What is HSG227?
HSG227, "A Comprehensive Guide to Managing Asbestos in Premises," is the Health and Safety Executive's authoritative guidance document for duty holders responsible for managing asbestos-containing materials (ACMs) in non-domestic buildings. This comprehensive publication provides practical guidance on complying with the duty to manage asbestos under the Control of Asbestos Regulations 2012.
The guide addresses the ongoing challenge of managing the legacy of asbestos used extensively in UK buildings before its prohibition. Asbestos remains present in an estimated 500,000 non-domestic premises, and when these materials are disturbed, they release fibres that cause serious diseases including mesothelioma, lung cancer, and asbestosis. Proper management is essential to prevent exposure.
HSG227 covers the complete management cycle from initial assessment and survey through to ongoing monitoring and review. It provides detailed guidance on survey types, risk assessment, management planning, and the practical steps needed to protect building occupants, maintenance workers, and contractors from asbestos exposure.
The document emphasises that managing asbestos effectively is not about panic removal but about informed decision-making. Often, ACMs in good condition pose low risk when left undisturbed and properly managed, while poorly planned removal work can create greater exposure risks.
Who Needs This Document?
HSG227 is essential reading for anyone with responsibilities for managing buildings or premises:
Primary Audiences:
- Building owners with legal duty holder responsibilities
- Property managers responsible for building portfolios
- Facilities managers overseeing building maintenance
- Health and safety managers in organisations occupying premises
- Landlords of commercial and industrial properties
- Directors of companies owning or managing premises
Secondary Audiences:
- Asbestos surveyors and consultants
- Maintenance managers and supervisors
- Contractors working in buildings that may contain asbestos
- Architects and designers planning refurbishment works
- Project managers overseeing building works
- Insurance professionals assessing property risks
- Environmental health officers
The guidance applies to all non-domestic premises including offices, factories, schools, hospitals, retail premises, and the common areas of domestic buildings such as flats.
Key Topics Covered
HSG227 provides comprehensive coverage of asbestos management:
Understanding the Duty to Manage
The guide explains the legal framework and responsibilities:
- The Control of Asbestos Regulations 2012 requirements
- Identifying the duty holder for premises
- Scope of the duty to manage
- Shared responsibilities in multi-occupied buildings
- Relationship with other asbestos regulations
- Enforcement and penalties for non-compliance
Asbestos Basics
Essential background knowledge on asbestos:
- Types of asbestos (chrysotile, amosite, crocidolite)
- Common asbestos-containing materials and products
- Where asbestos is typically found in buildings
- Health effects of asbestos exposure
- Fibre release mechanisms and exposure routes
- Understanding risk in context
Asbestos Surveys
Detailed guidance on surveying premises:
Management Surveys:
- Purpose and scope of management surveys
- Surveyor competence requirements
- Survey methodology and sampling
- Areas of limited access
- Presumptions and caveats
- Survey report requirements
Refurbishment and Demolition Surveys:
- When R&D surveys are required
- Intrusive survey techniques
- Pre-work survey planning
- Phased surveys during works
- Integration with project planning
The Asbestos Register
Creating and maintaining records:
- Required content of asbestos registers
- Recording ACM locations and conditions
- Photographic documentation
- Mapping and drawing requirements
- Version control and updates
- Making registers accessible
Risk Assessment
Assessing and prioritising risks:
- Material assessment algorithms
- Priority assessment factors
- Combining material and priority assessments
- Risk scoring and categorisation
- Reassessment triggers
- Documentation requirements
The Asbestos Management Plan
Developing effective management arrangements:
- Management plan contents and format
- Policies and procedures
- Roles and responsibilities
- Monitoring and inspection regimes
- Maintenance and repair procedures
- Emergency response arrangements
- Communication systems
- Training requirements
- Review and update processes
Managing ACMs in Practice
Practical guidance on day-to-day management:
Labelling and Marking:
- When to label ACMs
- Label types and placement
- Warning signs for restricted areas
- Updating labelling as conditions change
Monitoring and Inspection:
- Inspection frequencies and methods
- Recording condition changes
- Trigger points for action
- Photographic monitoring
Safe Systems of Work:
- Permit to work systems
- Contractor management
- Information provision to workers
- Emergency procedures
Dealing with ACMs
Options for managing identified materials:
- Leave in situ and manage
- Repair and encapsulation
- Enclosure and protection
- Removal by licensed contractors
- Decision-making criteria
- Cost-benefit considerations
Information, Instruction and Training
Ensuring competence across stakeholders:
- Duty holder training requirements
- Maintenance staff awareness training
- Contractor briefing procedures
- Providing information to occupants
- Record keeping for training
Using This Guidance
Implementing HSG227 effectively requires systematic application:
Step 1: Identify the Duty Holder Determine who has the duty to manage asbestos in your premises. This is typically the owner, but in leased premises, the duty may fall to the tenant or be shared. Review lease terms and clarify responsibilities in writing.
