Do I need an asbestos survey before refurbishment?
Many hotel owners and project managers assume that once they’ve had an asbestos management survey, they’re covered for all future works. But that’s a costly misconception. When refurbishment or demolition work is planned, even minor upgrades, The Control of Asbestos Regulations 2012 require a very different survey, a refurbishment and demolition (R&D) survey. While not exhaustive, this guide reflects good practice.
Do I legally need an asbestos survey before refurbishment?
Under Regulation 5 of the Control of Asbestos Regulations 2012, asbestos must be identified before any building work begins that could disturb the fabric of the structure. An asbestos survey can provide this information, but only if the correct type of survey is commissioned with a scope that fully covers the planned work.
An asbestos management survey is intended to locate asbestos-containing materials that could be disturbed during normal occupation and routine maintenance.
A refurbishment and demolition survey is more intrusive and is designed to identify materials concealed within the areas affected by the work, including behind walls and ceilings and within service ducts, risers and plant.
What happens if I don't have an asbestos survey?
The consequences of getting it wrong are very real. Hotels have been prosecuted after refurbishment works disturbed asbestos because suitable surveys and assessments had not been carried out before work started. In one case, Britannia Hotels was fined over £200,000 after asbestos was discovered during refurbishment at its Grand Burstin Hotel in Folkestone.
We’ve seen refurbishment projects delayed for weeks, and budgets blown, because asbestos was uncovered partway through works. That usually happens when the wrong survey type is chosen or when managers rely on old data instead of commissioning a new survey.
If your contractors disturb asbestos during works, the dutyholder and project manager are both legally accountable depending on their roles and the level of control they hold. The result?
HSE investigation and potential enforcement action
costly decontamination and remedial work
delays and unplanned project costs
temporary closure of affected areas
damage to the hotel’s reputation
Despite their different purposes, asbestos management surveys and refurbishment and demolition surveys have one important thing in common, they must be carried out by a competent surveyor. Although UKAS accreditation is not itself a legal requirement, HSE strongly recommends appointing a surveying organisation accredited by UKAS to BS EN ISO/IEC 17020.
For hotel projects, this should be the expected standard. Using an unaccredited or inexperienced provider increases the risk of an inadequate scope, incomplete findings and serious consequences if asbestos is later disturbed. Read more on the HSE guidance on selecting asbestos surveyors
How do I choose the right asbestos survey?
Before any refurbishment or demolition work, even seemingly minor projects such as repainting, rewiring, replacing flooring or refurbishing bathrooms, you should confirm that a refurbishment and demolition survey has been completed by UKAS-accredited asbestos surveyors in all areas affected by the work.
To stay compliant while avoiding unnecessary costs, consider speaking to an independent asbestos consultant before commissioning a new survey. By reviewing your project plans alongside your existing asbestos register and previous survey reports, they can determine whether your current information is sufficient or whether additional surveying is required. This independent advice can help prevent unnecessary duplication, reduce project costs and ensure you only commission the surveys you actually need.
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Frequently asked surveying questions:
Do I need a new asbestos survey before refurbishment?
Yes. Refurbishment or demolition work requires an R&D survey under the Control of Asbestos Regulations 2012. A management survey only covers normal occupation.
Who can carry out an asbestos refurbishment survey?
Only qualified asbestos surveyors with experience should perform R&D surveys. This ensures all asbestos-containing materials are located and sampled safely.
How is a refurbishment survey different from a management survey?
An asbestos management survey is non-intrusive and keeps your asbestos register current. A refurbishment survey is intrusive, it exposes hidden materials that may be disturbed during works.
When should a refurbishment survey be completed?
Before any refurbishment or demolition activity, including minor works such as drilling, rewiring, or replacing fittings.
What happens if asbestos is found during refurbishment?
Work must stop immediately. Take advice from your Asbestos Consultant before the project continues. Continuing work without assessment is a breach of Regulation 5.
How do I know if my existing asbestos survey is still valid?
If your last survey didn’t include intrusive inspections or has not been reviewed recently, it’s likely only a management survey. A consultant can review your records and advise.
Speak to one of our independent asbestos consultants before you commission a survey. We'll review your project, explain your options, and help you choose the right approach, avoiding unnecessary costs while keeping your project compliant.
