RAMS for Asbestos Work: Non-Licensed and Notifiable Tasks in the UK

Asbestos remains the single greatest cause of work-related death in the UK. Every week, 20 tradespeople die from past exposure. If your team is working on any building constructed before the year 2000, your RAMS must account for the possibility of asbestos-containing materials (ACMs). Getting this wrong is not a paperwork issue. It is a matter of life and death.

This guide explains how to write a RAMS for non-licensed and notifiable non-licensed asbestos work under the Control of Asbestos Regulations 2012 (CAR 2012). It covers hazard identification, control measures, RPE selection, decontamination procedures, waste disposal, and training requirements.

Asbestos in the UK: The Scale of the Problem

Asbestos kills over 5,000 people per year in the UK. That figure exceeds the annual death toll from road traffic accidents. The diseases caused by asbestos exposure, including mesothelioma, asbestosis, and lung cancer, typically take 15 to 60 years to develop. Workers exposed today may not show symptoms until decades later. There is no safe level of exposure and no cure for mesothelioma.

Asbestos was widely used in UK construction until it was fully banned in 1999. It is estimated to be present in over 75% of buildings built before 2000. It was valued for its heat resistance, strength, and insulating properties, which means it was used in a huge range of building materials.

Common locations where asbestos is found include:

• Textured coatings such as Artex on ceilings and walls
• Floor tiles and tile adhesive (thermoplastic tiles)
• Pipe lagging, boiler insulation, and loft insulation
• Asbestos cement sheets (roofing, wall cladding, guttering)
• Gaskets and rope seals in heating systems
• Corrugated roof sheets on garages, farm buildings, and industrial units
• Window putty and flue pipes

The critical rule: if a building was constructed or refurbished before 2000, assume asbestos is present until a competent survey proves otherwise.

Licensed vs Non-Licensed vs NNLW

The Control of Asbestos Regulations 2012 (CAR 2012) divides asbestos work into three categories. Understanding which category your work falls into determines everything: who can do the work, what notifications are required, and what level of control measures your RAMS must specify.

Licensed Work

Licensed work covers the most dangerous asbestos activities. This includes removal or disturbance of sprayed asbestos coatings, pipe lagging, asbestos insulating board (AIB) in poor condition, and any work where fibre release cannot be adequately controlled. Only contractors holding an HSE licence can carry out this work. Licensed work requires a 14-day notification to HSE, medical surveillance, and designated asbestos analysts for clearance testing. If your project involves licensed work, your RAMS alone is not sufficient. You need a licensed contractor with their own plan of work under Regulation 7 of CAR 2012.

Notifiable Non-Licensed Work (NNLW)

NNLW sits in the middle ground. It covers work with asbestos-containing materials that are in reasonable condition but still pose a risk above the background level. Typical examples include removing asbestos cement sheets, removing asbestos floor tiles (where the tiles are intact but bonded), and working with AIB in good condition where exposure is sporadic and of low intensity.

NNLW has specific legal requirements that your RAMS must reflect:

• You must notify HSE online at least 14 days before work starts (or pay the fee for a shorter notification period)
• Workers must be under health surveillance, including a medical examination by a doctor with an appropriate certificate (Regulation 22)
• You must keep records of NNLW on each worker's record (kept for 40 years)
• Workers must hold appropriate training (see Training Requirements below)

Non-Licensed Work

Non-licensed work covers tasks with the lowest risk: brief, non-continuous maintenance tasks on materials that are in good condition where exposure is well below the control limit. Examples include drilling through an asbestos cement wall to install a bracket, painting over asbestos cement in good condition, or minor repair work that does not involve cutting or significant abrasion.

Even non-licensed work still requires a RAMS, asbestos awareness training for all workers, and appropriate control measures. The fact that work is "non-licensed" does not mean it is safe. It means the exposure risk is lower, not absent.

When You Need an Asbestos Survey First

Before you can write a RAMS for any work that may disturb asbestos, you need to know what you are dealing with. This means an asbestos survey. Under the Duty to Manage asbestos (Regulation 4 of CAR 2012), the person responsible for the building (the duty holder) must identify and manage ACMs. There are two types of survey, and the distinction matters.

