Replacing a roof can involve much more than removing tiles or sheets. Contractors may disturb soffits, fascias, undercloaking, roof coverings, rainwater goods, insulation, service penetrations and concealed materials around the roof structure. If those materials could contain asbestos, suitable asbestos information should be available before work starts.
For London properties built or refurbished before 2000, the right approach depends on the roof construction, the materials present and exactly what the replacement work will disturb. A routine management survey may be useful for normal occupation, but it may not be sufficient for intrusive roof replacement work. Where the work will disturb the building fabric, review our refurbishment asbestos survey service.
Do you need an asbestos survey before replacing a roof?
Not every roof replacement automatically requires a completely new asbestos survey. The key question is whether the planned work could disturb materials that may contain asbestos and whether reliable existing information already covers those exact areas.
HSE guidance states that materials which may contain asbestos must be properly identified before refurbishment, maintenance or repair work that could disturb them. Where intrusive work is planned, a suitably scoped refurbishment survey may be needed for the affected area.
Roofing materials that may contain asbestos
HSE identifies several asbestos-containing products that can occur around roofs and rooflines. Their presence cannot be confirmed reliably by appearance alone, so existing records, competent inspection and laboratory analysis may be needed.
- Profiled asbestos cement roof sheets
- Asbestos cement roof tiles or slates
- Asbestos cement undercloaking beneath roof edges
- Asbestos insulating board (AIB) or asbestos cement soffits and fascias
- Asbestos cement gutters and downpipes
- Some older roofing felts and bituminous products
- AIB or other asbestos-containing panels around roof spaces or service areas
- Pipe insulation or other ACMs in roof voids and plant areas
For a broader overview of common ACMs, see our asbestos-containing materials guide.
Why an existing management survey may not be enough
A management survey is intended to support normal occupation and routine maintenance. It is generally less intrusive because its purpose is to identify ACMs that could be disturbed during normal use or foreseeable maintenance. For intrusive roof replacement, review our refurbishment asbestos survey service.
Roof replacement can require removal of coverings, opening roof voids, disturbing soffits or fascias, taking down rainwater goods and exposing concealed junctions. These areas may not have been accessible during a management survey.
HSE’s HSG264 survey guide explains that refurbishment surveys are designed to locate asbestos in the parts of a building that will be disturbed by planned work. That can require intrusive inspection into the building fabric.
If you are unsure which survey type applies, read our management survey vs refurbishment and demolition survey guide.
What should be checked before roof work starts?
- Any existing asbestos survey and asbestos register
- Whether the roof, soffits and external panels were included in the earlier survey
- Areas recorded as inaccessible or outside scope
- Roof plans and records of previous replacement or repairs
- The exact materials contractors intend to remove, drill, cut or disturb
- Roof voids, plant areas or service routes that will be opened
- Whether rainwater goods, panels or undercloaking will also be removed
- Whether representative sampling is required before work begins
When might a refurbishment survey be appropriate?
A refurbishment survey may be appropriate where roof replacement will disturb parts of the building fabric that have not already been adequately inspected. The survey should be targeted to the actual work area rather than automatically covering unrelated parts of the property.
| Planned roof work | Typical asbestos consideration |
|---|---|
| Replacing modern roof coverings with reliable asbestos records | Existing information may be sufficient if no suspect or concealed material will be disturbed |
| Removing older profiled cement sheets | The material should be identified before removal and handled using appropriate asbestos controls if confirmed |
| Removing soffits or fascias | AIB or asbestos cement may be present and can require sampling or intrusive investigation |
| Opening roof voids or service areas | Hidden boards, insulation, pipework or debris may need investigation |
| Major strip-out of an older roof system | A suitably scoped refurbishment survey is commonly required before intrusive work |
Asbestos cement roofs need careful planning
Asbestos cement roof sheets are one of the better-known asbestos products found on older industrial, commercial and domestic outbuildings. HSE describes asbestos cement as a hard material in which asbestos fibres are bound into a cement matrix.
Some work on asbestos cement can be non-licensed when the material is removed carefully without substantial breakage, but that does not mean the work is unrestricted. Workers still need the correct training, risk assessment, controls and waste arrangements. If asbestos cement is significantly broken up, the work may become notifiable non-licensed work.
Other roofline materials can present a higher risk. For example, work involving asbestos insulating board may fall into a different category and can require a licensed asbestos contractor depending on the task and condition.
Do not rely on appearance alone
Old cement sheets, soffit panels and roofing products can look similar whether or not they contain asbestos. Visual inspection can help identify suspect materials, but laboratory analysis is normally needed to confirm a sampled material.
If the concern relates to one specific accessible material rather than a wider refurbishment scope, our asbestos testing service and sample analysis guidance explain the difference between targeted testing and a full survey.
What if asbestos is identified in the roof?
Finding asbestos does not automatically mean the entire roof must be removed immediately. The next step depends on the type and condition of the material and whether the planned roof work will disturb it.
If an ACM is directly within the replacement scope, the project may need suitable asbestos removal, controlled work or a revised method before general roofing work proceeds. The contractor carrying out asbestos work must have the appropriate competence, and some higher-risk asbestos work requires an HSE-licensed contractor.
See our guide on what to do when asbestos is found in a survey.
Roof replacement asbestos checklist
- Define exactly which roof and roofline materials will be disturbed.
- Check existing asbestos surveys and registers before contractors start.
- Compare any survey limitations with the planned work area.
- Do not assume that an older management survey cleared concealed roof materials.
- Arrange targeted sampling or a refurbishment survey where appropriate.
- Provide relevant asbestos information to the roofing contractor before work begins.
- Plan removal or other controls before disturbing confirmed ACMs.
- Update the asbestos register where relevant after removal or new findings.
Authoritative HSE guidance
HSE’s HSG264: Asbestos – The survey guide explains how refurbishment surveys should be planned and scoped. HSE also provides guidance on where asbestos can be found in buildings and on health and safety in roof work.
This article provides general guidance rather than legal advice. The correct survey and work method depend on the property, the existing asbestos information and the exact materials and areas that will be disturbed.
Planning roof replacement in London?
If you are planning roof replacement, repairs or associated refurbishment and need to establish the appropriate asbestos survey scope, send us the property details and planned work. We can review the enquiry and provide a property-specific quotation.