Asbestos Management Plan Advice

Last Updated on 13 October 2026

Getting Asbestos Management Right: What Your Plan Needs to Actually Work

This article was written based on some good questions arising from a LinkedIn post by Marcus Hill – Director of Asbestos Risk Control Limited. The contention is that your typical asbestos surveyor or ‘consultant’ as some call themselves, does not have the necessary skills or training to adequately assist the duty holder in managing asbestos. The information in this article is designed to assist relevant persons in the asbestos industry as well as duty holders required to manage asbestos. The assumption is reasonable and backs up my own findings, which is that asbestos management in the UK is often wholly inadequate, even when some form of plan is in place.

Under Regulation 4 of the Control of Asbestos Regulations 2012 (CAR 2012), anyone who owns, controls, or maintains a non-domestic building has a clear ‘duty to manage’ asbestos in those premises. In short, an asbestos management plan is a written or digital document detailing how you will manage asbestos-containing materials (ACMs) within the property to safeguard the health and safety of occupants, staff, and contractors.

Whether you run a small business or oversee a large site, having a plan isn’t just about ticking a compliance box; it’s about making sure people don’t get exposed to a material that is still the biggest industrial killer in the UK, accounting for around 5,000 deaths every year.

The Duty Holder Problem: Who Is Actually Responsible?

The responsibility for managing asbestos in non domestic premises lies firmly with the Duty Holder. This is usually the Director or Chief Executive, or in smaller companies, the business owner. It can also be the individual who signs a ‘lease’ on a property, where they are in charge of maintenance activities.

The Duty Holder can bring in responsible persons or consultants to help with the duty, but the legal responsibility remains with the key individual and cannot be delegated.

This is where problems usually first occur:-

• The Duty Holder often doesn’t realise they have this specific duty, and they often know very little about asbestos. Getting their engagement from the start is vital.
• If the Duty Holder is too far up the chain of command, make sure their specific details and responsibilities are outlined in the asbestos management plan (AMP), complete with an area where they must sign and date it. Once they are engaged, they are far more likely to provide the required resources to support the plan and any further training required.
• Appropriate guidance can be found in HSE documents HSG 227 or the shorter INDG 223 guide.

 

 

Getting the Right People Trained

The second and third most important persons in this process are the trained individuals who will oversee the Asbestos Management Plan day to day. In most cases, they will not have the appropriate training to complete the task because there is very little appropriate training available currently.

The P405 course (generally around 5 days) might make sense for a large organisation managing lots of staff, contractors, and remediation projects. However, the UK is largely made up of small to medium enterprises who may not have large amounts of ACMs to manage, making this the wrong course for them.

What works best in practice is providing on-site, bespoke face to face training using their own AMP document. If there is no awareness training in place, this can be bolted on first.

Working face to face with the Duty Holder on their own site often uncovers issues unrelated to the standard building survey. In my own practice, this approach has identified asbestos elements inside renovated transport equipment at an engineering firm, and imported items containing asbestos at a supply company – issues that would have otherwise been missed.

A simple rule for training the person in charge of administering the day to day use of the asbestos management plan: Always train more than one individual. When the primary person is away on holiday, off sick, or working different shift patterns, a second trained individual needs to take their place or be available.

Core Elements of a Practical Asbestos Management Plan

Before starting the process of managing asbestos, you need to understand where all asbestos is located on a site through an up to date asbestos management survey. Without this, managing asbestos is pretty much a non starter.

From there, the cornerstones of a decent asbestos management plan should address the following items:-

1. Is the existing asbestos register up to date? Does it adequately reflect the current situation in the property?
2. Are the ACMs in a safe condition and labelled appropriately where possible?
3. Who is in charge of the process? Have they received proper site-specific training?
4. Where will the asbestos information be kept? It needs to be easily accessible, particularly for contractors and maintenance personnel.
5. Is a ‘Permit to Work’ system implemented? All contractors must be vetted and signed in.
6. Are Refurbishment/Demolition surveys carried out when needed? If works go beyond basic maintenance, a full R&D survey is required.
7. Is there a plan for damaged ACMs? You need a procedure ready for when materials become damaged.
8. Who handles the Priority Risk Score (PRS)? The responsibility for the PRS element of the risk assessment lies with the Duty Holder. Working with the Duty Holder to help them understand and adjust risk scores as work activities change is vital.

 

 

Managing Contractors and Staff Day to Day

Once the Asbestos Management Plan (AMP) is up and running, ongoing success revolves around two key areas:-

1. Robust Contractor Management

Contractors are often the most likely to cause damage to ACMs. To comply with Regulations 5 and 6 of CAR 2012, all persons working on site must not only be provided with asbestos information, but processed in a way that ensures they will not be working on or near ACMs they could conceivably damage. A simple “you signed the asbestos register” clause before starting work is not enough.

2. Staff Engagement & Toolbox Talks

Encourage trained individuals to engage with staff to inform them of ACMs in proximity to their work areas. This can be done through toolbox talks or asbestos awareness training under Regulation 10 (CAR 2012). It also provides “more eyes on the property” when things go wrong, such as storm damage, leaks, or impact damage.

Inspections and Keeping the Document ‘Live’

How frequently should you review your asbestos management plan and inspect ACMs? The short answer is: as often as is appropriate to the use of the area or building.

Under CAR 2012, the minimum requirement for re-inspection of an asbestos product is annually. However, frequency must be commensurate with risk:-

• High-Risk Areas: If ACMs are located near high-risk operations (for example, one client inspects their ACMs daily because they are close to a food production facility), inspect them much more frequently.
• Low-Risk Areas: Products that are low risk and away from front-line operations can be inspected less often.

If the long term costs of managing an ACM are likely to be greater than the costs of removal, then the choice should be simple: determine the cost of having it removed appropriately.

Treating the AMP as a Live Document

The asbestos management plan should be a live document that reflects ongoing changes within a building. It needs to be reviewed every 12 months at a minimum, and updated immediately if:-

• ACMs are removed, repaired, or encapsulated.
• There is a change of use of an area.
• Further Refurbishment/Demolition surveys discover new ACMs.
• ACMs become damaged.
• Trained staff leave or Duty Holders change.
• The business or property is being sold (unresolved asbestos issues often dissuade lenders and purchasers, interfering with the sales process).

Get In Touch For Asbestos Management Plan Advice

I have been helping large and small organisations manage asbestos for many years and learned the skills through 40 years of field experience. I write these articles to help others in the industry improve their approaches and skill set. Several colleagues and I are part of a pro bono working group looking to raise standards including RB Asbestos Consultants Limited, Marcus Hill – Asbestos Risk Control Limited, Paul Beaumont – 1-11 Compliance and the Asbestos Surveyors Guild ASG, Stephen Forster – Remedia Group Limited. Chair – Joint Industry Working Group on Asbestos in Soil and C&D Materials.

We hope you find the information in this blog post useful when you review your own organisation’s asbestos policies and plans.  If you need any advice at all on managing asbestos in your property or creating a management plan, then please call 0800 141 2676.

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