Management Survey

A management survey is the standard survey for normal occupancy and maintenance of a building. It identifies ACMs that could be disturbed during routine work (maintenance, minor repairs, cable routing). This survey type samples accessible materials but does not destructively inspect behind walls, above ceilings, or inside ducts.

Refurbishment and Demolition (R&D) Survey

An R&D survey is required before any refurbishment or demolition work. It is more intrusive, involving destructive inspection to access all areas where work will take place. This survey must be conducted in accordance with HSG264 (Asbestos: The survey guide). The building or area being surveyed should be vacated and, where possible, decommissioned before the survey takes place.

Do not start work without the correct survey.

The duty holder (building owner, landlord, or client) is responsible for commissioning and providing this survey. As a contractor, you have a duty to request it and to refuse to start work if it has not been provided. Your RAMS should state which survey type has been reviewed and reference the survey report by name, date, and surveyor.

Writing the RAMS: Key Sections

Your RAMS for asbestos work needs to be significantly more detailed than a standard construction RAMS. Every section must demonstrate that you understand the specific risks of asbestos fibre release and have planned proportionate controls. Here are the key sections your document must address.

Hazard Identification

Your RAMS must identify the specific type of asbestos present. There are three main types, each with different risk profiles:

• Chrysotile (white asbestos) is the most commonly encountered type, found in cement products, textured coatings, and roofing materials. It accounts for around 90% of asbestos used in UK buildings.
• Amosite (brown asbestos) was commonly used in insulation, ceiling tiles, and thermal insulation products. It is more hazardous than chrysotile.
• Crocidolite (blue asbestos) is the most dangerous form. It was used in spray coatings, pipe insulation, and some cement products. Any disturbance of crocidolite almost certainly requires licensed work.

Reference the asbestos survey results directly. State the material type, its condition (good, fair, poor), its location within the building, and the specific work activities that will disturb it.

Exposure Controls

The hierarchy of control for asbestos work prioritises preventing fibre release at source. Your RAMS should specify the following control measures, as appropriate to the task:

• Wet methods: Dampen materials with water containing a small amount of washing-up liquid (to reduce surface tension) before and during removal. This is the single most effective way to suppress fibre release.
• Shadow vacuuming: Use an H-class vacuum (BS EN 60335-2-69) held close to the point of work to capture fibres as they are released. Shadow vacuuming should be used alongside wet methods, not as a replacement.
• H-class vacuum: Only H-class (HEPA-filtered) vacuums are suitable for asbestos work. Standard industrial vacuums will pass asbestos fibres straight through the filter and increase airborne contamination.
• Controlled removal techniques: Remove materials whole wherever possible. Do not break, saw, drill, or use power tools on ACMs unless absolutely necessary and specified in the method statement. Bolts should be cut rather than unbolted where this reduces vibration and disturbance.
• Enclosure: For larger removal tasks, consider constructing a polythene enclosure with negative pressure (using a filtered extraction unit). This is mandatory for licensed work and strongly recommended for larger NNLW tasks.

Respiratory Protective Equipment (RPE)

RPE selection for asbestos work is governed by HSG248 (Asbestos: The analysts' guide for sampling, analysis and clearance procedures). The minimum standard for any asbestos work is an FFP3 disposable respirator. FFP3 provides an assigned protection factor (APF) of 20, meaning it reduces exposure by a factor of 20.

For sustained work or tasks with higher fibre release, a powered air-purifying respirator (PAPR) with a P3 filter provides an APF of 40 and is far more comfortable for extended wear. Full-face masks with P3 filters provide an APF of 40 as well.

All RPE must be face-fit tested to the individual wearer. A respirator that does not seal properly to the face provides no protection. Your RAMS must specify the RPE type, confirm that face-fit testing has been completed, and state that RPE will be inspected before each use.

Decontamination

Decontamination procedures prevent asbestos fibres from being carried outside the work area on clothing, skin, or equipment. Your RAMS should define a clear decontamination process. For NNLW, this typically includes:

• Transit route: A clearly defined and signed route from the work area to the decontamination facility. This route must be kept clear and not pass through occupied areas.
• Dirty area: Workers remove contaminated disposable overalls (Type 5/6 as a minimum) and place them in a labelled asbestos waste bag.
• Air shower / wash area: Workers shower or use a damp cloth to remove fibres from skin and hair before entering the clean area. For licensed work, a full decontamination unit with shower is required.
• Clean area: Workers put on clean clothing. Personal clothing must never be worn in the work area.

