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Asbestos re-inspection: how often, and what the register must show

How often asbestos must be re-inspected: HSE's 12-month plan review, regular condition checks, what the register must hold, and blocks of flats.

The short answer

The duty to manage asbestos is continuous. The Control of Asbestos Regulations 2012 require a suitable and sufficient assessment, a written management plan, and a plan that is reviewed and implemented. HSE's guidance says to put the plan into action, monitor it and review it every 12 months or sooner if necessary.

How often each material is checked is set by your plan, based on the risk. There is no single statutory interval for condition checks, and many providers settle on an annual cycle.

What the duty to manage requires

Regulation 4 of the Control of Asbestos Regulations 2012 places the duty on whoever has an obligation under a contract or tenancy to maintain or repair non-domestic premises, or otherwise has control of them. HSE sets out what the dutyholder must do:

  • Assess whether asbestos-containing materials (ACMs) are present, how much, where they are and what condition they are in
  • Presume materials contain asbestos unless there is strong evidence that they do not
  • Make and keep up to date a record or register of the location and condition of the ACMs or presumed ACMs
  • Assess the risk of anyone being exposed to airborne fibres from them
  • Write an asbestos management plan to manage the risk
  • Put the plan into action, monitor it and review it
  • Share information on the location and condition of ACMs with anyone who may disturb them, and with the emergency services

The regulation also requires the conclusions of the assessment, and of every review, to be recorded, and requires the measures taken to implement the plan to be recorded as well.

"Re-inspection" and what HSE calls it

Re-inspection is the term most surveyors and housing providers use for a return visit to check the ACMs in the register against their original condition. HSE's guidance speaks in terms of monitoring the condition of ACMs and of regular condition checks. They are the same activity: a competent person revisits known and presumed materials, records any change, and the plan is updated.

How often: three separate clocks

WhatIntervalWhere it comes from
Review of the management planEvery 12 months, or sooner if necessaryHSE guidance on the duty to manage
Condition checks on individual ACMsAs set in the monitoring schedule in your plan, based on the material's riskHSE guidance on the management plan; regulation 4
Review triggered by eventsWithout delayRegulation 4: if there is reason to suspect the assessment is no longer valid; HSE: when work affects ACMs, management staff change, or ACMs are accidentally disturbed

Notice what is not in that table: a statutory instruction to re-inspect every ACM every year. HSE says that all ACMs in good condition must be regularly inspected to check they remain in good condition, and it expects the plan to carry a monitoring schedule. The interval is yours to set and to justify.

An annual cycle is the common choice and is easy to defend, because it lines up with the 12-month plan review. A shorter interval is sensible for material that is damaged, more likely to be disturbed, or in a high-traffic area, and a longer interval needs a documented reason.

Condition checks also feed the plan review. HSE lists the results of scheduled condition checks as one of the things that should prompt an update to the plan, so the two clocks are meant to run together.

Blocks of flats: what is covered and what is not

In domestic buildings the regulation 4 duty applies to the common parts, not to individual dwellings. HSE's own examples include foyers, corridors, lifts and lift shafts, staircases, roof spaces, gardens, yards, outhouses and garages. Individual flats are not part of the common parts.

That does not mean flats are out of scope in practice. Regulation 4 does not apply inside people's homes, but COSHH does, and a landlord still owes general duties under section 3(1) of the Health and Safety at Work etc. Act 1974 to protect tenants from risks arising from work done in their homes. The practical rule is the one HSE gives: areas that have not been inspected must be presumed to contain ACMs, and they need to be surveyed before any work takes place.

For a housing provider that means an asbestos survey before refurbishment or significant works in a home, and a process that stops a contractor starting before the right information has reached them.

What the register and plan should contain

  • The register: location, extent, material type and condition for every ACM and presumed ACM, with areas not inspected recorded as presumed
  • The plan: who is responsible, the register, a schedule for monitoring the condition of the ACMs, and time-based actions that are reviewed with the plan
  • Information flow: evidence that contractors and others likely to disturb ACMs were told, and that the emergency services can obtain the information
  • Records of action: what was done in response to each finding, and when

Northern Ireland

The Control of Asbestos Regulations 2012 apply across Great Britain. Northern Ireland has its own closely equivalent regulations, the Control of Asbestos Regulations (Northern Ireland) 2012, enforced by HSENI, including the duty to manage in communal areas of residential premises.

Where providers commonly lose the thread

  • A register that was complete after the baseline survey and has not been updated since works were done
  • Presumed ACMs that were never re-checked because nothing prompted anyone to look
  • The plan reviewed on paper each year but with no evidence that the condition checks actually took place
  • Information that exists but does not reach the contractor on the day, especially for responsive repairs and voids
  • Survey and re-inspection reports held by a contractor in a format the provider cannot search by property or block

The common thread is that the information is correct somewhere but not where the decision gets made. A register that a repairs operative can check before opening up a ceiling does its job. A register that sits in a PDF folder does not.

Common questions

How often should asbestos be re-inspected?

HSE says to review the management plan every 12 months or sooner if necessary, and requires ACMs in good condition to be regularly inspected. The interval for each material is set in your monitoring schedule. An annual cycle is the common choice.

Does the duty to manage apply to individual flats?

No. The duty covers the common parts of domestic buildings, such as corridors, stairs, lifts and roof spaces. Work inside a flat falls under COSHH and general health and safety duties, and an unsurveyed area should be presumed to contain asbestos before works.

What is the difference between a re-inspection and a survey?

A survey locates and assesses ACMs. A re-inspection is a return visit to check the condition of the ACMs already in the register and record any change.

Who is the dutyholder in a block of flats?

The person with an obligation under a contract or tenancy to maintain or repair the common parts, or otherwise in control of them. For rented housing that is normally the landlord.

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