CDM Requirements and Asbestos Project Management: What Every Duty Holder Needs to Know
Asbestos project management is one of the most legally complex and safety-critical responsibilities in UK construction. Get it wrong and you face unlimited fines, criminal prosecution, and — far more seriously — workers developing fatal lung diseases years down the line. Get it right and you protect lives, meet your legal duties, and keep projects moving without costly disruption.
The Construction (Design and Management) Regulations — known as CDM 2015 — sit alongside the Control of Asbestos Regulations to create a clear framework for managing asbestos risks on construction sites. Whether you are a client commissioning a refurbishment, a principal designer coordinating pre-construction information, or a principal contractor running a live site, this post sets out exactly what is required of you.
Why Asbestos Project Management Cannot Be an Afterthought
Asbestos remains the single largest cause of work-related deaths in the UK. The fibres it releases when disturbed are invisible to the naked eye and can cause mesothelioma, asbestosis, and lung cancer — often decades after exposure.
Because symptoms take so long to appear, it is easy to underestimate the risk at the time work is being carried out. That complacency has cost thousands of lives, and the law is designed to prevent it from continuing.
Any building constructed before the year 2000 may contain asbestos-containing materials (ACMs). That includes offices, schools, hospitals, factories, warehouses, and residential properties. Before any refurbishment, renovation, or demolition work begins on such a building, the duty holders involved must have a clear picture of where ACMs are located, what condition they are in, and how the work will be managed safely around them.
This is not optional guidance — it is a legal requirement enforced by the Health and Safety Executive (HSE).
How CDM 2015 and the Control of Asbestos Regulations Work Together
CDM 2015 governs how construction projects are planned, managed, and executed. The Control of Asbestos Regulations set out the specific duties around asbestos identification, assessment, and control. In practice, these two sets of regulations overlap significantly and must be read together.
Under CDM 2015, clients are responsible for ensuring that pre-construction information — including any known asbestos data — is gathered and passed to the principal designer. The principal designer then incorporates that information into the Health and Safety File and coordinates with the principal contractor to ensure it feeds into the Construction Phase Plan.
Under the Control of Asbestos Regulations, duty holders in non-domestic premises are required to manage ACMs on an ongoing basis. This means having an up-to-date asbestos register, conducting regular condition checks, and ensuring anyone who might disturb ACMs is informed before work starts.
Effective asbestos project management means satisfying both sets of obligations — not treating them as separate exercises. Organisations that try to handle them in isolation almost always create gaps that put workers at risk and expose duty holders to enforcement action.
The Role of Asbestos Surveys in CDM Compliance
No asbestos project management plan is worth anything without accurate survey data underpinning it. There are two main types of survey relevant to construction projects, and choosing the right one for the circumstances is not optional — it is a legal obligation.
Management Surveys
A management survey is the standard survey required for the ongoing management of ACMs in occupied or operational buildings. It identifies the location, extent, and condition of ACMs that could be disturbed during normal occupancy or routine maintenance.
This type of survey is a legal requirement for non-domestic properties and forms the foundation of any asbestos management plan. Management surveys are not intrusive — they do not involve significant disruption to the building fabric — making them practical for commercial and public sector properties that need to remain operational during the process.
Refurbishment and Demolition Surveys
Where construction work is planned — whether a partial refurbishment or full demolition — a more detailed survey is required. A demolition survey is intrusive and destructive where necessary, accessing areas that would be disturbed during the work. It must be completed before any work begins in the affected area.
HSG264, the HSE’s guidance document on asbestos surveying, sets out the standards these surveys must meet. Surveys must be carried out by a competent surveyor with appropriate training and, where sampling is involved, analysis must be conducted by a UKAS-accredited laboratory.
Supernova carries out surveys across the country. Whether you need an asbestos survey in London, an asbestos survey in Manchester, or an asbestos survey in Birmingham, our local surveyors are ready to mobilise quickly.
Building a Robust Asbestos Management Plan
An asbestos management plan is the central document in any asbestos project management programme. It records what ACMs are present, where they are, what condition they are in, and what actions are required to manage or remove them safely.
For construction projects, this plan must be integrated into the wider CDM documentation — it cannot sit in isolation as a separate health and safety exercise.
What the Plan Must Include
- A full asbestos register listing all identified ACMs with location, type, condition, and risk rating
- Details of any ACMs that have been removed, encapsulated, or sealed
- A schedule for periodic condition monitoring of ACMs that are being managed in situ
- Procedures for informing contractors, maintenance workers, and other relevant parties before any work that could disturb ACMs
- Emergency procedures in the event of accidental disturbance
- Records of training provided to relevant staff
- A clear allocation of responsibilities — who is the duty holder, who carries out monitoring, who authorises work near ACMs
The plan must be a living document. It should be reviewed whenever there is a change in the condition of ACMs, whenever new materials are identified, and at least annually as a matter of routine.
