Guidance

Managing asbestos in your school or college

Updated 11 March 2025

Applies to England

© Crown copyright 2025

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Overview

This non-statutory guidance provides an overview of requirements for the effective management of asbestos materials within schools and colleges. It explains the obligations on dutyholders and signposts to more detailed guidance.

Your school or college buildings may contain asbestos if any part of them was built before 2000. It is extremely important that any asbestos present in your school or college is located and managed effectively.

Failure to comply with the Control of Asbestos Regulations 2012 is a criminal offence. The Health and Safety Executive (HSE) investigates incidents where dutyholders fail to manage the risks and takes enforcement action where appropriate.

This guidance includes examples which outline some of the consequences that have followed when dutyholders either failed to seek competent advice or ignored advice in the procurement of works, including minor works.

Further guidance can be found in HSE’s duty to manage asbestos in buildings and asbestos management checklist for schools.

Following the steps set out in this guidance should protect the health of staff, pupils, students and visitors, including contractors, to the school or college from the risk of exposure to asbestos. Where appropriate measures are not taken, those with responsibility could face prosecution.

This guidance is subject to changes in policy or legislation. Enquiries about this guidance should be directed to the Department for Education: Contact the Department for Education.

Audience

This guidance applies to dutyholders and others in state-funded schools and colleges who have a role to play in the safe management of asbestos. This includes:

  • local authorities
  • headteachers
  • business managers
  • facilities managers
  • governing bodies
  • all teaching and support staff
  • maintenance and caretaking staff
  • trade union health and safety representatives
  • members of school and college management teams
  • charitable trusts working in schools or colleges containing asbestos

Legislative framework

The advice in this guidance reflects the Control of Asbestos Regulations 2012 (CAR) and wider duties under health and safety legislation including:

  • The Health and Safety at Work act 1974 (HSWA)
  • Hazardous Waste Regulations 2005
  • Safety Representatives and Safety Committees Regulations 1977
  • Health and Safety (Consultation with Employees) Regulations 1996
  • Construction (Design and Management) Regulations 2015
  • The Management of Health and Safety at Work Regulations 1992

This guidance does not replace any of the above legislation, and if there is any conflict, the legislative documents are primary.

Where we include ‘must’ or ‘will’ in this guidance, this indicates a legislative requirement, whereas ‘should’ reflects measures which are not legal requirements like HSE guidance or best practice.

Asbestos and when it becomes a risk

Most school and college buildings contain asbestos. Asbestos is a naturally occurring fibrous mineral, which was incorporated into a wide variety of materials used in the UK up to the year 2000.

If managed actively and safely, the presence of asbestos in your school or college should not pose a risk to occupants. Poor management of asbestos can pose serious health risks.

Undamaged, sealed materials will not release fibres. If materials containing asbestos are disturbed or damaged, asbestos fibres can be released into the air and breathed in by building occupants. This is more likely to happen as asbestos materials age and deteriorate.

The activities most likely to lead to the disturbance of asbestos materials in schools and colleges are building and maintenance work. Depending on their nature and location, asbestos materials could also be disturbed through vandalism and other everyday impacts on the asbestos material.

Everyday activities can disturb asbestos, including physical damage to asbestos materials, water damage, and air movements (over asbestos which is already in poor condition and unencapsulated). Encapsulated materials within clad structural columns and areas such as ceiling voids can also be disturbed in these ways.

Asbestos exposure puts individuals at risk of contracting several serious diseases in later life, including mesothelioma, which is an aggressive cancer most commonly caused by exposure to asbestos fibres, and lung cancer.  See HSE information: Why is asbestos dangerous?

Responsibilities for managing asbestos

The following are responsible for managing asbestos, under regulation 4 of the Control of Asbestos Regulations 2012 (CAR):

Employers

In public buildings, who the dutyholder is depends on who is responsible for maintenance or repair. In schools it varies with the type of school. Further information on identifying the dutyholder can be found in HSE’s guidance: The duty to manage asbestos in buildings: Check if you have the duty to manage asbestos.

