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