Why Your Asbestos Survey Should Not Tell You When to Re-Inspect

(And why many still do)

If you manage buildings long enough, you’ll notice something curious.

Almost every asbestos survey report says the same thing:

Reinspect annually.

Sometimes six months.
Occasionally twelve.
Nearly always identical wording, regardless of whether the material sits sealed above a ceiling void or is mounted beside a busy commercial kitchen door.

It looks authoritative.
It feels compliant.
But technically, it’s often wrong.

And more importantly, it misunderstands how asbestos management is supposed to work under UK law.

The quiet misunderstanding in the asbestos industry

Under Regulation 4 of the Control of Asbestos Regulations 2012, responsibility for managing asbestos sits firmly with the dutyholder.

Not the surveyor.
Not the laboratory.
Not the template report.

The dutyholder must ensure asbestos-containing materials are:

• identified,

• assessed,

• monitored, and

• managed appropriately over time.

Notice what the regulation does not say.

There is no requirement for annual inspections.
No mandated six-month review.
No fixed timetable anywhere in the legislation.

Instead, the law requires something more demanding: Judgement.

Surveys inform management, they do not replace it

The role of an asbestos survey is clearly defined within HSG264 Asbestos: The Survey Guide.

A surveyor assesses material risk:

• product type

• condition

• surface treatment

• asbestos type

This produces the familiar Material Assessment Score.

But asbestos risk is only half the equation.

Real risk depends on questions a surveyor usually cannot answer during a site visit:

• Who occupies the space?

• How often is it accessed?

• What maintenance takes place?

• Are contractors regularly disturbing the area?

• Is refurbishment planned?

• Is the space rarely entered or operationally critical?

These factors form the Priority Assessment and they belong to building management.

In other words:

The survey provides data.
Management determines risk.

So where did “annual reinspection” come from?

The answer lies in guidance written for simplicity, not prescription.

The HSE leaflet INDG223 Managing asbestos in buildings suggests inspections are typically every 6–12 months, depending on material type, location and condition.

This was intended as practical advice for dutyholders starting an asbestos management system.

Over time, however, something subtle happened.

Typical practice became perceived requirement.

And template-driven reporting turned guidance into default instruction.

The template problem

Many survey organisations operate under highly standardised reporting systems.

From a quality assurance perspective, this makes sense:

• consistent outputs,

• easier technical review,

• reduced professional liability.

But templates favour uniformity, not context.

So a panel board sealed in a locked riser receives the same inspection recommendation as damaged insulation in an active plant room.

The report looks complete.

Yet the decision has been made without operational knowledge of the building.

What HSE guidance actually says

HSG227 A Comprehensive Guide to Managing Asbestos in Premises is clear:

ACMs must be inspected periodically, and the frequency depends on:

• location,

• accessibility,

• building activities,

• occupancy,

• likelihood of disturbance,

• and changes in use.

This is risk-based management, not calendar-based compliance.

The inspection regime should emerge from the Asbestos Management Plan, not be pre-written into a survey report.

Why this distinction matters

When inspection intervals are copied blindly into reports, three problems arise:

1. Responsibility becomes blurred

Dutyholders may assume compliance sits with the survey recommendation rather than ongoing management.

2. Resources are misdirected

Low-risk materials receive unnecessary attention while higher operational risks remain unchanged.

3. Compliance becomes performative

Tick-box inspections replace informed risk management.

True asbestos compliance is not about doing things annually.

It is about doing the right thing, at the right frequency, for the right reason.

The role of a competent asbestos manager

Effective asbestos management separates functions clearly:

The survey process is responsible for identifying asbestos-containing materials and assessing their physical condition.

Management then considers how those materials interact with day-to-day building operations and assesses the real risk of disturbance. Decisions regarding inspection frequency sit with the dutyholder as part of the asbestos management plan.

Ongoing review and monitoring are delivered through the management system, ensuring risks remain controlled as building use, occupancy and maintenance activities change over time.

This is how Regulation 4 was designed to operate. And increasingly, large property portfolios are returning to this model, moving away from template-led compliance toward managed, risk-based systems.

A better question to ask

Instead of asking:

“When should this be reinspected?”

The better question is:

“How likely is this material to deteriorate or be disturbed in this building?”

That answer rarely fits neatly into twelve months.

Compliance is not a template

Asbestos management works best when surveys inform decisions, not make them.

A good surveyor provides accurate information.

A competent dutyholder applies context.

And effective management happens in the space between the two.

Learn more about asbestos compliance for hotels, or

Speak with The KV Group for impartial advice.

The KV Group stands for impartiality and expertise in asbestos management, giving clients reassurance and financial control over compliance.