The Health and Safety at Work Act 1974 (HSWA) requires employers of school and college staff to:

  • protect the health and safety of their employees at work
  • ensure pupils, students, visitors, and all other persons that use the school or college premises are protected from harm to their health and safety from known or foreseeable risks

Whilst the employer can delegate responsibilities, functions or roles to staff, the ‘duty’ cannot be delegated and rests with the employer.

The employer should:

  • support governing bodies and leadership teams to ensure that there are suitable arrangements in place to manage the asbestos materials within a school
  • regularly monitor the effectiveness of the arrangements to ensure that the risks are controlled
  • ensure that all staff with delegated responsibilities in this area are suitably trained to undertake their role – this is particularly relevant where budgets are delegated to the school, but where the local authority or a separate academy trust employs the staff

Employers should allocate resources to train staff with delegated responsibility, including:

The employer varies depending upon the type of school. HSE provides guidance on responsibility for health and safety within schools. The local authority is the employer for:

  • community and community special schools
  • voluntary-controlled schools
  • maintained nursery schools
  • pupil referral units

The governing body is the employer for:

  • foundation and foundation special schools
  • voluntary-aided schools

The school’s proprietor (the academy trust for academies and free schools) is the employer in:

  • academies
  • free schools
  • other independent schools

The corporation is the employer for further education colleges and sixth form colleges. This does not apply to employees that are provided through another organisation.

Dutyholders

Under regulation 4 of the Control of Asbestos Regulations 2012 (CAR), legal responsibility for the safe management of asbestos lies with the ‘dutyholder’. A dutyholder is anyone who has, by virtue of a contract or tenancy, any maintenance or repair obligations in respect of the school or college premises or any means of access to or egress from the premises. Otherwise, where there is no contract or tenancy, the dutyholder will be anyone who has any control over any part of the school or college premises or any means of access to or egress from the premises.

Schools and colleges should identify who the dutyholders are for their premises, noting that this may be individual persons or corporate bodies. They should include this in their asbestos management plan. It is likely that governing bodies of schools and colleges and the owner of the school or college land and premises may share responsibility. Other bodies may also have responsibility, such as church and other faith bodies.

Who the dutyholder is will depend on the local circumstances, and there may be more than one dutyholder.

Setting Dutyholder
local authority-maintained school local authority is likely to be a dutyholder
single academy or multi-academy trust academy trust is likely to be a dutyholder
voluntary aided schools the board of governors will be the dutyholder for the school buildings and others will be the dutyholder for the playing fields and associated structures.
foundation schools the dutyholder’s responsibilities may lie with several individuals or corporate bodies
further education and sixth form colleges the corporation is likely to be the dutyholder

In certain cases, schools and colleges may need to seek legal advice to confirm who the dutyholders are for their premises.

Appointed person

Dutyholders should identify a person (and in some cases a deputy) within their organisation who will be responsible for ensuring that asbestos materials are properly managed. An appointed person will be even more important where the dutyholder has a large or complex buildings portfolio and multiple employers.

The appointed person will need the resources, skills, training and authority to ensure the asbestos materials are managed effectively.

An ‘appointed person’ is not a statutory role and does not remove the legal obligations of the dutyholder. Further information can be found in HSE’s Asbestos: The survey guide HSG264 in paragraph 14.

School and college staff

Even if you are not the legal dutyholder in your school or college, it is still your responsibility to play your part in the safe management of asbestos.

All staff and workers in your school or college should receive adequate training and understand what precautions, detailed in the asbestos management plan (AMP), to follow (see step 4). Trade union health and safety representatives can use their regular health and safety inspections to raise awareness of asbestos and discuss concerns with their members and management.

It is good practice for schools to provide information about the presence of asbestos to parents and carers, and to assure them that effective management arrangements are in place. If parents and carers request information, schools should provide clear and accurate information. HSE explains that if asbestos management arrangements fail and there is an accidental release of asbestos fibres, those affected should be informed. See the section on what to do if things go wrong.

