Before Carrying Out Any Work in a 1960s Non-Domestic Building, the Duty Holder Should Follow This Process
If you manage or own a non-domestic building constructed in the 1960s, asbestos is almost certainly present somewhere inside it. Before carrying out any work in a 1960s non-domestic building, the duty holder should follow a clear, legally mandated process — one that protects workers, occupants, and the wider public from one of the UK’s most serious occupational health hazards.
This is not discretionary. The Control of Asbestos Regulations places a legal duty on those responsible for non-domestic premises to identify, assess, and manage asbestos-containing materials (ACMs). Get it wrong and the consequences range from enforcement action and unlimited fines to life-altering illness for the people working in your building.
Here is exactly what you need to know — and do — before a single tool is picked up.
Why 1960s Buildings Carry Such High Asbestos Risk
The 1960s were arguably the peak decade for asbestos use in UK construction. Asbestos was cheap, fire-resistant, thermally insulating, and acoustically effective. Builders, architects, and developers used it liberally across commercial, industrial, and public sector projects.
By the time the full health picture became undeniable, asbestos had been woven into the fabric of an entire generation of buildings. The UK did not ban all forms of asbestos until 1999, meaning any building constructed or refurbished before that date may contain ACMs.
In 1960s non-domestic buildings specifically, you are likely to encounter asbestos in:
- Ceiling tiles and floor tiles
- Pipe and boiler lagging
- Sprayed coatings on structural steelwork
- Insulating board used in partition walls, ceiling panels, and fire doors
- Roof sheets and soffit boards
- Textured coatings on walls and ceilings
- Gaskets and rope seals in plant rooms
- Bitumen products and adhesives
Some of these materials are obvious. Many are not. That is precisely why a professional survey is the mandatory starting point before any work begins.
The Legal Duty: What the Control of Asbestos Regulations Requires
The Control of Asbestos Regulations set out a clear framework for managing asbestos in non-domestic premises. The duty to manage under Regulation 4 applies to anyone who has responsibility for the maintenance or repair of non-domestic premises — whether as an owner, landlord, facilities manager, or employer.
Regulation 5 is particularly relevant before any work begins. It requires that before maintenance, repair, or any other work is carried out, the duty holder must find out whether asbestos is present, where it is, and what condition it is in. You cannot assume. You must know.
The HSE’s guidance document HSG264 — Asbestos: The Survey Guide — provides the definitive standard for how asbestos surveys should be conducted. Every reputable surveying firm works to this standard, and any survey that does not comply with HSG264 is not fit for purpose.
Failure to comply with the Control of Asbestos Regulations can result in:
- Prohibition notices stopping all work on site
- Improvement notices requiring remedial action
- Unlimited fines in the Crown Court
- Criminal prosecution of duty holders and directors
- Civil liability for any harm caused to workers or occupants
Step One: Commission the Right Type of Asbestos Survey
Not all asbestos surveys are the same. The type of survey you need depends entirely on what work is planned. Getting this wrong wastes money and leaves you legally exposed.
Management Survey
A management survey is the baseline requirement for any non-domestic building. It is designed to locate ACMs that could be disturbed during normal occupation, routine maintenance, and minor works. It is not intrusive — the surveyor works within the normal fabric of the building without breaking into concealed areas.
Every non-domestic building built before 2000 should have a current, valid management survey in place. If yours does not, that is the first thing to rectify before any work is planned or commissioned.
Refurbishment Survey
If you are planning any renovation, fit-out, or refurbishment work, a refurbishment survey is legally required before work starts in the affected area. This is an intrusive survey — the surveyor accesses voids, breaks into substrates, and inspects areas that will be disturbed by the planned works.
A management survey is not sufficient before refurbishment. This is a common and costly mistake made by duty holders who assume their existing survey covers them. It does not.
Demolition Survey
Before any demolition work takes place — whether partial or full — a demolition survey must be completed. This is the most thorough and intrusive type of survey, designed to locate all ACMs in the entire structure so they can be removed prior to demolition.
It requires destructive access and must cover the whole building. Under the Control of Asbestos Regulations, asbestos must be removed before demolition begins wherever it is reasonably practicable to do so. A demolition survey provides the evidence base for that removal programme.
Step Two: Establish or Update Your Asbestos Register
Once a survey has been completed, the results must be compiled into an asbestos register. This is a live document that records the location, type, condition, and risk rating of every ACM identified in the building.
The asbestos register must be:
- Kept on site and readily accessible at all times
- Made available to any contractor or worker before they start work
- Updated whenever new ACMs are found or existing ones are disturbed or removed
- Reviewed regularly as part of your asbestos management plan
If your building has had a previous survey but it is more than a few years old, or if works have been carried out since it was completed, you may need a re-inspection survey to verify that the register remains accurate and that the condition of known ACMs has not deteriorated.
