If you are a dutyholder for a non-domestic building built before 2000, you are legally required to have a written asbestos management plan. This guide explains what an AMP must contain, how it differs from the asbestos register, when it must be reviewed, and how to ensure it actually protects you — and your contractors — in practice.
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.
CAR 2012 and the HSE's guidance document HSG227 set out the minimum content requirements for an AMP. The six core elements are:
A record of every ACM found in the survey: location, type, condition, risk rating, and recommended action. The register is the factual foundation of the AMP.
An assessment of the likelihood that each ACM will be disturbed and the potential for fibre release if it is. Drives the priority order for management actions.
What will be done with each ACM — leave in place and monitor, encapsulate, or remove — and who is responsible for each action.
A programme of periodic re-inspections to monitor the condition of ACMs left in place. Typically annual, but more frequent for ACMs in poor condition or high-traffic areas.
How ACM locations and conditions will be communicated to contractors before they begin work. Must be documented and consistently applied.
What to do if an ACM is accidentally disturbed — who to contact, how to seal the area, and when to notify the HSE.
Note on format: CAR 2012 does not prescribe a specific format for the AMP. It can be a standalone document, a section within a broader health and safety management system, or a digital record — provided it contains all the required elements and is accessible to those who need it.
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.
| Document | What it records | Who produces it |
|---|---|---|
| Asbestos register | ACM locations, types, conditions, and risk ratings | The surveyor, updated by the dutyholder after re-inspections |
| Asbestos management plan | Management actions, responsibilities, contractor communication, re-inspection schedule, emergency procedures | The dutyholder (often with surveyor input), reviewed and updated regularly |
CAR 2012 requires the AMP to be reviewed at regular intervals and whenever circumstances change. The following triggers require a review:
Common failure mode: The original survey was carried out when the building was acquired; the AMP was produced at the same time; neither has been reviewed since. If ACMs have deteriorated, been disturbed, or if building use has changed, the AMP no longer reflects the actual risk. This is the scenario most likely to result in an enforcement notice or a contractor exposure incident.
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.
One of the most frequently overlooked elements of the AMP is the contractor communication procedure. CAR 2012 requires the dutyholder to ensure that information about ACM locations and conditions is passed on to anyone who might disturb them. In practice, this means:
The contractor communication procedure is the element of the AMP most likely to be tested in an enforcement investigation. If a contractor is exposed to asbestos during work on your building, the HSE will ask to see evidence that they were informed of ACM locations before work began. A verbal briefing is not sufficient.
If your management survey is more than 12 months old and you have no re-inspection records, your AMP may not reflect the current condition of ACMs in your building. We carry out re-inspection surveys and can update your register and AMP as part of the same visit.
Regulation 4 CAR 2012 — the full legal obligations for dutyholders of non-domestic premises
ReadThe Regulation 4 survey that produces the register — what it covers and what it does not
ReadThe full legal framework for asbestos management and removal in the UK
ReadWe carry out management surveys, re-inspections, and can advise on AMP content and structure. Free site survey. No obligation.