Do I Need an Asbestos Survey Before Refurbishment?

The legal position

Regulation 5 of the Control of Asbestos Regulations 2012 (CAR 2012) requires that no work that is liable to expose employees or others to asbestos shall be carried out unless the employer has identified the type and condition of asbestos present, or assumed that asbestos is present and treated it accordingly.

The Approved Code of Practice (L143, paragraph 91) makes clear that a refurbishment and demolition survey is needed before any refurbishment, maintenance, or demolition work that could disturb asbestos. This applies regardless of the size of the project.

Two types of asbestos survey

The HSE recognises two types of asbestos survey, defined in HSG264:

Management survey

Non-intrusive. Identifies ACMs that could be disturbed during normal occupation. Does not involve breaking into walls, ceilings, or floors. Suitable for buildings in normal use where no refurbishment is planned.

Refurbishment and demolition (R&D) survey

Fully intrusive. The surveyor accesses all areas where work will take place, including behind panels, above ceilings, under floors, and inside service risers. Required before any refurbishment, maintenance, or demolition work that could disturb the building fabric.

A management survey is not sufficient before refurbishment work. The management survey only looks at accessible materials. A wall that appears clean in a management survey may have asbestos insulating board behind the plasterboard, which would only be found by an R&D survey.

When you might not need a survey

There are limited circumstances where a survey may not be needed:

The building was constructed entirely after 1999, and there is documented evidence (such as building control records or the original specification) confirming that no asbestos-containing materials were used. Even in this case, the dutyholder should formally record the basis for the decision not to survey.

The area of work has already been subject to a recent R&D survey that covers the exact scope of the proposed works. A survey from a different area of the same building does not count. Neither does a management survey.

The dutyholder's responsibility

Under CDM 2015, the client has a duty to provide pre-construction information to every designer and contractor. This includes information about the presence of asbestos or other hazardous materials. If the client does not hold a current asbestos survey, they should commission one before appointing contractors.

The principal designer should verify that the survey has been carried out and that the results are included in the pre-construction information pack. If the survey identifies ACMs in the work area, the construction phase plan must include the arrangements for managing or removing those materials.

Practical steps

Commission the R&D survey early in the project timeline. A typical survey takes one to three days on site depending on the building size, plus five to ten working days for the laboratory analysis and report. Delays in receiving the survey report will delay the start of work.

Ensure the surveyor's brief matches the scope of work. An R&D survey covers only the areas specified in the brief. If the scope of work expands after the survey, the additional areas must be surveyed before work begins in them.

Keep the survey report on site and make it available to all contractors and workers. Under CAR 2012 Regulation 4, the dutyholder must ensure that information about the location and condition of ACMs is made available to anyone who may disturb them.

Frequently asked questions

What is the difference between a management survey and a refurbishment and demolition survey?

A management survey identifies asbestos-containing materials (ACMs) that could be disturbed during normal occupation and use. It is non-intrusive — the surveyor looks at visible and accessible materials without damaging finishes. A refurbishment and demolition (R&D) survey is fully intrusive: the surveyor opens up walls, ceilings, floors, and service risers to find all ACMs in the area where work will take place. An R&D survey is required before any refurbishment, alteration, or demolition work.

Do buildings built after 2000 need an asbestos survey?

The UK banned the import and use of all asbestos by 1999. Buildings where construction started after this date should not contain asbestos. However, if there is any doubt about whether post-1999 materials were used (for example, in a renovation that used reclaimed materials), a survey may still be prudent. In practice, most surveyors will issue a brief inspection report confirming the building post-dates the ban rather than a full survey.

Who can carry out an asbestos survey?

Asbestos surveys must be carried out by a competent person. The HSE recommends using a surveyor accredited by UKAS (United Kingdom Accreditation Service) to ISO 17020. Accredited surveyors are listed on the UKAS website. Using a non-accredited surveyor is not illegal, but it carries risk — if the survey misses ACMs and a worker is exposed, the dutyholder may face prosecution.

Can I start work while waiting for the survey results?

No. The Approved Code of Practice for CAR 2012 (L143) states that an R&D survey must be completed and the results available before refurbishment or demolition work begins in the survey area. Starting work without the survey is a breach of Regulation 5. The only exception is emergency work to prevent imminent danger to life, where the work should be carried out under controlled conditions with appropriate precautions.

What if the survey finds asbestos?

If the survey identifies ACMs in the work area, those materials must be removed or managed before the refurbishment work proceeds. If the ACMs are licensed materials (such as sprayed coatings, lagging, or asbestos insulating board), removal must be carried out by an HSE-licensed contractor. Non-licensed materials can be removed by trained workers following the correct procedures, though many clients choose to use a licensed contractor for all removals.

Is a survey needed for minor works like fitting a shelf?

Even small jobs that disturb the fabric of a building can release asbestos fibres. HSE guidance states that if the work will disturb the building fabric in any building constructed before 2000, the dutyholder should check whether ACMs are present. For very minor works, this might mean checking the existing management survey and asbestos register rather than commissioning a new R&D survey. If there is no existing survey, or the register does not cover the area where work is planned, a targeted R&D survey is needed.

Do I need an asbestos survey before refurbishment?