Asbestos removal for schools and public buildings

The dutyholder in a school depends on the type of school. In a local authority maintained school, the local authority is typically the dutyholder for the building, with the governing body responsible for day-to-day management. In an academy, the academy trust is the dutyholder. In a free school or independent school, the governing body or proprietor holds the duty. In all cases, the obligation is to have a current asbestos management plan, to maintain an asbestos register, and to ensure that contractors are informed about asbestos locations before work begins.

The DfE guidance is more prescriptive than CAR 2012 in several areas. It requires that all staff who may disturb asbestos — including caretakers, maintenance staff, and teachers who may move ceiling tiles or drill into walls — receive appropriate awareness training. It recommends a more precautionary approach to managing ACMs in teaching spaces, where children are present for extended periods. And it requires that the asbestos management plan is reviewed and updated annually, not just when ACMs are removed or their condition changes.

The most common compliance failure we encounter in schools is the absence of a current asbestos register. Many schools have had surveys carried out in the past — often as part of a local authority programme — but the register has not been updated as ACMs have been removed or their condition has changed. An out-of-date register is almost as problematic as no register at all, because it may give contractors a false picture of what is present and where.

A primary school in Deptford contacted us in January after a routine maintenance inspection found that several asbestos cement panels in the boiler room had been damaged — one had been partially drilled through by a contractor who had not been shown the asbestos register before beginning work. The school's register was eight years old and had not been updated since the original survey.

We carried out an emergency inspection of the boiler room within 24 hours. The damaged panel was contained and the boiler room was sealed pending a full assessment. We then carried out a fresh management survey of the entire building — a 1960s-built two-storey primary school — over two days during the following half-term.

The survey found asbestos cement panels in the boiler room and plant areas, Artex on ceilings in three classrooms, asbestos insulating board in the caretaker's store, and asbestos floor tiles under the vinyl flooring in the main corridor. The Artex in the classrooms was intact and in good condition — we recorded it in the register with a monitoring schedule and advised the school that it should be left in place and managed, not removed.

Removal work was planned in two phases: the boiler room and plant area (including the damaged panels) during the Easter holiday, and the AIB in the caretaker's store and the floor tiles in the corridor during the summer holiday. The classroom Artex was not removed — it remains on the register with a monitoring schedule and will be removed if the school plans any ceiling work.

The school received an updated asbestos register, a revised management plan, air clearance certificates for both removal phases, and waste consignment notes for the compliance file. The contractor who had drilled through the panel was reported to the HSE — not by us, but by the school, on our advice. The school's governing body also introduced a mandatory contractor briefing procedure, requiring all contractors to sign a form confirming they had read the relevant sections of the asbestos register before beginning work.