Why Factories and Manufacturing Sites Face Unique Asbestos Risks
If your factory or manufacturing facility was built or refurbished before 2000, asbestos-containing materials (ACMs) are almost certainly present somewhere in the building fabric. An asbestos survey for factories and manufacturing sites is not just best practice — it is a legal requirement under the Control of Asbestos Regulations, and getting it right is the foundation of everything that follows.
Industrial buildings present challenges that residential or light commercial properties simply do not. Large floor plates, complex service runs, plant rooms, roof voids, and decades of piecemeal maintenance all create conditions where ACMs can be hidden, disturbed, or poorly documented.
Asbestos was used extensively in UK industrial construction — in pipe lagging, sprayed coatings, insulation boards, roofing sheets, floor tiles, and fire-resistant panels. The scale of exposure risk in a busy manufacturing environment is significant. Understanding what type of survey you need, how to prepare your site, and what to do with the results is essential for any dutyholder managing an industrial property.
Your Legal Duties as a Dutyholder
The Control of Asbestos Regulations place a clear legal duty on those who manage non-domestic premises — including factories and manufacturing facilities — to identify, assess, and manage any asbestos present. This is known as the “duty to manage” and it applies to owners, employers, and anyone with contractual or practical responsibility for maintaining the building.
Failure to comply is not a minor administrative matter. It can result in enforcement action from the Health and Safety Executive (HSE), substantial fines, and — most critically — serious harm to the workers and contractors who rely on you to keep them safe.
HSG264, the HSE’s guidance document for asbestos surveys, sets out the standards that surveyors must follow. Any survey you commission should align with this guidance and be carried out by appropriately qualified, UKAS-accredited surveyors.
Your obligations as a dutyholder include:
- Identifying the location and condition of all ACMs in your premises
- Maintaining an up-to-date asbestos register
- Producing and implementing an asbestos management plan
- Sharing information with anyone who may disturb ACMs — contractors, maintenance staff, and others
- Arranging regular reinspections to monitor the condition of known ACMs
These are ongoing obligations, not a one-off exercise. The duty to manage asbestos continues for as long as the building is in use.
The Three Types of Asbestos Survey for Industrial Sites
Choosing the right type of survey matters. Using the wrong one can leave you legally exposed and, more importantly, can put workers at serious risk. Here is what each survey involves and when you need it.
Asbestos Management Survey
A management survey is the standard survey for premises in normal occupation and use. Its purpose is to identify ACMs that could be disturbed during everyday activities or routine maintenance, forming the basis of your asbestos register and management plan.
For factories and manufacturing sites, this typically covers accessible areas including offices, welfare facilities, plant rooms, roof spaces, and production floor structures. Surveyors will take samples of suspect materials for laboratory analysis, assess the condition of any ACMs found, and assign a risk priority score to each one.
The report will tell you whether each ACM should be managed in place, monitored, or removed. Areas that cannot be accessed are presumed to contain asbestos until proven otherwise — a presumption that must be recorded in your register.
You should commission an asbestos management survey before occupying a new industrial premises, when no previous survey records exist, or when existing records are out of date or incomplete.
Asbestos Refurbishment Survey
If you are planning any building work — installing new equipment, upgrading services, modifying the production floor layout, or carrying out significant maintenance — you need an asbestos refurbishment survey before work starts.
This is a more intrusive process than a management survey. Surveyors will open up walls, lift floor coverings, break into ceiling voids, and access any areas that will be disturbed during the planned works. The aim is to locate all ACMs in those specific zones so they can be removed or made safe before contractors move in.
A refurbishment survey is scoped to the area of planned work, not the whole building. If you are refitting a production line in one section of the factory, the survey covers that zone. This keeps the process proportionate while ensuring workers are fully protected.
Do not rely on an existing management survey for refurbishment work. The two serve different purposes, and using the wrong one puts workers at risk and may leave you in breach of the regulations.
Asbestos Demolition Survey
Before any building or structure is demolished, a full asbestos demolition survey must be completed. This is the most thorough type of survey, involving fully intrusive and, where necessary, destructive access to every part of the building fabric.
