Not all asbestos work is the same. UK law divides asbestos work into three categories based on risk: licensed work, notifiable non-licensed work (NNLW), and non-licensed work. Understanding which category applies to your work is crucial for legal compliance and worker safety.
What type of asbestos work are you planning?
Let's determine what's required.
Overview: Three categories of asbestos work
Under the Control of Asbestos Regulations 2012 (CAR 2012), asbestos work is divided into three categories based on the level of risk:
1. Licensed work
High-risk work with asbestos insulation, insulation board, or coatings. Requires an HSE license. Typically involves high fibre release.
2. Notifiable non-licensed work (NNLW)
Medium-risk work that doesn't require a license but must be notified to the HSE if it exceeds certain thresholds.
3. Non-licensed work
Lower-risk work with certain asbestos materials in good condition. No license or notification required, but strict controls still apply.
Every category of asbestos work requires proper training, risk assessment, and controls. "Non-licensed" doesn't mean "safe" or "unregulated" — it simply means a license isn't legally required.
Licensed asbestos work
Licensed work involves the highest risk activities and can only be carried out by contractors holding a valid HSE license.
What is licensed work?
Licensed work includes work with:
Asbestos insulation:
- Pipe lagging and thermal insulation
- Boiler and vessel insulation
- Spray-applied insulation on structural members
- Loose-fill insulation in cavity walls or lofts
- Mattress-type insulation products
Asbestos insulating board (AIB):
- Wall and ceiling panels
- Fire protection boards
- Partitions and fire doors
- Window sills and panels
- Bath panels made from AIB
- Duct and service enclosures
Asbestos coatings:
- Spray-applied coatings on steel beams and columns
- Textured coatings containing asbestos (when removing large areas)
- Decorative spray finishes
Asbestos insulation, AIB, and coatings are considered high-risk because they typically contain high percentages of asbestos (often 20-85%) and release large quantities of fibres when disturbed.
Exceptions to licensing
Even for materials above, a license is NOT required for:
- Asbestos cement — although it contains chrysotile, the asbestos is tightly bound
- Textured coatings (like Artex) containing asbestos — when removing small areas (less than 10m² externally or 5m² internally per person per hour)
- Short non-continuous maintenance activities — where cumulative exposure is below action level and work is sporadic
HSE licensing requirements
To obtain an asbestos license, contractors must demonstrate:
1. Technical competence:
- Supervisors with appropriate qualifications (BOHS P405 or equivalent)
- Operatives trained to appropriate standard
- Demonstrated experience with licensed work
2. Adequate resources:
- Appropriate equipment and facilities
- Suitable decontamination units
- Personal protective equipment (PPE)
- Air monitoring and testing equipment
3. Management systems:
- Written procedures and work methods
- Quality management system
- Emergency procedures
- Record keeping systems
4. Insurance:
- Public liability insurance (minimum £1 million)
- Employers' liability insurance
5. Medical surveillance:
- Health surveillance programme for all workers
- Medical examinations before starting work
- Ongoing monitoring throughout employment
Licenses must be renewed every three years and can be revoked for non-compliance.
Check any contractor's license status on the HSE website before appointing them. The HSE maintains a public register of all licensed asbestos contractors.
Non-licensed asbestos work
Non-licensed work involves lower-risk asbestos materials or small-scale work where exposure can be controlled to very low levels.
What is non-licensed work?
Non-licensed work includes:
Asbestos cement products:
- Roof sheets and tiles
- Wall cladding and panels
- Rainwater gutters and downpipes
- Window surrounds
- Soffits and fascias
Textured coatings:
- Small areas of Artex or similar (below notification thresholds)
- Decorative finishes containing chrysotile
Vinyl and thermoplastic floor tiles:
- Floor tiles containing asbestos
- Adhesives and backings
Certain bituminous products:
- Roofing felt and flashings
- Damp-proof courses
- Gaskets and packing materials
Low-risk maintenance:
- Minor repairs that don't disturb asbestos
- Non-intrusive maintenance on ACMs in good condition
When non-licensed work becomes NNLW
Non-licensed work must be notified to the HSE (becoming NNLW) if:
- Work will take more than 2 hours in total, OR
- More than one person is involved and combined work exceeds 1 hour
These thresholds are cumulative over a 7-day period for the same project.