Integrating the Plan with the Construction Phase Plan
Under CDM 2015, the Construction Phase Plan must address asbestos risks specifically. The principal contractor cannot simply reference the asbestos management plan and leave it there — they must translate the information into practical site procedures.
The Construction Phase Plan should set out:
- Which areas of the site contain ACMs and what the risks are in those areas
- What work methods will be used to avoid or control disturbance of ACMs
- What licensed or non-licensed asbestos removal work is required before other trades can proceed
- How information will be communicated to all workers on site, including subcontractors
- What personal protective equipment is required and when
- What air monitoring or clearance testing will be conducted
- How unexpected finds will be handled — including who has authority to stop work
Responsibilities of Each Duty Holder
One of the most common failures in asbestos project management is a lack of clarity about who is responsible for what. CDM 2015 assigns specific duties to each party, and those duties do not disappear just because someone else is also involved.
Clients
The client sets the tone for the entire project. Under CDM 2015, clients must ensure that suitable arrangements are in place for managing the project, including adequate time and resources for asbestos management. Specifically, clients must:
- Commission appropriate asbestos surveys before work begins
- Provide all known asbestos information to the principal designer as part of pre-construction information
- Notify the HSE where the project meets the notification threshold
- Ensure the Construction Phase Plan adequately addresses asbestos risks before work starts
Clients who delegate these responsibilities without checking they have been properly discharged remain legally liable if something goes wrong. Delegation is not absolution.
Principal Designers
The principal designer is responsible for coordinating health and safety during the pre-construction phase. In the context of asbestos project management, this means:
- Collating and reviewing all asbestos survey data
- Ensuring the design takes account of asbestos risks — for example, by avoiding unnecessary disturbance of ACMs where possible
- Passing complete and accurate asbestos information to the principal contractor
- Incorporating asbestos information into the Health and Safety File
Principal Contractors
The principal contractor takes on the day-to-day management of asbestos risks on site. Their responsibilities include:
- Ensuring the Construction Phase Plan addresses asbestos comprehensively
- Briefing all workers — including subcontractors — on asbestos risks before they start work
- Establishing exclusion zones and control measures around ACMs
- Ensuring that any licensed asbestos removal is carried out by a licensed contractor notified to the HSE
- Maintaining site records of all asbestos-related activities
- Stopping work immediately if unexpected ACMs are discovered
Licensed vs Non-Licensed Asbestos Work
Not all asbestos work requires a licensed contractor, but understanding the distinction is essential for accurate asbestos project management planning. Getting this wrong — whether by over-specifying or, more dangerously, under-specifying — creates both cost and compliance problems.
Licensed work is required where the exposure to asbestos is not sporadic and low intensity, or where the material involved is high-risk — such as sprayed coatings, lagging, or insulating board in poor condition. Licensed contractors must be approved by the HSE, and the work must be notified in advance.
Non-licensed work covers lower-risk activities, such as minor work on asbestos cement or textured coatings, provided the material is in good condition and exposure is short-term. Even for non-licensed work, a risk assessment must be completed and appropriate controls must be in place.
Some non-licensed work is notifiable — meaning it must be reported to the HSE even though a licence is not required. This category sits between fully licensed and straightforward non-licensed work, and the distinction matters for your project records and legal compliance.
When licensed removal is required, it must be completed and the area cleared before other trades are allowed in. Attempting to work around licensed asbestos removal in progress is not just dangerous — it is a criminal offence.
For projects where asbestos removal is required, using a contractor with the appropriate HSE licence and a clear method statement is non-negotiable. Supernova can advise on whether removal is the right course of action or whether management in situ is a viable alternative.
Monitoring, Record-Keeping, and the Health and Safety File
Asbestos project management does not end when the construction work is complete. CDM 2015 requires the principal designer — or the principal contractor where there is no principal designer — to prepare and maintain a Health and Safety File.
This file must contain all relevant asbestos information for the building as it stands at the end of the project. It is handed to the client on project completion and becomes the foundation of the ongoing asbestos management plan for the building, informing future maintenance and any further construction work.
Good record-keeping throughout the project is not just a legal formality — it is what makes the Health and Safety File genuinely useful rather than a box-ticking exercise. Records should include:
- Survey reports and laboratory analysis results
- Air monitoring data and clearance certificates
- Details of any ACMs that remain in the building and their current condition
- Records of all asbestos-related works carried out during the project, including method statements and waste transfer notes
- Details of any unexpected finds and how they were managed
- Training records for workers involved in asbestos-related activities
If the Health and Safety File is incomplete or inaccurate, the next contractor to work on the building starts at a disadvantage — and that is where accidents happen.
Common Failures in Asbestos Project Management — and How to Avoid Them
After conducting tens of thousands of surveys across the UK, Supernova’s team has seen the same mistakes made repeatedly. Knowing what they are is the first step to avoiding them.
Commissioning the Wrong Type of Survey
A management survey is not sufficient for a refurbishment or demolition project. Relying on one when a full refurbishment and demolition survey is required is a compliance failure that can halt a project entirely — and expose duty holders to enforcement action. Always match the survey type to the scope of work.
