What Is Non-Licensed Asbestos Removal?

Asbestos is still present in a large proportion of UK buildings constructed or refurbished
before the year 2000. While the word causes understandable concern, not all asbestos-related
work carries the same level of risk, and not all of it requires a licensed contractor.
Understanding the distinction between licensed, notifiable non-licensed, and non-licensed
asbestos work matters if you are a property owner, landlord, facilities manager, or anyone
planning renovation work on an older building.

How the HSE Categorises Asbestos Work

The Health and Safety Executive (HSE) divides asbestos work into three categories based on risk:

• Licensed work (highest risk):
  Work with asbestos insulation, asbestos coating, or asbestos insulating board (AIB) in poor
  condition. It must be carried out by an HSE-licensed contractor with full notification,
  medical surveillance and decontamination procedures.
• Notifiable non-licensed work (NNLW):
  Work with certain materials that do not require a licence but must be notified to the relevant
  enforcing authority before work starts. This includes work with AIB in good condition where
  the risk of fibre release is low. Employers must also maintain health records and designate
  work areas.
• Non-licensed work (lowest risk):
  Work with materials where asbestos fibres are firmly bound within a matrix and are unlikely
  to be released during careful removal. No licence or notification is required, but all other
  duties under the Control of Asbestos Regulations 2012 still apply.

Which Materials Fall Under Non-Licensed Removal?

According to the HSE’s Asbestos Essentials guidance, common materials that can be removed
without a licence include:

• Asbestos cement, including roof sheets, guttering, downpipes, flue pipes, water tanks and garage roofs
• Textured decorative coatings, such as Artex applied before 2000
• Vinyl floor tiles containing asbestos
• Bitumen-based products, including roofing felt and damp-proof courses
• Asbestos-containing gaskets, rope seals and flash guards

These materials are considered lower risk because the asbestos fibres are tightly bound within
a matrix such as cement, resin, bitumen or PVC. They are unlikely to become airborne unless the
material is significantly damaged, aggressively cut, drilled at high speed or ground down.

The key condition for non-licensed work is that the material must be in reasonable condition
and must not be deliberately broken up during removal. If the material is degraded, crumbling
or friable, it will likely move into the NNLW or licensed category.

Legal Duties for Non-Licensed Work

Although no licence is required, the Control of Asbestos Regulations 2012 still impose strict
duties on anyone carrying out the work:

1. Training:
   All workers must have received adequate asbestos awareness training and task-specific
   training appropriate to the work being undertaken.
2. Risk assessment:
   A written risk assessment must be completed before work begins, identifying the type and
   condition of the material and the control measures to be used.
3. Method statement or plan of work:
   A written plan must detail how the work will be carried out safely.
4. Control measures:
   Appropriate PPE must be used, including respiratory protective equipment and disposable
   overalls. Other measures include wet removal methods, protective sheeting, controlled
   lowering instead of dropping or breaking materials, and Class H vacuum cleaning.
5. Waste disposal:
   All asbestos waste must be double-bagged in correctly labelled bags, transported by a
   registered waste carrier, and disposed of at a licensed facility with the correct
   consignment notes.
6. Record keeping:
   Records of the work and all waste disposal documentation must be retained.

The HSE’s Asbestos Essentials task sheets provide step-by-step instructions for specific
non-licensed tasks, including removing cement roof sheets, cleaning gutters on asbestos
cement roofs and drilling into cement products.

Can a Homeowner Remove It Themselves?

There is no legal prohibition on a homeowner removing non-licensed asbestos materials from
their own property. However, it is strongly discouraged for several practical reasons:

• Without training, you may not correctly identify all asbestos-containing materials present.
• Incorrect handling, such as snapping, dropping or dry cutting, can release fibres into your
  breathing zone.
• You remain legally responsible for correct disposal, and your local household waste recycling
  centre may require advance booking, specific packaging and a disposal fee.
• No documentation trail will exist if you later sell the property and a buyer’s surveyor asks
  about asbestos management.

Using a professional team ensures safe handling, certified disposal with a full paper trail,
and peace of mind that nothing has been missed.

What About Asbestos Surveys?

Before any refurbishment or demolition work begins on a building constructed before 2000,
a refurbishment and demolition (R&D) survey should be carried out to identify all
asbestos-containing materials in the areas affected by the work. This is a legal requirement
under Regulation 7 of the Control of Asbestos Regulations 2012.

Even for smaller projects, such as a bathroom renovation, kitchen extension or new boiler
installation, it is worth checking whether the materials being disturbed contain asbestos
before any other trades start work.

How Smiths Groundworks Can Help

Our trained asbestos handling team carries out non-licensed asbestos removal across London
and Surrey for both residential and commercial properties.

We commonly handle:

• Asbestos cement roof sheets and panels during refurbishment
• Textured coating, including Artex removal during renovation
• Asbestos-containing floor tile removal before new flooring is installed
• Asbestos cement downpipe and guttering replacement

Every job includes a site assessment, written plan of work, safe removal using
HSE-recommended methods, full PPE for our team, and certified waste disposal with
consignment documentation for your records.