Asbestos management survey

What the survey is really answering

Regulation 4 of the Control of Asbestos Regulations 2012 puts a duty on whoever controls a non-domestic building, and the common parts of flats, to assess whether asbestos is present, record where it is and what condition it is in, assess the risk and manage it. You can discharge that duty by presuming asbestos everywhere and managing on that basis. Almost nobody does, because presumption is expensive: every drilled hole becomes a controlled job. So you survey.

HSG264 sets the management survey as the standard route. Its job is to locate, so far as is reasonably practicable, the materials that could be disturbed while the building is simply being occupied and maintained: a contractor lifting a ceiling tile to run a cable, a plumber cutting into a riser, a caretaker replacing a light fitting. It is baseline information for day to day control, not an exhaustive inventory of everything hidden in the structure.

What I expect a surveyor to find, and where

The building’s age tells me most of what I will be looking at before I arrive. Crocidolite and amosite were banned in 1985; chrysotile followed in 1999, with the last products off the shelves that year. Anything built or refitted between roughly 1950 and 1985 is where the serious material sits.

Sprayed coatings and lagging on pipework and boilers are the ones that matter most: high fibre content, poor condition after decades of maintenance men leaning on them. Asbestos insulating board is the material I find most often and the one clients most often mistake for plasterboard. It is in ceiling tiles, riser panels, soffits, fire doors, boxing around columns and the panel behind almost every night storage heater of that era. Below that in risk sit the bonded products: cement roof sheets and downpipes, bitumen-backed floor tiles and the black adhesive under them, textured coatings on ceilings and walls, toilet cisterns and rope seals on old boilers.

None of this is confirmed by looking at it. Textured coating is the trap: I have seen post-1999 Artex sampled needlessly and 1970s coating waved through on a glance. Where confirmation matters, a representative sample goes to a laboratory accredited to ISO/IEC 17025 for the relevant method. Appearance is a hypothesis, not a result.

Where the survey stops

A management survey involves some opening up. Ceiling tiles come out, riser doors open, a few panels get lifted. It does not go behind a wall, into a sealed cavity or inside a structural element, because doing that in an occupied building is destructive and, in the case of a live plant room or a school corridor, unsafe.

The consequence is the part clients skip. Anything not inspected is not asbestos-free. It is unknown, and it must be recorded as unknown and presumed to contain asbestos until someone proves otherwise. A locked room, a live switch panel, a high-level void you needed a scaffold for: all of these come back as no access, and a report that quietly omits them rather than listing them is a report I would send back. The no-access schedule is the most useful page in the document, because it tells you exactly where your next problem is.

Get the access sorted before the surveyor arrives. Keys, escorts, permits, isolations, roof access. Every area you cannot open on the day is an area you pay to revisit.

Reading the report properly

The report is a technical document, and the test of it is whether a contractor who has never been to your site can use it to plan safely. I look for the scope stated plainly, plans with each identified or presumed material marked and referenced, a description of extent and condition for each item, the laboratory certificates behind every sample, a material assessment scored for each item, and the exclusions written out rather than buried in a caveat page.

The material assessment scores product type, damage, surface treatment and asbestos type. It tells you the fibre release potential if the material is disturbed. It does not tell you your risk, because it knows nothing about your building. That is the priority assessment, and it is yours to do or to have done: who uses the space, how often, how likely disturbance is. Sprayed coating in a sealed plant room nobody enters and AIB in a primary school corridor can score identically on material assessment and sit at opposite ends of any sensible action list.

The report is also not your register. This is the single most common confusion I meet. The survey is the source document; the register is the live record you build from it and keep updating after every repair, every bit of damage, every removal. If your register is a PDF of the 2011 survey sitting on a shared drive, you do not have a register.

What happens after, and when it runs out

Findings feed the register, the register feeds the management plan, the plan sets out labelling, encapsulation, repair, monitoring or removal and the interval for re-inspecting what stays. Anyone who might disturb the material sees the register before they start work. That includes the electrician you called this morning.

The survey supports occupation and simple maintenance. It does not support refurbishment. The moment work will disturb the fabric and your existing information does not cover the specific area in the detail required, you need a refurbishment survey for that defined work area, and the area normally needs to be empty for it. If you are planning works and reaching for a management survey to cover them, you are about to stop the job three weeks in.

On competence: HSE guidance supports the use of surveying organisations accredited by UKAS to BS EN ISO/IEC 17020, and analysis by a laboratory accredited to ISO/IEC 17025. Accreditation is held by the organisation and it is scoped. Ask what the scope covers and check the certificate rather than the logo.