Control of Asbestos Regulations 2012 regulation 4, UK wide
Asbestos Management Plans
A survey tells you where the asbestos is. Regulation 4 of the Control of Asbestos Regulations 2012 asks the harder question of what you do about it every day for the rest of the building's life. AL23 Safety writes and maintains asbestos management plans that hold up under an HSE visit and control work on site, for duty holders UK wide.
What is an asbestos management plan?
The document that turns a survey into daily control
An asbestos management plan is the written record of how you will manage the asbestos containing materials in your building. It names who is accountable, records where each material is and what condition it is in, sets the condition monitoring regime and states the controls that apply before anyone drills a wall, lifts a ceiling tile or runs a cable through a void.
The plan is a legal requirement in its own right. The survey is the evidence that feeds it. Our asbestos surveys page covers management, refurbishment and demolition surveys and re-inspection. Regulation 4 goes further. It requires the duty holder to prepare a written plan setting out how the risk is to be managed, to put that plan into effect and to review it. A folder of survey reports with no plan wrapped around it does not meet the duty.
Who needs one
Every duty holder for non-domestic premises built or refurbished before 2000
- Owners and occupiers of non-domestic premises, where the duty falls on whoever holds the repair or maintenance obligation under a lease or contract.
- Landlords and managing agents responsible for the common parts of blocks of flats, which are non-domestic for the purpose of regulation 4 even though the individual flats are not.
- Schools, academy trusts and colleges, where the duty sits with the responsible body rather than with the head teacher or the site manager.
- Registered providers of social housing, NHS estates, local authorities and anyone holding a mixed-age portfolio built or refurbished before the 1999 ban took full effect.
- Premises with no lease clause allocating repair at all, where the duty defaults to the person in control of the premises.
- Employers whose staff work in other people's buildings, who must co-operate with the duty holder and must not disturb material they have not checked for.
The regulations that apply
Your legal framework, in plain terms
The Control of Asbestos Regulations 2012 sit under the Health and Safety at Work etc. Act 1974 and apply across the United Kingdom. They are reinforced by the Management of Health and Safety at Work Regulations 1999 where employers share a workplace and by the Construction (Design and Management) Regulations 2015 where the work is construction work. The control limit in Great Britain remains 0.1 fibres per millilitre averaged over four hours. HSE confirmed on 18 May 2026 that it will not lower it, despite the European Union cutting its own occupational exposure limit in December 2025. Reducing exposure as low as is reasonably practicable remains the driver rather than the number itself.
Regulation 4, the duty to manage
Take reasonable steps to find asbestos containing materials, presume material contains asbestos unless there is strong evidence otherwise, assess the risk, prepare a written plan, act on it and review it.
Regulation 5, identification before work
No work liable to disturb the fabric of a building may start until the presence of asbestos has been identified or properly presumed.
Regulation 10, information, instruction and training
Anyone liable to disturb asbestos in the course of their work must be trained, at a level matched to what they actually do.
Regulation 11, prevention or reduction of exposure
Exposure must be prevented. Where prevention is not reasonably practicable it must be reduced to the lowest level reasonably practicable.
Regulations 19 and 20, air monitoring and standards
Air monitoring must be carried out where it is appropriate. Organisations carrying out clearance air testing and site clearance certification must hold accreditation for that work.
Licensed, notifiable non-licensed and non-licensed work
Three categories, three different sets of obligations. Putting work in the wrong category is the single most common failure we find when we read an existing plan.
Licensed work
covers the higher risk materials, principally sprayed coatings, pipe and boiler lagging and most work on asbestos insulating board. It can only be carried out by a contractor holding an HSE licence. It must be notified to the enforcing authority in advance and carried out under a written plan of work inside a controlled enclosure. The four stage clearance process must be completed before anyone goes back in. Workers on licensed work are medically examined every two years.
Notifiable non-licensed work
is lower risk work that still has to be notified to the enforcing authority. Health records must be kept and workers are medically examined every three years. Typical examples are short duration maintenance work on asbestos insulating board and the removal of asbestos cement that is badly damaged or has to be broken up.
Non-licensed work
covers materials where the fibres are firmly bound in a matrix, such as asbestos cement sheets removed whole, floor tiles and bitumen products. It still needs trained operatives, a task specific risk assessment, controls and correct waste routing. It does not need notification.
The boundary between the three is set by the risk assessment rather than by the material alone. HSE consulted between 10 November 2025 and 9 January 2026 on clarifying what counts as notifiable non-licensed work and on securing the independence and impartiality of the roles in the four stage clearance process. No implementation date has been announced. Treat the current rules as live and expect change with notice.
What the service covers
From a gap review to a permit the site can use
- A regulation 4 gap review of what you already hold, identifying which buildings have never been surveyed and which surveys predate the last refurbishment.
- The written management plan itself, naming the duty holder, the appointed asbestos manager and the deputy, with their real authority written down.
- An asbestos register item by item, with location, material type, extent, condition, surface treatment, accessibility and the resulting material and priority risk scores.
- A presumption policy covering the parts of the building nobody has ever opened up. Not surveyed must never be read as no asbestos.
- A prioritised remedial programme separating remove, encapsulate, repair, label and manage in place, with the reasoning for each decision recorded.
- Condition monitoring intervals set item by item on risk rather than a blanket annual sweep of everything.
- The contractor interface, covering how the register is issued before work starts, who signs to confirm they have read it and what happens when something unexpected is found.
