R&D asbestos surveys: when demolition work legally needs one

Why an R&D survey exists and when it bites

If you type refurbishment and demolition survey into your phone at 9pm, you are probably staring at a programme that starts next week and you have no asbestos report that lets you open up walls. I see this constantly. The law is blunt here. Before you start demolition or any refurb that will disturb the fabric of a pre‑2000 building, you must identify asbestos, assess the risk and plan the work. That comes straight from the Control of Asbestos Regulations 2012, regs 5, 6 and 7, and HSG264 Asbestos: The Survey Guide.

R&D stands for refurbishment and demolition. It is an intrusive asbestos survey carried out to support the actual work you are going to do, not a general wander with a clipboard. HSG264 says an R&D survey is needed prior to all demolition and most intrusive refurb because it has to locate asbestos hidden in risers, behind tiles, inside floor voids, above ceilings and within service ducts you will disturb. If the building went up before 2000, presume asbestos is present until a competent survey proves otherwise, as set out in HSG264.

Management survey vs R&D survey, in real terms

A management survey is for day‑to‑day occupation and minor maintenance. It is non‑intrusive. Think ceiling tile peeks, surface checks and sampling where there are reasonable suspicions. It keeps an asbestos register up to date so caretakers and maintenance sparkies do not drill into AIB by mistake. It does not give you permission to smash out blockwork or chase services. I have rejected method statements that tried to rely on a management survey for major rip‑out. It is the wrong tool.

An R&D survey is designed around your exact scope. Going to cut openings in a stair core, drop risers and rip back to structure on level 2? The survey has to open those areas up, with destructive access, so it can see what you will disturb. That means lifting floors, removing boxing, chasing small trial holes, taking down localised sections of soffit, and sampling anything suspect. HSG264 is clear that an R&D survey must be as intrusive as necessary for the work, and areas not accessed must be listed with reasons.

Here is the simple rule I use. If you would need a breaker, saw, core drill or wrecking bar to do the job, you need an R&D survey first. If you are changing light fittings like for like with no new penetrations and you have a current management survey, you might be able to proceed under controlled procedures, but the second you start cutting into unknown fabric the R&D requirement lands.

If you are writing up the job after the survey, the Demolition RAMS Template UK will help you reference the survey drawings, permits and clearance sequence in one place.

What the surveyor needs access to and how to set it up

This is where jobs slip. A decent R&D surveyor needs access to everything you plan to touch, and a bit beyond. That means plant and services isolated where necessary, rooms cleared, ceiling voids reachable, riser doors opened, cupboards emptied and temporary protection in place so they can make small openings safely. If the building is occupied, you will need a plan to decant areas and control dust. I have stood in corridors at 7am explaining to office managers why we need to lift their carpet tiles. It is easier if you set it out early.

Expect the surveyor to: lift a representative number of ceiling tiles and floor tiles, pop skirting, open boxing, cut small chases, drill sample cores, check behind panels, and access roof voids and plant rooms. They will take samples of suspected asbestos containing materials, for example older Artex, AIB, pipe insulation, gaskets, floor tiles, bitumen adhesives, cement boards and soffits. They are not there to strip the building, they are there to expose enough to be confident in locations where you will work.

Give them safe access. That might mean a tower in the atrium, a scissor lift in the loading bay, lock‑outs on live boards and safe isolation certificates. Services that stop you opening up are classic survey limitations, and they come back to bite you when you start. If your programme is tight, plan enabling works for survey access. It is cheaper to pay a spark to isolate a riser for a morning than to stand down a demolition crew for a week because the survey had caveats.

What happens during the survey and what the report should give you

On the day, you will see small destructive openings and a lot of bagging and tagging. The surveyor will label samples, log locations and reinstate small openings temporarily. Do not expect perfect make good. The point is to find ACMs before the demolition crew hits them. The smell of cut cement board and the snap of old floor tile bitumen are normal on a proper R&D survey. Dust control is part of it, but you should not be running a vacuum job, you should be exposing just enough to be sure.

The lab work confirms material types. The report should include plans and photos, sample results, and a clear list of confirmed ACMs and presumed ACMs in your work area. HSG264 sets out reporting content for R&D surveys and says limitations must be explicit. Good reports separate out voids and rooms that were not accessed, and they say why. They also give material assessment scores. If you manage the building, you can turn those into priority risk scores with your use patterns, but for a demolition job the key is location and type.

Watch the caveats. If half the risers could not be opened and three plant rooms were locked, your demolition RAMS will be full of unknowns. I have seen reports that lump all ceiling voids as no access and presume no asbestos, which is worthless. Push back. Get the areas opened and re‑surveyed. Under reg 5 of the Control of Asbestos Regulations 2012 you must identify asbestos likely to be disturbed. A report that ducks the hard bits does not meet that duty.