Day-to-day management of asbestos in schools or colleges

There are 5 steps to take in meeting the core requirement for day-to-day asbestos management in your school or college:

  1. A management survey undertaken by appropriate professionals indicating the location and type of identified occurrences of asbestos should be recorded in an asbestos location register.
  2. An assessment of the risks posed by each identified occurrence of asbestos.
  3. A plan for actively managing and reviewing the risk from asbestos in your school or college – the asbestos management plan (AMP).
  4. Communication and training arrangements to ensure that all staff (teaching and non-teaching) are aware of asbestos documents and management plans and have appropriate training.
  5. Regular review of the AMP and asbestos location register including associated remedial actions.

You should implement further measures if maintenance or construction work is taking place, which may disturb the fabric of the building. Further details are in the asbestos management during maintenance or building works section.

Step 1: Conduct a management survey of asbestos materials

Each school or college must have an up-to-date survey of the buildings to identify the presence of asbestos materials, unless all the structures on site were wholly constructed since the year 2000. The survey should:

  • establish the location, type and condition of asbestos materials
  • provide a current and accurate picture of the presence and condition of asbestos materials within accessible areas
  • include the material assessment score or category (high, medium, low, or very low)
  • identify the inaccessible areas within buildings where the presence of asbestos is presumed or cannot be ruled out
  • include representative photographs to make it easier to measure any damage or deterioration to asbestos materials

A management survey is the standard survey. Its purpose is to locate, as far as reasonably practicable, the presence and extent of any suspect ACMs in the building which could be damaged or disturbed during normal occupancy. This includes foreseeable maintenance and installation of things like boiler rooms, loft spaces and service ducts as well as assessing their condition.

The survey should be conducted in accordance with HSE’s HSG264 survey guide and undertaken by a competent asbestos surveyor. HSE Introduction to asbestos safety: Arrange an asbestos survey and Asbestos: The survey guide HSG264 (page 15 – see green ‘box 3’) set out how to commission a competent surveyor.

You need to do this for all buildings constructed before 2000, including new buildings with residual elements and equipment of pre-2000 buildings, such as kiln ovens. The information collected within the survey should then be used to produce an asbestos register. The register should include building diagrams showing the asbestos material locations.

All ACMs should be identified as far as is reasonably practicable as part of the management survey.

The areas inspected should include:

  • underfloor coverings
  • above false ceilings (ceiling voids)
  • lofts
  • inside risers
  • service ducts and lift shafts
  • basements
  • cellars
  • underground rooms
  • undercrofts

All areas that are considered accessible should be inspected.  Any areas not accessed must be presumed to contain asbestos. These should be clearly indicated on the survey and will have to be managed on this basis.

System buildings

This is especially true of system buildings and columns, as detailed in HSE’s managing asbestos in system built schools guidance (PDF, 70KB).

System buildings typically:

  • are prefabricated timber or light weight steel framed buildings, although they are sometimes concrete
  • have flat roofs
  • were constructed in the late 1940s to the early 1980s

Consideration must be given to those asbestos materials which are hidden within the structure of the building. They may include asbestos under floors, above ceilings and within walls and columns.

Management survey

A management survey is only suitable for managing asbestos during the normal occupation and use of your school or college. When maintenance or construction work is taking place, a refurbishment or demolition survey may be required. See asbestos management during maintenance or building works for the requirements in these cases.

When commissioning a survey, schools and colleges may find it helpful to arrange for the surveyor to meet staff to brief them on the survey once it is completed, advise them on the risks presented by the materials and how they should be managed. These meetings can be included within the surveyor’s terms of appointment.