The notification thresholds are deliberately low to ensure the HSE is aware of significant asbestos work, even if it doesn't require licensing. NNLW must be notified at least 14 days before work starts (or 28 days if it's the first time you've notified).
Notifiable non-licensed work (NNLW)
NNLW sits between licensed and non-licensed work. It doesn't require a license, but you must notify the HSE before starting.
NNLW notification requirements
What to notify:
- Description of work and location
- Types of asbestos involved
- Methods to be used
- Start date and expected duration
- Names of persons carrying out the work
- Evidence of training and competence
When to notify:
- At least 14 days before work starts (first notification for an employer)
- At least 14 days for subsequent notifications
- 28 days for first-ever notification by that employer
Where to notify:
- HSE online notification system
- Postal notifications for paper forms
- Keep evidence of submission
NNLW record keeping
For all NNLW, you must maintain records including:
- Risk assessment and method statement
- Training certificates for all workers
- Air monitoring results (where required)
- Details of controls and RPE used
- Health surveillance records
- Waste consignment notes
- Clearance certificates
Records must be kept for at least 5 years (40 years for health surveillance records).
Builder fined for unlicensed asbestos removal
A small building firm removed asbestos insulating board (AIB) from a ceiling during a property renovation without an HSE license or proper controls.
- ✗Assumed AIB removal was non-licensed work
- ✗Did not conduct proper survey or testing
- ✗No license, training, or proper controls in place
- ✗Exposed workers and building occupants to fibres
- ✗Failed to notify HSE or obtain clearance certificate
HSE prosecution resulted in £80,000 fine plus costs. Director received a suspended prison sentence. Workers required ongoing health surveillance. Property required expensive emergency decontamination.
AIB removal is always licensed work, regardless of quantity. Never assume material type or work category without proper identification. The penalties for working without a license are severe.
Types of asbestos and work categories
The type of asbestos affects which work category applies.
Chrysotile (white asbestos)
Characteristics:
- Most common type (95% of UK usage)
- White or grey fibrous appearance
- Relatively flexible serpentine fibres
Work categories:
- Licensed: When in insulation, AIB, or spray coatings
- Non-licensed/NNLW: When in asbestos cement, floor tiles, or other low-risk materials
- Risk level: Lower than amphiboles but still dangerous
Even though chrysotile is considered "less dangerous" than blue or brown asbestos, it's still a proven carcinogen. All chrysotile exposure must be prevented or minimized.
Amosite (brown asbestos)
Characteristics:
- Second most common in UK buildings
- Brown or grey straight brittle fibres
- Amphibole type (more hazardous)
Work categories:
- Licensed: Almost always requires licensing
- Common in: Pipe insulation, AIB, thermal insulation, rope seals
- Risk level: Higher than chrysotile — fibres more easily inhaled
Typical uses:
- Sprayed coatings on steel structures
- Thermal insulation around pipes and vessels
- AIB in ceiling tiles and panels
- Gaskets and packing
Crocidolite (blue asbestos)
Characteristics:
- Blue coloured fibres
- Straight, very fine amphibole fibres
- Most dangerous type
Work categories:
- Licensed: Always requires licensing
- Common in: Spray coatings, insulation, some cement products, certain AIB
- Risk level: Highest risk — very fine fibres easily lodge in lungs
Typical uses:
- Sprayed insulation on structural steel
- Pipe insulation (especially in industrial settings)
- Some specialized cement products
- Certain insulating boards
You cannot determine asbestos type or work category by sight alone. Always obtain a laboratory-verified asbestos survey before planning any work. Assume the highest risk category until proven otherwise.
