Asbestos in London Homes: Where It Is, Surveys, and What Must Happen Before Works Start

Asbestos was used in a wide variety of building materials during the 20th century. In London residential properties, the most commonly found asbestos-containing materials (ACMs) include:

Artex and textured coatings: the most widespread ACM in London homes — Artex and similar textured coatings applied to ceilings and sometimes walls, particularly in properties built or refurbished between the 1950s and 1990s. Many Artex products contained white asbestos (chrysotile). Artex in good condition that is left undisturbed poses a low risk — the problem arises when Artex is dry-sanded, machined, or removed as part of decoration or refurbishment works, which releases asbestos fibres into the air.

Floor tiles and floor tile adhesive: vinyl and thermoplastic floor tiles used in kitchens, bathrooms, and hallways in 1940s–1980s construction frequently contain asbestos. The tile adhesive (black bitumen mastic) also frequently contains asbestos. Tiles and adhesive in good condition that are left in place or covered over can often be managed in place — cutting, grinding, or removing them creates a risk.

Pipe lagging and pipe insulation: asbestos lagging was used on boiler pipes, central heating pipes, and hot water cylinders — particularly in properties built or refurbished between the 1950s and 1970s. Pipe lagging is frequently in a deteriorated condition and may be friable (crumbling) — friable lagging is a higher-risk ACM.

Asbestos insulating board (AIB): used as a lining material in service cupboards, boiler cupboards, around heating systems, and as partition board — particularly in 1950s–1970s construction and in social housing. AIB is a higher-risk ACM — it is easily damaged and releases fibres when cut, drilled, or broken.

Asbestos cement products: asbestos cement was used extensively for roof slates, rainwater gutters and downpipes, soffits, fascias, garage roofs, outbuilding roofs, and external wall cladding. Asbestos cement products are typically a lower-risk ACM when in good condition — they are dense and fibre release is lower than with AIB or lagging — but they still require proper management and, when removal is needed, must be removed as ACMs without breakage or machining.

Ceiling tiles: suspended ceiling tiles in kitchens, bathrooms, and communal areas of flats were frequently made from asbestos insulating board or asbestos-reinforced tiles — particularly in 1960s–1980s construction.

Loose-fill insulation: some properties (particularly those built or refurbished in the 1960s and 1970s) had loosefill asbestos used as loft or cavity insulation. Loose-fill asbestos is a higher-risk ACM. It is rare in London residential properties but is still found occasionally — particularly in council properties built or refurbished in the 1960s–1970s.

There are two main types of asbestos survey under the Control of Asbestos Regulations 2012:

Management Survey (formerly Type 2): a management survey is carried out to identify the presence, location, and condition of ACMs in a property that is to remain in normal occupation, without intrusive investigation. A management survey is used to: Produce an asbestos register and management plan for a property. Identify the condition of ACMs and assess their risk. Ensure that ACMs in the property can be managed safely during normal occupation.

A management survey does not require intrusive investigation — the surveyor does not lift floor coverings, open voids, or probe behind finishes. It is therefore not suitable as a basis for construction or refurbishment work, because ACMs hidden behind finishes, within floor construction, or within service voids will not be found.

Refurbishment and Demolition Survey (R&D Survey — formerly Type 3): an R&D survey is required before any construction, refurbishment, or demolition work that will disturb the fabric of the building. It is intrusive — the surveyor lifts floor coverings, opens ceiling voids, probes behind finishes, and investigates within service risers and cupboards. The extent of intrusion depends on the scope of the proposed works.

An R&D survey is required: Before any refurbishment works that will disturb the building fabric — extension, loft conversion, full refurbishment, kitchen or bathroom replacement, structural alterations, rewiring, replumbing. Before demolition of any structure. In the areas of the building that will be disturbed — not necessarily throughout the entire property.

Practical implication: for a London rear extension, an R&D survey should be carried out in the areas where the extension will impact the existing building — the rear wall (which will be opened for the new extension opening), the kitchen floor and ceiling (if the kitchen is being reconfigured), and any areas where new service routes will be cut through existing structure. An R&D survey of the entire house is not always required for a limited-area extension — but the surveyor should scope the survey to match the planned works.

UKAS accreditation: R&D surveys must be carried out by a surveyor holding UKAS (United Kingdom Accreditation Service) accreditation for asbestos surveying under ISO 17020. Always confirm that the survey company holds current UKAS accreditation before commissioning an R&D survey.

The Control of Asbestos Regulations 2012 divides asbestos removal work into three categories: licensed work, notifiable non-licensed work (NNLW), and non-licensed work.

