This discussion, while grounded in the UK regulatory framework, explores broader questions around accreditation, competence, and accountability that are relevant across many jurisdictions, including Australia.
About the author: Marcus Hill is Director of Asbestos Risk Control Ltd, an independent asbestos consultancy based in Edinburgh.
Marcus holds the Certificate of Competence in Asbestos and has worked across asbestos surveying, management, consultancy and dutyholder support in local government, healthcare, commercial and industrial property sectors. This article was first published in the April 2026 newsletter of FAMANZ, the Faculty of Asbestos Management of Australia and New Zealand.
After lobbying from industry members, the UK Department for Work and Pensions Committee issued a report in 2022 with a variety of recommendations for the purpose of reducing the risks to the public from asbestos exposure. One of these recommendations was that all people carrying out asbestos surveys should be accredited. This triggered a heated debate and a subsequent HSE consultation for the revision of the Control of Asbestos Regulations.
To understand the roots of this debate, it is necessary to look back at how the modern asbestos surveying industry developed and the pressures that shaped current practice.
Although precise figures are not available, it is believed that the UK asbestos surveying market is worth roughly £300 million with many thousands of asbestos surveyors carrying out surveys for a variety of organisations. These include large testing bodies who will likely hold a UKAS accreditation to ISO 17020, smaller businesses and independent surveyors, and also some organisations who employ in-house surveyors to survey their own buildings, such as some local authorities.
What problem is this policy seeking to address?
To establish this we need to go back in time. The 2002 Control of Asbestos at Work Regulations brought in a new duty, the duty to manage asbestos in non-domestic premises. This is commonly referred to as Regulation 4. A two-year grace period was in place to permit organisations to get their surveys and management plans in place by 2004.
The new major compliance requirement triggered a gold rush, the legacy of which is still noticeable today. Prior to Regulation 4 and the 2001 HSE guidance for surveying, MDHS 100, asbestos surveys were carried out in a wide variety of styles and formats. Some older reports I have found were creatively written and are highly professional, combining scientific and standard building survey reporting styles. Some reports were so inadequate they were of little to no use to the client. The new HSE guidance in the early 2000s, MDHS 100 and HSG 227, introduced industry standard risk assessment algorithms. This led to reports becoming more standardised. So far so good.
The difficulty the industry was facing at the time was the result of the new massive demand for surveyors. The people recruited into the industry often had very little experience of asbestos or even of building construction. There was also a requirement to qualify these new surveyors. This was resolved by the introduction of a proficiency module called the P402. A delegate could attend a two or three-day course, and submit two survey reports for review together with a statement from a colleague stating they had had six months of supervised experience of surveying. This was, of course, open to abuse. While this approach enabled the industry to meet demand, it also introduced variability in competence that remains a central issue today.
During this training, surveyors are taught the typical products likely to contain asbestos, and how to sample them safely and record the findings using the new algorithms. There was often no training to cover construction methods or structural fire protection. The preparation of an asbestos management plan is also not included. It has been forgotten that the legal duty is to manage asbestos, but this was widely interpreted as a duty to survey. This misunderstanding shaped how surveys were commissioned and used, often reducing them to compliance documents rather than tools for active risk management.
Over the following two decades, vast numbers of asbestos survey reports were produced and placed in filing cabinets, often with little or no active asbestos management taking place. The fundamental purpose of asbestos management is to ensure that adequate measures are in place to prevent occupants and workers from inhaling asbestos fibres. Reports left in filing cabinets do not prevent inadvertent intrusive or destructive work on asbestos-containing materials.
The central issue is competence. You can train a person to take samples, note down where they took them from, and put recommendations in reports, but if that person has inadequate understanding of the nature of asbestos and the relative risk from the products they are working with, then we have a problem.
There is a huge legacy in the UK of very poor quality asbestos surveys. It is widely accepted that if a survey has been carried out by a UKAS accredited company, then that company will have sufficient quality assurance measures in place to ensure that all their surveys are adequate.
There are many independent asbestos surveyors working within the UK. For many, like myself, having worked for many years within UKAS accredited organisations and having been a dutyholder, or more appropriately “the customer”, for local government and the NHS, working as an independent gives me full control over the standard of the planning, execution and delivery of a survey project. The discussions leading up to a survey and the subsequent advice and support I am able to personally offer are invaluable to clients. It is a pleasure to be able to work this way, whereas I was unable to do this in larger organisations. But with this comes key questions of governance and competence.
