What Is an Asbestos Register? A Practical Guide for Hotel General Managers.
An asbestos register is a live document that records the location, type, condition, and risk level of any known or presumed asbestos-containing materials (ACMs) within a building.
The asbestos register underpins your management plan and is a statutory requirement for all hotels built before 2000, as mandated by Regulation 4 of the Control of Asbestos Regulations 2012.
In hotels, this means General Manager or anyone appointed as their deputy duty holder, like the Chief Engineer must ensure the register is accurate, accessible, and up to date.
Why Hotels Need One
Hotels are constantly in motion — with ongoing maintenance, refurbishments, and high contractor access. If asbestos is present (or suspected), the register helps you:
Prevent accidental disturbance of ACMs
Protect guests, staff, and contractors
Comply with legal duties under Regulation 4 of the Control of Asbestos Regulations 2012
Keep your insurance and audit trail intact
What the Register Should Include
Your asbestos register should clearly list:
📍 Location of ACMs (room/area, floor, etc.)
🔍 Description (material type, presumed or confirmed, condition)
🧪 Sample or survey references
⚠️ Material and priority risk scores
🛠️ Management actions taken (e.g. encapsulated, removed)
📅 Reinspection dates and last review
Who Creates and Maintains the Register?
The register should be created and maintained by the duty holder, their deputy duty holder or a competent asbestos consultant acting on their behalf. It is common to base the register on the findings of a UKAS-accredited surveyor, but:
Surveyors do not create the register for you. It is not their responsibility — it’s yours.
In a recent UKATA webinar, Sam Lord, HM Principal Specialist Inspector at the Health and Safety Executive (HSE), delivered an important reminder for duty holders managing asbestos.
❌ A Survey Is Not a Register — And It’s Not Enough
One of the key concerns raised was that many organisations are still confusing their asbestos survey with a register. The two are not the same.
Sam Lord, HSE discussed recent inspections where, for many the register had not been extracted or developed as a live, standalone document. Instead, it was left embedded as a static PDF at the back of a survey report — rarely reviewed, updated, or used correctly.
Your asbestos register must be a working document, created and maintained by the duty holder or a competent asbestos consultant acting on their behalf. It should be updated over time, reflect real changes to the building, hold content from all of your surveys and inform decisions about maintenance, refurbishment, or contractor access.
❌ Treating a survey as “the register” is a common compliance failure — and one that puts your team at risk.
A register is a working document, that should:
Be accessible and editable
Include notes and real-world annotations as conditions change
Be updated when ACM’s are discovered in your hotel.
Reflect today’s risk, not the snapshot from a year ago
Be updated when materials are removed, repaired, or re-surveyed
When Should the Register Be Updated?
Update your register whenever there’s a change in:
The condition of ACMs (e.g. damage, deterioration)
The presence of ACMs (e.g. after removal or further sampling)
The likelihood of disturbance (e.g. room use changes, planned works)
Registers must be reviewed at least annually, even if no changes are made.
Who Needs Access?
Anyone working on the building must have access to the relevant parts of the register — this includes:
Engineers
Maintenance staff
External contractors
Project teams
Don’t keep it locked away in a file or buried in a system. Make it visible, up-to-date, and relevant.
✅ Quick Hotel Checklist
Do we have an asbestos register in place for all areas?
Is it based on up-to-date information from surveys and reinspections?
Does it reflect any removal, repairs, or project work done?
Has it been reviewed in the last 12 months?
Do our teams and contractors know how to access it?
The asbestos register is your first line of defence against accidental disturbance — and a critical tool in your legal compliance.
✅If you’re relying on a PDF from your last survey, it’s time for a review.
Need help reviewing or reformatting your asbestos register into something usable? Get in touch — we support hotels in turning paperwork into live, safe systems.
t. 0333 880 1864
e. info@kustenvorland.com
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