Do We Have to Have an Asbestos Survey?

One of the most common questions we are asked is:

“Do we have to have an asbestos survey?”

The answer may surprise you.

Strictly speaking, the law does not require an asbestos survey. What the law requires is that dutyholders identify, assess and manage asbestos-containing materials (ACMs) within their premises.

A survey is often the most practical and reliable way of obtaining that information, but it is not an end in itself. The objective is not to possess a survey report. The objective is to understand where asbestos is present and manage the associated risks.

Key takeaways:

• The legal requirement is to identify, assess and manage asbestos-containing materials, rather than simply to have an asbestos survey.
• The information you need depends on what is happening in the building, from normal occupation and maintenance to refurbishment or demolition.
• Existing records may provide sufficient information in some circumstances, while gaps or unreliable information may mean a survey or further investigation is needed.
• Any survey limitations should be considered against the planned work. If an inaccessible or uninspected area will be disturbed, the asbestos risk still needs to be resolved before work begins.

Start With The Question You’re Trying To Answer

The type and extent of information required depends on what you are planning to do.

Are you managing a building that remains occupied and in use?

Are you carrying out maintenance activities?

Are you refurbishing a specific area?

Or are you demolishing the entire structure?

Each situation requires a different level of information.

Unfortunately, many organisations fall into the trap of viewing asbestos surveys as a paperwork exercise rather than a process for gathering the information needed to manage risk.

Management Surveys

For occupied buildings, the primary concern is usually day-to-day occupation, routine maintenance and accidental disturbance.

The key question is:

“Do we know where asbestos is and can we prevent people from disturbing it?”

The Control of Asbestos Regulations require dutyholders to take reasonable steps to locate asbestos, assess its condition and have arrangements in place to manage it.

In some circumstances, existing records may already provide sufficient information. Previous refurbishment records, historical surveys and documented asbestos removal works may together provide a reliable understanding of the building’s asbestos risks.

Where information is incomplete, unreliable or absent, a survey may be required to fill the gaps.

The important point is that the focus should always be on effective management rather than simply obtaining another report.

For example, if a water leak caused part of a ceiling to collapse tomorrow, would you know whether asbestos-containing materials might be present in the debris above the ceiling void? Would contractors attending to make repairs have access to that information? These are the practical questions that asbestos management should address.

Refurbishment and Demolition Surveys

The purpose of a refurbishment and demolition survey is often misunderstood.

An R&D survey is not intended to identify every asbestos-containing material within a building regardless of whether it will be affected by the work.

Its purpose is to identify asbestos in the areas that are likely to be disturbed as part of the planned works.

If refurbishment works are confined to a single office, there may be no need to investigate the opposite end of the building at that stage. However, the survey must fully address the areas where disturbance is expected to occur.

Equally, where survey limitations exist, these should be clearly identified and managed. Access restrictions cannot simply be ignored if the planned works require access to those areas.

When Caveats Become A Problem

Recently, I reviewed a demolition survey for a warehouse where the surveyor had included a limitation stating that only a visual inspection had been undertaken above two metres due to access constraints.

At first glance, this might appear reasonable.

However, the building was scheduled for demolition.

The roof formed part of the structure being demolished and contained a significant quantity of asbestos cement sheeting.

In circumstances such as these, access limitations cannot simply be accepted without challenge. If the purpose of the survey is to identify asbestos materials that will be affected by demolition works, the survey must address the whole structure or identify what additional investigation is required before works commence.

A limitation that excludes areas directly affected by the proposed works does not resolve the risk; it merely records that the risk remains unknown.

It Is About Risk Management, Not Surveys

Too often, discussions about asbestos become focused on whether a survey exists.

The more important question is:

“Do we have sufficient information to manage the risk?”

A survey may provide that information.

Existing records may provide that information.

Further intrusive investigation may be required to obtain that information.

The right approach depends on the circumstances.

What matters is that employers can demonstrate they understand where asbestos-containing materials are present, who may be affected, how accidental disturbance will be prevented and what arrangements are in place should asbestos be encountered unexpectedly.

The Question to Ask

Instead of asking:

“Do we have an asbestos survey?”

Perhaps the better question is:

“Do we know enough about asbestos in our premises to safely occupy, maintain, refurbish or demolish them?”

Because that is ultimately what the legislation is trying to achieve.

A survey is often part of the answer.

It is rarely the whole answer.