Get this wrong and you create two problems at once: unsafe asbestos work and a breach of the law. If you are asking how should you contact the health and safety executive to notify them if you intend to undertake notifiable non-licensed work?, the correct route is to notify the HSE online before the work starts, using the appropriate asbestos notification process for notifiable non-licensed work.
That sounds straightforward, but the detail matters. For property managers, dutyholders, landlords, contractors and facilities teams, the issue is not just sending a form. You need to know whether the job is actually notifiable non-licensed work, what information the HSE expects, what records must be kept, and what employer duties continue after the notification is submitted.
These duties sit within the wider framework of the Control of Asbestos Regulations, supported by HSE guidance and survey standards in HSG264. A poor decision at planning stage can delay works, expose staff and contractors, and lead to enforcement action that was entirely avoidable.
How should you contact the health and safety executive to notify them if you intend to undertake notifiable non-licensed work?
The accepted method is to contact the HSE through its online notification system before the work begins. For notifiable non-licensed work, there is no fixed waiting period in the same way as licensed asbestos work, but the notification still has to be made before the task starts.
In practical terms, that means notification should be built into your pre-start process. Do not leave it until operatives are on site, tools are unpacked and access has been arranged. By that point, you are already too close to the line.
A sensible order is:
- Review the asbestos information.
- Classify the work correctly.
- Prepare the risk assessment and plan of work.
- Confirm training, equipment and waste arrangements.
- Submit the HSE notification.
- Start work only once everything is in place.
If anything changes before the job starts, review the classification again. A change in material condition, work method or scope can move a task from ordinary non-licensed work into notifiable non-licensed work, or from NNLW into licensed work.
What is notifiable non-licensed work?
Notifiable non-licensed work, usually shortened to NNLW, is asbestos work that does not require a licence but still carries enough risk to trigger additional legal duties. Those duties include notifying the HSE before the work starts, keeping records of the work, and arranging medical surveillance for workers who carry out NNLW.
This matters because asbestos work generally falls into three broad categories:
- Licensed work – higher-risk asbestos work that must be carried out by a licensed contractor.
- Notifiable non-licensed work – lower risk than licensed work, but still notifiable and subject to extra duties.
- Non-licensed work – lower-risk tasks that do not require a licence or notification, though they still require suitable controls, training and assessment.
NNLW often applies where the material is in poor condition, where the task is likely to cause deterioration, or where the work is more than minor and short duration. The type of asbestos-containing material also matters, because some products are far more likely to release fibres than others.
Examples of work that may fall under NNLW
Every task needs its own assessment, but examples can include:
- Removing asbestos cement sheets or products that are substantially damaged
- Disturbing textured coatings in a way that is not minor and short duration
- Lifting asbestos-containing floor tiles where backing or adhesive is significantly disturbed
- Repairing or removing asbestos insulating board in limited circumstances that do not fall into licensed work but still create a notifiable risk
- Cleaning up asbestos debris where the material condition increases the potential for exposure
Do not rely on assumptions such as “cement is always low risk” or “small jobs never need notification”. The condition of the material, the work method and the likely fibre release are what count.
When do you need to notify the HSE?
You notify the HSE before work starts if the task has been correctly assessed as notifiable non-licensed work. You do not notify simply because asbestos is present in a building. Notification depends on the category of work being undertaken.
If the task is licensed work, a different notification regime applies. If the task is genuinely non-licensed work and does not meet the threshold for NNLW, notification is not required. Even then, the rest of your asbestos duties still apply, including assessment, training and proper control measures.
Questions to ask before deciding
- What asbestos-containing material is involved?
- What condition is it in?
- Will the task cut, break, abrade or otherwise damage it?
- Is the work sporadic and of low intensity?
- How long will the task take?
- Is fibre release likely to increase because of the planned method?
- Could the work category change if the material is worse than expected once exposed?
If you cannot answer those questions with confidence, stop and get competent advice. Classifying asbestos work by guesswork is one of the quickest ways to create a compliance problem.
Reliable survey information is critical here. For occupied buildings and routine management, a current management survey helps identify asbestos-containing materials and their condition so maintenance teams are not working blind.
What information should be included in the notification?
The exact fields can vary depending on the HSE form, but the information must be clear, accurate and specific to the job. The HSE will expect enough detail to understand what is being done, where it is happening and how exposure will be controlled.
