Addressing Asbestos Concerns in the Design and Planning of Construction Projects

Why Asbestos Hazards in Construction Still Catch Teams Off Guard

Asbestos hazards in construction remain one of the most serious and persistent risks facing the UK building industry. Despite a complete ban on the use of asbestos in 1999, millions of tonnes of asbestos-containing materials (ACMs) are still embedded in buildings across the country — and every time a drill, saw, or demolition crew disturbs them, fibres can become airborne with potentially fatal consequences.

Around 5,000 people die each year in the UK from asbestos-related diseases, making it the single largest cause of work-related deaths in the country. For construction professionals — designers, project managers, principal contractors, and site workers alike — understanding how to identify, assess, and manage these risks is not optional. It is a legal obligation.

Where Asbestos Hides in Construction Projects

Any building constructed or refurbished before the year 2000 must be treated as potentially containing asbestos until proven otherwise. Asbestos was used extensively in British construction for decades because of its fire resistance, durability, and insulating properties — and it turns up in places that routinely catch teams off guard.

Common locations where ACMs are found during construction and refurbishment work include:

  • Insulation boards and lagging — around pipes, boilers, and structural steelwork
  • Ceiling and floor tiles — particularly in commercial and industrial buildings
  • Roofing and wall cladding — corrugated asbestos cement sheets are widespread
  • Textured coatings — Artex and similar decorative finishes on ceilings and walls
  • Soffit boards and partition walls — especially in schools, hospitals, and offices built between the 1950s and 1980s
  • Guttering, downpipes, and rainwater systems — asbestos cement was commonly used outdoors
  • Sprayed coatings — highly friable and among the most dangerous forms of asbestos

The challenge for construction teams is that ACMs are not always visible or obvious. Materials can look entirely benign until they are sampled and tested. This is why pre-work surveying is not just good practice — it is a legal requirement before any refurbishment or demolition activity.

The Legal Framework Governing Asbestos Hazards in Construction

Construction professionals operate within a clear and demanding regulatory framework. Getting this wrong carries serious consequences, including unlimited fines, prosecution, and imprisonment.

Control of Asbestos Regulations

The Control of Asbestos Regulations (CAR) is the primary legislation governing work with asbestos in Great Britain. It sets out licensing requirements, notification duties, and the obligations on employers and duty holders to protect workers and others from asbestos exposure.

Under CAR, work with asbestos is categorised into three tiers: licensed work, notifiable non-licensed work (NNLW), and non-licensed work. The category determines what controls, training, and notification requirements apply. Most construction activities that disturb significant quantities of ACMs will require a licensed contractor.

Construction (Design and Management) Regulations

The Construction (Design and Management) Regulations (CDM) place specific duties on clients, designers, and principal contractors to address hazardous materials — including asbestos — during the pre-construction phase. Designers must eliminate or reduce foreseeable risks where possible, and the construction phase plan must account for any identified asbestos hazards.

Failure to comply with CDM in relation to asbestos management is a criminal offence. The responsibilities are shared across the project team, meaning no single party can simply pass the liability on.

HSG264 — The HSE’s Survey Guide

HSG264 is the Health and Safety Executive’s definitive guidance on asbestos surveying. It defines the two main survey types — management surveys and refurbishment/demolition surveys — and sets out the standards that qualified surveyors must follow. Any survey that does not comply with HSG264 will not satisfy your legal duty of care.

Duty to Manage (Regulation 4)

For non-domestic premises, Regulation 4 of CAR places a legal duty to manage asbestos on the owner or person in control of the building. This means identifying ACMs, assessing their condition and risk, and maintaining an up-to-date asbestos register. If you are commissioning construction work on a non-domestic building, this duty is yours — and it must be discharged before work begins.

Asbestos Surveys: The Essential First Step Before Any Construction Work

Before any refurbishment, demolition, or intrusive construction work begins on a pre-2000 building, a suitable asbestos survey is legally required. The type of survey you need depends on the nature of the work.

Management Surveys

A management survey is used during the normal occupation and maintenance of a building. It identifies ACMs that could be disturbed during day-to-day activities and provides the information needed to produce an asbestos register and management plan.

If your construction project involves minor works or ongoing maintenance on a building in use, this is the survey you need as a baseline. It sets the foundation for all subsequent decisions about how ACMs are managed throughout the building’s lifecycle.

Refurbishment and Demolition Surveys

For any construction work that involves disturbing the building fabric — whether that is a full demolition, a strip-out, or a targeted refurbishment — a refurbishment survey is required. This is a more intrusive investigation that accesses all areas to be affected by the works, and it must be completed before work starts, not during it.