Do not assume an old survey still reflects the current state of the building. Materials degrade, building works disturb previously stable ACMs, and new areas may have been opened up since the last inspection was carried out.
Step Three: Arrange Professional Asbestos Testing Where Required
Sometimes a surveyor will identify materials that are suspected to contain asbestos but cannot be confirmed by visual inspection alone. In these cases, bulk samples are taken and sent to a UKAS-accredited laboratory for analysis under polarised light microscopy.
Professional asbestos testing provides the definitive answer. Without confirmed laboratory results, you cannot make informed decisions about risk management, and any contractor who disturbs unconfirmed material is operating without adequate information.
For smaller-scale situations where a full survey is not yet in place, a postal testing kit can allow samples to be collected and submitted for laboratory analysis. However, sample collection must only be carried out by someone who is competent to do so safely — disturbing a suspect material without proper precautions can release fibres and create the very risk you are trying to assess.
You can find further detail about your options through Supernova’s dedicated asbestos testing page, which outlines the full range of sampling and laboratory services available across the UK.
Step Four: Develop and Implement an Asbestos Management Plan
A survey and register alone are not enough. The Control of Asbestos Regulations require duty holders to put in place an asbestos management plan — a written document that sets out how ACMs in the building will be managed, monitored, and controlled over time.
A robust asbestos management plan should include:
- Details of all ACMs identified, cross-referenced with the asbestos register
- A risk assessment for each ACM, taking into account its type, condition, and likelihood of disturbance
- Decisions on whether each ACM will be managed in situ, encapsulated, or removed
- Procedures for informing contractors and workers about ACM locations before any work begins
- Emergency procedures in the event of accidental disturbance
- A schedule for regular re-inspection of ACMs to monitor condition changes
- Records of all actions taken, including any removal or remediation work
The plan must be reviewed and updated whenever circumstances change — including after any work that affects ACMs, after a re-inspection, or when new materials are discovered. It is a living document, not a one-time exercise.
Step Five: Ensure Contractors Are Informed and Competent
Before carrying out any work in a 1960s non-domestic building, the duty holder should ensure that every contractor entering the building has been shown the asbestos register and management plan. This is a legal requirement, not a professional courtesy.
Contractors must be made aware of:
- The location of all known ACMs in the areas where they will be working
- The condition of those materials and the risk they present
- What they must do if they encounter a material they suspect may contain asbestos
- The emergency procedures in place if an accidental disturbance occurs
Regulation 10 of the Control of Asbestos Regulations also requires that anyone liable to disturb asbestos during their work receives appropriate training. This applies to maintenance workers, tradespeople, and any other personnel who may encounter ACMs in the course of their duties.
For higher-risk work — including work with sprayed coatings, asbestos insulating board, or pipe lagging — only licensed contractors holding a current HSE licence may carry out the removal. Using an unlicensed contractor for licensable work is a serious criminal offence that carries significant penalties for the duty holder as well as the contractor.
Step Six: Plan for Safe Asbestos Removal Where Necessary
Not every ACM needs to be removed immediately. In many cases, ACMs in good condition and unlikely to be disturbed are best managed in situ. However, where refurbishment or demolition is planned, asbestos removal before work begins is usually the safest and most legally compliant approach.
Professional removal must be carried out by competent contractors using appropriate control measures, including:
- Full personal protective equipment (PPE) and respiratory protective equipment (RPE)
- Sealed and sheeted work areas with negative air pressure containment where required
- Wet removal techniques to suppress fibre release
- HEPA-filtered vacuuming for clean-up
- Air monitoring during and after removal to confirm the area is safe
- Correct disposal of asbestos waste — double-bagged, labelled, and transported to a licensed hazardous waste facility
All asbestos waste disposal is governed by the Environmental Protection Act and associated hazardous waste regulations. Asbestos cannot be placed in general waste streams under any circumstances.
Do Not Overlook Your Fire Risk Assessment
Asbestos management and fire safety are closely linked in older non-domestic buildings. Many fire-resistant materials used in 1960s construction — including fire doors, ceiling panels, and structural coatings — may contain asbestos.
Any fire risk assessment for a pre-2000 building should be conducted with full awareness of where ACMs are located. Fire damage or suppression activities can disturb asbestos and create a secondary exposure risk that compounds an already serious incident.
Ensure your fire risk assessor has access to the asbestos register before their inspection, and that any fire safety works planned for the building are assessed for potential ACM disturbance before they begin. The two disciplines must be coordinated, not treated in isolation.