You should be ready to provide:
- The address where the work will take place
- The nature of the asbestos-containing material
- The type of task being carried out
- The planned start date and expected duration
- The number of workers involved
- The control measures being used to limit fibre release
- Decontamination arrangements
- Waste handling and disposal arrangements
- Employer and contractor details, where required by the form
Keep the wording factual. Do not guess the asbestos product, extent or condition if you are not sure. Check the asbestos register, survey findings and any sampling information first.
If there is uncertainty, resolve it before you notify. A weak notification usually reflects weak planning, and weak planning is what causes most asbestos failures on site.
The legal framework behind notifiable non-licensed work
NNLW sits under the Control of Asbestos Regulations. Those regulations place duties on employers, dutyholders and anyone controlling maintenance, repair or refurbishment work in premises where asbestos may be present.
The aim is simple: prevent exposure where possible, and where exposure cannot be avoided, reduce it to the lowest level reasonably practicable. HSE guidance supports those duties by explaining how work should be assessed, classified and controlled.
For survey work, HSG264 remains the recognised guidance for how asbestos surveys should be planned, carried out and reported. If you are relying on poor-quality survey information, the rest of your compliance process is built on weak foundations.
Core duties that regularly affect property managers
- Identify whether asbestos is present
- Assess the risk from asbestos-containing materials
- Maintain an up-to-date asbestos register
- Provide relevant information to anyone liable to disturb asbestos
- Ensure work is planned and carried out by competent people
- Review whether the proposed task is licensed, notifiable non-licensed or non-licensed work
If maintenance or refurbishment is planned without reliable asbestos information, the risk of accidental disturbance rises sharply. That can turn a manageable project into a site shutdown, with added cost and avoidable disruption.
How to prepare before notifying the HSE
Notification is not a substitute for planning. The HSE expects the work to be properly assessed before the notification is sent, not worked out afterwards.
1. Check the asbestos information
Start with the asbestos register and relevant survey report. If the information is old, unclear or does not cover the exact work area, update it before approving the job.
If you are planning works in the capital, a current asbestos survey London service can help confirm the material type, location and condition before contractors attend site.
The same principle applies elsewhere. For northern commercial sites, arranging an asbestos survey Manchester inspection can prevent assumptions being made about older premises and hidden materials.
For projects in the Midlands, an asbestos survey Birmingham assessment is often the first practical step before any intrusive work is approved.
2. Carry out a task-specific risk assessment
Do not copy a generic risk assessment from another site. The assessment should deal with the exact material, its condition, the proposed work method, likely fibre release, who may be affected and what happens if the condition is worse than expected.
A useful risk assessment should answer:
- Why the work has been classified as NNLW
- What controls will prevent or reduce exposure
- How the work area will be segregated
- What PPE and RPE are required
- How waste will be handled
- What emergency arrangements are in place
3. Produce a clear plan of work
The plan of work should explain exactly how the task will be completed. If the document is vague, the job is not ready to start.
It should include:
- The sequence of the task
- The tools and methods to be used
- How dust and debris will be controlled
- Access restrictions and signage
- Decontamination steps
- Waste packaging, labelling and removal arrangements
4. Verify competence and training
Anyone carrying out NNLW must have suitable asbestos training for the work they do. Supervisors should also understand how to recognise when actual site conditions no longer match the plan.
Ask for evidence. Do not assume training is in place because a contractor says they “deal with asbestos jobs all the time”.
5. Arrange waste handling in advance
Asbestos waste cannot be treated like standard construction waste. Packaging, labelling, transport and disposal arrangements need to be confirmed before work begins.
If the task is likely to escalate, or if the material condition is poor, using a specialist asbestos removal contractor may be the safer and more practical option.
Records, medical surveillance and employer duties after notification
Once work is classified as NNLW, the employer takes on duties that go beyond simply submitting the form. This is where many smaller contractors fall short.
Record keeping
You should keep a record of each notifiable non-licensed job. That record should allow you to show:
- What work was done
- Where it took place
- When it was carried out
- Who carried it out
- What asbestos-containing material was involved
- What control measures were used
Those records should be organised and easy to retrieve. If the HSE asks for them, you should not be searching through old emails, permit files and site diaries trying to rebuild the sequence.
Medical surveillance
Workers who carry out NNLW are subject to medical surveillance requirements. Employers should make sure this is arranged through an appropriate occupational health route and that records are retained as required.
This is one of the clearest signs that NNLW is not “light-touch” asbestos work. Even where a licence is not needed, the law still treats the exposure risk seriously.
Information sharing
Facilities managers should make sure that contractors, in-house maintenance teams and project managers all have access to the same asbestos information. Many incidents happen because one party assumed someone else had checked the register.