Step 2: Gather Existing Information Collect any existing asbestos surveys, registers, or management plans. Review building plans and construction dates. Identify previous refurbishment or remediation works. Assess the reliability of existing information.
Step 3: Commission Surveys Engage a competent surveyor to conduct a management survey covering all accessible areas. Ensure the surveyor is UKAS accredited and follows HSG264 survey guidance. Review the survey report critically and clarify any uncertainties.
Step 4: Create the Asbestos Register Compile survey findings into an accessible register. Include locations, material types, condition assessments, and photographs. Create floor plans showing ACM locations. Make the register readily available to those who need it.
Step 5: Conduct Risk Assessments Apply material and priority assessment methodology to all identified ACMs. Prioritise materials by risk level. Identify any requiring immediate attention. Document assessment rationale and outcomes.
Step 6: Develop the Management Plan Create a written plan covering how ACMs will be managed. Define inspection regimes, maintenance procedures, and emergency responses. Assign responsibilities and establish monitoring systems.
Step 7: Implement Control Measures Put management plan provisions into practice. Label ACMs appropriately. Brief maintenance staff and contractors. Establish permit systems for work affecting ACMs. Train relevant personnel.
Step 8: Monitor and Review Conduct regular inspections of ACM conditions. Update the register when changes occur. Review the management plan at least annually. Commission new surveys before refurbishment or demolition.
Step 9: Communicate Effectively Ensure everyone who needs to know about ACMs is informed. Brief contractors before they start work. Display warning signs where appropriate. Respond promptly to queries and concerns.
Step 10: Maintain Records Keep comprehensive records of all asbestos management activities. Retain survey reports, training records, and inspection logs. Document any incidents or remediation works. Maintain records for at least 40 years.
Why It Matters
Managing asbestos effectively is critical for multiple compelling reasons:
Legal Compliance: The duty to manage asbestos is a specific legal requirement under the Control of Asbestos Regulations 2012. Failure to comply can result in enforcement notices, prosecution, and significant fines. Directors can face personal liability for serious breaches.
Preventing Fatal Disease: Asbestos-related diseases kill over 5,000 people annually in the UK, more than road traffic accidents. These diseases are entirely preventable through proper management. Every exposure avoided is a potential life saved.
Protecting Workers: Maintenance workers, contractors, and tradespeople are at particular risk from disturbing ACMs during routine work. Effective management ensures they receive warning of asbestos presence and work safely.
Building Occupant Safety: While undamaged, well-managed ACMs pose low risk to occupants, deteriorating or disturbed materials can release fibres into occupied spaces. Management protects everyone using the building.
Liability Protection: If workers or occupants develop asbestos-related diseases, employers and building owners may face civil claims. Demonstrating compliance with HSG227 guidance provides evidence of reasonable precautions.
Insurance Requirements: Many insurers require evidence of asbestos management as a condition of cover. Inadequate management may affect insurance validity or increase premiums.
Property Transactions: Asbestos management records are scrutinised during property sales and leases. Good management protects property values and facilitates transactions.
Refurbishment Planning: Before any building work, the presence of asbestos must be established. Good management records enable efficient planning of refurbishment and maintenance projects.
Contractor Relations: Reputable contractors will request asbestos information before working on premises. Proper management enables efficient contractor engagement and demonstrates professionalism.
Moral Responsibility: Beyond legal requirements, protecting people from preventable harm is a fundamental ethical duty. Those who control premises have a moral obligation to manage the risks they create.
By following HSG227 guidance, duty holders can effectively manage the asbestos legacy in their premises, protecting workers and occupants from exposure while maintaining compliance with regulatory requirements. The systematic approach outlined provides a practical framework for fulfilling this critical responsibility.