- An asbestos permit to work that plugs into your existing permit regime, covering drilling, cable routing, ceiling void access and any intrusive maintenance.
- Emergency arrangements for an uncontrolled disturbance, covering evacuation of the area, isolation, decontamination, reporting under RIDDOR 2013 where the release amounts to a dangerous occurrence and how the area is cleared before reoccupation.
- Training mapped to the three levels of asbestos awareness, non-licensed work and licensed work, with a record of who has had what and when it expires.
- An air testing strategy, defining when background, reassurance, leak and personal monitoring are used and who is competent to carry out each type.
- A communication routine that reaches the people who need it, including in-house maintenance staff, cleaners, IT and telecoms installers and every external contractor.
Our process
Settle the duty holder first, then build the plan
- 01
Establish the duty holder
We read the leases and the maintenance obligations before we write anything. Getting this wrong is how two organisations each end up assuming the other holds the duty.
- 02
Audit the information
We test your survey coverage against the actual building, room by room. We then list what is surveyed, what is presumed and what remains inaccessible.
- 03
Assess and prioritise
We score each item for material risk and priority risk using occupancy, activity and likelihood of disturbance, then build the remedial and monitoring programme from the scores.
- 04
Write the plan and the register
Short, specific and readable. If your site manager cannot use it at eight on a Monday morning with a contractor waiting, it is not a plan.
- 05
Embed and review
We brief the people who will run it, test the permit route on a live job and review the plan annually or sooner whenever the building changes.
What you get
A plan the site manager can actually use
- A written asbestos management plan meeting regulation 4, with named roles, defined authority and dated review points.
- An asbestos register in a format your team and your contractors can read, held in one controlled location rather than four.
- A prioritised action plan with owners and target dates, split into urgent, programmed and monitor.
- An asbestos permit to work template and a contractor register issue and sign-off form, ready to use.
- A condition monitoring schedule with intervals set item by item and a re-inspection due date for each.
- An awareness briefing pack for staff, plus record templates for training and for register issue.
What we need from you
Every survey you hold and access to the locked spaces
- Every asbestos survey, sampling result, removal certificate and clearance certificate you hold, no matter how old.
- Floor plans, plus the record drawings from the last refurbishment where you have them.
- Lease and maintenance contract information so we can settle who the duty holder actually is.
- A named person who will own the plan once we hand it over.
- Access to plant rooms, roof voids, risers, ducts and any space that is normally locked.
Why AL23 Safety
Written for the person about to drill the wall
Accountable
Where a plan is not being followed we say so in writing. We have told clients that their register was unusable. That is a more useful conversation than handing over a compliant looking document.
Expert and chartered
Qualified, chartered professionals working to the Control of Asbestos Regulations 2012 and to current HSE guidance for duty holders and analysts.
Practical, not just compliant
We write the plan for the person who has to stop a contractor drilling a wall, not for an auditor's shelf.
UK wide
We prepare and maintain asbestos management plans across the UK, from a single unit to a mixed portfolio. We join them up with contractor management so the register reaches the people holding the drill.
HSE has been checking these plans
Inspectors ask for the plan, not the survey
During Global Asbestos Awareness Week from 1 to 7 April 2026, HSE ran a duty to manage inspection campaign across non-domestic premises. Inspectors focused on accurate identification and assessment of asbestos containing materials, a live management plan with condition monitoring, information and training for workers and controls over work that could disturb the material. In 2024/25 HSE carried out more than 600 duty to manage inspections alongside 713 inspections of licensed asbestos contractors.
If you would struggle with that conversation today, it is usually a short piece of work to fix.
Common questions
Answers, up front
Cannot see your question? Get in touch and we will answer it directly.
Contact usNo. The survey identifies and assesses the material. The plan states what you are going to do about it, who is responsible and how the risk is controlled from one day to the next. Regulation 4 requires both. The plan is the part inspectors ask for first.
Regulation 4 requires review at regular intervals and whenever there is reason to think the plan is no longer valid. HSE does not set a fixed number of months. Common practice is a full review every twelve months, with an immediate review after any refurbishment, removal, change of use or change of duty holder. Where an annual cycle is more than your building needs, we will tell you.
It is the sequence an analyst follows before an area is handed back after licensed removal. Stage one is a preliminary check of the site condition and job completeness. Stage two is a thorough visual inspection inside the enclosure. Stage three is air monitoring. Stage four is a final assessment after the enclosure has been dismantled. Only then can a certificate of reoccupation be issued.
Clearance air testing and site clearance certification must be done by an organisation holding UKAS accreditation for that work, assessed against UKAS publication LAB 30, Application of ISO/IEC 17025 for Asbestos Sampling and Testing, Edition 5, July 2022. We scope the work, appoint the accredited analyst, interpret the results and turn them into an action plan you can actually deliver. HSE consulted in late 2025 on strengthening the independence of the roles in that process. The outcome had not been published when this page was written.
It applies to non-domestic premises, which includes the common parts of blocks of flats, shared corridors, plant rooms, bin stores and boiler houses. The inside of an individual let dwelling falls outside regulation 4, although the landlord still holds duties under the Health and Safety at Work etc. Act 1974 and under housing legislation whenever works are carried out. Our page on health and safety in housing and property sets out how the two fit together.
Cost is driven by the number of buildings, the state of the survey information you already hold, how much presumption has to be resolved and whether the register has to be rebuilt from paper records. A single site with a current survey is a short piece of work. A portfolio carrying twenty years of mixed survey formats is not. Send us a building list and a note of what you hold and we will price it properly.
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