A practical rule works well on most sites: no intrusive work starts until the asbestos information has been reviewed, the work category has been confirmed and the controls have been signed off.
Common mistakes when dealing with NNLW notification
Most failures are avoidable. They usually happen because the classification was rushed, the survey information was poor, or asbestos paperwork was treated as an afterthought.
Frequent errors to avoid
- Using the wrong work category – classifying licensed work as NNLW, or NNLW as ordinary non-licensed work
- Notifying too late – sending the notification after the work has started
- Relying on old survey data – using reports that do not reflect the actual work area or current material condition
- Submitting vague information – incomplete descriptions of the material, task or controls
- Weak plans of work – no clear method, decontamination steps or waste procedure
- Poor contractor checks – assuming competence without verifying training and experience
- No clear records – being unable to show what was done and by whom
If your organisation regularly undertakes maintenance in older buildings, build an asbestos review into every permit-to-work or pre-start checklist. That single step prevents a large share of avoidable mistakes.
Practical advice for property managers and dutyholders
If you oversee multiple sites, consistency matters more than good intentions. A repeatable process helps you make the right decision every time, even when different contractors and project managers are involved.
A workable site process
- Check whether the age and history of the building suggest asbestos is likely to be present.
- Review the asbestos register and relevant survey report.
- Confirm whether the proposed task is non-licensed, notifiable non-licensed or licensed work.
- Require a task-specific risk assessment and plan of work.
- Check contractor competence, training and supervision.
- Confirm waste arrangements and emergency procedures.
- Submit the HSE notification where the work is NNLW.
- Keep records of the work and monitor completion.
This process is especially useful across portfolios that include schools, offices, retail sites, industrial units and residential blocks. The details of the job may change, but the decision-making structure should not.
When to pause the job
Stop and review the work if:
- The material is in worse condition than expected
- The scope expands beyond the original plan
- The contractor wants to change the method on site
- The survey does not clearly cover the work area
- There is disagreement about whether the work is NNLW or licensed
Pausing for a proper review is far better than pressing ahead with the wrong classification. Most asbestos enforcement problems start with someone deciding to “just get on with it”.
Why good survey information matters before any notification
You cannot classify asbestos work properly if you do not know what material is present, what condition it is in or how likely it is to release fibres. That is why survey quality matters so much.
HSG264 sets the standard for how asbestos surveys should be planned, carried out and reported. A reliable survey gives you the information needed to decide whether work is licensed, notifiable non-licensed or non-licensed. A poor survey leaves too much room for assumption.
For property managers, the practical takeaway is simple:
- Keep your asbestos register current
- Make sure surveys match the planned works
- Do not send contractors into areas that are not properly assessed
- Review survey findings before approving any intrusive task
If the information is incomplete, update it first. Notification should be based on evidence, not optimism.
Frequently Asked Questions
How should you contact the health and safety executive to notify them if you intend to undertake notifiable non-licensed work?
You should contact the HSE through its online asbestos notification system before the work starts. Notifiable non-licensed work must be notified in advance, even though it does not follow the same notification timetable as licensed asbestos work.
Do you need to notify the HSE every time asbestos is present?
No. The presence of asbestos alone does not trigger notification. You notify the HSE when the planned task has been correctly assessed as notifiable non-licensed work. Some lower-risk non-licensed tasks do not require notification, although they still require proper controls and training.
What happens if you start NNLW before notifying the HSE?
Starting notifiable non-licensed work before notification creates a compliance breach and may expose workers to unmanaged risk. If this happens, stop the work, review the classification and planning, and take competent advice before any restart is considered.
Does notifiable non-licensed work require a licensed contractor?
Not always. By definition, NNLW does not require a licence, but it still requires competent people, suitable training, proper controls, records and medical surveillance. If the risk is higher than first thought, the work may actually fall into the licensed category and should be reassessed immediately.
What records should be kept for notifiable non-licensed work?
You should keep records showing what work was carried out, where and when it happened, who completed it, what asbestos-containing material was involved and what control measures were used. Employers also need to address medical surveillance duties for workers carrying out NNLW.
Need expert help with asbestos compliance?
If you are unsure whether a task is non-licensed, notifiable non-licensed or licensed work, get the asbestos information checked before anyone starts. Supernova Asbestos Surveys carries out surveys nationwide for commercial, public sector and residential clients, helping dutyholders make clear, compliant decisions before work begins.
For expert advice, asbestos surveys and support with planning works safely, call 020 4586 0680 or visit asbestos-surveys.org.uk.