There are also many asbestos surveyors in the UK who may only hold a P402, or not even that, and have had minimal peer contact in the early stages of their career, yet are self-appointed experts. Many of these individuals have also determined themselves to be experts in asbestos removal. The dangers arising from these circumstances are self-explanatory.
Accreditation to ISO 17020 confirms that the organisation, an “inspection body”, has processes in place to ensure that the organisation is competent, impartial, and consistent in how it inspects buildings for asbestos. Survey methods are expected to be standardised and documented, and surveyors are expected to be competent. This is partially validated by the surveyors holding the P402, or a later alternative qualification, the RSPH Level 3. UKAS document RG 8 also makes provision for surveyors being authorised to carry out certain surveys depending on building complexity and survey type.
The organisation is also expected to have a quality management system and carry out in-house audits. For procurement departments, accreditation provides a valuable baseline for procurement and quality assurance, giving clients confidence that recognised systems and controls are in place. This framework has played a crucial role in raising baseline standards and improving consistency across the sector. However, while accreditation addresses organisational systems and controls, changes in working practices over the past decade have introduced new pressures that also influence survey quality.
Significant amounts of survey time in the UK are spent resurveying buildings that have already been surveyed due to problems with the original survey. These will include asbestos surveys carried out by accredited and non-accredited organisations. Recent HSE research has found significant problems with the standard of asbestos surveys. If we come back to the main principles, poor surveys mean asbestos does not get identified and people get exposed to asbestos.
The industry has a problem. Training people fully, i.e. to Certificate of Competence level, is a lengthy and expensive process. Only roughly 2% of asbestos surveyors in the UK are fully qualified to CoCA level. The qualification bar has been lowered now that the requirement to submit reports for assessment for P402 and RSPH has been removed. This raises the question: if a surveyor is not qualified to write a report, how can they be qualified to check one? This is of particular concern in organisations that have automated reporting workflows.
Databases are wonderful things. When combined with mobile apps, the days of manually entering data from site notes are over. This also prevents replication of errors and typos.
Survey companies are widely generating survey reports at the touch of a button from data collected on site on mobile apps. Surveyors are sent out far and wide with a car and a tablet. They don’t need a desk any more or a computer. They are provided with a list of addresses and a schedule. Submit data, then on to the next job.
These operational pressures can be reflected in the reports produced. The problem is that the report has little else in it but generic text and tables. The executive summary says, “We did a survey at Battersea Dogs Home in accordance with our standard procedures,” and so on. No one has added any consultancy for the client. There is no discussion of what was found and the best solution for dealing with it, or a discussion of why part of the building may not have been surveyed and the reasons for that.
The consequences become more significant in refurbishment surveys, where inadequate inspection or poorly defined scope can lead directly to exposure risks. It is crucial to ensure that an adequate inspection has been made of the part of a building where destructive works are planned. A suitable refurbishment survey report with a defined and documented scope of works evidences this. However, it is widespread industry practice in the UK to issue a refurbishment survey with no scope of works. The user of the report has no way of telling what was inspected or whether it is safe for their works to proceed. As a result, workers get exposed.
A further concern arising from remote working models is the separation between site inspection and report preparation. The remote report pipeline is that the surveyors who carried out the surveys never get to write or check their own survey reports. Their name goes on the report, but the person who was actually on site does not validate that it is correct.
It was often common practice for work to be split 60/40 site to reporting time in good consultancies. This has now often changed to 100% site time. This is a key contributing reason why asbestos surveys are often poor quality.
Planning and carrying out surveys properly takes time. Liaison with the client prior to the survey provides invaluable information about their level of compliance knowledge, specific information about their building, and key access and risk assessment details.
The goal when conducting surveys is to squeeze as much information out of the building as possible so it can reveal its asbestos secrets. We must also state where we have been unable to inspect the building. The process of recording data must be highly efficient. We need asbestos surveyors to be heads-up looking at the building, not heads-down fighting their way through poorly designed software.
There need to be simple methods for checking data validity on site, to ensure it is complete and adequate to guide the duty holder in their decisions.
The asbestos survey report is a huge weak link. Is the report written for the client or is it written to facilitate output? The goal of the report is to get that key asbestos information into the heads of every user, many of whom may not be asbestos people.
These issues keep pointing back to a common point. A recurring challenge lies at the level of individual competence and judgement. An organisation may have the finest procedures on paper, but asbestos surveying is a subjective discipline.
