An outdated asbestos register can create a serious information gap for landlords, managing agents and commercial property dutyholders in London. Contractors may be about to enter a ceiling void, drill a service riser or replace building components without reliable information on asbestos-containing materials (ACMs).
A missing or old register does not automatically mean you must commission a completely new survey. The correct response depends on the building, who is responsible for it, the quality and scope of the existing evidence, and what work is planned. This guide explains how to make that decision.
Quick answer: what should you do first?
Identify the responsible dutyholder, collect all existing asbestos records, check whether they cover the building and affected areas, and prevent work that could disturb suspect materials until appropriate information and controls are in place. Update the register and management plan where needed; arrange a competent survey if the available evidence is inadequate.
1. Check whether the duty to manage applies
Under regulation 4 of the Control of Asbestos Regulations 2012, the duty to manage applies to non-domestic premises and common parts of multi-occupancy domestic buildings. It can apply to offices, shops, warehouses, shared corridors, stairs, lift spaces, service areas and other relevant common parts of blocks of flats.
The legal responsibility depends on who controls maintenance and repair. An owner, landlord, tenant or other person may have duties; contractual arrangements matter. The duty does not extend under regulation 4 to the private interior of an individual domestic flat simply because it is rented. However, separate duties still apply to work that could expose occupants or workers to asbestos.
See the HSE explanation of who holds the duty to manage and our guide to communal areas of flats.
2. Gather the existing information before ordering another survey
Ask the owner, previous managing agent, facilities team and any relevant contractors for documents. Do not assume that an unavailable report never existed.
- Previous asbestos management surveys and refurbishment or demolition survey reports.
- The current asbestos register, drawings, sample analysis results and records of presumed ACMs.
- An asbestos management plan, inspection records and maintenance logs.
- Asbestos removal or remedial-work records, including suitable clearance and reoccupation documentation where relevant.
- Records of alterations, new service routes or changes in the use of the building.
Compare the documents with the actual address, building areas, extensions, plant rooms, garages and common parts. A report for a single flat or shop unit does not necessarily cover the whole block or the communal fabric.
3. Decide whether the register is genuinely out of date
An asbestos register does not simply ‘expire’ on a fixed date. The key question is whether the information still accurately represents known or presumed asbestos, its location and condition, and the current use of the premises. A survey may still be useful years later if its scope and findings remain applicable, but changed conditions can make records unreliable much sooner.
Warning signs to investigate
- A survey lists ‘no access’ or excluded areas relevant to current maintenance.
- Partitions, floors, ceilings, services or roof areas have been altered since the survey.
- Recorded asbestos materials have deteriorated, been damaged or undergone remediation.
- The register is missing sample references, drawings, clear locations or condition information.
- Contractors plan intrusive work beyond the original management survey’s scope.
- The dutyholder cannot readily provide relevant information to people who may disturb building materials.
HSE guidance expects an asbestos management plan to be monitored and reviewed at least every 12 months, or sooner when necessary. That is not the same as a legal requirement to commission a new asbestos survey every 12 months. Read our asbestos reinspection and condition-monitoring guide.
4. Choose the right investigation for the gap
| Situation | Practical next step |
|---|---|
| No usable asbestos records for a relevant pre-2000 commercial building or communal area | Assess the information gap and normally arrange a suitable management survey by a competent surveyor. |
| Existing report is mostly reliable but parts of the building were inaccessible | Resolve access restrictions and obtain additional investigation for the affected areas, while managing uninspected suspect materials as presumed asbestos. |
| A specific material or location is uncertain | A competent assessment and targeted sampling may be appropriate, depending on what information is needed and whether work is planned. |
| Drilling, strip-out, structural alterations or demolition are planned | Check whether a targeted refurbishment survey or demolition survey is required before disturbing concealed building fabric. |
| Known ACMs remain in place and nothing has materially changed | Review their condition and the risk assessment, update the register and management arrangements as appropriate; a full new survey may be unnecessary. |
HSE’s survey guidance distinguishes management surveys for normal occupation from more intrusive refurbishment or demolition surveys. A routine management survey should not be treated as clearance for destructive building works.
5. Update the register and management plan
The register should identify known or presumed ACMs sufficiently clearly to support safe maintenance decisions. Record their locations, materials, condition and any limitations or assumptions. Include drawings and references to sample results where these are available.
A register alone does not complete the duty to manage. The dutyholder also needs a suitable risk assessment and management plan covering how ACMs will be protected, checked, repaired or removed where necessary, and how accidental disturbance will be dealt with.
For the service scope, see our asbestos register service page. Detailed technical guidance is available in HSE publication HSG264: Asbestos – The survey guide.
6. Give contractors the right information before work starts
Share the relevant register entries, plans, survey limitations and management arrangements with contractors and others likely to disturb asbestos. They need information for the specific location and task, not merely a statement that an old asbestos survey exists.
If a contractor proposes opening a wall or ceiling that has not been properly investigated, stop that element of work until the risks are assessed and suitable precautions are agreed. Suspect material should not be drilled, broken or sampled by untrained people.
See the HSE advice on providing asbestos information.
A seven-point asbestos register recovery checklist
- Confirm who controls maintenance and repair of each part of the building.
- Retrieve the latest register, surveys, sampling and previous remediation records.
- Check building identity, survey boundaries, dates and ‘no access’ entries.
- Walk through known changes, damage and forthcoming maintenance activities.
- Ask a competent surveyor to investigate material gaps where evidence is insufficient.
- Update the register, risk assessment and asbestos management plan.
- Make relevant information accessible to contractors and schedule regular reviews.
Questions London landlords and managing agents ask
Is an asbestos survey legally required every year?
No general annual re-survey rule applies to every building. Dutyholders must keep records and risk management arrangements effective; HSE recommends reviewing the management plan at least every 12 months and earlier when circumstances change. Whether a further survey is necessary depends on the evidence and risks.
Can we use a previous owner’s asbestos report?
Potentially, if it is credible, suitably scoped, accessible and still reflects the building’s condition. Verify the report’s limitations and investigate any gaps. Ownership change alone does not always justify repeating satisfactory survey work.
What if asbestos is recorded in good condition?
Asbestos does not automatically need removal just because it is present. Where suitable, it may be managed in place with appropriate controls and monitoring. The choice depends on the material, condition, exposure risk and planned work.
Get help checking your London building’s asbestos information
If your asbestos register is missing, incomplete or out of date, request an asbestos survey quotation and tell us the property type, location, existing records and planned works. We can help establish an appropriate survey scope rather than automatically recommending a whole-building re-survey.
We offer same-day site visits subject to availability, digital reports issued within 24-48 hours of the site visit, and transparent pricing with no hidden charges.