The asbestos survey is complete.
Is the risk under control?
Having an asbestos survey does not necessarily mean the risk is under control. For clients and project teams, what matters is whether the information is suitable for the planned work, whether its limitations are understood and whether it informs decisions before construction begins.
In September 2026, the Health and Safety Executive sought industry feedback as part of its review of the Control of Asbestos Regulations 2012, including how asbestos is identified before work starts.
The review provides a useful prompt to look at how asbestos information is used in practice. On refurbishment, maintenance and demolition projects, a survey should do more than sit within the pre-construction information. It should help the team understand what can be done safely, what needs further investigation and what must happen before work proceeds.
Every project affects a building differently. Information gathered for day-to-day management may not provide the detail needed for refurbishment or demolition.
A survey may exist but still leave important gaps. Areas might have been excluded or inaccessible. An older survey may no longer reflect the building or the proposed work. Previous asbestos removal may not have been properly recorded, leaving uncertainty about what remains.
These are not simply qualifications at the back of a report. They can affect the design, construction approach and programme.
For example, if a proposed service route passes through an area excluded from the survey, the team needs to resolve that information gap before intrusive work takes place. Assuming that an area is clear because asbestos has not been recorded there is not a sound basis for planning.
The question is not simply, “Do we have a survey?” It is: “Does the information we have allow this particular project to be planned and delivered safely?”
Surveys need to be scoped and commissioned at the right point in the design process, so their findings can be considered alongside the planned construction work.
For an existing property built before 2000, a management survey can provide baseline information about known or presumed asbestos-containing materials and their condition. It supports the management of asbestos during normal occupation and use.
However, it may not identify materials concealed within parts of the building fabric that will be disturbed by construction work.
Where refurbishment or demolition is planned, the team needs to establish what further survey work is required. A refurbishment or demolition survey involves more intrusive investigation, with its scope matched to the areas and materials affected by the proposed works.
This is not simply a matter of renaming or updating a management survey. It requires the right investigation for the work being planned.
The same principle applies to maintenance in an occupied building. A management survey should not automatically be treated as sufficient for intrusive work. Its coverage and limitations must be checked against the actual task, with further investigation arranged where necessary before disturbance occurs.
The Principal Designer can support the client and designers in identifying the information needed, understanding survey findings and considering their implications for delivery.
As the project develops towards RIBA Stage 4, Technical Design, asbestos information should inform the technical design and, where tendering takes place at this stage, the tender information. The timing should follow the project’s procurement route, with significant issues addressed early enough to influence decisions before contractor appointment wherever practicable.
This could mean considering:
whether asbestos removal should be undertaken as an earlier enabling phase;
how removal affects access, sequencing and the programme;
whether any asbestos can appropriately remain in place and how the design will avoid disturbing it;
what further surveys or specialist technical advice are needed; and
what information contractors need to understand and plan the work.
The Principal Designer’s role is to help coordinate these matters through the pre-construction phase, bringing together the client, designers and relevant asbestos specialists.
That does not make the Principal Designer automatically responsible for asbestos management or for preparing a specialist contractor’s removal methodology. It does help the client obtain and use the right advice before unresolved issues reach site.
During RIBA Stage 5, Manufacturing and Construction, the relevant refurbishment or demolition survey findings need to be understood by those planning, managing and carrying out the work.
The pre-construction information should communicate the identified asbestos, survey limitations and outstanding actions. The Principal Contractor’s construction phase plan and supporting arrangements should then reflect how those risks will be managed during delivery.
Issuing a report is only part of that process. The team needs to be clear about which areas have been surveyed, what remains uncertain and whether the work being undertaken is covered by the available information.
If the design or scope changes, the adequacy of the survey information should be reconsidered. An investigation scoped for one package of work may not cover a later alteration or additional intrusive activity.
This is where coordination becomes practical: making sure information leads to clear instructions and appropriate controls for the people who could disturb asbestos.
The need for reliable information does not end when construction is complete.
Relevant information about asbestos remaining in the building should be recorded in the health and safety file at handover and reflected in the building’s asbestos register and management arrangements.
During RIBA Stage 7, Use, this information helps facilities management teams and those commissioning maintenance understand what remains, where it is located and what needs to be considered before further work.
Records should also reflect asbestos removed during the project, so future teams are not left relying on incomplete or conflicting information.
The health and safety file provides an important source of information, but it does not replace ongoing asbestos management. Before any subsequent intrusive work, the available information must still be checked against the proposed task.
Karl’s practical message is equally relevant to the quality of the survey itself: commissioning a report is not the end of the process.
Using a UKAS-accredited asbestos surveying organisation provides an important basis for selecting a survey provider. The brief must still clearly describe the proposed work, affected areas and access requirements.
Once received, the report needs to be reviewed against that brief. Are there exclusions or caveats? Has the required scope been covered? Are there gaps in the existing records? Do the findings give designers and contractors the information they need?
A peer review can help clients and designers understand these issues and identify where clarification or further investigation is required. It does not replace a survey or resolve inaccessible areas by itself, but it can help prevent limitations from being overlooked.
The value of asbestos information lies in what the project team does with it.
Gathering it early allows the client to understand the implications for scope, cost and programme. Reviewing it helps designers identify where proposals need to change or further advice is required. Communicating it properly helps contractors and maintenance teams plan their work.
Asbestos risk is not managed by possessing a survey. It is managed by using suitable information to make informed decisions about whether asbestos needs to be safely removed or can remain in place with appropriate controls and ongoing management.
Article written by Karl Tindale, Associate, Construction Safety at Safer Sphere.
Our consultants bring asbestos technical expertise alongside their CDM knowledge to support clients and designers working with existing buildings.
We undertake peer review of asbestos surveys, help teams understand findings and limitations, and advise on information gaps, further investigation and the implications for design and project delivery.
From early survey planning to construction and handover information, we help clients and designers navigate the complexities of working alongside existing asbestos-containing materials.
Speak to our Construction Safety team about your next refurbishment, maintenance or demolition project.
