Independent guidance · For architects & principal designers

Independent Asbestos Guidance for UK Architects & Designers

Written by the UK's Independent Asbestos Consultancy. Under CDM 2015 the principal designer is responsible for planning, managing and monitoring the pre-construction phase, and for providing Pre-Construction Information (PCI) that includes asbestos data. A design that proceeds without an in-date Refurbishment or Demolition Survey transfers risk to the client and to the contractor — and increasingly to the designer's own PI policy. Independent survey data, free of removal-contractor bias, is the only defensible PCI input.

Survey at RIBA stage

2 / 3

Required in PCI

Yes — CDM 2015

Designer's PI exposure

High if omitted

Best practice

Pre-tender survey

Where the survey sits in the RIBA workplan

A useable Refurbishment & Demolition Survey should be commissioned at RIBA Stage 2 for any pre-2000 building, with results informing Stage 3 detail design and Stage 4 technical design. A survey commissioned at Stage 5 (construction) almost always produces a change-control claim from the principal contractor — and frequently a programme overrun. The cost of an early-stage survey is recovered many times over by removing late-stage discoveries.

What the PCI must contain

CDM 2015 requires the PCI to include 'information about any hazards known or likely to be encountered, including asbestos'. The Approved Code of Practice (L153) makes clear that a generic statement is insufficient: the PCI must include a specific survey reference, the survey type, the date, the surveyor, the location of identified ACMs, and any presumed materials. Designers who issue a PCI without these are commonly cited in HSE enforcement notices.

Designing out asbestos disturbance

Where a survey identifies asbestos in the works area, the principal designer's first move under CDM 2015 Regulation 9 is to consider whether the design can be changed to avoid disturbance — re-routing services around a riser, retaining a column casing rather than removing it, or moving a partition. Where disturbance cannot be designed out, the design must specify the removal sequence, the type of contractor required (licensed / non-licensed / NNLW) and the air-monitoring strategy.

Heritage and listed-building considerations

Listed buildings and conservation-area properties require additional sensitivity. Sampling in plaster, lath, or original Artex coatings may require Listed Building Consent for the sample patch. Our heritage team works with specialist conservation officers to plan a sampling strategy that complies with both CAR 2012 and the Planning (Listed Buildings and Conservation Areas) Act 1990.

Printable checklist

Architect / principal designer pre-construction checklist

  • Commission Refurbishment / Demolition Survey at RIBA Stage 2
  • Survey scope tracks the full project envelope, not just the brief
  • PCI references the survey by date, surveyor and UKAS lab
  • Identified ACMs marked on the survey drawings supplied to tender
  • Design changes considered before specifying removal
  • Removal sequence and contractor competency specified in Stage 4
  • Listed-building / conservation consent for any heritage sampling
  • Survey re-issued or addended at any material design change

Frequently asked questions

Whose budget should the survey come out of?

The client commissions and pays for the survey under CAR 2012, but the principal designer programmes it into the design timeline. Architects who flag the requirement early and write it into the Stage 1/2 fee proposal avoid the awkward late-stage conversation.

Can we use an old Management Survey for a refurbishment?

No. A Management Survey is non-intrusive and does not cover concealed materials likely to be disturbed in refurbishment. A Refurbishment Survey scoped to the affected areas is always required.

What if the survey identifies asbestos after planning has been submitted?

Most cases can be accommodated through detail-design changes without altering the planning consent. Where the design must materially change (e.g. removing a feature wall), a non-material amendment is usually sufficient.