Asbestos management plans: what they must contain and how to keep them up to date

An asbestos management plan (AMP) is a written document required by Regulation 4 of the Control of Asbestos Regulations 2012 (CAR 2012). It is not the same as the asbestos survey or the asbestos register — though it incorporates both. The survey identifies what asbestos-containing materials (ACMs) are present; the register records their location, type, and condition; the AMP sets out what you are going to do about them.

The duty to manage asbestos applies to every person who has responsibility for the maintenance or repair of non-domestic premises built before 2000. That includes building owners, long-term leaseholders, and managing agents. The duty requires you to have an AMP in place, to implement it, and to review and revise it at regular intervals.

The most common misconception we encounter is that having a survey is sufficient. It is not. The survey is the starting point; the AMP is the ongoing obligation. A survey that was carried out five years ago and has never been reviewed, with no re-inspection records and no contractor communication procedure, does not constitute compliance with the duty to manage.

The asbestos register is a record of facts: where ACMs are, what type they are, what condition they are in, and what risk they present. It is produced by the surveyor as part of the management survey and updated after each re-inspection.

The AMP is a record of decisions and actions: what you are going to do with the ACMs in the register, who is responsible for doing it, and how you will ensure that everyone who needs to know about them does. The AMP references the register but goes beyond it.

In practice, the two documents are often combined into a single binder or digital file. The register forms the appendix; the AMP forms the body. What matters is that both elements are present and current — a register without an AMP, or an AMP that references a register that has not been updated since the original survey, does not constitute compliance.

A property management company in Lewisham contacted us after acquiring a 1960s warehouse that came with an asbestos management plan from the previous owner. The AMP was professionally produced and covered all the required elements — register, risk assessment, management actions, contractor communication procedure. On paper, it was compliant.

The problem was the date. The AMP had been produced in 2014 and had never been reviewed. There were no re-inspection records. The register listed twelve ACMs in various conditions; we had no way of knowing whether those conditions were still accurate. Two of the ACMs were rated as requiring monitoring every six months. There was no evidence that any monitoring had taken place in eleven years.

We carried out a re-inspection survey. Of the twelve ACMs, three had deteriorated significantly — one asbestos cement panel on an external wall had cracked and was releasing fibres into a storage area that was in regular use. The panel required immediate encapsulation pending removal.

The new property management company had inherited a liability that the previous owner had created by treating the AMP as a one-off exercise rather than an ongoing obligation. The lesson we draw from this — and share with every new commercial client — is that an AMP is not a document you produce and file. It is a living record that must be maintained. The survey tells you what you have. The AMP tells you what you are doing about it. If the AMP is not current, you do not know what you have.