The refurbishment survey will identify all ACMs in the work zone, assess their condition, and provide recommendations for removal or encapsulation before construction teams move in.

Where a building is being fully demolished, a demolition survey is required — this covers the entire structure, not just the areas of immediate work, and must be carried out before any demolition activity commences.

Re-inspection Surveys

Where ACMs are being managed in situ rather than removed, they must be monitored regularly. A re-inspection survey checks the condition of known ACMs at regular intervals — typically annually — to ensure they have not deteriorated and that the management plan remains fit for purpose.

For long-running construction projects or phased developments, re-inspection surveys are an essential part of ongoing risk management. A material that was stable at the outset of a project may have been disturbed or degraded by the time later phases commence.

Asbestos Testing: Confirming What You Are Dealing With

Surveying identifies suspect materials. Testing confirms whether they actually contain asbestos and, if so, which type. This distinction matters because different asbestos types — chrysotile, amosite, crocidolite — carry different risk profiles, and the type of fibre affects how work is categorised under CAR.

Samples are analysed under polarised light microscopy (PLM) at a UKAS-accredited laboratory. The results determine whether materials are ACMs, which informs the risk assessment and the controls required before and during construction work.

If you need rapid confirmation of a suspect material on site, professional asbestos testing provides legally defensible results from a UKAS-accredited lab. Alternatively, where sampling is permitted and safe to carry out, a testing kit can be used to collect bulk samples for laboratory analysis.

For broader guidance on the testing process, including what to expect and how results are used, our asbestos testing resource covers the key steps in plain terms.

Managing Asbestos Hazards During Construction: Key Controls

Once asbestos has been identified, the construction team must decide how to manage it. There are three broad approaches, and the right choice depends on the condition of the material, the extent of the works, and the risk to workers and building occupants.

Removal

Full asbestos removal is often the preferred option before major refurbishment or demolition, as it eliminates the hazard entirely. Licensed removal contractors must carry out work on most types of asbestos insulation and asbestos insulating board (AIB).

The work area must be enclosed, under negative pressure, and subject to air monitoring throughout. Air monitoring ensures that fibre levels remain below the control limits set under CAR: 0.1 fibres per cubic centimetre as a four-hour time-weighted average for licensed work, and 0.6 fibres per cubic centimetre over a ten-minute period. Clearance air testing must be carried out after removal before the enclosure is dismantled.

Encapsulation

Where removal is not practicable — or where ACMs are in good condition and will not be disturbed — encapsulation may be appropriate. This involves sealing or coating the material to prevent fibre release.

Encapsulated ACMs must be clearly labelled and included in the asbestos register, with regular re-inspection to monitor their condition. Encapsulation is not a permanent solution — it is a management measure that requires ongoing oversight.

Short-Duration Work Controls

Some construction activities involving asbestos are classified as short-duration, non-licensed work. CAR defines this as work carried out by one person for less than one hour, or a maximum of two hours collectively across the work team within a seven-day period.

Even for short-duration tasks, appropriate respiratory protective equipment (RPE), controlled work methods, and decontamination procedures must be in place. Short-duration does not mean low-risk — the same fibres are released, and the same precautions apply.

Health Risks: Why Asbestos Hazards in Construction Cannot Be Ignored

Asbestos fibres are invisible to the naked eye. When inhaled, they lodge in the lungs and cannot be expelled. The diseases they cause — mesothelioma, asbestosis, pleural disease, and asbestos-related lung cancer — have latency periods of between 15 and 60 years.

A worker exposed on a construction site today may not develop symptoms until well into retirement. This latency period is one of the reasons asbestos hazards in construction are sometimes underestimated — the consequences are not immediate, and the connection between exposure and illness can be difficult to trace decades later.

But the diseases themselves are invariably serious, often terminal, and entirely preventable with the right controls in place. Employers are required under CAR to keep health records for workers involved in licensed asbestos work for 40 years from the date of the last entry. Significant exposure events must be reported under RIDDOR. These obligations exist because the health consequences are long-lasting and the legal accountability must match.

Integrating Asbestos Risk Into Construction Design and Planning

The most effective way to manage asbestos hazards in construction is to address them at the earliest possible stage — during design and planning, not on site. CDM places a clear duty on designers to consider foreseeable risks and eliminate or reduce them through design decisions where possible.