If any occurrence of asbestos is deemed high-risk, the surveyor may recommend removal. In these cases, the dutyholder should seek to understand:

  • the basis of the recommendation, to enable suitable planning and prioritisation
  • any immediate or short-term management measures that are required to manage the risk

Schools and colleges that already have a survey should review their current document to ensure they are adequate and remain current. Some review questions may include:

  • was the survey undertaken by a suitably qualified UKAS accredited surveyor?
  • does the survey cover all relevant buildings or structures associated with the school or college and include all areas which are considered as accessible?
  • is the survey coherent and complete? All information relating to asbestos should be held together, clearly understandable, and any gaps in the information should be understood and filled, where possible
  • does the survey include details of hidden asbestos particularly if the building is a system building?
  • does the survey clearly identify any areas that were not surveyed and why? What are the implications of this? Are any other limitations or caveats within the survey considered and planned for?
  • does the survey clearly identify the location (including accessibility), quantity, type and condition of the asbestos materials identified and what they look like?
  • does the survey clearly identify genuinely inaccessible areas where the presence of asbestos is foreseeable or cannot be ruled out and as such must be presumed?
  • does the survey provide sufficient information to update or produce an asbestos register and an asbestos management plan for the premises? Both these documents should be kept up to date to reflect current locations and condition of any asbestos materials.
  • have any urgent remedial actions identified at the time of the survey been completed, for example the removal of ACMs in poor condition?
  • have all remedial actions detailed in the survey been included in the asbestos register, and reviewed to give timescales for completion or ongoing checks as appropriate?

Example

Previous interventions in schools by the HSE found that some schools did not understand the limitations of the surveys that had been undertaken. In one case the school had failed to recognise that the management survey did not extend to include the void above the ceilings, yet had undertaken work within the ceiling voids. An additional survey should have been commissioned prior to the start of any intrusive works above the ceilings.

Step 2: Assess the risks associated with asbestos materials in your school or college

Once the management survey is complete, the school or college must work with the asbestos surveyor to assess the risk associated with each identified occurrence of easily accessible and presumed asbestos. This is detailed in HSE’s A comprehensive guide to Managing Asbestos in premises guidance HSG 227: refer to appendices 3 and 4.  

The assessment has 3 parts:

Requirement Further information Responsibility
Material assessment: this is usually provided within the survey and is an assessment of each item of asbestos material identified based upon the type of material, the type of asbestos it contains, its surface treatment and the extent of damage. For ‘hidden’ asbestos, or asbestos which is ‘presumed’ or ‘strongly presumed,’ the material should be assumed to be Crocidolite, the more dangerous type, unless there is strong evidence to show otherwise. The survey provider should include this for every instance of asbestos-containing material identified, or those presumed to contain asbestos.
Priority assessment: this is your assessment of the likelihood of someone disturbing the material based upon factors such as the number and type (for example, children) of people using the room, the time they spend in the room, the location, accessibility and extent of the asbestos and the frequency and type of activity that might disturb it. This should include everyday activities and any risks of unusual activities which might disturb it (such as out of hours sports clubs, or pinning up decorations). It is crucial that staff are encouraged to feed into discussion on what the activities could be when planning, and to report any disturbance in their work areas or by those using the spaces. This should be undertaken by the school or college, supported by the surveying organisation and possibly the employer.
Total assessment: the material and priority assessments are combined to give the total risk assessment. This allows a comparison to be made of the risk presented by each item of asbestos materials in the building so that priorities can be set, and plans made for managing the asbestos materials. The HSE offers an example scoring system (algorithm) for the material and priority assessment contributions to the total risk assessment. Refer to appendices 2, 3 and 4 in A comprehensive guide to Managing Asbestos in premises. This should be undertaken by the duty holder or those appointed to help them complete the assessment. It combines the above two assessments and informs the AMP requirement.

The asbestos register

The management survey report Step 1 should contain a summary of the survey results in a format that can be used as the basis for an updatable register of ACMs. This should include:

  • drawings and photographs where relevant
  • the location, accessibility, extent and condition of the asbestos materials
  • the forms and material types of asbestos materials
  • what the asbestos materials look like (photographs can be helpful here)
  • the associated risk assessment of asbestos materials Step 2
  • a clear indication of parts of the building where the presence of asbestos materials is presumed
  • any areas which were not captured within the management survey and where the presence of asbestos cannot be ruled out. These areas will need to undergo a further survey ahead of access

HSE have an example register (PDF.293KB) and site plan.