Licensed work (must be carried out by an HSE Licensed Asbestos Removal Contractor): Licensed work is required for any work with higher-risk ACMs where the risk of fibre release cannot be adequately controlled by non-licensed methods. Licensed work includes: Work with sprayed asbestos (historically used as fire protection on structural steelwork). Work with asbestos lagging (pipe and boiler insulation). Work with asbestos insulating board (AIB) — except for minor works lasting less than 1 hour per worker per week. Work with loose-fill asbestos insulation. Work where the risk assessment shows that the work cannot be carried out without the controls required for licensed work.

For licensed work, the contractor must hold an HSE Licence (renewed every 3 years). They must notify the HSE at least 14 days before licensed work begins (using ASB5 notification). They must provide suitable health surveillance for workers.

Notifiable non-licensed work (NNLW): work with lower-risk ACMs that does not meet the threshold for licensed work, but which must still be notified to the relevant enforcing authority (the local authority environmental health department, or the HSE depending on the premises type) before work begins. NNLW includes some work with asbestos cement and some work with Artex where the risk assessment shows that work does not meet the licensed threshold but fibre exposure is still significant.

Non-licensed work: the lowest-risk asbestos removal work — work where the risk assessment shows that asbestos exposure is likely to be sporadic and of low intensity. This can include, for example, encapsulation (sealing) of undamaged Artex in good condition, or very minor work with asbestos cement that does not create significant dust. Non-licensed work still requires compliance with CAR 2012 — a risk assessment, an appropriate method statement, and worker awareness training.

Practical rule: if in doubt about whether asbestos removal work is licensed or non-licensed, engage an HSE Licensed Asbestos Removal Contractor to carry out the assessment and the work. The penalties for using an unlicensed contractor for licensed asbestos work are significant.

Under the Control of Asbestos Regulations 2012, the contractor's obligation before construction or refurbishment work starts on a pre-2000 building is clear:

CAR 2012, Regulation 5 (Duty to manage asbestos) and Regulation 16 (Identification of the presence of asbestos): before any construction, refurbishment, or demolition work commences, the contractor must: Obtain an R&D survey for the areas to be disturbed. Review the survey findings and asbestos register. If ACMs are found in the areas to be disturbed: engage the appropriate contractor (licensed or non-licensed as the case requires) to remove or encapsulate the ACMs before construction works in those areas commence.

The building owner's role: the building owner (client) has a responsibility to commission an R&D survey before notifiable construction or refurbishment work commences. In practice, for domestic projects, this responsibility is often passed to the principal contractor — but the building owner should confirm that an R&D survey has been commissioned and that the survey results have been reviewed before works commence.

What to do with the survey results: If no ACMs are found in the areas to be disturbed: the contractor can proceed with the works. The survey report should be retained on site. If ACMs are found in good condition and can be left undisturbed: the contractor must ensure the ACMs are not disturbed during the construction works and must make arrangements for managing them (noting their presence in the project health and safety file). If ACMs are found that must be removed or disturbed: the contractor must arrange for the ACMs to be removed (by the appropriate licensed or non-licensed contractor) before construction works in that area commence. Removal must comply with CAR 2012 in full.

The Health and Safety File: under CDM 2015, the health and safety file for the project must include information about the presence and location of any remaining ACMs, so that future building owners and contractors are aware of them.

Despite proper surveys, ACMs are sometimes found unexpectedly during construction works — hidden in a wall cavity, under a floor screed, in a service void that could not be accessed during the survey. When this happens, the CAR 2012 emergency procedure applies.

Immediate actions when suspected asbestos is found during works: Stop work immediately in the disturbed area. Workers should leave the area and, if possible, close off access to it. Do not further disturb the suspected ACM. Do not attempt to clean up or remove material that may be asbestos. Treat the material as asbestos until proven otherwise. If there is doubt, it is asbestos until a UKAS-accredited analyst has confirmed otherwise. Seal off the area if practicable. Close doors and windows in the affected area to prevent the spread of any released fibres to other parts of the property. Notify the principal contractor immediately. The principal contractor is responsible for the next steps. Arrange for a UKAS-accredited analyst to take a sample and confirm whether the material contains asbestos. Bulk sampling and fibre identification must be carried out by a UKAS-accredited laboratory. If the material is confirmed as asbestos: arrange for a licensed contractor to attend (if licensed work is required) and carry out the remediation, clearance air test, and waste disposal. Licensed work requires HSE notification at least 14 days before commencement — but HSE emergency notification is available for unexpected finds.

Re-occupation of the disturbed area: the area must not be re-occupied or used until a clearance air test (carried out by a UKAS-accredited analyst) has confirmed that the area is safe. Only after a clearance certificate has been issued should work in the area resume.

Asbestos waste disposal: all asbestos waste (including the bags and overalls used during removal) must be disposed of as hazardous waste at a suitably licensed landfill. Asbestos waste cannot be put in general skips or taken to household recycling centres.