RPE should be the last item removed during decontamination, after overalls and before entering the clean area.

Waste Handling

Asbestos waste is classified as hazardous waste under the Hazardous Waste Regulations. Your RAMS must specify the complete waste disposal chain:

• All asbestos waste must be double-bagged in labelled red asbestos waste bags or wrapped in polythene sheeting (for larger items like cement sheets) and labelled with the asbestos warning symbol.
• Waste must be transported by a licensed waste carrier registered with the Environment Agency.
• A consignment note must be completed for every load of asbestos waste. You must keep copies for a minimum of three years.
• Waste must be disposed of at a licensed landfill site that accepts asbestos waste.
• Disposable PPE (overalls, gloves, overshoes) used during asbestos work must also be treated as asbestos waste.

Never use a standard skip for asbestos waste. Never mix asbestos waste with general construction waste. These are criminal offences under environmental legislation.

Training Requirements

Regulation 10 of CAR 2012 requires that every employer must ensure that anyone who is liable to be exposed to asbestos receives adequate training. Your RAMS must specify the training requirements for every person on site.

• All workers on site: Asbestos awareness training (Category A). This applies to anyone who might come into contact with ACMs during their normal work, including electricians, plumbers, joiners, roofers, heating engineers, and general labourers. This training must be refreshed annually.
• Workers handling asbestos directly: Category B training for non-licensed work. This covers the practical skills needed to safely carry out non-licensed asbestos tasks: using wet methods, RPE selection and use, decontamination procedures, and waste handling.
• Analysts: If air monitoring or clearance testing is required, the analyst must be UKAS accredited (ISO 17025). Your RAMS should name the analyst firm and their UKAS accreditation number.

As the employer or principal contractor, you have a duty to check competence. Do not accept verbal assurances. Request and record certificates for every operative before they enter the work area. Your RAMS should include a section confirming that training records have been verified.

Air Monitoring

Air monitoring measures the concentration of asbestos fibres in the air during and after removal work. The workplace exposure limit (WEL) for asbestos is 0.1 fibres per cubic centimetre of air, measured as a 4-hour time-weighted average, or over a 10-minute short-term exposure limit. This limit applies to all types of asbestos.

For licensed removal work, a 4-stage clearance process is required after removal is complete:

1. Preliminary check of the enclosure by the analyst to confirm all visible ACMs have been removed.
2. Thorough visual inspection after the enclosure has been cleaned and all sheeting is intact.
3. Air monitoring using the fibre counting method. The clearance indicator level is 0.01 fibres/cm3 (one-tenth of the WEL).
4. Final assessment after enclosure dismantling and a second visual check to confirm the area is safe for reoccupation.

For NNLW and non-licensed work, formal 4-stage clearance is not mandatory, but your RAMS should still specify how you will verify the area is safe after work is complete. At a minimum, this should include a thorough visual inspection and cleaning of the area with an H-class vacuum, followed by confirmation that no visible debris remains.

Generate Your Asbestos RAMS

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Related Guides

For more guidance on health and safety documentation, see our other guides:

• COSHH Assessment for Silica Dust
• Construction Phase Plan: What You Need to Know
• CDM Regulations 2015: A Complete Guide
• What is a RAMS? The Complete Guide

Where to Find Asbestos in Buildings

Asbestos was used in thousands of building products across the UK from the 1950s through to the late 1990s. If a building was constructed or refurbished before the year 2000, you should assume asbestos is present until a competent surveyor confirms otherwise. The material was cheap, fire-resistant and easy to work with, which is why it ended up in so many different building elements.

The following is a detailed breakdown of where asbestos-containing materials (ACMs) are commonly found, organised by building element.

Textured coatings and Artex: Textured decorative coatings applied to ceilings and walls before 2000 frequently contained chrysotile (white asbestos). Artex is the best-known brand, but many other products used the same formulation. Sanding, scraping, or drilling into these coatings can release fibres. A bulk sample analysis is needed before any disturbance.