You should update the asbestos register at least once a year as part of your asbestos management review to reflect the current status of the asbestos materials within the buildings. You can also do this before if anything changes the risk from an asbestos- containing material. An example is following routine ACM condition checks. You should record where further asbestos materials have been identified or removed during refurbishment work.

Where asbestos materials are in good condition, well protected and unlikely to be damaged or disturbed, they may be left in place and managed, provided they are regularly monitored, and the situation reassessed if conditions change. A change of circumstances, such as change of building use, will also require a review of the assessment.

If any asbestos materials are in poor condition, insufficiently encapsulated or at risk of being damaged or disturbed, seek professional advice regarding necessary remedial works.

In the case of schools, any asbestos materials remaining within accessible areas should be encapsulated, protected or be in a safe position to reduce the likelihood of damage.

HSE’s 3 worked examples of priority assessment algorithms for a primary school in a comprehensive guide to managing asbestos in premises (see appendices 3 and 4) contain further guidance on:

  • how you should consider the presence of children as part of your priority assessment
  • priority and material assessments
  • how to prioritise management action

Step 3: Prepare an asbestos management plan

A current AMP is essential to safe management of asbestos. The plan should set out your day-to-day management arrangements for controlling the risks from asbestos materials during normal and foreseeable activities in the premises.

The asbestos register (steps 1 and 2) information should be included in the AMP. The register and AMP should be shared with relevant safety representatives and all staff, particularly maintenance and cleaning staff.

Your AMP can be written or held as a computer-based record and should be readily accessible. Further information is available in HSE’s The duty to manage asbestos in buildings: write your asbestos management plan and monitor it.

The AMP should include:

  • the leadership statement on ownership of the risk and training arrangements for staff, including clear roles of specific individuals
  • plans for any necessary work identified from the risk assessment – both for any remedial work and for ongoing management actions
  • the asbestos register which brings together all the available and relevant information
  • ongoing arrangements to monitor and record the condition of asbestos materials
  • arrangements for actively managing the potential risk from presumed or ‘hidden’ asbestos
  • procedures for controlling routine maintenance work undertaken at the school or college
  • arrangements for the management of any construction or maintenance work – this should identify the checks to ensure that the correct controls and that competent HSE-licenced contractors are used
  • emergency procedures to be actioned in the event of inadvertent disturbance of asbestos-containing materials both within and outside the normal opening hours. See further guidance on What to do if things go wrong
  • communication arrangements for sharing the plan with staff and visitors (anyone who is liable to disturb asbestos materials as identified through a risk assessment)
  • the reporting and escalation procedures where any damaged asbestos is noted
  • AMP governance arrangements including
    • nomination of those who can make entries to or amendments to the AMP
    • the formal arrangements for reviewing and updating the AMP
    • the location of all asbestos related documentation as well as back up and business continuity arrangements

Arrangements for the management of asbestos in system building blocks

Dutyholders, appointed persons and staff should be aware of managing asbestos in system built schools guidance (PDF, 70KB). HSE’s guidance on managing asbestos in system buildings with asbestos clad columns.

Dutyholders of system buildings should assume that asbestos materials are present around structural columns and beneath casings and claddings, unless they know for certain that no asbestos materials are present.

Dutyholders should also be aware that similar asbestos protection may have been afforded to steel columns incorporated into traditionally built schools of the time. Those with asbestos clad columns should follow the checklist in annex 2.

This hidden and presumed asbestos may be visibly disturbed by maintenance and renovation activities but may also be unknowingly disturbed by:

  • everyday school activities
  • significant air movements
  • flooding
  • water ingress
  • weathering

Dutyholders should therefore always seek advice from an appropriate professional about the level of the potential risk from presumed or hidden asbestos and follow HSE’s guidance on managing asbestos in system built schools guidance (PDF, 70KB). Your management arrangements must consider all parties who may use the buildings. They should also be effective for community use during school or college closure periods, when staff presence is minimal or absent.

