What a non-licensed asbestos RAMS covers — and where it has to stop
Asbestos is the single most scrutinised material in UK refurbishment and maintenance, and the first thing a reviewer looks for is the licensed line. Under the Control of Asbestos Regulations 2012 there are three tiers of work: licensed (which must be done by an HSE-licensed contractor — asbestos insulating board, lagging, sprayed coatings), notifiable non-licensed work (NNLW), and non-licensed work on lower-risk materials such as asbestos cement and textured coatings. These templates cover non-licensed and NNLW work only — and the RAMS has to make that boundary explicit, because using a non-licensed method on licensed material is dangerous and unlawful.
More detail
CAR 2012 requires the asbestos risk assessment to contain a written statement explaining why the work does not need a licence, and whether it falls into NNLW. If there is any doubt about the material or the method, the right answer in the RAMS is to stop and bring in a licensed contractor.
Survey first, then assess
Non-licensed asbestos work starts from the survey, not the task. A refurbishment/demolition asbestos survey identifies the asbestos-containing materials, their type and their condition before any intrusive work — and that is what decides the tier and the method. The RAMS should reference the survey, name the specific ACM being worked on, and confirm it is a non-licensed (or NNLW) material before anyone disturbs it.
Training, controls and waste
Awareness training is not enough to work on asbestos — drilling into ACMs, cleaning or repairing asbestos-cement roofing, or removing textured coatings all cross from awareness into hands-on non-licensed asbestos training. The controls follow the same logic every time: keep exposure as low as reasonably practicable — no power tools, keep materials wet, controlled removal — with FFP3 face-fit RPE and Type 5 coveralls, an enclosure or sheeting, decontamination, and waste that is double-bagged, labelled and taken by a licensed carrier to a licensed site. NNLW adds notification to the enforcing authority, area designation, medical surveillance and health records.
Asbestos RAMS FAQs
Can we remove asbestos without a licence?
Only lower-risk non-licensed materials — typically asbestos cement and textured coatings — and only with the right training, controls and (for NNLW) notification. Licensed materials such as asbestos insulating board, lagging and sprayed coatings must be removed by an HSE-licensed contractor.
What is NNLW?
Notifiable Non-Licensed Work — a middle tier under CAR 2012. It does not need a licence, but you must notify the enforcing authority before starting, designate and demarcate the area, arrange medical surveillance for the workers and keep health records.
Does the risk assessment have to say why the work is non-licensed?
Yes. CAR 2012 requires the asbestos risk assessment to contain a written statement explaining why a licence is not needed and whether the work is NNLW. A reviewer will look for it.
Is asbestos awareness training enough to do the work?
No. Awareness training is to help people avoid disturbing asbestos. Actually working on ACMs — drilling, cleaning cement roofing, removal — requires task-specific non-licensed asbestos training on top of awareness.