Floor tiles (especially 9x9 inch thermoplastic tiles): Vinyl and thermoplastic floor tiles manufactured before the mid-1980s commonly contained chrysotile asbestos. The classic 9x9 inch (229mm) tile is a strong indicator, though other sizes can also contain asbestos. The adhesive (bitumen-based mastic) used to stick these tiles down may also be an ACM. Breaking, grinding, or using power tools on these tiles is particularly hazardous.

Pipe lagging and thermal insulation: Pipes in older buildings, particularly heating systems and hot water pipework, were often insulated with asbestos lagging. This is one of the most dangerous forms because the material is typically loose and friable, meaning it crumbles easily and releases fibres with minimal disturbance. Lagging removal is almost always licensed work under CAR 2012.

Boiler flues and heating appliances: Flue pipes, gaskets inside boilers, and rope seals around boiler doors often contained asbestos for its heat-resistant properties. Plumbers and heating engineers should always check the age and specification of a boiler system before dismantling any part of it.

Ceiling tiles: Suspended ceiling tiles in commercial and public buildings frequently contained asbestos. These are commonly found in offices, schools, hospitals, and council buildings built or refurbished before 2000. The void above the ceiling grid can also contain loose asbestos debris from previous work.

Asbestos insulation board (AIB): AIB was used as a general-purpose building board. Common locations include panels around heaters and radiators, linings inside ceiling voids, partition walls, soffits, and fire-stopping in service risers. AIB typically contained amosite (brown asbestos) and is classified as a higher-risk material. Its removal normally requires a licensed contractor, unless the work qualifies as notifiable non-licensed work (NNLW) under specific conditions.

Window putty and sealants: Putty used to bed glass into window frames, particularly in metal-framed windows, may contain chrysotile asbestos. This is often overlooked during window replacement projects. Removal by scraping or grinding creates fine dust that can contain asbestos fibres.

Roofing felt and cement roofing products: Bituminous roofing felt, corrugated roof sheets, and flat roof decking material can all contain asbestos. Asbestos cement products were extremely common in industrial, agricultural, and domestic buildings. While intact cement sheets are relatively low risk, cutting, drilling, or breaking them releases fibres.

Cement rainwater goods: Gutters, downpipes, and soffits made from asbestos cement are found on many older properties. They are usually grey in colour and noticeably heavier than modern plastic equivalents. Breakage during removal is the main risk.

Fire doors: Older fire doors may have an asbestos core or contain asbestos insulation board as part of their fire rating. Cutting, planing, or routing these doors will release fibres. Any modification to a fire door in a pre-2000 building should be preceded by testing.

Fuse box backings and electrical switchgear: Flash guards and backing boards behind electrical distribution boards were frequently made from asbestos insulation board due to its electrical insulating and fireproofing properties. Electricians working on older installations should check for this before drilling or removing boards.

Gaskets and rope seals: Asbestos was woven into rope seals, gaskets, and packing materials used in boilers, pipework flanges, and industrial plant. These components are often small and easily missed during surveys but can still release harmful fibres when disturbed.

The key takeaway: if a building was constructed or refurbished before the year 2000, treat every material as a potential ACM until a survey confirms it is asbestos-free. A pre-work asbestos survey is not optional. It is a legal requirement under CAR 2012 for any refurbishment or demolition project.

The Refurbishment and Demolition Survey

Before any refurbishment or demolition work begins on a building constructed before 2000, the duty holder must commission a Refurbishment and Demolition (R&D) Survey. This is a legal obligation under Regulation 5 of the Control of Asbestos Regulations 2012, and the guidance for conducting these surveys is set out in HSG264 (the Asbestos Survey Guide published by the HSE).

An R&D survey is fundamentally different from a management survey. A management survey is designed to locate asbestos that could be disturbed during normal occupancy and routine maintenance. It is primarily a visual inspection with limited sampling. An R&D survey, by contrast, is intrusive. The surveyor must physically access concealed spaces and materials that will be affected by the planned work. This means lifting carpet, opening up walls, removing panels, breaking into ceiling voids, and taking samples from every suspect material in the work area.

The R&D survey must cover all areas that will be affected by the refurbishment or demolition work. If the scope of the project changes after the initial survey, additional areas must be surveyed before work extends into them. The survey cannot be partial or selective. Every element that workers will cut, drill, remove, or disturb must be assessed.

