drawings, condition ratings, and risk priority scores. These findings will subsequently be fed into the asbestos register and asbestos management plan.
It is important to remember that an asbestos survey report does not, on its own, fulfil the “duty to manage”. It is only the starting point for compliance with Regulation 4 of CAR 2012, rather than the endpoint.
When does a management survey need to be repeated or reviewed?
An asbestos management survey doesn’t come with a fixed “expiry date” under CAR 2012. Instead, the specific requirement is for the asbestos register and asbestos management plan for a particular property to be up to date and effective.
Triggers for a new or updated survey include:
- Significant alterations or extensions to the building
- The uncovering of areas that were previously inaccessible
- Changes in the condition of known ACMs
- Any incident that may have affected ACMs at the site.
Re-inspection obligations under a live management plan are a separate matter to the commissioning of a new asbestos survey. As a duty holder, you should arrange regular re-inspections to monitor the condition of identified ACMs. It is when a given building’s status changes materially that a new survey will be needed.
The HSE’s position is that the asbestos register for a particular site must always reflect the current situation.
What happens after the survey and what does the duty holder need to do?
The survey findings will feed directly into your asbestos register. This underpins a robust asbestos management plan (AMP), which will set out:
- How risks are to be controlled
- Re-inspection frequencies (which will be based on the risk)
- The obligations and procedures for notifying contractors and staff
- Training and emergency arrangements
Over recent years, many duty holders have turned to digital systems as a means of managing all this data efficiently. Such technology makes it easier to share this vital information with contractors and demonstrate compliance during audits or inspections.
Conclusion: take control of asbestos management at your site
To return to the question we posed at the beginning of this article: yes, you will almost certainly require an asbestos management survey if you are responsible for a pre-2000 non-domestic property (or the relevant parts of a mixed or residential building) and do not have a current, suitable management survey and an up-to-date register.
As a duty holder, having read this guide, you should now know what an asbestos management survey is, whether it applies to you, and what it sets in motion.
Are you looking to take control of your asbestos management obligations as an individual or organisation? If so, please don’t hesitate to reach out to the Assets & Compliance Managed Services (ACMS) team to find out more about our solutions and expertise, and to request advice, or support.
