What You Must Do Before Any Asbestos Work Begins
Asbestos notification requirements before work are not optional formalities — they are legal duties that protect workers, building users, and the public from one of the UK’s most dangerous workplace hazards. Get them wrong, and you risk enforcement action, unlimited fines, and — far more seriously — irreversible harm to people’s health.
Whether you manage a commercial property, run a construction firm, or are responsible for a school or public building, understanding what to notify, when, and to whom is non-negotiable. This post breaks it all down clearly so you can act with confidence.
Why Notification Exists: The Legal Framework
The Control of Asbestos Regulations requires dutyholders and employers to notify the relevant enforcing authority before certain types of asbestos work begin. This sits within a broader framework of legislation designed to eliminate preventable asbestos-related diseases — conditions like mesothelioma, asbestosis, and lung cancer that can take decades to develop but are directly linked to fibre inhalation.
Asbestos was used extensively in UK construction until it was fully banned in 1999. Any building constructed or refurbished before that date may contain asbestos-containing materials (ACMs). You cannot identify ACMs by sight alone — only a professional survey followed by laboratory analysis can confirm their presence.
The Health and Safety Executive (HSE) is the primary enforcing authority for most workplaces. For certain sites, enforcement falls to the Local Authority (LA) or the Office of Rail and Road (ORR). Knowing which body oversees your site matters, because that is where your notification must go.
The Three Categories of Asbestos Work
Before you can understand notification requirements, you need to know which category of asbestos work applies to your situation. The Control of Asbestos Regulations divides work into three distinct types, each carrying different legal obligations.
Licensed Work
Licensed work involves the highest-risk asbestos activities. Only contractors holding a licence issued by the HSE may carry out this work. It typically includes:
- Removing or repairing asbestos insulating board (AIB)
- Stripping loose fill insulation
- Working with pipe lagging or thermal insulation containing asbestos
- Handling asbestos millboard or sprayed coatings
These materials release high concentrations of fibres when disturbed. The risk to health is severe and immediate without the correct controls, equipment, and training.
Notifiable Non-Licensed Work (NNLW)
Some asbestos tasks do not require a licence but still carry enough risk to require notification. This category — known as Notifiable Non-Licensed Work (NNLW) — includes shorter duration tasks with lower-risk ACMs, such as:
- Disturbing textured decorative coatings like Artex
- Replacing asbestos gaskets or rope seals
- Minor work on asbestos cement products
- Short-duration maintenance tasks involving ACMs
NNLW still demands formal notification, medical surveillance, and detailed record-keeping. It is not a lighter-touch regime — it simply covers a different risk profile.
Non-Licensed Work
Certain very low-risk tasks involving ACMs in good condition may be carried out without a licence and without notification. However, a risk assessment is still required, and workers must be trained. This category is narrower than many people assume — if in doubt, treat the work as NNLW or seek professional advice.
Asbestos Notification Requirements Before Work: Licensed Jobs
For any licensed asbestos work, employers must submit a formal notification to the enforcing authority — HSE, LA, or ORR — at least 14 days before work begins. This is a hard deadline, not a guideline. Starting work before the notice period expires is a breach of the regulations.
The ASB5 Form
The ASB5 form is the official notification document for licensed asbestos work. It must be submitted online through the HSE portal. Postal or telephone notifications are not accepted for this purpose.
Your ASB5 submission must include:
- The name and licence number of the asbestos removal contractor
- The full address of the site where work will take place
- A clear description of the work, including which ACMs are involved
- The planned start date and expected duration
- The number of workers on each shift
- Details of the analytical organisation carrying out clearance air monitoring
- Whether the notification is new or an update to a previous submission
Once submitted, you will receive a notification number and a PDF confirmation. Keep both — they are your proof of compliance and may be requested during inspections or audits.
Before completing the ASB5, a full site survey must already be in place. Notifying without knowing what ACMs are present is not compliant — the notification must reflect accurate, surveyed information. If you need a management survey carried out before work proceeds, Supernova Asbestos Surveys can arrange this quickly and professionally.
What Happens After You Notify
The enforcing authority reviews your notification. HSE or LA inspectors may contact you with questions, request additional documentation, or visit the site. In some cases, they may object to the proposed method of work. This is why your plan of work and risk assessment must be thorough and accurate before you submit.