A Practical Checklist for Duty Holders
Before carrying out any work in a 1960s non-domestic building, the duty holder should work through the following checklist:
- Confirm whether a valid asbestos survey is in place — if not, commission one before any work starts
- Identify the correct survey type — management, refurbishment, or demolition depending on the scope of works
- Review the asbestos register — check whether the areas affected by the planned works are covered
- Arrange a re-inspection or additional testing if the existing survey is out of date or incomplete
- Update the asbestos management plan to reflect the planned works and any new findings
- Brief all contractors on ACM locations, risks, and emergency procedures before they set foot on site
- Verify that contractors carrying out licensable work hold a current HSE licence
- Confirm that asbestos removal — where required — is completed and signed off before other trades begin
- Ensure waste disposal documentation is in order and retained for your records
- Coordinate with your fire risk assessor if fire safety works form part of the project
If you are based in the capital and need support with any stage of this process, Supernova provides a full range of services through its asbestos survey London team, covering all survey types, testing, and management planning.
What Happens If You Get It Wrong
The consequences of failing to follow the correct process before work begins in a 1960s non-domestic building are severe — and they fall squarely on the duty holder.
From a legal standpoint, the HSE has the power to issue prohibition notices that halt all work immediately, issue improvement notices, and bring criminal prosecutions against individuals as well as organisations. Courts have handed down substantial fines and custodial sentences in cases involving serious asbestos breaches.
From a health standpoint, the consequences can be far worse. Asbestos-related diseases — including mesothelioma, asbestosis, and asbestos-related lung cancer — have a latency period of 20 to 40 years. Workers exposed today may not develop symptoms until decades later, by which time nothing can be done to reverse the damage. There is no safe level of exposure to asbestos fibres.
The duty holder who failed to follow the correct process will not be able to claim ignorance as a defence. The legal obligations are clearly set out in the Control of Asbestos Regulations and supported by extensive HSE guidance. Compliance is not complicated — it simply requires following the right steps in the right order.
Frequently Asked Questions
Before carrying out any work in a 1960s non-domestic building, the duty holder should do what first?
The first step is to establish whether a valid, up-to-date asbestos survey is in place for the building. If one does not exist, or if it does not cover the areas affected by the planned works, a survey must be commissioned before any work begins. The type of survey required — management, refurbishment, or demolition — depends on the nature and scope of the work planned.
Is asbestos definitely present in a 1960s non-domestic building?
Not every 1960s building will contain asbestos in every location, but the risk is extremely high. Asbestos use was widespread in UK construction throughout the 1960s and was not fully banned until 1999. Any non-domestic building constructed or significantly refurbished before 2000 must be treated as potentially containing ACMs until a professional survey confirms otherwise.
Can a management survey cover a refurbishment project?
No. A management survey is designed to identify ACMs that could be disturbed during normal occupation and routine maintenance. It is not intrusive and does not access concealed voids or substrates. Before any refurbishment work begins, a dedicated refurbishment survey must be carried out in the affected areas. Using a management survey to authorise refurbishment work is a common mistake that leaves duty holders legally exposed.
What is the duty holder’s responsibility regarding contractors and asbestos?
Under the Control of Asbestos Regulations, duty holders must provide contractors with access to the asbestos register and management plan before any work begins. Contractors must be made aware of the location and condition of all known ACMs in their working areas. For licensable asbestos work — such as removal of sprayed coatings, asbestos insulating board, or pipe lagging — only contractors holding a current HSE licence may carry out the work.
How often should an asbestos register be updated?
The asbestos register is a live document and should be updated whenever new ACMs are identified, existing materials are disturbed or removed, or the condition of known ACMs changes. In addition, a formal re-inspection of all ACMs should be carried out at regular intervals — typically annually, though higher-risk materials may require more frequent monitoring. An out-of-date register does not satisfy the legal duty to manage asbestos under the Control of Asbestos Regulations.
Get Expert Support from Supernova Asbestos Surveys
Supernova Asbestos Surveys has completed over 50,000 surveys across the UK, helping duty holders in every sector meet their legal obligations with confidence. Whether you need a management survey for an occupied 1960s office block, a refurbishment survey ahead of a fit-out, or a full demolition survey before a site is cleared, our accredited surveyors deliver results you can rely on.
We also provide asbestos testing, re-inspection surveys, management planning support, and fire risk assessments — everything you need to manage asbestos safely throughout the lifecycle of your building.
Call us on 020 4586 0680 or visit asbestos-surveys.org.uk to discuss your requirements with our team today.