The purpose is to locate every ACM in the structure so that all asbestos can be removed before demolition begins. Releasing asbestos fibres during uncontrolled demolition is an extremely serious health hazard and a significant legal liability.
A demolition survey must be carried out by UKAS-accredited surveyors. The findings must be acted on before any demolition contractor starts work, and the report will include detailed plans showing the location and extent of all ACMs, informing the asbestos removal programme that follows.
Preparing Your Factory for an Asbestos Survey
A well-prepared site produces a more efficient survey and a more accurate report. The steps you take before the surveyors arrive directly affect the quality of the information you receive.
Gather Existing Documentation
Pull together everything you have relating to the building’s history and condition. Even incomplete records are useful — they give surveyors context about the building’s construction history and help them prioritise areas of concern.
Useful documents include:
- Original building plans, drawings, and layout documents
- Previous asbestos survey reports and reinspection records
- Maintenance logs, repair histories, and contractor records
- Any existing asbestos register, even if incomplete or out of date
- Results from previous asbestos testing or air monitoring exercises
- Records of any previous remediation or removal work
Communicate With Staff and Contractors
Everyone on site needs to know a survey is taking place. Under the Control of Asbestos Regulations, you have a legal obligation to share asbestos-related information with those who may be affected.
Notify employees in advance, explaining which areas will be surveyed, what access restrictions will apply, and who to contact with questions. Brief any contractors or maintenance staff working on site during the survey period and post clear notices in affected areas.
Encourage staff to flag any areas they have noticed that look damaged or suspect. Workers often have knowledge of the building that does not appear in any formal records — and that information can be genuinely valuable to the surveying team.
Ensure Full Access
Surveyors can only report on what they can access. If plant rooms are locked, roof voids are inaccessible, or certain production areas cannot be entered during a shift, the survey will have gaps — and those gaps become presumed ACMs until they are properly assessed.
Arrange for keys, access codes, and any necessary permits to work to be available on the day. If access to certain areas requires a shutdown or shift change, plan this in advance with the surveying company.
What Happens During the Survey
Understanding what surveyors actually do on the day helps you support the process and interpret the results with confidence.
Visual Inspection and Sampling
Surveyors begin with a systematic visual inspection of all accessible areas, working through the building in a structured sequence. They are looking for materials known to have contained asbestos — pipe lagging, sprayed coatings, ceiling tiles, floor tiles, textured coatings, gaskets, roofing sheets, and many others.
Where a material is suspected to contain asbestos, surveyors take a small sample using controlled methods — typically a core borer or scalpel — collecting the material in a sealed, labelled bag. Sampling points are numbered and recorded on site plans.
The sample collection process is carried out carefully to minimise fibre release, and any disturbed surfaces are immediately sealed. Surveyors wear appropriate PPE throughout, including half-mask P3 respirators, disposable coveralls, gloves, and protective footwear. For intrusive surveys, additional controls are put in place to contain any fibres released during sampling.
Laboratory Analysis
All samples are sent to a UKAS-accredited laboratory for analysis. The lab identifies whether asbestos is present and, if so, which type — chrysotile (white), amosite (brown), or crocidolite (blue). Each type carries different risk profiles, though all are hazardous and none should be treated as safe.
If you have a specific concern about a single suspect material rather than requiring a full survey, standalone asbestos testing can be arranged. This is a cost-effective way to get clarity on a particular item quickly without commissioning a full survey.
Results are typically returned within a few working days. Positive results are reported as the type and percentage of asbestos identified. Where no asbestos is detected, the result is recorded as NAD — No Asbestos Detected.
The Survey Report
Once sampling and analysis are complete, your surveying company will produce a full written report. For factories and manufacturing sites, this should include:
- An executive summary of key findings
- A room-by-room or zone-by-zone breakdown of all materials assessed
- Photographs of each material and sampling point
- Laboratory certificates of analysis
- A risk assessment score for each ACM based on its type, condition, and accessibility
- Clear action recommendations — manage in place, monitor, or remove
- Site plans showing ACM locations
- A record of any areas not accessed, presumed to contain asbestos
This report forms the basis of your asbestos register. It is a live document — it must be updated whenever new information becomes available, whether from a reinspection, additional sampling, or removal work.
