Notifiable Non-Licensed Asbestos Removal

There are two categories of Non-Licensed asbestos work, one of which ‘notifiable non-licensed work (NNLW)’ has additional requirements for employers. Operatives will need to be suitably trained and be able to demonstrate competency and be under medical surveillance (every 3 years). Records will need to be kept for 40 years.

Under new HSE regulations introduced April 2012, some non-licensed work will require notification to the HSE. NNLW was introduced to account for scenarios where materials that are normally regarded as non-licensed have an increased risk of fibre release during removal. This is because the material has become friable or the material will be damaged and the matrix degraded during removal.

Friable means easily crumbled or reduced to powder. The more friable a material is, the more likely it will release asbestos fibres when worked on and the greater the risk of exposure. Work which disturbs more friable materials such as asbestos pipe insulation, will tend to be NNLW. Work which disturbs the least friable materials such asbestos cement, can normally be treated as non-licensed work.

Bonded in a matrix means the asbestos is coated, covered or contained within another material, such as cement, paint or plastic.  ACMs of this type in good condition can usually be treated as non-licensed work.  However, where they are significantly damaged, and so more likely to release fibres, they will need to be treated as NNLW.

Examples of notifiable non- licensed work include large-scale removal of asbestos textured decorative coatings using steaming or gelling methods, asbestos cement products where the material has been substantially damaged or broken up (as a result of fire or flood damage) or wherein the removal will damage the cement sheeting and release significant amount of dust containing asbestos fibres.