Determining work category
Follow this process to determine which category your work falls into:
Step 1: Identify the material
Get a proper survey:
- Management survey for building management
- Refurbishment/demolition survey before any work
- Laboratory analysis of samples
- Asbestos register review
What you need to know:
- Material type (insulation, cement, floor tiles, etc.)
- Asbestos type (chrysotile, amosite, crocidolite)
- Condition and friability
- Location and extent
Step 2: Assess the work scope
Consider these factors:
- What work will be done? (removal, repair, disturbance)
- How much material is involved?
- How long will the work take?
- How many people will be working?
- What's the risk of fibre release?
Step 3: Apply the decision tree
Use this simplified decision process:
Work Category Decision Flow
Licensed Work Required If:
- •Work involves asbestos insulation of any type
- •Work involves asbestos insulating board (AIB)
- •Work involves asbestos spray coatings
- •Removing textured coating >10m² external or >5m² internal per hour
- •Material contains amosite or crocidolite in insulation products
Non-Licensed (possibly NNLW) If:
- •Work with asbestos cement in good condition
- •Work with vinyl/thermoplastic floor tiles
- •Small areas of textured coating below thresholds
- •Certain bituminous products
- •Very short-duration maintenance below exposure limits
Bottom line: When in doubt, assume the work is licensed. Using a licensed contractor when not strictly required is much safer than working without a license when one is needed.
Step 4: Assess notification requirements
If work is non-licensed, determine if NNLW notification applies:
Notify HSE if:
- Total work time exceeds 2 hours, OR
- Multiple workers combine for more than 1 hour
- (Over 7-day period for same project)
Exemptions from notification:
- Work with materials naturally occurring in the ground
- Work below time thresholds
- Licensed work (separate license requirements apply)
Getting the work category wrong is a serious offense. If you work on licensed materials without a license, you face prosecution, unlimited fines, and up to 2 years imprisonment. Always seek expert advice if uncertain.
Training requirements
Training requirements differ by work category, but all asbestos work requires some level of training.
Category A: Licensed work
Supervisors must have:
- BOHS P405 (Asbestos Supervision of Licensed Work) or equivalent
- Experience in planning and supervising licensed work
- Knowledge of regulations and control measures
- Annual refresher training
Operatives must have:
- BOHS P401 (Asbestos Surveying and Bulk Sampling) or equivalent
- Hands-on training in licensed removal techniques
- Respiratory protective equipment (RPE) fit testing
- Use of decontamination units and airlocks
- Emergency procedures
- Annual refresher training
Additional training:
- Air monitoring and testing (for designated staff)
- Asbestos analyst training (for clearance testing)
- Emergency procedures and rescue
Category B: Non-licensed and NNLW
All workers must have:
- Asbestos awareness training (minimum)
- CAR 2012 Regulation 10 training for non-licensed work
- Training specific to the work type and materials
- RPE fit testing if wearing respirators
- Annual refresher training recommended
Training should cover:
- Health risks of asbestos exposure
- Types and uses of asbestos
- Where asbestos is likely to be found
- How to recognize asbestos-containing materials
- Safe work practices and control measures
- Selecting and using RPE
- Decontamination procedures
- Waste handling and disposal
- Emergency procedures
Category C: General awareness
Anyone who might encounter asbestos needs:
- Basic asbestos awareness training
- Understanding of where asbestos might be found
- Recognition of ACMs
- What to do if asbestos is discovered
- Who to report to
This includes:
- Maintenance workers
- Electricians and plumbers
- Building managers
- Facilities staff
- Contractors working in pre-2000 buildings
Training certificates should be verified before work starts. Workers should carry proof of training. Employers must maintain training records for all workers who may be exposed to asbestos.
Control measures by work category
Different control measures apply depending on work category.