Acting on Your Survey Results
Receiving the report is not the end of the process. You now have a legal and moral obligation to act on what it tells you.
Prioritising Risk
Not all ACMs require immediate removal. Many materials in good condition, located where they are unlikely to be disturbed, can be safely managed in place. Your survey report will assign a priority score to each ACM, and this guides your response.
High-priority materials — those in poor condition or in areas where disturbance is likely — need prompt attention. Lower-priority materials may simply require monitoring through a reinspection survey carried out at regular intervals, typically annually.
Your asbestos management plan should set out clearly who is responsible for each ACM, what action is required, and by when. This plan must be kept up to date and shared with anyone who may work on or near the identified materials.
When Asbestos Removal Is Necessary
Where removal is required — because a material is in poor condition, is at risk of disturbance, or because building work is planned — you must use appropriately licensed contractors. Asbestos removal in industrial settings is tightly regulated under the Control of Asbestos Regulations.
Licensed contractors must notify the HSE before starting notifiable work, use appropriate enclosures and air filtration equipment, and carry out clearance air testing before the area is handed back. The type of licence required depends on the material being removed — not all asbestos work requires a licensed contractor, but the most hazardous materials always do.
Never attempt to remove asbestos yourself or instruct untrained workers to do so. The consequences — for health, for your workforce, and for your legal position — are severe.
Keeping Your Register Current
An asbestos register is only as useful as it is accurate. Every time work is carried out that affects an ACM — whether it is removed, encapsulated, or disturbed — the register must be updated to reflect the change.
New tenants, new contractors, and new maintenance staff should be made aware of the register’s existence and location. In a busy manufacturing environment, where the workforce and the building’s use can change frequently, keeping this information accessible and current is a practical safety measure, not just a compliance tick-box.
Common Asbestos-Containing Materials Found in Factories
Knowing where ACMs typically appear in industrial buildings helps you understand the scope of a survey and anticipate what the report may identify. The following materials were all widely used in UK factory construction and refurbishment before the ban on asbestos use came into force.
- Pipe lagging and thermal insulation — Found on boilers, pipework, and heating systems throughout plant rooms and production areas. Often contains amosite or crocidolite.
- Sprayed coatings — Applied to structural steelwork and concrete for fire protection or thermal insulation. Typically high in asbestos content and highly friable when disturbed.
- Asbestos cement roofing and cladding sheets — Extremely common in industrial buildings of all ages. Generally lower risk when intact, but deteriorate over time and must be monitored carefully.
- Insulation boards — Used in partition walls, ceiling tiles, fire doors, and service ducts. Amosite-containing boards were widely used and can be found in almost any pre-2000 factory.
- Floor tiles and adhesives — Vinyl floor tiles and their bitumen adhesive backing frequently contain chrysotile. Found throughout office, welfare, and production areas.
- Textured coatings — Applied to walls and ceilings in office and welfare areas within factory complexes.
- Gaskets and rope seals — Found in boilers, furnaces, and industrial machinery. Often overlooked but a genuine risk during maintenance work.
- Electrical equipment and switchgear — Older electrical installations may incorporate asbestos-containing components, particularly in switchrooms and distribution boards.
This list is not exhaustive. A thorough asbestos survey for factories and manufacturing premises will assess all suspect materials systematically, not just the obvious ones.
How Often Should You Survey and Reinspect?
A survey is the starting point, not the finish line. Once ACMs have been identified and your asbestos register is in place, you need a structured programme of ongoing management.
HSG264 and HSE guidance recommend that known ACMs in normal use are reinspected at least annually, though higher-risk materials or those in areas of heavy activity may warrant more frequent checks. The reinspection assesses whether the condition of each ACM has changed — whether it has deteriorated, been damaged, or been disturbed — and updates the risk score accordingly.