When you brief the team, run your paperwork against the Demolition RAMS Checklist so the asbestos controls, zones and waste routes are not missed in the rush.

What you do if asbestos is found

Do not panic, plan it. The report will list ACMs by material type and location. Some can be removed by a licensed asbestos contractor only, for example pipe lagging, sprayed coatings and most AIB. Others can be removed as non‑licensed work, for example asbestos cement sheets and some floor tiles, provided you follow strict control measures. HSE guidance sets out which tasks are licensable and when notifiable non‑licensed work applies, and the Control of Asbestos Regulations 2012 back that up.

Your next legal steps are clear. Assess the exposure under reg 6, then write a plan of work under reg 7 that sets out the sequence, the controls and the waste route. If it is licensed removal, you will need an independent analyst to carry out a four‑stage clearance and issue a certificate of reoccupation before anyone else goes back in, as required by HSE guidance for licensed asbestos removal. Book that into the programme, because waiting on clearance can wipe out a week if you pretend it is not needed.

Keep the demolition sequence sensible. I have seen crews soft strip around an AIB duct because someone did not want to stop. That ends with an emergency and a regulator visit. Strip and clear ACMs first in your zones, prove the areas clean, update the asbestos register, then move on. Waste must go via licensed carriers to permitted sites with consignment notes, which is standard environmental compliance that sits alongside your asbestos duties.

Who is responsible and how this fits with RAMS and CDM

This is the bit people argue about. The duty to manage asbestos in non‑domestic premises sits with the dutyholder, which is usually the client or person in control of the building, under reg 4 of the Control of Asbestos Regulations 2012. The duty to identify asbestos before work that might disturb it sits with the employer carrying out the work under reg 5. Put that together and you get this. The client must provide asbestos information as part of the pre‑construction information under CDM 2015, and the contractor must refuse to start where that information is missing.

Demolition and strip‑out subcontractors wear the delays when this is botched, but the legal duty to commission a proper R&D survey sits with the client or dutyholder. I tell demo firms to push back, politely but firmly. No R&D survey for a pre‑2000 building, no intrusive works. If you take the risk on your own head, you own the prosecution when a labourer bursts a lagged elbow. Name the regs and stand your ground.

When your R&D survey is done, fold it into your method statements and risk assessments. Spell out who is controlling the zones where ACMs were removed, how you are preventing re‑contamination, what permits you are using, and how you will brief your teams. Your RAMS should refer to the specific survey drawings. If the survey had caveats, explain how you will open and check those areas before work. I reject RAMS that say survey available on request. Integrate it or the controls will not happen on site.

Questions we get asked

Do I need an R&D survey to remove a kitchen in a 1990s house?

If you will disturb the fabric, for example chasing walls, lifting floors or altering services, you must identify any asbestos before work starts under reg 5 of the Control of Asbestos Regulations 2012. Reg 4 does not apply to domestic premises, but regs 5 to 7 still do. A targeted R&D survey of the areas you will open is the right route.

Our management survey is in date. Can we demolish with that?

No. A management survey is non‑intrusive and is not suitable for demolition or major refurb. HSG264 says an R&D survey is required before demolition and intrusive refurb so asbestos in hidden locations is found and sampled. Use the management survey for day‑to‑day control, and commission an R&D survey for the actual rip‑out scope.

The building is live and we cannot access risers. What now?

If areas cannot be accessed, the survey must record the limitations. You then either presume asbestos is present in those locations or arrange enabling works to gain access and re‑survey. Under reg 5 of the Control of Asbestos Regulations 2012 you still have to identify asbestos likely to be disturbed, so do not start cutting until those risers are opened and checked.

Who pays for the R&D survey on a CDM job?

Under CDM 2015 the client must provide pre‑construction information, which includes asbestos information, and under reg 4 of the Control of Asbestos Regulations 2012 the dutyholder must manage asbestos in non‑domestic premises. In practice the client arranges and funds the R&D survey, not the demolition subcontractor. Agree it in writing before you price or start.

What if the R&D survey misses an area and we find asbestos?

Stop and make the area safe. Update the survey and asbestos register, reassess under reg 6 and revise the plan of work under reg 7 of the Control of Asbestos Regulations 2012. Bring in a licensed contractor if the material is licensable, and do not restart until controls and, where needed, clearance are in place.

The short version

An R&D asbestos survey is the intrusive survey you carry out before demolition or any refurb that disturbs the fabric of a pre‑2000 building. It is required by the Control of Asbestos Regulations 2012 regs 5 to 7 and guided by HSG264.

The client or dutyholder must arrange it. The surveyor needs real access, isolations and the chance to open up the exact areas you will touch. If asbestos is found, plan the removal or controls, then weave the findings into your RAMS and programme before you lift a breaker.

Do not accept vague caveats or rely on a management survey for demolition. Get the right survey, get the access, and you will save yourself a stop notice and a miserable week in dust masks.