Licensed work controls
Essential requirements:
- Full hazmat-style protective clothing
- Powered respirators (RPE with assigned protection factor of at least 40)
- Fully enclosed work area with airlocks
- Negative pressure ventilation (NPU)
- Decontamination facilities
- Air monitoring during work
- Four-stage clearance testing after completion
- Medical surveillance for all workers
Additional measures:
- Written method statements for all work
- Emergency procedures and equipment
- Trained supervisor on site at all times
- Daily exposure records
- Comprehensive waste management procedures
NNLW controls
Required measures:
- Appropriate RPE (minimum FFP3 disposable respirators)
- Disposable protective clothing (Type 5, Category III)
- Work area isolation and barriers
- Wetting agents to suppress fibres
- HEPA-filtered vacuum equipment
- Controlled removal and double-bagging
- Clearance testing (visual inspection and air test)
- Waste disposal via licensed carrier
Risk assessment must address:
- Means of preventing or reducing exposure
- Provision and use of RPE
- Control measures to prevent spread
- Decontamination procedures
- Waste handling and disposal
Non-licensed work controls
Basic requirements:
- Risk assessment before work starts
- Appropriate controls to minimize exposure
- RPE when exposure cannot be prevented
- Protective clothing where necessary
- Wetting to prevent fibre release
- Appropriate waste disposal
- Decontamination and cleaning
Work should be designed to:
- Minimize fibre release (work wet, avoid breaking/cutting)
- Prevent spread of contamination
- Protect workers and others nearby
- Enable safe waste disposal
Even for non-licensed work, the goal is the same: prevent exposure to asbestos fibres. If you can't prevent exposure entirely, it must be reduced to as low as reasonably practicable (ALARP).
Record keeping and notification
Comprehensive records are essential for all categories of asbestos work.
Licensed work records
Must be maintained:
- Notification to HSE (separate from license)
- Method statements and risk assessments
- Daily exposure records for each worker
- Air monitoring results during work
- Four-stage clearance certificates
- Medical surveillance records (40 years)
- Training certificates
- Waste consignment notes
- Accident/incident reports
Retention periods:
- Medical surveillance: 40 years
- Exposure records: 5 years minimum
- Training records: Until superseded plus 5 years
- Clearance certificates: Permanent
NNLW records
Must be maintained:
- HSE notification (submitted at least 14 days before work)
- Risk assessment and method statement
- Training records for all workers
- Air monitoring results (if conducted)
- Visual inspection and clearance results
- Waste consignment notes
- Health surveillance records (if applicable)
Retention periods:
- Health surveillance: 40 years
- Other records: 5 years minimum
Non-licensed work records
Should be maintained:
- Risk assessment
- Evidence of competence/training
- Details of controls used
- RPE selection and fit testing
- Waste disposal records
- Incident reports
Retention periods:
- Recommended: 5 years minimum
- Health records: 40 years if exposure occurred
Good record keeping protects both workers and employers. Records provide evidence of compliance, support health surveillance, and are crucial if workers develop asbestos-related diseases decades later.
UK regulatory context: CAR 2012
The Control of Asbestos Regulations 2012 (CAR 2012) is the primary legislation governing asbestos work in the UK.