It is the duty holder's responsibility (typically the building owner or client) to commission and pay for the R&D survey. The contractor carrying out the refurbishment should not be expected to fund the survey, and, critically, no contractor should start work without first seeing the survey results. If a contractor arrives on site and no R&D survey has been carried out, the correct course of action is to refuse to start until the survey is complete.

The survey must be conducted by a UKAS-accredited surveying organisation. The surveyor will produce a report identifying all ACMs found, their condition, and recommendations for how they should be managed or removed before the work proceeds. This report directly informs the RAMS and method statements for the project.

Notifiable Non-Licensed Work: The Process

Notifiable non-licensed work (NNLW) covers tasks involving certain asbestos-containing materials where the risk is significant enough to require HSE notification, but not so high that a licensed contractor is needed. Examples include removing asbestos cement sheets, asbestos textured coatings, or certain asbestos insulation board in limited quantities. The following is a step-by-step process for carrying out NNLW safely and legally.

1. Designate a supervisor. A competent person must be appointed to oversee the asbestos work. This supervisor must understand the risks, the control measures, and the legal requirements. They are responsible for ensuring the work is carried out in accordance with the plan of work.

2. Ensure workers hold Category B asbestos training. All operatives carrying out NNLW must have completed asbestos awareness training (Category A) plus the additional Category B training for non-licensed work. This training must be refreshed annually. Basic asbestos awareness alone is not sufficient for hands-on NNLW tasks.

3. Notify the HSE at least 14 days before work starts. NNLW requires online notification to the HSE via the ASB5 form. This must be submitted at least 14 days before the work begins. If the work is urgent (for example, an emergency repair), you can notify the HSE by telephone to request short-notice approval. Keep a copy of the notification and the HSE acknowledgement on site.

4. Set up controlled wetting. All asbestos materials must be thoroughly wetted before and during removal to suppress fibre release. Use a low-pressure garden sprayer with water and a small amount of washing-up liquid (to act as a wetting agent). Never use power tools or high-pressure water on asbestos materials. The material should be damp throughout, not just on the surface.

5. Use shadow vacuuming with an H-class vacuum. While removing asbestos materials, a second operative should hold the nozzle of an H-class (HEPA-filtered) vacuum cleaner close to the point of disturbance to capture any fibres released. This technique is known as shadow vacuuming and is a key control measure for NNLW. Standard workshop or domestic vacuum cleaners must never be used as they do not capture asbestos fibres and will actually spread contamination.

6. Wear appropriate RPE (FFP3 minimum). All workers must wear respiratory protective equipment rated to at least FFP3 (disposable) or a half-mask with P3 filters. RPE must be face-fit tested for each individual wearer. Disposable overalls (Type 5/6), gloves, and boot covers should also be worn. All PPE is single-use and must be disposed of as asbestos waste after the task.

7. Set up a mini enclosure or polythene sheeting. The work area must be isolated from surrounding spaces. For small-scale NNLW, this typically means laying 500-gauge polythene sheeting on the floor beneath the work area and taping it up the walls to create a contained zone. For larger tasks, a mini enclosure with a simple airlock may be necessary. Warning signs and barriers must be placed to prevent unauthorised access.

8. Double-bag waste in red asbestos waste bags. All asbestos waste, including the polythene sheeting, used PPE, rags, and the ACMs themselves, must be double-bagged in clearly labelled red asbestos waste bags or wrapped in polythene and labelled. Waste must be collected by a licensed waste carrier and taken to a site permitted to accept asbestos waste. You must obtain a consignment note (hazardous waste) and keep it for at least three years.

9. Personal decontamination. After completing the work, operatives must decontaminate before leaving the work area. For NNLW, this typically involves carefully removing disposable overalls (rolling them inwards to trap fibres), wiping down with damp rags, and bagging all contaminated items. A personal shower should be taken as soon as practicable after the work. Do not take contaminated clothing home or wash it with regular laundry.

10. Air monitoring (recommended). Air monitoring is not legally mandatory for NNLW, but it is strongly recommended, especially for textured coating removal and AIB work. Personal air sampling during the task and background/reassurance sampling after completion provide evidence that fibre levels were controlled and the area is safe to reoccupy. This evidence also demonstrates due diligence in the event of any future claims.

