Compliance Guide

CDM Regulations and Asbestos

A practical guide for UK site managers, contractors and small builders.

Asbestos is one of the risks the CDM Regulations expect you to plan for from the very start of a project, not something you deal with only if you happen to trip over it. On any construction, refurbishment or demolition job in Great Britain, the Construction (Design and Management) Regulations 2015 work alongside the Control of Asbestos Regulations 2012, and between them they set out who must find out about asbestos, who must control it, and what has to happen before a tool touches the fabric of the building. This guide explains how the two sets of rules fit together, which asbestos survey you need, and what to do if you find asbestos on site.

How CDM 2015 and the asbestos regulations fit together

CDM 2015 governs how health and safety risks are planned and managed across a whole construction project, while the Control of Asbestos Regulations 2012 set the specific duties for work that disturbs or could disturb asbestos. The two overlap by design. CDM requires duty holders to identify significant risks and control them proportionately, and asbestos is exactly the kind of hidden, high-harm risk it has in mind. So when you meet your CDM duties properly on a building that may contain asbestos, you are also feeding into the asbestos regime: the information you gather, the plan you write and the way you sequence the work all have to account for it.

Asbestos and pre-construction information

Under CDM 2015 the client must provide pre-construction information to the designers and contractors, and where the building was built or last refurbished before the year 2000 that information should say what is known about asbestos. This normally comes from an asbestos survey or the building's asbestos register, which the duty holder for the premises is required to hold under the Control of Asbestos Regulations. If that information is missing, the client cannot simply leave the gap for the contractor to discover the hard way; the whole point of pre-construction information is that risks like asbestos are flagged early so the work can be designed and priced to deal with them safely.

Which asbestos survey you need

The right survey depends on what the work involves, and getting this wrong is one of the most common asbestos failures on site. The three types you are likely to meet are set out below.

Management survey. This is the routine survey that supports the ongoing management of asbestos in an occupied building. It locates asbestos so it can be managed in place, but it is not designed to clear an area for construction work.
Refurbishment survey. Before any refurbishment or intrusive work, a refurbishment survey is needed for the area affected. It is more thorough and intrusive than a management survey because the point is to find asbestos that the work would otherwise disturb.
Demolition survey. Before demolition, a full demolition survey is required so that all asbestos can be located and removed before the structure comes down. It is the most intrusive of the three and covers the whole building or the part being demolished.

Duty holder responsibilities for asbestos

Responsibility for asbestos is shared across the CDM duty holders. The client must make sure the pre-construction information reflects what is known about asbestos and commission the right survey where one is needed. The principal designer must take asbestos into account when coordinating the pre-construction phase, and designers should avoid designs that force needless disturbance of asbestos-containing materials. The principal contractor and contractors must plan the work so that asbestos is not disturbed without proper controls, brief workers, and stop and reassess if the survey information turns out to be wrong. None of these duties depends on the size of the job.

What to do if you find asbestos during the works

If you uncover a material you suspect is asbestos that was not identified beforehand, stop work in that area immediately, keep people away and do not disturb it further. Have the material assessed, and only resume once the right controls are in place. The nature of the controls depends on the material and the task: some higher-risk work must be done by a licensed contractor under a licence from the Health and Safety Executive, some lower-risk tasks fall under notifiable non-licensed work, and some minor work is non-licensed but still tightly controlled. Whichever category applies, the CDM principle holds: the work must be planned, managed and monitored so that nobody is exposed.

The rule in one line: On any pre-2000 building, CDM 2015 and the Control of Asbestos Regulations 2012 work together to require that asbestos is identified through the right survey, flagged in the pre-construction information, and controlled before the work starts, with the specific survey and controls scaled to whether the job is management, refurbishment or demolition.

Frequently asked questions

Do the CDM Regulations cover asbestos?

Yes, indirectly but importantly. CDM 2015 requires duty holders to identify significant health and safety risks and control them proportionately, and asbestos is one of those risks. On site the CDM duties sit alongside the Control of Asbestos Regulations 2012, so meeting your CDM obligations means gathering asbestos information, planning around it and controlling exposure, not treating it as a separate afterthought.

Do I need an asbestos survey before construction work?

For any building built or last refurbished before the year 2000, you should assume asbestos may be present and get the right survey before intrusive work begins. A refurbishment survey is needed before refurbishment or intrusive work in the affected area, and a full demolition survey before demolition. This information then belongs in the pre-construction information the client provides under CDM 2015.

Who is responsible for asbestos on a construction project?

Responsibility is shared. The client must ensure asbestos information and the right survey are provided, the principal designer must factor it into the pre-construction phase, and the principal contractor and contractors must plan and manage the work so asbestos is not disturbed without proper controls. Higher-risk asbestos work must be carried out by a licensed contractor under a Health and Safety Executive licence.

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This article is general guidance for UK construction and is not legal advice. For requirements specific to your work, check the full text of CDM 2015, the Control of Asbestos Regulations 2012 and current HSE guidance L153 and HSG264, along with your own duty holder obligations.