CareHomeDeskCareHomeDeskA practical pre-works checklist for FMs and property managers on older care home buildings -- what your asbestos register does and doesn't cover, when you need a refurbishment and demolition survey, and what a contractor needs from you before they start.
If your care home was built or last refurbished before 2000, HSE's position is that it is likely to contain asbestos-containing materials (ACMs) somewhere in the fabric. Asbestos was banned in Great Britain in 1999, and buildings constructed after 2000 are unlikely to contain it -- but almost every older care home estate falls on the wrong side of that line. The risk isn't the asbestos sitting undisturbed behind a wall or above a ceiling tile. The risk is drilling into it, ripping it out, or disturbing it without knowing it's there. Most enforcement action and prosecutions in this area follow exactly that pattern: works started without checking first. Getting the survey and information step right before you commission work is the single most effective thing an FM can do to prevent an incident, a stalled project, or a regulatory problem.
Under regulation 4 of the Control of Asbestos Regulations 2012 (CAR 2012), the 'dutyholder' for non-domestic premises -- typically the building owner, the landlord, or whoever has clear responsibility for maintenance and repair of the premises -- has to manage the risk from asbestos in the building. In practice that means: presuming materials contain asbestos unless there's strong evidence they don't; keeping an up-to-date record (register) of the location and condition of ACMs or presumed ACMs; assessing the risk of exposure; producing and acting on an asbestos management plan; reviewing that plan at least annually or sooner if something changes; and making the information available to anyone who might disturb the material, including contractors and, where relevant, emergency services. If you're the FM and responsibility for the building's maintenance sits with you, you are very likely to be acting for the dutyholder in practice, even if the legal dutyholder is a landlord, provider group or freeholder. Establish clearly, in writing, who the dutyholder is for each property you manage and where the asbestos register actually sits -- you cannot assume it exists just because the building has been operating for years.
This is the most common and costly misunderstanding. An asbestos register produced for day-to-day management purposes is based on a management survey -- a survey designed to find ACMs that could be disturbed during normal occupation and maintenance (redecoration, minor repairs, routine access). It is not designed to find everything that would be disturbed by construction work, and it does not authorise or clear the area for refurbishment, alteration, or demolition. A management survey deliberately avoids destructive inspection -- it won't lift floor tiles, open up ceiling voids in areas not normally accessed, or drill into wall cavities. If a contractor is about to chase a wall, lift flooring, remove a ceiling, strip out a bathroom, break into a service riser, or do anything that opens up the building fabric, the existing management survey and register are not sufficient on their own. This applies just as much to a single bedroom refurbishment or an ensuite retrofit as it does to a full wing redevelopment -- scale doesn't change the legal position, only the practical scope of what needs surveying.
HSE guidance (set out in HSG264, the asbestos survey guide) describes two main survey types: the management survey described above, and the refurbishment and demolition survey. An R&D survey is more intrusive -- it's intended to find all ACMs, including those concealed within the structure, before any disruptive work starts, so that any asbestos identified can be removed (where required) before work begins. Because it involves destructive inspection, it usually means the affected area needs to be vacated during the survey, and a competent surveyor confirms the area is fit for reoccupation afterwards. As a working rule for care home FMs: if the proposed work will disturb the fabric of the building in a way that goes beyond what a management survey inspected -- new doorways, removed partitions, floor strip-out, service alterations, roof work, window or cladding replacement, any demolition -- treat it as requiring an R&D survey for the specific area of work, scoped to what's being done. Don't rely on 'we had a survey done a few years ago' as a substitute. If you're not sure whether proposed work crosses that line, that itself is a trigger to get advice from a competent asbestos surveyor rather than guess.
HSE's guidance on locations and materials is a useful checklist to have in mind when scoping any project, particularly in the areas care homes routinely alter: - Asbestos insulating board (AIB) -- partition walls above ceilings, fire door panels, ceiling tiles, panelling around windows, riser and duct linings. Common in 1960s-80s buildings and extensions. - Thermal insulation/lagging -- around old boilers, calorifiers, and pipework in plant rooms and risers. HSE describes most work on lagging as high risk, licensed-contractor-only work. - Floor coverings -- vinyl tiles, sheet flooring, stair nosings, sometimes hidden under later carpet or laminate in corridors, day rooms and kitchens. - Textured coatings (e.g. Artex-type finishes) -- ceilings and walls, especially in older bedroom wings. - Asbestos cement products -- external roof sheeting, downpipes, gutters, flues, garden stores and outbuildings. - Sprayed asbestos coatings -- structural beams and undersides of roofs in some plant areas and older service voids; always licensed-contractor work. - Gaskets and textiles -- in older boiler and heating equipment, fuse boxes. These are exactly the areas that get disturbed during typical care home refurbishment: en-suite retrofits, nurse call and electrical upgrades, kitchen refits, boiler replacements, wing refurbishments and window/roof works.
Before instructing any contractor to start work involving the building fabric: 1. Confirm the dutyholder and locate the current asbestos register and management plan for the specific building -- not just 'the group has one somewhere.' 2. Check what survey the register is based on (management survey only, or has an R&D survey already been done for this area). 3. Define the exact scope of proposed works and identify every element that will disturb the fabric -- drilling, cutting, lifting, stripping, opening voids. 4. If the works go beyond what the management survey covered, commission an R&D survey scoped to the specific work area before appointing a contractor, or before that contractor starts on site. 5. Share the asbestos register and any survey findings with the contractor and their principal contractor/principal designer (where CDM 2015 applies) before work starts -- this should form part of the pre-construction information. 6. Ask the contractor directly: are you satisfied you have the information you need on ACMs in this area before pricing/starting the work? Get this in writing. 7. Confirm who is responsible for stopping work immediately if suspect material is found unexpectedly, and that this is written into the contract and communicated to site staff and residents' safety leads. 8. Update the asbestos register and management plan once work is complete, reflecting any material removed, encapsulated, or newly identified. What to ask a contractor before they start: Have they seen the current asbestos register and any R&D survey for this area? Do they hold the right licence if licensable work is anticipated? What is their process if they encounter suspect material not identified in the survey? Who is their asbestos-competent point of contact?
CareHomeDesk does not provide asbestos surveys, certification, or a substitute for competent-person judgement, and nothing here should be used to classify materials or clear an area for work. Bring in a competent, accredited asbestos surveyor (and, where licensable work is involved, a licensed contractor) whenever: you're planning any work that will disturb the building fabric and don't have an R&D survey covering that specific area; suspect material is found during works and you need it identified and classified; the condition of a known ACM has changed or is in doubt; you're unsure whether planned work is notifiable or licensable; or the asbestos register itself is old, incomplete, or you can't establish who commissioned it or to what standard. Getting this judgement wrong -- either by assuming a general survey covers intrusive works, or by delaying work indefinitely out of excess caution without commissioning the right survey -- both create real cost and safety problems. The way through both is the same: scope the actual works, check what the existing survey covers, and commission the right survey for what's about to happen before you commit a contractor to site.
CareHomeDesk gives you compliance checklists, maintenance logs, and contractor management tools built around exactly this kind of knowledge.