- The asbestos register records the location, type, extent and condition of every asbestos-containing material (and presumed material), usually derived from the management survey.
- The management plan sets out how each material will be managed, who is responsible, how the information is shared, and when materials are re-inspected.
- Both must be kept up to date, reviewed at least annually, and made available to anyone liable to disturb the materials, including contractors.
- A survey without a plan, a plan nobody has read, and a register that is five years old are the three most common failures.
A surprising number of buildings have an asbestos survey in a drawer and nothing else. The survey on its own does not discharge the duty to manage. The law requires a record of where the asbestos is and what condition it is in, a plan for managing it, and for that information to reach the people who might disturb it. Here is what the register and the plan contain and how to keep them current.
The asbestos register
The register is the record of findings. For each asbestos-containing material, or material presumed to contain asbestos, it should state the location (with a plan), the type of material and asbestos (where sampled), the extent, the condition, the assessed risk and any action taken. It is typically produced from the management survey report and updated as materials are removed, encapsulated or re-inspected. HSE expects it to be readily available on site.
General information, not legal advice.
The management plan
The plan says what you will do about what the register records. It should set out: who is responsible for managing asbestos in the building; the decision for each material (manage in place, encapsulate, remove) and the reasoning; how the condition will be monitored and how often; how the information will be communicated to staff, contractors and the emergency services; the procedures for work that may disturb materials, including a permit-to-work system; and arrangements for emergencies, such as accidental damage. It is a working document, not a certificate.
Who must see them
Anyone liable to disturb the materials: maintenance staff, every contractor before they start work, utility engineers, and the fire and rescue service if asked. The practical test is simple: could a tradesperson drill into that wall or lift that ceiling tile without knowing what is behind it? If so, the information has not been shared. Many duty holders keep the register at reception and brief every contractor on arrival.
Get your register and plan
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Review and re-inspection
The plan should be reviewed at least every twelve months and whenever the building, its use or the materials change. Materials left in place should be re-inspected periodically, with the interval set by their condition and location: a damaged board in a busy corridor more often than sound insulation in a locked plant room. Re-inspection results go into the register, and that is how it stays accurate.
The common mistakes
- Treating the survey report as the plan.
- Nobody named as responsible.
- A register kept at head office that nobody on site has seen.
- Contractors starting work without a briefing.
- No re-inspection since the original survey.
- Removals or works done and the register never updated.
Getting the documents right
A qualified surveyor produces the survey, register and a management plan you can actually run. Our guide to the duty to manage sets out the legal context. ComSurv matches you with qualified asbestos surveyors who cover your area, with no-obligation quotes.
Sources & further reading
- HSE: The duty to manage asbestos — what the register and plan must do
- Control of Asbestos Regulations 2012, regulation 4 — the legal requirement
External links open in a new tab. ComSurv is a matching service, not a firm of surveyors, and is not affiliated with these organisations. This article is general information, not legal, surveying or valuation advice; take advice on your specific situation.