Understanding Your Asbestos Register: A Guide for Building Managers

If you manage a non-domestic building in the UK, you are legally required to know whether asbestos is present and to manage the risk it poses. The asbestos register is the foundation of that obligation. This guide explains what it must contain, who needs one, and how to keep it up to date.

What is an asbestos register?

An asbestos register is a written record of all known or presumed asbestos-containing materials (ACMs) in a building. It is produced following an asbestos management survey and forms the core document of your asbestos management plan. The register records the location, type, condition, and risk rating of every ACM identified, along with recommendations for how each material should be managed.

The register is a living document. It must be kept up to date as the condition of ACMs changes, as materials are removed or encapsulated, or as new areas of the building are surveyed. It must also be made available to anyone who might disturb ACMs during their work — including maintenance staff, contractors, and emergency services.

The legal requirement: Regulation 4, CAR 2012

The requirement to maintain an asbestos register comes from Regulation 4 of the Control of Asbestos Regulations 2012, commonly known as the duty to manage asbestos. This regulation applies to anyone who has responsibility for the maintenance or repair of non-domestic premises, or the common areas of domestic premises such as blocks of flats.

The duty holder must take reasonable steps to determine whether asbestos is present, assess the risk, prepare a written plan for managing it, and provide information to anyone who might disturb it. The asbestos register is the practical mechanism through which these obligations are met.

Failure to maintain an adequate register — or to make it available to those who need it — is a breach of Regulation 4. The HSE can issue improvement or prohibition notices, and in serious cases, prosecute. Penalties include unlimited fines and, for the most serious offences, imprisonment.

Who needs an asbestos register?

The duty to manage — and therefore the obligation to hold an asbestos register — applies to:

  • Owners and landlords of commercial properties
  • Facilities managers and managing agents of office buildings, retail premises, warehouses, and industrial units
  • Freeholders and management companies responsible for the common areas of residential blocks (hallways, stairwells, plant rooms, roof spaces)
  • Social housing providers managing communal areas of their stock
  • Schools, hospitals, churches, and other public buildings
  • Tenants who hold a repairing obligation in their lease

Note: Private domestic homes (houses and flats occupied by their owner) are not covered by Regulation 4. However, if you commission any building work on a pre-2000 home, the contractor has a legal duty under Regulation 7 to check for asbestos before starting work.

What must an asbestos register contain?

While the regulations do not prescribe a specific format, an adequate asbestos register should include the following for every identified or presumed ACM:

1

Location

The precise location of the ACM within the building, described clearly enough that someone unfamiliar with the building could find it. This should include the floor, room, and specific element (e.g. "Ground floor, boiler room, pipe lagging on hot water pipework").

2

Material type

The type of asbestos-containing material — for example, asbestos insulation board (AIB), sprayed coating, textured decorative coating (Artex), asbestos cement, pipe lagging, or floor tiles.

3

Asbestos fibre type

Where laboratory analysis has been carried out, the type of asbestos fibre present — chrysotile (white), amosite (brown), or crocidolite (blue). Where analysis has not been carried out, the material should be presumed to contain asbestos.

4

Condition assessment

A record of the current condition of the material — good, fair, or poor. This should note any damage, deterioration, or signs of disturbance. The condition directly affects the risk rating.

5

Risk rating / priority score

A numerical or descriptive risk rating based on the material type, condition, accessibility, and the likelihood that it could be disturbed during normal use. The HSE's algorithm considers material assessment and priority assessment scores.

6

Management recommendation

The recommended action for each ACM — typically monitor and manage in place, encapsulate, repair, or remove. The recommendation should be based on the risk rating and the planned use of the building.

7

Photographs and floor plans

Photographs of each ACM and annotated floor plans showing their locations. These are invaluable for contractors who need to identify ACMs before starting work.

8

Sample and analysis records

Details of any samples taken, the laboratory used for analysis, and the results. If no samples were taken and the material is presumed to contain asbestos, this should be clearly stated.

How often should you reinspect?

The Control of Asbestos Regulations 2012 do not specify a fixed reinspection interval. However, HSE guidance recommends that identified ACMs are monitored regularly to check for any change in condition. In practice, this means:

  • Annual reinspection — the most common interval for ACMs in good or fair condition. A competent person should visually inspect each recorded ACM and note any change in condition.
  • Six-monthly reinspection — appropriate for higher-risk materials (e.g. damaged lagging, deteriorating sprayed coatings) or ACMs in areas with heavy foot traffic or frequent maintenance activity.
  • After any incident or disturbance — if any ACM is accidentally damaged or disturbed, a reinspection should be carried out immediately and the register updated.
  • Before any building work — even if a management survey exists, a refurbishment and demolition survey must be commissioned before any work that could disturb the building fabric. See our guide to survey types for more detail.

Each reinspection should be documented with the date, the name of the inspector, and any observations about changes in condition. The register should be updated accordingly.

Making the register available

One of the most important obligations under Regulation 4 is to provide information about the location and condition of ACMs to anyone who is liable to disturb them. This includes:

  • Maintenance staff and in-house tradespeople
  • External contractors (electricians, plumbers, heating engineers, builders, decorators)
  • Emergency services (the register should be accessible in an emergency)
  • Building occupants, where relevant

Best practice is to keep a physical copy of the register at the building (for example, in the reception, concierge office, or plant room) and to issue a permit-to-work system that requires anyone carrying out maintenance or repair work to check the register before starting. Many building managers now also maintain a digital copy that can be shared electronically with contractors before they visit site.

Common mistakes to avoid

Treating the register as a one-off document

The register must be kept up to date. If ACMs are removed, encapsulated, or their condition changes, the register must be updated to reflect the current position. An outdated register is almost as dangerous as having no register at all.

Failing to share it with contractors

Every contractor working on the building should be shown the asbestos register before starting work. If a contractor accidentally disturbs asbestos because they were not told it was present, the duty holder — not the contractor — is likely to be held responsible.

Relying on a management survey for refurbishment work

A management survey identifies ACMs that could be disturbed during normal building use. It does not cover ACMs hidden within the building fabric. Before any refurbishment, maintenance, or demolition work, a separate refurbishment and demolition survey is required for the area where work is planned.

Not budgeting for reinspection

Annual reinspection is a recurring cost that should be built into the building's maintenance budget. A brief annual inspection is far cheaper than the consequences of an undetected deterioration.

Getting started

If you do not yet have an asbestos register for your building, the first step is to commission a management survey from a competent asbestos surveyor, ideally one accredited by UKAS to ISO 17020. The survey report will include the register as a core deliverable.

If you already have a register but it has not been reviewed recently, arrange a reinspection to verify that the recorded conditions are still accurate and that no new ACMs have been uncovered through building work or deterioration.

For more on the legal framework, see our guide to the duty to manage asbestos.

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