If your scope changes significantly after submission — more ACMs discovered, a different removal method required, an extended timeline — you must re-notify. Submit an updated ASB5 form and treat it as a new notification. Do not assume the original notice still covers you.
Notification for Notifiable Non-Licensed Work (NNLW)
The asbestos notification requirements before work in the NNLW category follow a slightly different process. There is no fixed 14-day notice period, but the notification must be received by the enforcing authority before work starts. Leaving it until the morning of the job is not acceptable practice.
NNLW notifications are submitted online using the dedicated NNLW notification form — not the ASB5. Telephone and postal submissions are not accepted here either.
A single notification can cover multiple tasks within one project, provided all the work falls within the same scope and follows the agreed plan of work. If the scope changes, update your notification accordingly.
Medical Surveillance for NNLW Workers
Every worker who regularly carries out NNLW must undergo medical examination by a licensed medical practitioner. The first examination must be completed before the worker begins NNLW, and subsequent examinations are required at least every three years while NNLW continues.
Doctors issue a certificate after each examination. Employers must keep these certificates for at least four years from the date of issue. The cost of medical surveillance is the employer’s responsibility — agree fees with the clinic or practitioner in advance.
Documentation and Record-Keeping
Notification is only one part of the compliance picture. The Control of Asbestos Regulations also requires detailed documentation before, during, and after any work involving ACMs.
The Plan of Work
Before licensed or NNLW begins, a written plan of work must be prepared. This document sets out:
- The nature and likely duration of the work
- The location of all ACMs to be disturbed
- The methods to be used for removal, encapsulation, or repair
- The controls in place to prevent fibre release
- Arrangements for decontamination and waste disposal
- Emergency procedures
The plan of work is a live document. If conditions on site change — new ACMs are found, methods need to change — update the plan and brief the team before proceeding.
Health Records
Employers must maintain a health record for every worker who performs NNLW. Each record must include:
- The worker’s name and date of birth
- Dates and types of tasks carried out
- Estimated duration of exposure for each task
- The ACMs involved — for example, textured coatings, gaskets, or AIB
- Dates of medical examinations and certificate references
These records must be retained for 40 years. Asbestos-related diseases have long latency periods, and health records may be needed decades after the work took place to support medical investigations or legal proceedings.
Risk Assessments and Exposure Estimates
A written risk assessment is required before any work with ACMs begins. It must identify the hazards, assess the likelihood and severity of exposure, and set out the controls in place. For NNLW, air monitoring is not always mandatory, but exposure estimates must still be recorded.
Where air monitoring is carried out, results must be retained. The Control of Asbestos Regulations sets a workplace exposure limit of 0.1 fibres per cubic centimetre, averaged over four hours. Any result approaching or exceeding this limit requires immediate review of controls.
Informing Building Users Before Work Starts
Notification to the enforcing authority is one obligation. Communicating with building users is another — and it is equally important for safety.
Before any asbestos work begins, everyone who uses or occupies the affected areas must be informed. This includes staff, tenants, contractors, and visitors. The information should cover:
- Which areas are affected and what ACMs are present
- What work is being carried out and why
- Which zones are restricted and who may enter
- What personal protective equipment is required in or near the work area
- The health risks from asbestos fibre inhalation
- Who to contact with questions or concerns
Clear warning signs must be posted in all affected areas and must remain in place for the full duration of the work. This applies whether the work is licensed or NNLW. Accidental disturbance by an uninformed cleaner or maintenance operative can cause serious harm and significant legal liability.
Good communication also protects you. If an incident occurs and you cannot demonstrate that building users were properly informed, the consequences — both legal and reputational — can be severe.
Before You Notify: Get the Survey Right
The most common mistake made before asbestos work is proceeding without an adequate survey. Notification forms and risk assessments are only as good as the information underpinning them. If you do not know exactly where ACMs are located, what type they are, and what condition they are in, you cannot complete a compliant notification.
HSG264 — the HSE’s guidance on asbestos surveys — sets out the standards that surveys must meet. A refurbishment and demolition survey is required before any intrusive work that may disturb the fabric of a building. A management survey is appropriate for ongoing management of ACMs in occupied premises.
For properties across the UK, Supernova Asbestos Surveys provides accredited survey services. If you are based in the capital, our asbestos survey London service covers the full metropolitan area. We also operate across the Midlands — our asbestos survey Birmingham team is ready to mobilise quickly — and in the North West, where our asbestos survey Manchester service supports clients across Greater Manchester and beyond.