Example

Concerns were identified during some HSE inspections concerning the lack of clarity about the responsibilities associated with the management of asbestos.

In some cases, this shortfall meant that known asbestos-containing materials were not being monitored to identify any damage or deterioration in condition, which could lead to a risk of exposure. Shortfalls were also identified in respect of the employer’s wider monitoring to validate that the arrangements set out in the AMP were in place.

Step 4: Communication and training arrangements

Those with explicit asbestos responsibility

This will include the employer, dutyholder and any appointed persons. It is important that these persons are given suitable asbestos training and time to carry out the associated work alongside their existing obligations. There should also be business continuity deputies for those with responsibility, to avoid situations where there are no responsible staff on site at the time of a possible incident or query about asbestos materials.

School and college staff

A wider duty under the Control of Asbestos Regulations 2012 (CAR), Reg 10, requires employers to make sure that anyone liable to disturb asbestos during their work, or who supervises such employees, receives the correct level of information, instruction and training to enable them to carry out their work safely and competently and without risk to themselves or others. This will include agency, catering, premises and maintenance staff and should include every member of staff or voluntary supporter.

An important factor in selecting a suitable training provider is to ensure that the training content is appropriate for the ‘duty to manage’ responsibilities of the role. HSE’s Asbestos information, instruction and training contains information on asbestos awareness and management training

Some people, such as teachers, are unlikely to disturb asbestos but work in a building that contains it. You must inform them:

  • about the specific locations of ACMs in the rooms or areas they use and to avoid work that may disturb them
  • what to do in the event of accidental damage

See: The duty to manage asbestos in buildings: Provide information to anyone who might disturb asbestos

Contractors and those undertaking work in a school or college

It is essential to train contractors and communicate information about asbestos materials which may be disturbed. See the section on asbestos management during maintenance or building works.

Parents, carers and visitors

The AMP should clearly set out the information made available to parents, carers and other visitors (who are liable to disturb asbestos materials as identified through a risk assessment). Consider the controls in place for any out-of-hours or community use of the buildings.

Emergency services

Dutyholders should make information about the location and condition of any asbestos or suspected asbestos available to the emergency services. You should record in your AMP how this will be done. Conventionally, this will be achieved by the provision of an up-to-date copy of the asbestos register. In an emergency, you will need access to this information without having access to the building.

The public

Schools and colleges should agree their policy on sharing information with the general public and possibly include this within their AMP.

Step 5: Regularly review your asbestos management plan and asbestos register

You must update your asbestos register and AMP as circumstances change.

We recommend that you review the asbestos register and AMP at least annually. This should confirm that the information is accurate and that the arrangements are being effectively applied. It may include an audit.

Following the review, address any identified changes or shortfalls. Communicate any changes to the asbestos register or your AMP to all staff.

The review of the AMP should confirm that:

  • all responsible staff remain aware of their duties, and their training is up to date
  • regular inspections of ACMs to check their condition are taking place
  • contact details for people and organisations are up to date
  • all arrangements detailed in the plan are current, relevant, and proving effective

You must update it if:

  • there are changes in the identified responsible people or organisations, and consider arrangements to handover responsibilities where staff move on, to maintain continuity
  • you get new information, for example, from refurbishment or demolition surveys
  • work is undertaken on asbestos materials
  • asbestos-containing materials are removed, or any damage or deterioration to them is noticed
  • significant building works are undertaken which might confuse the documented location of identified asbestos

Asbestos management during maintenance or building works

For most schools and colleges, a key risk area is the potential disturbance of asbestos during maintenance or construction works.

There are specific actions that you must take where work is carried out on the premises, which might disturb asbestos materials, including upgrading, refurbishment or demolition. This includes any work that disturbs the fabric of your building, whether it is small-scale repair work carried out by your own staff or a large-scale project that is being contracted out.

