Understanding the difference between non licensed work with asbestos, notifiable non-licensed work (NNLW) and licensed work is essential for protecting workers and complying with the Control of Asbestos Regulations 2012.
This guide explains how to determine whether work is non-licensed, the legal duties that still apply, the training required for working with non-licensed asbestos, and when notifying the Health and Safety Executive (HSE) and medical surveillance are required.
What is non licensed work with asbestos?
Non licensed work with asbestos is work with ACMs (asbestos-containing materials) that does not require an HSE licence.
Asbestos work falls into three categories:
- Licensed work – Higher-risk work that must be carried out by an HSE-licensed contractor.
- Notifiable non-licensed work (NNLW) – Work that does not require an HSE licence but must be notified to HSE before it starts. Additional legal requirements, including medical surveillance and health records, also apply.
- Non-licensed work – Work that does not require an HSE licence or notification, provided it does not meet the criteria for licensed work or NNLW.
What determines whether asbestos work is non-licenced?
The HSE state that whether work is licensed, notifiable non-licensed or non-licensed “will depend on the type of work you are going to do, the type of material you are going to work on and its condition”. In general, work involving less friable asbestos-containing materials in good condition is more likely to be non-licensed.
Before any asbestos work begins, carry out a suitable and sufficient risk assessment to determine whether the work must be licensed, notifiable non-licensed or non-licensed. If there is any doubt about the correct category, follow HSE guidance and seek advice from a competent asbestos professional before starting work.
| Work category | Material type and condition | HSE notification |
| Non-licensed work | Lower-risk, well-bonded materials in good condition, such as intact asbestos cement sheets or vinyl floor tiles | Not usually required |
| Notifiable non-licensed work (NNLW) | Lower-risk materials that are damaged, degraded or more likely to release fibres, including some short-duration AIB tasks | Required before work starts |
| Licensed work | Higher-risk, friable materials such as pipe lagging, sprayed coatings, asbestos insulation and extensive AIB work | Required |
Does non licensed work with asbestos still have legal requirements?
Non licensed asbestos work with asbestos is still regulated under the Control of Asbestos Regulations 2012.
Before work begins, employers must meet these legal duties:
Carry out a suitable and sufficient risk assessment
Under Regulation 6, employers must assess the risk of exposure to asbestos before work starts. The risk assessment should determine whether the work is licensed, notifiable non-licensed or non-licensed and identify the control measures needed to protect workers and anyone else who could be affected.
Prepare a written plan of work
Regulation 7 requires employers to prepare a written plan describing how the work will be carried out safely. The plan should set out the working methods, control measures, equipment, decontamination procedures and arrangements for handling and disposing of asbestos waste.
Prevent or reduce exposure to asbestos
Under Regulation 11, exposure to asbestos must be prevented wherever reasonably practicable. Where this is not possible, employers must reduce exposure to the lowest level reasonably practicable by using appropriate control measures, safe working methods and suitable equipment.
Provide appropriate training
Regulation 10 requires anyone liable to be exposed to asbestos to receive adequate information, instruction and training. Workers carrying out non-licensed asbestos work must understand the risks, know how to work safely and be competent to follow the required control measures.
See ‘Can anyone carry out non-licensed asbestos work?’ below.
Provide suitable PPE and RPE where required
Where the risk assessment identifies the need for personal protective equipment (PPE) or respiratory protective equipment (RPE), employers must provide suitable equipment and ensure it is correctly selected, used, maintained and worn.
Meet additional requirements for notifiable non-licensed work
Where work is classified as notifiable non-licensed work (NNLW), additional legal duties apply. Employers must notify the HSE before work starts, provide medical surveillance for workers carrying out NNLW, and keep a health record (register) for each employee undertaking this work.
For more information, see HSE guidance, Notifiable Non-Licensed Work (NNLW).
Do you need a medical for non licensed work with asbestos?
Medical surveillance is not normally required for standard non licensed work with asbestos.
However, workers carrying out notifiable non-licensed work (NNLW) must undergo regular medical surveillance, and employers must keep a health record for each worker, as required by the Control of Asbestos Regulations 2012, Regulation 22.
Medical surveillance is one of the main legal differences between standard non-licensed asbestos work and NNLW.
Can anyone carry out non licensed work with asbestos?
Under the Control of Asbestos Regulations 2012, Regulation 10 anyone liable to be exposed to asbestos must receive adequate information, instruction and training.
Those working with non licensed asbestos must therefore have training that is appropriate to the work they will undertake.
Employers must also ensure workers are competent to carry out the work safely. Under the Management of Health and Safety at Work Regulations 1999, Regulation 13, employees must be capable of undertaking their work in relation to health and safety, taking account of their relevant experience and knowledge as well as training they have completed.
What are the types of asbestos training?
Training is often delivered by providers approved by organisations such as the United Kingdom Asbestos Training Association (UKATA) or the Independent Asbestos Training Providers (IATP).
These are the types of training available and who they are appropriate for:
Asbestos awareness training
Asbestos awareness training is for workers who may encounter ACMs but are not expected to disturb them. It helps workers recognise where asbestos may be present, understand the risks and know what to do if they suspect asbestos.
Asbestos awareness training does not qualify someone to work on or remove asbestos-containing materials.
Non-licensed asbestos work training
Non-licensed asbestos work training is for workers who will intentionally disturb or remove ACMs as part of non-licensed work.
The training covers the practical knowledge and skills needed to carry out non-licensed asbestos work safely. This includes identifying ACMs, understanding health risks, using control measures, preventing fibre release, correctly using PPE and RPE, decontamination procedures, asbestos waste handling and emergency arrangements.
Licensed asbestos work training
Licensed asbestos work training is for workers employed by HSE-licensed asbestos removal contractors. It covers the additional knowledge and practical skills required to carry out licensed asbestos work safely and in compliance with the Control of Asbestos Regulations 2012.
Praxis42 UKATA Asbestos Awareness Training
If your employees may encounter asbestos during their work, asbestos awareness training helps protect them from accidental exposure while supporting your duties under the Control of Asbestos Regulations 2012.
Approved by the UK Asbestos Training Association (UKATA), our Asbestos Awareness course helps workers recognise ACMs, understand the risks of exposure, and know how to respond safely if asbestos is suspected.
Find out more about our UKATA Asbestos Awareness course on the website, or call our friendly team today on 0203 011 4242 / [email protected]
Adam Clarke
Managing Director (Consulting)