Treating Asbestos Information as Static
Survey data has a shelf life. ACMs deteriorate over time, and buildings change. An asbestos register compiled five years ago may not accurately reflect current conditions. Before work begins, verify that the survey data is current and that no material changes have occurred since it was produced.
Failing to Brief Subcontractors
The principal contractor’s duty to inform workers about asbestos risks extends to every subcontractor on site. A tool-box talk delivered to the main workforce is not sufficient if specialist subcontractors are brought in later without equivalent briefing. Every worker who could potentially disturb an ACM must be informed before they start.
Inadequate Unexpected Find Procedures
Even the best surveys cannot guarantee that every ACM will be identified — particularly in older or complex buildings. Every Construction Phase Plan must include a clear, actionable procedure for what happens when unexpected materials are found. That means stopping work, isolating the area, arranging an emergency survey, and not resuming until the situation has been assessed by a competent person.
Leaving Asbestos Management to the End
Asbestos project management must begin at the design stage, not when contractors arrive on site. Designers who factor asbestos risks into their proposals — avoiding unnecessary penetration of suspected ACM locations, for example — can significantly reduce the complexity and cost of managing those risks during construction.
Practical Steps to Get Your Asbestos Project Management Right
If you are approaching a construction project and need to get asbestos management right from the outset, the following sequence will help you structure your approach:
- Commission an appropriate survey early. Do not wait until you have a contractor on board. The survey data needs to inform the design and the pre-construction information pack.
- Appoint competent duty holders. Ensure your principal designer and principal contractor have demonstrable experience of managing asbestos risks on similar projects.
- Build asbestos into the pre-construction information. All known asbestos data must be included in the information provided to designers and contractors at tender stage.
- Integrate the asbestos management plan with CDM documentation. The Construction Phase Plan must address asbestos specifically — not just reference a separate document.
- Establish clear communication protocols. Every worker on site must know what ACMs are present, where they are, and what to do if they encounter something unexpected.
- Arrange licensed removal in advance. Licensed asbestos removal takes time to plan, notify, and execute. Build it into the programme early so it does not become a critical path issue.
- Maintain records throughout. Every survey, clearance certificate, waste note, and monitoring result should be filed and accessible. They will form the basis of the Health and Safety File.
- Review and update as the project progresses. Conditions change on site. The asbestos management plan should be reviewed regularly and updated whenever new information comes to light.
Frequently Asked Questions
What is asbestos project management and who is responsible for it?
Asbestos project management refers to the structured process of identifying, assessing, and controlling asbestos-containing materials (ACMs) throughout the lifecycle of a construction project. Under CDM 2015 and the Control of Asbestos Regulations, responsibility is shared between the client, principal designer, and principal contractor — each with distinct legal duties that cannot be delegated away.
Do I need a new asbestos survey if one was carried out a few years ago?
Possibly. Survey data can become outdated as ACMs deteriorate or building conditions change. If a refurbishment or demolition is planned, a full refurbishment and demolition survey is required regardless of whether a management survey exists. Always verify that any existing survey data is current and relevant to the scope of work before relying on it.
What is the difference between licensed and non-licensed asbestos work?
Licensed asbestos work involves higher-risk materials or activities where exposure is not sporadic and low intensity — such as removing lagging, sprayed coatings, or asbestos insulating board in poor condition. This work must be carried out by an HSE-licensed contractor and notified in advance. Non-licensed work covers lower-risk tasks, such as minor work on intact asbestos cement, but still requires a risk assessment and appropriate controls. Some non-licensed work is notifiable to the HSE even though a licence is not required.
What happens if unexpected asbestos is found during construction work?
Work must stop immediately in the affected area. The site should be isolated and a competent asbestos surveyor brought in to assess the material. Work cannot resume until the situation has been evaluated and appropriate controls put in place. Every Construction Phase Plan should include a written procedure for exactly this scenario — an unexpected find is not unusual, and being unprepared for one is not an acceptable position.
What should the Health and Safety File contain regarding asbestos?
The Health and Safety File must include all relevant asbestos information for the building as it stands at the end of the project. This includes survey reports, laboratory results, air monitoring data, clearance certificates, records of any ACMs removed or left in situ, and details of any unexpected finds and how they were managed. This file is handed to the client on completion and informs all future maintenance and construction work on the building.
Work With a Surveying Team That Understands the Full Picture
Supernova Asbestos Surveys has completed over 50,000 surveys across the UK, working with clients ranging from individual property owners to major construction programmes. We understand how asbestos project management fits into the wider CDM framework — and we provide the survey data, reports, and expert guidance that duty holders need to meet their obligations with confidence.
Whether your project is at the planning stage or already under way, our team can help you identify the right survey type, interpret the results, and understand what action is required. We work quickly, report clearly, and stand behind the quality of our work.
Call us on 020 4586 0680 or visit asbestos-surveys.org.uk to discuss your project with one of our surveyors.