When commissioning construction work, the Construction (Design and Management) Regulations 2015 require you to determine whether there is a risk that the work might disturb any asbestos materials, including any unidentified, presumed or hidden asbestos materials. Where this work will disturb the fabric of the building, you will need to arrange for a relevant refurbishment or demolition survey to be carried out. This is a more intrusive type of survey which involves destructive inspection by a trained specialist to identify all asbestos materials.

You must pass on the findings of both types of survey and details of any known or presumed asbestos materials in the work area to those who will be doing the work. You should also make sure that they use the correct risk control measures. This could be done by implementing a ‘permit to work’ system. Some small, short duration tasks can be carried out by non-licensed workers provided they have received appropriate training and the correct risk control measures are used. All licensed work on asbestos should be done by a licensed asbestos removal contractor (LARC).

HSE has published advice on the types of work considered to be licensable, notifiable non-licensable and non-licensable. Those undertaking the work should confirm that the information provided is sufficient. Examples can also be found in the HSE asbestos image gallery.

Checking work is proceeding safely

Once work is appropriately authorised, contractors should be prepared for the unexpected presence of asbestos materials. If further asbestos materials or suspect materials are uncovered, the work should stop, the area made safe and the work reassessed before continuing.

Where safe and reasonable to do so, school or college staff may check that work is proceeding safely and in accordance with the agreed method.

You should check that those undertaking the work have undertaken appropriate post work checks to ensure that the area is safe for re-occupation. If licensed asbestos works have been undertaken, this should include clearance and air test certificates.

It is essential that following any work to asbestos-containing materials, that the asbestos register and management plan are updated accordingly.

Asbestos-containing waste must be properly contained and disposed of in accordance with the Hazardous Waste Regulations 2005. If you have contracted out the work, disposal is the responsibility of the contractor, although you will have responsibility for obtaining a waste consignment note to confirm that the asbestos was appropriately disposed of.

Schools and colleges should ensure that all staff and other stakeholders are informed of the proposed works. Trade union health and safety representatives should be consulted in a timely manner on matters relating to the planned work as required by the Safety Representatives and Safety Committees Regulations 1977 (as amended) and the Health and Safety (Consultation with Employees) Regulations 1996 (as amended).

Example

The importance of managing works in line with regulations to avoid asbestos exposure, prosecution and financial sanctions.

The unsafe removal of asbestos insulation boards at a large school led to several people being exposed to asbestos fibres.

HSE prosecuted the school and the director of the company responsible for the refurbishment project, after an investigation found they had failed to identify and prevent the risk of asbestos exposure.

The HSE investigation found that over an 18-month period, from the initial design stages through to the construction work, there was inadequate planning and a failure to carry out a full asbestos survey, despite the fact that a sample taken from the building had identified the presence of asbestos.

The school was fined £60,000 and ordered to pay £13,000 in costs. The director of the company was fined £10,000 with costs of £6,000.

Additional survey information and specialist advice

Assume that materials contain asbestos if there is any doubt. Where the asbestos register is inconclusive, further survey information will be required. This may be the confirmation of an individual item or a targeted refurbishment or demolition survey.

A refurbishment survey is more intrusive than a management survey but typically includes only the specific areas where work is being undertaken. A refurbishment or demolition survey cannot be undertaken in occupied areas. In most cases it will result in significant damage to the fabric of the building. For these reasons careful planning will be required to ensure the survey can be completed. Use the findings from additional surveys to update the asbestos risk assessments, asbestos register, and AMP.

The Construction (Design and Management) Regulations 2015 (CDM) require you to provide information about existing hazards, including asbestos, to designers and builders at an early stage.

What to do if things go wrong

Contractors who may be working at the school or college are required to have procedures to deal with any unexpected release or exposure to asbestos. Schools and colleges must have similar arrangements. Exposure to asbestos can result from everyday school or college activities or accidents, such as the collapse of an asbestos ceiling.