ISO 17020 was designed to assure organisational competence, impartiality and consistency in inspection bodies. However, asbestos surveying remains a highly judgement-based discipline, and organisational accreditation alone may not fully demonstrate the competence of individual practitioners. You may question what about ISO/IEC 17024. While ISO/IEC 17024 offers a framework for certification schemes that assess and certify individuals, it has not been widely adopted within the asbestos surveying sector. As a result, assurance of competence remains focused on organisations rather than practitioners themselves. This does not diminish the value of ISO 17020, which remains essential for assuring organisational quality and impartiality.
Mandatory organisational accreditation improves quality assurance and procurement confidence, but it does not, on its own, provide full assurance of individual competence.
How do we fix problems in the industry? We must address individual accountability. Organisational accreditation cannot entirely eliminate poor practice, particularly where systems rely heavily on individual judgement. As in many professions, variability in practitioner competence can exist within both accredited and non-accredited organisations. Only when individuals are properly held accountable to a professional body can we restore pride and responsibility in line with other professions.
To improve outcomes, the industry must continue evolving the role of the asbestos surveyor from people with sample-focused practices into bona fide consultants in line with other construction and safety professionals such as structural engineers.
We should be training our surveyors to be fully rounded consultants who are able to write an asbestos management plan, disseminate survey findings, discuss remedial actions, and explain legislation to their clients. For most clients, the only asbestos professional they will likely ever meet or talk to is an asbestos surveyor. To think that person may have only had three days of classroom training is quite concerning.
These considerations raise a practical policy question: even if mandatory accreditation were desirable, is it proportionate and achievable across the full spectrum of the industry?
An examination of the costs of gaining UKAS accreditation shows that over a four-year period it will cost £46,000 in fees to UKAS. For that, a prospect will be required to have developed their own systems compliant with ISO 17020, which for some surveyors can be quite a challenge if they do not know what ISO compliant documentation looks like. To that end, they are on their own and may need to engage a specialist consultant to get this started.
I recently spoke to one organisation going through the process. They said they found UKAS very helpful during the prequalification inspection and that UKAS clearly wanted them to achieve accreditation. The company already held ISO 9001 accreditation and hoped that many of their procedures would be transferable. Unfortunately, their quality system needed a comprehensive rewrite and they engaged a consultant to assist with this at an additional cost of circa £20,000, in addition to the loss of chargeable time taken to develop the system, which amounted to another £40,000 of lost income.
HSE estimate the maintenance of an accredited quality scheme should require the equivalent resource of 0.7 of a full-time equivalent worker. This level of resource commitment can be particularly challenging for small organisations and sole practitioners. These were costs incurred in year one and they still have not achieved accreditation. That accreditation would also be restricted as they are struggling to find buildings of sufficient complexity to meet the audit requirements of RG 8, i.e. a demolition survey of a legacy building containing sufficient high-risk ACMs such as sprayed coating or asbestos insulation. Many of these items have now been removed.
This also suggests the nature of surveying has changed. In many cases, trainee surveyors have not had the chance to see sprayed coating or plant rooms full of lagging as these items have largely been removed. This has knock-on effects for the knowledge levels of new surveyors, and perhaps the focus should be on detecting the signs of a poor strip and the forensic level of inspection required to find the residues.
The recent HSE consultation on changes to asbestos legislation has indicated that the current view of the authorities is that mandatory accreditation is likely to be prohibitively expensive and that UKAS does not have the resources to meet the demand should this be mandated.
Frustratingly, the 2022 DWP report recommendations were not compatible with the current state of the UK industry. However, the benefit of the report is that it has generated widespread discussion, which has been overdue for many years.
Organisational accreditation plays an essential role in assuring quality systems and procurement confidence. However, improving outcomes in asbestos surveying requires a complementary focus on individual competence, professional accountability, and the development of surveyors as consultants rather than data collectors.
Encouragingly, the momentum generated by these discussions has already begun to produce constructive initiatives, including the imminent release of the BOHS register of asbestos surveyors and the formation of the Asbestos Surveyors Guild, which will focus on certifying individual competence. In addition to this, BOHS has prepared an asbestos survey “Buyer’s Guide”, which I have been proud to have assisted with drafting. This document will help consumers purchase surveys as informed buyers.
As always, reform in the asbestos industry is a painfully slow process, but with the work of committed and visionary people, our buildings can be made much safer.