11. Health surveillance within 30 days. Employers must ensure that workers who carry out NNLW receive health surveillance. This involves a medical examination (including a respiratory questionnaire and lung function test) that must be completed within 30 days of the first exposure. Health records must be kept for 40 years. This is a legal requirement under Regulation 22 of CAR 2012.

Frequently Asked Questions

Can I drill into Artex without a survey?

No. If the Artex or textured coating was applied before 2000, you must assume it contains asbestos until laboratory analysis of a bulk sample confirms otherwise. Drilling into asbestos-containing Artex releases fibres directly into the breathing zone. Even a single hole can produce measurable fibre concentrations. Either have the material tested first, or treat it as an ACM and follow the appropriate controls. DIY sampling kits are available, but commercial and industrial settings require a UKAS-accredited surveyor.

What about textured paint in a house I am renovating?

The same rules apply to domestic properties as to commercial ones. If you are a homeowner carrying out DIY work, you are not subject to CAR 2012 in the same way as an employer, but the health risks are identical. If you are a contractor or tradesperson working on someone else's home, you have the same legal duties as you would on any other site. Have the textured coating tested. If it contains asbestos, either leave it in place (overboard with new plasterboard, for example) or have it removed by a competent person following NNLW procedures. Sanding asbestos-containing textured coatings is one of the most common causes of avoidable asbestos exposure in the UK.

Is white asbestos (chrysotile) safe?

No. All forms of asbestos are classified as carcinogenic. Chrysotile (white asbestos) is the most commonly encountered type in UK buildings and causes mesothelioma, lung cancer, and asbestosis just like amosite (brown) and crocidolite (blue). The perception that white asbestos is "safe" or "low risk" is a dangerous misconception. The legal controls under CAR 2012 apply equally to all asbestos types. The only difference in regulation is that some work with chrysotile-only materials may fall under non-licensed or NNLW categories rather than requiring a licensed contractor, but the health hazard remains serious.

How long does asbestos awareness training last?

Asbestos awareness training (Category A) is valid for 12 months and must be refreshed annually. This applies to anyone whose work could foreseeably disturb asbestos, including electricians, plumbers, joiners, roofers, and general builders. Category B training for non-licensed work must also be refreshed annually. The training does not need to be a full-day course each time. A shorter refresher covering current legislation, case studies, and practical controls is acceptable, provided it is delivered by a competent trainer and documented.

What happens if I accidentally disturb asbestos?

Stop work immediately. Do not attempt to clean up the material yourself. Evacuate the area and prevent anyone from entering. Close doors and windows to limit fibre spread. Contact your supervisor and, if you are on a commercial site, the duty holder. The incident may need to be reported to the HSE under RIDDOR. A specialist asbestos contractor should be called to assess the contamination, carry out air monitoring, and clean up the area. Do not resume work until the area has been declared safe. Record the incident in writing, including who was present and the duration of potential exposure.

Authority Sources

The following external resources provide authoritative guidance on asbestos management and compliance in the UK.

HSG248: Asbestos: The Analysts' Guide - The HSE technical guidance for air monitoring and bulk sample analysis of asbestos. Essential reference for anyone commissioning air testing during or after asbestos work.

HSG264: Asbestos: The Survey Guide - The definitive guide to management surveys and refurbishment/demolition surveys. Covers survey planning, sampling strategies, and reporting requirements.

Control of Asbestos Regulations 2012 (CAR 2012) - The full text of the primary legislation governing asbestos management, removal, and disposal in Great Britain. Published on legislation.gov.uk.

HSE Asbestos Licensing Page - Explains the licensing requirements for asbestos removal work, how to check if a contractor is licensed, and the distinction between licensed, NNLW, and non-licensed work categories.

You may also find these related guides from our blog useful.

COSHH Assessment for Silica Dust - Another hazardous substance commonly encountered on construction sites, with similar COSHH obligations to asbestos.

Construction Phase Plan Guide - How to prepare the principal document for managing health and safety on a construction project, including provisions for asbestos.

CDM Regulations Explained - Understanding the Construction (Design and Management) Regulations 2015, which place duties on clients, designers, and contractors to manage risks including asbestos.

Confined Space Risk Assessment - Asbestos work sometimes takes place in confined or enclosed spaces, adding additional hazards that require their own assessment.

What Is a RAMS? - A complete introduction to Risk Assessment and Method Statements, the foundation document for planning any asbestos task safely.