Independent guidance · Legal & compliance
Employer Duties Regarding Asbestos
What UK employers must do about asbestos — training tiers, written risk assessments, medical surveillance, and evidence the HSE looks for.
Key takeaways
- Awareness training — Regulation 10
- Non-licensed and licensed work training
- Written risk assessment — Regulation 6
- Control measures and RPE
- Health surveillance and record-keeping
Employer duties around asbestos come from two directions: the Health and Safety at Work etc. Act 1974 (the general duty to protect employees and others affected by the undertaking) and the Control of Asbestos Regulations 2012 (the specific duties around identification, exposure prevention, training and health surveillance). This guide sets out the practical employer duties and the evidence the HSE expects to see.
Awareness training — Regulation 10
Every employee who may be liable to be exposed to asbestos must receive asbestos awareness training. This includes electricians, plumbers, heating engineers, joiners, decorators, IT and telecoms installers, cleaners, caretakers, facilities technicians and general maintenance staff. Training must be delivered by a competent provider, tailored to the trade, and refreshed at intervals suitable to the risk — annually is the market norm. Records must be kept and produced on request.
What this means
Awareness training is the first thing the HSE asks for. Central register, dated certificates, annual refresh.
Non-licensed and licensed work training
Employees carrying out Notifiable Non-Licensed Work (NNLW) need training beyond awareness — task-specific, with practical elements. Employees carrying out licensed work require BOHS-accredited course completion and licensed contractor employment. Choosing the wrong tier for a task is a recurring enforcement failure — for example, treating AIB removal as non-licensed when it is licensed.
What this means
Three training tiers, matched to three work tiers. Get the classification right before the task starts.
Written risk assessment — Regulation 6
Before any work with asbestos, a suitable and sufficient written risk assessment is required. It must cover the type of asbestos, its condition, the nature of the work, the likelihood of exposure, the control measures, the PPE, the RPE and the emergency arrangements. It must be kept on site while work is in progress and reviewed whenever conditions change materially.
What this means
'Written' is not optional and 'suitable and sufficient' is a legal test — pro-forma tick sheets rarely pass it.
Control measures and RPE
Regulation 11 requires exposure to be prevented or, where not reasonably practicable, reduced to the lowest level. Regulation 12 requires control measures to be maintained and tested. Respiratory Protective Equipment must be face-fit tested for the individual wearer, and the fit-test record kept on file. The workplace exposure limit is 0.1 fibres per cm³ of air averaged over 4 hours, but employers must aim for as low as reasonably practicable — the limit is a legal ceiling, not a target.
What this means
The exposure limit is a ceiling, not a target. RPE without a fit-test record is worthless in an HSE audit.
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Health surveillance and record-keeping
Employees carrying out licensed work or NNLW must undergo medical examination before starting and at least every three years thereafter. Health records must be kept for 40 years. Exposure records (who was exposed, when, to what, for how long, at what estimated concentration) must be kept for 40 years and made available to the individual on request. Failure to maintain these records is one of the highest-fine categories of CAR 2012 offence.
What this means
40 years is not a typo. Health and exposure records outlive the projects, the contracts and often the company.
What HSE inspectors ask for
In an unannounced visit the HSE will typically ask for: the asbestos register for the workplace; the training records for all trades; the written risk assessment and plan of work for any current asbestos-related activity; the RPE fit-test records; the health surveillance schedule and outcomes; the exposure records for the last 40 years. Absence of any of these is a Fee-for-Intervention trigger.
What this means
Six documents. Have them in one folder, updated monthly, and the HSE visit takes an hour instead of a day.
Frequently asked questions
Is awareness training a legal requirement?
Yes, under Regulation 10 of CAR 2012, for any employee liable to be exposed to asbestos. It applies to a very wide range of trades and support roles.
How often must training be refreshed?
The regulations require refresher training at intervals suitable to the risk. Annual is the practical norm and what most HSE inspectors expect to see for anyone actively working with or near ACMs.
Who can deliver asbestos awareness training?
A competent provider — typically UKATA-registered or IATP-registered. In-house delivery is acceptable if the trainer is demonstrably competent.
Do office-only staff need training?
Not usually — the duty applies to those liable to be exposed. Office workers with no maintenance role are outside scope, but caretakers, cleaners and facilities staff in the same building are inside.
What is the workplace exposure limit?
0.1 fibres per cm³ of air, averaged over a 4-hour reference period. It is a legal ceiling, not a target — exposure must be reduced to as low as reasonably practicable.
How long must health records be kept?
40 years for both health surveillance records and exposure records. This survives changes of employer for the individual.
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