Actions to take

If something goes wrong and you find that there has been, or may have been, an unplanned disturbance of asbestos you should:

  • stop any activity in the affected area immediately
  • remove everyone from the affected area and do not remove any items from the area as the spread of asbestos can occur through contaminated clothing or possessions
  • prevent access to the area until any necessary remedial action has been taken
  • seek immediate expert advice regarding necessary remedial action to be taken – there may be a need to decontaminate individuals or areas exposed to asbestos

Certain incidents which may have resulted in the release of asbestos fibres should be reported to HSE. Where relevant, this is a legal requirement under the Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR). If you are unsure whether the regulations apply, seek professional advice or contact HSE.

Staff, pupils, students and their parents or carers should be given relevant information to understand the risks and should be advised to consult their doctor.

Example

The financial costs of having to carry out decontamination can be high, and the education of pupils can suffer as a result.

In one school, a laboratory technician installed an IT cable through a ceiling void, putting holes through fire barriers and walls and contaminating most ceiling voids throughout the building. It was 9 months before the exposure was spotted by a surveyor. The clean-up required new ceilings and lighting to be installed and cost £280,000.

Another school arranged an electrical re-wiring over the summer. On observing the contractors with unsealed bags of asbestos waste, the school’s site manager contacted an experienced asbestos consultant. Asbestos contamination had spread throughout the school, affecting everything from computers, files and records to pupils’ coursework.

At the start of the autumn term, 1000 pupils had to move to temporary accommodation. The school did not reopen until the following summer term. The school and council incurred costs of £4.54 million as a direct result of the contamination. The HSE prosecuted the contractor.

Effective asbestos management arrangements should have prevented all these occurrences. For examples of how disturbance should have been prevented, refer to HSEs website: The duty to manage asbestos in buildings: Examples of how asbestos risks can be managed. 

There may still be case of inadvertent disturbance of ACMs even with effective asbestos management as not all events are foreseeable, such as a burst pipe. This is why scenario-based testing of the Asbestos Management Plan (AMP) including incident procedures is helpful to ensure that a school is as prepared as it can be.

Funding and support available for asbestos works

Capital funding is allocated to maintain and improve the condition of school buildings, including removing or encapsulating asbestos, where appropriate. Information is available on capital funding. Where there are serious issues with buildings that cannot be managed by responsible bodies, the department provides additional support on a case-by-case basis.

Typically, asbestos works are undertaken in conjunction with other condition related works, or will require significant associated works. For example, removal of an asbestos ceiling will generally require replacement of the lighting and potentially other electrical, fire alarm, IT and CCTV work.

Colleges are expected to budget for managing asbestos within their premises.

In implementing capital works to existing premises, colleges are expected to undertake any asbestos remediation works needed to deliver the project. Colleges should therefore ensure that appropriate asbestos surveys are undertaken to identify costs of addressing asbestos remediation and budget for this within overall project costs and funding bids, where applicable. Where there are serious issues with buildings that cannot be managed by FE colleges, the department may provide additional support on a case-by-case basis.

Procurement support

Visit Find a Framework to find DfE approved frameworks. To find asbestos services search for ‘Services’ then ‘Facilities Management and Estates,’ and then either ‘Estate Management Professional Services’ or ‘Total Facilities Management.’

If you need help using DfE approved frameworks contact Get Help Buying for Schools, the DfE’s free and impartial procurement service for people who buy goods and services for schools or trusts.  The service offers different levels of support including advice, guidance, and signposting to DfE approved frameworks. Select ‘I’m ready to buy now’ to start the process.

Further reading and resources

Responsibility for managing asbestos

Management surveys

Assessing associated risks

Asbestos management plans

Asbestos management plans

Communication and training arrangements

Asbestos management during maintenance or building works

Asbestos management

HSE guidance

Other guidance

The following organisations are a useful source of further information and have contributed to the creation of this guidance and its refresh. We would like to take this opportunity to thank them for their contribution.

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