Key regulations for work categories
Regulation 3: Prohibits asbestos importation, supply, and use (all asbestos banned since 1999)
Regulation 4: Duty to manage asbestos in non-domestic premises
Regulation 5: Identification of asbestos (survey requirements)
Regulation 6: Assessment of work with asbestos (risk assessment required)
Regulation 7: Plans of work for licensed work
Regulation 8: Licensing requirements and exemptions
Regulation 9: Notification of work with asbestos (NNLW)
Regulation 10: Information and training requirements
Regulation 11: Prevention or reduction of exposure
Regulation 16: Medical surveillance requirements
Regulation 18: Standards for licensed asbestos work
Enforcement and penalties
The HSE enforces asbestos regulations and has significant powers:
Improvement notices:
- Require specific improvements within set timeframe
- Can prohibit work until compliant
Prohibition notices:
- Immediate stop to dangerous work
- Cannot resume until HSE satisfied
Prosecution:
- Unlimited fines for serious breaches
- Up to 2 years imprisonment for individuals
- Corporate manslaughter charges possible for fatal exposures
License revocation:
- HSE can revoke asbestos licenses for non-compliance
- Effectively ends ability to conduct licensed work
Company prosecuted for asbestos cement work failures
A roofing company removed asbestos cement roof sheets without proper controls, notification, or training. Work exceeded NNLW thresholds but HSE was not notified.
- ✗Failed to notify HSE despite work exceeding 2 hours
- ✗Workers had no appropriate asbestos training
- ✗No RPE or protective clothing provided
- ✗Roof sheets broken and thrown from height
- ✗No waste controls — material dumped in general waste
- ✗Adjacent properties contaminated with debris
Company fined £40,000 plus £15,000 costs. HSE prohibition notice halted all work. Company reputation damaged. Had to pay for professional decontamination of neighboring properties.
Even 'simple' asbestos cement work requires proper assessment, notification, training, and controls. Don't assume non-licensed work means no regulations apply.
Other relevant legislation
Health and Safety at Work etc. Act 1974:
- General duty of care to employees and others
- Requirement to provide safe systems of work
Management of Health and Safety at Work Regulations 1999:
- Risk assessment requirements
- Health surveillance duties
Construction (Design and Management) Regulations 2015:
- Pre-construction information requirements
- Notification of construction projects
- Principal contractor duties for asbestos management
Environmental Protection Act 1990 / Hazardous Waste Regulations:
- Asbestos waste classification and disposal
- Duty of care for waste management
Common mistakes and how to avoid them
Mistake 1: Assuming material type without testing
The problem: "It looks like asbestos cement, so we treated it as non-licensed work. Turned out to be AIB."
How to avoid:
- Always get laboratory confirmation of material type
- Never assume based on appearance alone
- Commission proper survey before any work
- When in doubt, treat as licensed until proven otherwise
Mistake 2: Underestimating work duration
The problem: "We thought it would take less than 2 hours, so didn't notify HSE. Actually took all day."
How to avoid:
- Realistically estimate time including setup and cleanup
- Remember thresholds are cumulative over 7 days
- Include travel time to/from work area if in protective equipment
- Notify if there's any chance of exceeding thresholds
Mistake 3: Inadequate training
The problem: "Workers did online asbestos awareness course. HSE said this wasn't sufficient for hands-on work."
How to avoid:
- Asbestos awareness is minimum — not sufficient for hands-on work
- Ensure Regulation 10 training for non-licensed work
- Verify training is appropriate for specific work type
- Maintain training records and ensure refreshers
Mistake 4: Mixing work categories
The problem: "Started as non-licensed asbestos cement work, then found AIB behind panels. Kept working."
How to avoid:
- Stop immediately if unexpected materials found
- Reassess work category with new information
- Get licensed contractor if licensed materials discovered
- Update notifications and risk assessments
Mistake 5: Poor record keeping
The problem: "HSE asked for evidence we'd done air testing. We did it but didn't keep the certificate."
How to avoid:
- Maintain comprehensive records from day one
- Keep all certificates, reports, and test results
- Store records securely for required retention periods
- Make records available to HSE inspectors on request
Create a work-specific folder for each asbestos project containing all documentation: surveys, risk assessments, notifications, training records, test certificates, and waste documentation. This ensures everything is in one place if HSE inspectors visit.
