An asbestos awareness risk assessment under the Control of Asbestos Regulations 2012 (CAR 2012) is the document that records whether asbestos-containing materials (ACMs) are present in a work area, whether the planned work will disturb them, and — if so — whether the work is non-licensed, notifiable non-licensed (NNLW), or licensed. Getting this categorisation wrong is one of the most heavily penalised failures in UK construction.
Regulation 4 of CAR 2012 imposes the 'duty to manage' on the dutyholder of any non-domestic premises: an asbestos register must exist, and any contractor working on the building must be provided with the relevant entries before work starts. For pre-2000 buildings, a Refurbishment and Demolition (R&D) survey is required before any intrusive work. The risk assessment opens by recording (a) whether an R&D survey exists, (b) when it was carried out, and (c) what ACMs it identified in the work area.
A risk assessment that does not reference an R&D survey for a pre-2000 building is non-compliant on its face. Reviewers reject these immediately.
CAR 2012 splits asbestos work into three categories. Licensed work (most friable ACMs — sprayed coatings, pipe lagging, AIB above a small task threshold) requires an HSE-licensed contractor and is out of scope of a general construction risk assessment. NNLW (notifiable non-licensed work — typically removal of textured coatings, gaskets, rope seals, AIB in small quantities) requires HSE notification (form ASB5), medical surveillance, and centralised record-keeping. Non-licensed work (drilling, cutting, sanding of bonded ACMs in good condition for short durations) requires competence, a risk assessment, and a specific work method but no HSE notification.
The risk assessment must record which category the planned work falls into, with a clear justification against the CAR 2012 thresholds (Schedule 3 sets the criteria).
Regulation 11 sets the prevention / control hierarchy. The risk assessment names the chosen control: shadow vacuuming (with H-class M-class is insufficient for asbestos — only H-class extraction meets the regulation), wet methods (water-injected drilling, damping), enclosure where dust generation is unavoidable, and RPE (FFP3 disposable for short-duration non-licensed work, half-mask P3 for longer; powered TH3 hoods for higher-risk NNLW).
The assessment also names the decontamination procedure: bag and double-bag protocol, clearance air monitoring where required, and waste consignment under the Hazardous Waste Regulations 2005 (asbestos is hazardous waste code 17 06 05*).
For NNLW, regulation 22 requires medical surveillance — a chest examination by an appointed doctor at least every two years, with records kept for 40 years. The risk assessment names the surveillance provider and the recall regime. Operatives must hold category-appropriate training — Asbestos Awareness (CAR Cat A) for any operative who may encounter asbestos, Non-Licensed Work (Cat B) for operatives carrying out non-licensed or NNLW tasks. Training is annual under CAR 2012 reg 10.
The numbered sections a reviewer expects to see, in order.
Construction date, R&D survey reference and date (mandatory for pre-2000 buildings), asbestos register extract.
Specific ACMs identified, their location, condition (Material Assessment Score), and whether the planned work will disturb them.
Licensed / NNLW / non-licensed — with justification against CAR 2012 Schedule 3 thresholds.
Form ASB5 reference, notification date (at least 14 days before work commences).
Avoid / enclose / wet methods / H-class extraction / RPE — applied in order with justification for the chosen control.
FFP3 / half-mask P3 / powered TH3 — face-fit records, disposable coveralls (Type 5), gloves.
Decon unit (3-stage for licensed, 1-stage acceptable for short non-licensed), bag and double-bag protocol, transit waste route.
Hazardous Waste Regulations 2005 — consignment note, EWC code 17 06 05*, licensed waste carrier.
Operative Asbestos Awareness / Non-Licensed Work training (annual under reg 10), medical surveillance for NNLW operatives (reg 22, 2-yearly).
Why a risk assessment gets sent back — these are the patterns we see most often.
The legal framework this risk assessment operates inside. Links go to the official source.
SI 2012/632
The statutory framework — duty to manage, categorisation, work method hierarchy, training and surveillance.
HSE L143
Approved Code of Practice for CAR 2012; the benchmark for non-licensed and NNLW work.
HSE HSG264
Reference for the Refurbishment and Demolition (R&D) survey required before intrusive work in pre-2000 buildings.
SI 2005/894
The waste consignment regime — asbestos waste code 17 06 05*, licensed carrier and disposal records.
Yes for any intrusive work in a building constructed before 2000. CAR 2012 regulation 5 requires it. A Management Survey is not sufficient for intrusive work — it identifies ACMs in accessible locations to manage them in place, but does not cover the depths an R&D survey reaches. Carrying out intrusive work on a pre-2000 building without an R&D survey is a CAR 2012 breach.
Non-licensed work involves bonded ACMs in good condition, short-duration tasks below the CAR 2012 Schedule 3 thresholds — e.g. drilling a hole through cement-asbestos sheet. NNLW (notifiable non-licensed work) sits above the Schedule 3 threshold but below licensed work — e.g. removing a small area of textured coating, or sanding an AIB panel. NNLW requires HSE notification (ASB5), medical surveillance, and a 40-year record retention regime.
FFP3 disposable as a minimum for short-duration tasks; half-mask with P3 cartridge for longer or higher-exposure work; powered respirator TH3 for higher-risk NNLW. FFP2 is not acceptable for asbestos work. All tight-fitting RPE requires face-fit testing under HSE OC282/28.
No. CAR 2012 and L143 specify H-class (high efficiency) extraction for asbestos — M-class is insufficient because the filter efficiency does not meet the standard for fibres in the asbestos size range. Using M-class extraction is one of the most common non-compliances on small refurbishment jobs.
Annually under CAR 2012 regulation 10. The HSE position is that any operative who may encounter asbestos (which includes most construction operatives working on pre-2000 buildings) must have current Category A Asbestos Awareness training. NNLW operatives also need Category B (Non-Licensed Work) training, also annually.
Trade-specific RAMS guidance for the contractors who typically produce this risk assessment.
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Final RAMS must be reviewed and approved by a competent person before use.