In practice, this means:

  • Commissioning a refurbishment or demolition survey as part of the pre-construction phase, before detailed designs are finalised
  • Incorporating asbestos removal programmes into the project programme and budget from the outset
  • Sharing asbestos information with all designers, principal contractors, and specialist subcontractors through the pre-construction information pack
  • Including asbestos management procedures in the construction phase plan
  • Reviewing the asbestos register at each stage of a phased project to account for newly identified materials

Construction projects that treat asbestos as an afterthought — something to deal with when it is encountered on site — consistently run into delays, cost overruns, and enforcement action. Projects that plan for it from day one run more smoothly, more safely, and at lower overall cost.

Regional Considerations: Asbestos Surveys Across the UK

Asbestos hazards in construction are not limited to any one region — the legacy of pre-2000 construction affects every city and county in the UK. However, the density of older building stock in major urban areas means that construction teams working in cities face a particularly high likelihood of encountering ACMs.

If you are managing a construction project in the capital, our asbestos survey London service covers the full range of survey types across all London boroughs. For projects in the North West, our asbestos survey Manchester team provides the same standard of UKAS-accredited surveying across Greater Manchester and the surrounding area.

Wherever your project is located, the same legal obligations apply and the same standard of survey is required. Do not assume that regional variation in building stock changes your duty of care — it does not.

What Happens If Asbestos Is Discovered Unexpectedly on Site?

Despite best efforts at the planning stage, unexpected discoveries do occur — particularly in older buildings where previous surveys were incomplete or where records have been lost. When this happens, the response must be immediate and controlled.

The correct procedure is:

  1. Stop work immediately in the affected area and prevent access
  2. Do not disturb the material further — leave it as found
  3. Notify the principal contractor and site manager without delay
  4. Arrange for a qualified surveyor to inspect and sample the suspect material
  5. Await laboratory results before any further work proceeds in the area
  6. If exposure has occurred, report the incident under RIDDOR and seek occupational health advice for affected workers

Do not rely on visual identification alone. Many materials that do not look like asbestos contain it, and many that appear suspicious do not. Only laboratory analysis provides a definitive answer.

The temptation to press on with a programme and deal with the paperwork later is understandable — but it is precisely the kind of decision that leads to enforcement action, prosecution, and, most seriously, preventable harm to workers.

Frequently Asked Questions

Do I need an asbestos survey before every construction project?

If the building was constructed or refurbished before the year 2000, a suitable asbestos survey is legally required before any refurbishment, demolition, or intrusive construction work begins. The type of survey required — management, refurbishment, or demolition — depends on the nature of the work. For new-build projects on greenfield sites with no pre-existing structures, a survey is not required, but any demolition of existing buildings on the site must be surveyed first.

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

A management survey is designed for buildings in normal occupation and identifies ACMs that could be disturbed during routine maintenance. A refurbishment survey is more intrusive and is required before any work that will disturb the building fabric — it accesses all areas affected by the planned works and must be completed before work starts. The two surveys serve different purposes and one cannot substitute for the other.

Who is responsible for managing asbestos hazards on a construction site?

Responsibility is shared across the project team under both the Control of Asbestos Regulations and CDM. The duty holder or building owner is responsible for providing accurate asbestos information before work begins. The principal contractor is responsible for ensuring that information is communicated to all relevant parties and that appropriate controls are in place during the works. Designers also have a duty to consider asbestos risks during the design phase and eliminate or reduce them where possible.

Can construction workers carry out asbestos removal themselves?

Most significant asbestos removal work requires a contractor licensed by the HSE. Licensed work covers asbestos insulating board, asbestos insulation, and sprayed asbestos coatings, among others. Some lower-risk, short-duration tasks may be carried out as non-licensed work, but even these require appropriate training, RPE, and controlled working methods. Unlicensed workers carrying out licensed work face serious legal consequences, and the health risks to those workers are equally severe.

What should I do if asbestos is found unexpectedly during construction?

Stop work immediately in the affected area, prevent access, and do not disturb the material further. Notify the principal contractor and arrange for a qualified surveyor to inspect and sample the suspect material. Await laboratory confirmation before resuming work in the area. If workers may have been exposed, report the incident under RIDDOR and arrange occupational health support. Pressing on without confirmation is both illegal and potentially life-threatening.

Speak to Supernova Asbestos Surveys

Supernova Asbestos Surveys has completed over 50,000 surveys nationwide, working with construction companies, developers, principal contractors, and building owners across the UK. Our UKAS-accredited surveyors provide management surveys, refurbishment surveys, demolition surveys, re-inspection surveys, asbestos testing, and removal support — everything your project needs to manage asbestos hazards in construction safely and in full legal compliance.

Whether you are at the design stage, about to break ground, or dealing with an unexpected discovery on site, we can help. Call us on 020 4586 0680 or visit asbestos-surveys.org.uk to arrange a survey or speak to one of our team.