Once the survey is complete and ACMs are confirmed, you are in a position to commission a licensed contractor, prepare your plan of work, and submit your notification with confidence.
When Asbestos Must Be Removed
Not all ACMs need to be removed immediately. In many cases, ACMs in good condition and unlikely to be disturbed can be safely managed in place. However, where refurbishment or demolition is planned, or where ACMs are damaged and pose an ongoing risk, removal is the appropriate course of action.
Only HSE-licensed contractors may carry out licensable asbestos removal work. Attempting to remove high-risk ACMs without a licence is a criminal offence. Always verify that your contractor holds a current HSE licence before work begins — you can check this on the HSE website.
Following removal, a clearance inspection and four-stage clearance procedure must be completed before the area is reoccupied. This includes a thorough visual inspection and air monitoring carried out by an independent analyst. Do not allow reoccupation until a certificate of reoccupation has been issued.
Employer Responsibilities: A Practical Summary
If you are an employer or dutyholder, your responsibilities under the Control of Asbestos Regulations are clear. Here is a practical checklist to work through before any asbestos work begins:
- Commission a survey — ensure an accredited surveyor has inspected the building and produced a written report identifying all ACMs.
- Assess the risk — prepare a written risk assessment based on the survey findings.
- Prepare a plan of work — document the methods, controls, and emergency procedures for the job.
- Appoint a licensed contractor — for licensable work, verify HSE licence status before engaging anyone.
- Submit notification — ASB5 for licensed work (at least 14 days before start); NNLW form for notifiable non-licensed work (before work starts).
- Inform building users — post signs, restrict access, and communicate clearly with all occupants.
- Arrange medical surveillance — for NNLW workers, ensure examinations are booked and records are maintained.
- Keep records — retain health records for 40 years; medical certificates for four years; notification confirmations indefinitely.
- Monitor and update — if scope changes, re-notify and update the plan of work before proceeding.
Frequently Asked Questions
What are the asbestos notification requirements before work for licensed jobs?
For licensed asbestos work, employers must submit an ASB5 form to the relevant enforcing authority — HSE, Local Authority, or Office of Rail and Road — at least 14 days before work begins. The form must include details of the contractor, the site, the ACMs involved, the planned start date, the number of workers, and the analytical organisation carrying out clearance monitoring.
Do I need to notify anyone before notifiable non-licensed work (NNLW)?
Yes. NNLW must be notified to the enforcing authority using the online NNLW notification form before work starts. There is no fixed minimum notice period, but the notification must be received before the work begins. A single notification can cover multiple tasks within one project if they fall within the same scope and plan of work.
How long must health records for asbestos workers be kept?
Health records for workers who carry out notifiable non-licensed work must be retained for 40 years from the date the records were made. Medical examination certificates must be kept for at least four years from the date of issue. Both sets of records may be requested by the enforcing authority during inspections.
Can I carry out asbestos work without a survey?
No. A survey is a prerequisite for any work that may disturb ACMs. Without survey data, you cannot complete a compliant risk assessment, plan of work, or notification form. HSG264 sets out the standards for asbestos surveys in the UK. A refurbishment and demolition survey is required before intrusive work; a management survey supports ongoing ACM management in occupied premises.
What happens if I fail to notify before asbestos work starts?
Failing to notify the enforcing authority before licensed or notifiable non-licensed asbestos work is a breach of the Control of Asbestos Regulations. This can result in enforcement notices, improvement notices, prohibition of work, prosecution, and unlimited fines. In serious cases, individuals — not just companies — can face criminal liability. The health consequences of non-compliant asbestos work can also result in civil claims from affected workers or building users.
Get Expert Support from Supernova Asbestos Surveys
Meeting your asbestos notification requirements before work starts is straightforward when you have the right survey data and the right team behind you. Supernova Asbestos Surveys has completed over 50,000 surveys across the UK, working with property managers, contractors, local authorities, and businesses of every size.
We provide accredited management surveys, refurbishment and demolition surveys, asbestos testing, and removal support — everything you need to move from initial assessment to compliant, safe completion. Get a free quote online today, or call our team directly on 020 4586 0680. You can also visit us at asbestos-surveys.org.uk to learn more about our services and locations nationwide.
Do not wait until work is already planned to think about asbestos. The earlier you act, the smoother the process — and the safer everyone on site will be.