Choosing the right contractor
For licensed work
Essential criteria:
- Valid HSE asbestos license (check HSE public register)
- UKAS accreditation for licensed work
- Adequate insurance (minimum £5 million public liability)
- Qualified supervisors (BOHS P405 or equivalent)
- Proven track record and references
Ask for evidence of:
- Recent similar projects
- Medical surveillance program
- Safety record and incident rates
- Quality management systems
- Emergency procedures
For NNLW and non-licensed work
Essential criteria:
- Appropriate training certificates (Regulation 10)
- Public liability insurance
- Method statements and risk assessments
- Appropriate equipment and RPE
- Waste disposal arrangements
Verify:
- Training is current and appropriate
- Previous experience with similar materials
- Understanding of notification requirements
- Commitment to proper controls and clearance
Warning signs
Be cautious of contractors who:
- Quote significantly lower than competitors
- Suggest shortcuts or minimal controls
- Don't ask to see survey or asbestos register
- Can't provide evidence of training or insurance
- Suggest licensed work can be done as non-licensed
- Don't mention notification requirements for NNLW
- Offer to skip clearance testing
The cheapest quote often becomes the most expensive mistake. Choose contractors based on competence, compliance, and safety record, not just price.
Frequently asked questions
Legally, you can do non-licensed asbestos work if you have appropriate training, equipment, and controls. However, it's strongly recommended to use professional contractors. Asbestos work is dangerous, and mistakes can have fatal consequences. If you do work yourself, you must comply fully with CAR 2012, including risk assessments, proper controls, and RPE.
Check the HSE's public register of licensed asbestos contractors on the HSE website. Search by company name or license number. The register shows license status, issue date, and expiry date. Never accept a contractor's claim about licensing without verifying it yourself on the HSE register.
Stop work immediately. Seal the area and prevent access. Do not attempt to continue. Contact a licensed asbestos contractor to assess and complete the work. Report the discovery to your supervisor or building manager. Anyone potentially exposed should be recorded for health surveillance purposes.
The notification threshold is work exceeding 2 hours. Exactly 2 hours doesn't require notification. However, be realistic about timing — if there's any chance work will exceed 2 hours, notify the HSE. It's better to notify unnecessarily than to exceed thresholds without notification.
Yes, asbestos cement roof work can be non-licensed, but only if proper controls are in place and the material is in good condition. If work exceeds NNLW thresholds (2 hours or 1 person-hour for multiple workers), you must notify the HSE. Workers need appropriate training (not just awareness training), and fibre release must be controlled.
No. Small areas can be non-licensed: less than 10m² externally or 5m² internally per person per hour. Above these thresholds, it becomes licensed work. The thresholds are deliberately low because textured coatings can release significant fibres when removed improperly. For large areas or if you're unsure, use a licensed contractor.
NNLW (Notifiable Non-Licensed Work) is non-licensed work that exceeds notification thresholds (2 hours total or 1 person-hour for multiple workers). The work itself is the same and doesn't require a license, but you must notify the HSE at least 14 days before starting. Both require proper training, controls, and safety measures.
There's no legal expiry for asbestos training certificates, but annual refresher training is strongly recommended and often required by industry standards and insurance companies. HSE guidance suggests refresher training every year. Employers should ensure workers' knowledge remains current, especially if regulations or guidance change.
No. Licensed work requires RPE with an assigned protection factor (APF) of at least 40, which FFP3 masks (APF 20) don't meet. You need powered air-purifying respirators (hood or full-face) or airline breathing apparatus. Using inadequate RPE for licensed work is a serious breach of regulations.
The duty holder or employer must determine the work category before work starts, based on the survey findings and work scope. When in doubt, consult a licensed asbestos contractor or specialist consultant. The HSE can challenge your determination if they believe you've incorrectly categorized licensed work as non-licensed.
Next steps
To understand your duties before any asbestos work begins:
Asbestos duty to manage explained →
To identify what asbestos you have:
To learn about asbestos basics:
Unsure which category your work falls into? A licensed asbestos contractor or consultant can review your survey findings and work scope to advise on the correct approach, training requirements, and notification obligations.
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