And because asbestos can be present in any building built or refurbished before 2000, you cannot rely on “we’ve never had an issue” as a control measure.
This asbestos compliance checklist is written for duty holders, landlords, property owners, and managing agents who need a clear, workable set of steps.
Key takeaways
- Duty to manage applies to non-domestic buildings and communal areas of flats.
- Your asbestos register must stay current, and your management plan must be used, not filed away.
- Before major works, you will usually need a refurbishment or demolition survey that is intrusive by design.
- Anyone who could disturb asbestos must get the right information early, including contractors quoting for work.
Confirm who the duty holder is (and what you control)
Start with the basics: who actually controls maintenance and repair?
HSE’s check if you have the duty to manage asbestos page is a useful reality check. It lists the typical duty holder as the building owner, landlord, or whoever has clear responsibility for maintenance and repair. It also makes a key point for property owners: you can appoint a managing agent, but you cannot sign the legal duty away.
Checklist
- Identify the duty holder for each building (and communal areas, where relevant).
- Confirm responsibilities in leases, FM contracts, and repair agreements.
- Name an accountable person and a deputy for continuity.
Gather what you already have (then assume gaps exist)
Many organisations already hold pieces of the picture: old surveys, O&M manuals, health and safety files, and removal paperwork. Pull it together and look for any holes.
You should be explicitly checking that records cover all buildings built before 2000 and that the information is up to date.
Checklist
- Collect existing surveys, plans, previous removal records, and any current register.
- Record “unknowns” (areas not inspected, missing history, inaccessible voids).
Commission the right survey at the right time
There is a big difference between “managing day-to-day” and “opening up the building fabric”.
A refurbishment or demolition survey is destructive; the area must be vacated, and the survey should be carried out by a competent surveyor working in line with the current guidance (HSG264).
Checklist
- Use a management survey to support normal occupation and planned maintenance.
- Use an R&D survey before major refurbishment, intrusive works, or demolition.
- Check competence and quality assurance, not just price.
Build a live asbestos register (and keep it current)
Your asbestos register is not a one-off output. It should be a live document that must always contain current information on the presence and condition of ACMs.
HSE’s make a register and assess the risk page also sets out what “good” includes: type, amount and condition, inspection dates, and both material and priority assessments.
Checklist
- Create one register per site, with clear referencing to plans.
- Record known ACMs and presumed ACMs, and minimise “presumed” by planning access.
- Set inspection frequencies based on condition and the likelihood of disturbance.
Write the management plan so it runs the work, not the other way around
Your plan should name responsible people, include the register and monitoring schedule, set control arrangements to prevent disturbance, and include emergency procedures. It can be written or electronic, but it must be easy to update and find.
Checklist
- Define roles, deputies, and decision points (repair, encapsulate, remove).
- Include site-specific controls (permits to work, access control, method statement review).
- State what changes trigger a review (works affecting ACMs, staff change, disturbance, scheduled condition checks).
Put contractor controls in place
Most asbestos risk is introduced by “normal work”: drilling, cable runs, heating upgrades, kitchen and bathroom renewals, and void works.
You must tell employees, contractors and maintenance workers about the plan, and for planned work you should provide information as early as possible, including at the quote stage.
Checklist
- Make asbestos information part of every job pack and pre-start.
- Use a permit-to-work approach for any work on the fabric of the building.
- Define a site liaison and handover/handback steps.
Match the work type to the correct controls (licensed, non-licensed, NNLW)
Not all asbestos work is “licensed removal”, but all of it needs proper assessment and control. For safer, limited tasks, HSE’s Asbestos essentials task sheets set out controls for non-licensed work.
Where risk rises, you may be in notifiable non-licensed work territory. HSE’s NNLW guidance explains how friability, condition, and the way the material is worked affects classification.
Checklist
- Confirm the category before work starts (and document why).
- Use task-specific controls for non-licensed work (method, PPE/RPE, cleaning, waste).
- Where NNLW applies, follow the extra steps required for notifiable work.
Training: align content to what people actually do
“Asbestos awareness” is not the finish line for trades who will disturb ACMs.
HSE’s asbestos training guidance distinguishes between awareness and the higher level required for workers planning to disturb asbestos, including non-licensed and NNLW work. It also references Regulation 10 of CAR 2012 for the standard of information, instruction and training.
Checklist
- Map roles to training needs (awareness vs task-specific).
- Refresh training on a schedule and after incidents or process changes.
Prepare for the day it goes wrong
Even good systems get tested: an unplanned leak, a contractor cuts the wrong void, a resident reports damage.
You should make emergency procedures part of the plan, and you should already have prepared guidance on what to do if asbestos is discovered or disturbed.
Checklist
- Write a clear “stop work” process and escalation route.
- Define isolation, communication, and reoccupation controls.
Keep evidence audit-ready
You do not want to assemble proof under pressure.
Keep these current
- Asbestos register and site plans
- Management plan and review log
- Surveys (management and R&D)
- Contractor briefings and permits to work
- Inspection records and actions (repair, encapsulation, removal)
If you’d like to learn more about how technology can help make this whole process more seamless and less risky, you can check out True Compliance’s Asbestos Compliance page.