If you carry out significant structural changes, extend the building, or take on new areas of a site, a new or supplementary survey will be needed to cover those areas. The same applies if you discover materials during maintenance that were not captured in your existing survey.
Treating asbestos management as a live, ongoing process — rather than a one-off compliance exercise — is the only approach that genuinely protects your workforce and keeps you on the right side of the regulations.
Choosing the Right Surveying Company for an Industrial Site
Not all surveying companies have the experience or accreditation to handle the complexity of a large industrial site. When commissioning an asbestos survey for factories and manufacturing facilities, look for the following:
- UKAS accreditation — The surveying company should hold UKAS accreditation to ISO 17020. This is the recognised standard for asbestos surveying organisations in the UK and a baseline requirement, not an optional extra.
- P402-qualified surveyors — Individual surveyors should hold the British Occupational Hygiene Society (BOHS) P402 qualification or equivalent, demonstrating they are trained to survey and sample ACMs correctly.
- Industrial experience — Ask specifically whether the company has surveyed factories and manufacturing sites of similar scale and complexity. Industrial buildings require a different approach to offices or retail units.
- Clear, actionable reporting — A good survey report tells you what to do, not just what was found. Look for a company that provides clear risk scoring, prioritised recommendations, and site plans you can actually use.
- Transparent sampling methodology — Ask how many samples will be taken, how suspect materials are identified, and how presumed materials are handled in the report.
Choosing on price alone is a false economy. A poorly conducted survey that misses ACMs — or one that is not compliant with HSG264 — creates legal and safety risks that far outweigh any saving on the survey fee.
Frequently Asked Questions
Do all factories need an asbestos survey?
Any factory or manufacturing facility built or refurbished before 2000 should have an asbestos survey in place. The Control of Asbestos Regulations require dutyholders of non-domestic premises to manage asbestos, and an up-to-date survey is the foundation of that obligation. Even if you believe no asbestos is present, that belief must be supported by a formal survey from a UKAS-accredited surveyor — not assumption.
How long does an asbestos survey take in a factory?
The duration depends on the size, complexity, and age of the building. A large industrial site with multiple buildings, extensive plant rooms, and complex service runs may require several days of survey work. A surveying company should provide a realistic timescale during the quoting stage, and you should plan site access accordingly to avoid gaps in coverage.
Can we continue production during the survey?
In most cases, yes — a management survey is designed to be carried out with the premises in normal use. However, some areas may need to be temporarily vacated during sampling, particularly where the surveyor needs to access ceiling voids or disturb suspect materials. Your surveying company will advise on any access requirements in advance so you can plan around production schedules.
What is the difference between an asbestos survey and asbestos testing?
A survey is a systematic inspection of the whole building or a defined area, identifying all suspect materials and taking samples for laboratory analysis. Standalone asbestos testing involves submitting a sample from a specific material you have already identified — without the broader inspection element. Testing alone is not sufficient to fulfil your duty to manage, but it can be a useful tool when you need a quick answer about a single item of concern.
What happens if asbestos is found during the survey?
Finding asbestos does not mean the building must close or that immediate removal is required. Many ACMs can be safely managed in place if they are in good condition and are unlikely to be disturbed. Your survey report will assign a risk score to each material and recommend whether it should be managed, monitored, or removed. Only materials that present an active risk or are in poor condition typically require urgent action.
Get Your Factory Surveyed by Supernova Asbestos Surveys
Supernova Asbestos Surveys has completed over 50,000 surveys across the UK, including large-scale industrial and manufacturing sites. Our UKAS-accredited surveyors understand the specific challenges of factory environments — from complex plant rooms and roof structures to production areas that cannot be taken offline without careful planning.
Whether you need a management survey to establish your asbestos register, a refurbishment or demolition survey ahead of planned works, or a reinspection programme to keep your existing register current, we can help. We provide clear, actionable reports that tell you exactly what you have, where it is, and what to do about it.
Call us on 020 4586 0680 or visit asbestos-surveys.org.uk to discuss your requirements or request a quote.