Notifiable Non-Licensed Asbestos Work (NNLW) — The UK Rules for Trades (2026)

The Three Categories of Asbestos Work

Under the Control of Asbestos Regulations 2012 (CAR 2012), all work that disturbs asbestos-containing materials (ACMs) falls into one of three categories. Which category you're in is driven by the type and condition of the material and the level of exposure the work creates — not by who you are or what trade you hold.

• Licensed work — the highest-risk category. This covers most sprayed coatings, pipe lagging and thermal insulation, and large-scale work on asbestos insulating board (AIB). It can only be carried out by a contractor holding an HSE asbestos licence, must be notified at least 14 days in advance using form ASB5, and carries the full weight of medical surveillance, designated areas and air monitoring.
• Notifiable Non-Licensed Work (NNLW) — a middle tier introduced because some non-licensed work still carries enough risk to warrant extra duties. It does not need an HSE licence, but it does need notification, medical surveillance and additional record-keeping.
• Non-notifiable non-licensed work — the lowest-risk category. This covers short, low-exposure tasks on materials that are well-bonded and in good condition, where exposure is sporadic and of low intensity. No notification or medical surveillance is required, but the core control measures still apply.

NNLW sits in the middle: more onerous than ordinary non-licensed work, but a long way short of full licensed work. Misclassifying a job is one of the most common — and most dangerous — mistakes trades make.

What Makes Work NNLW?

Whether a job is notifiable or non-notifiable comes down to the material, its condition, and how much fibre the work is likely to release. The legal test hinges on whether the exposure is "sporadic and of low intensity" and whether the control limit (0.1 fibres per cm³ of air, averaged over four hours) could be exceeded for any short period. If the work risks a brief breach of the control limit, or involves materials that release more fibre, it tips into NNLW.

Common examples of NNLW that crop up in everyday trade work include:

• Removing AIB ceiling tiles, panels or partition boards where the work is short-duration but breaks the board up
• Removing asbestos cement (e.g. corrugated roof sheets, soffits, flue pipes, gutters) where the work involves significant breakage rather than careful whole-sheet removal
• Drilling, cutting or otherwise working on textured decorative coatings ("Artex") using methods that break up the material rather than removing it intact
• Cleaning up or removing larger quantities of asbestos debris
• Any task where a proper assessment shows the control limit might be exceeded, even briefly

By contrast, drilling a single hole through asbestos cement using controlled wetting, or removing a small intact AIB panel without breaking it, may stay in the non-notifiable category. The line is genuinely fine, which is why a competent risk assessment is the first thing every job needs.

The Extra Duties That Come With NNLW

NNLW exists precisely because it carries three additional legal duties that ordinary non-licensed work does not. These are what catch trades out, because they sound like "licensed work" obligations — but they apply even though no licence is needed.

1. Notify the Enforcing Authority

Before NNLW starts, you must notify the relevant enforcing authority. For most construction and refurbishment work that's the Health and Safety Executive (HSE); for some premises (shops, offices and similar) it's the local authority. Crucially, this is a notification, not a licence application. You do not use form ASB5 and there is no mandatory 14-day waiting period as there is for licensed work. The HSE provides an online NNLW notification process — you complete it before work begins, but you do not have to wait for permission to proceed.

2. Medical Surveillance

Workers carrying out NNLW must be under medical surveillance. That means a medical examination by a doctor, including any lung-function checks the doctor considers appropriate, and the examination must be kept up to date — repeated at least once every three years. The medical certificate must be in place; you cannot simply send someone to do NNLW because they hold an awareness course certificate. Records of these examinations must be kept for at least 40 years.

3. Health Records and a Register

You must keep health records for workers who carry out NNLW, recording the work they did and their exposure. These records — like the medical surveillance records — must be retained for at least 40 years because asbestos-related disease can take decades to develop. Keeping a register of which employees have done NNLW, with their medical dates, is the practical way to stay on top of this.

Controls That Apply to ALL Non-Licensed Asbestos Work

Whether your job is notifiable or not, the core control measures under CAR 2012 are the same. NNLW simply layers the three extra duties above on top of these. Every non-licensed asbestos job needs:

• A suitable and sufficient risk assessment and a written plan of work setting out the materials, the method, the controls and the waste route before anyone touches the ACM.
• Trained, competent workers. Everyone needs asbestos awareness training, and anyone doing the work needs task-specific non-licensed/NNLW training that covers the actual method they'll use.
• Respiratory protective equipment (RPE) — typically a properly face-fit-tested FFP3 disposable mask or half-mask with P3 filters. Face-fit testing is mandatory and clean-shaven faces are required for a proper seal.
• Disposable coveralls (type 5) with the hood over the mask straps, plus disposable footwear or boot covers.
• Controlled wetting and no power tools. Keep materials damp to suppress fibres, and never use sanders, grinders or high-speed cutters that generate clouds of dust.
• Enclosure and sheeting of the work area with polythene to contain debris, with warning signage and restricted access.
• Decontamination — clean down with a Class H (asbestos-rated) vacuum and damp rags, and remove coveralls and RPE in the correct order before leaving.
• Double-bagged hazardous waste (red asbestos bag inside a clear bag, both labelled) removed by a registered hazardous waste carrier to a licensed disposal site, with consignment notes kept.
• Air clearance / reassurance air testing where appropriate to confirm the area is safe before it's handed back.

Find the Asbestos First: The Survey Duty

None of the above matters if you don't know the asbestos is there. The duty to manage asbestos under Regulation 4 of CAR 2012 places a legal obligation on whoever is responsible for the building's maintenance to identify ACMs and manage the risk. Before any refurbishment or demolition that will disturb the fabric of a pre-2000 building, a refurbishment and demolition (R&D) survey must be carried out to locate and identify all ACMs in the work area.

As a trade, never assume someone else has done this. Ask for the asbestos register or survey before you start. If there is no survey, or the survey doesn't cover the area you're working in, the safe rule is simple: if in doubt, treat the material as asbestos. Stop, have a sample tested by a UKAS-accredited lab, and don't disturb the material until you know what it is. A short delay for a test is nothing next to a prosecution or a future diagnosis.

Quick Reference: Licensed vs NNLW vs Non-Notifiable

The examples here are illustrative — the actual category always depends on a proper assessment of the specific material, its condition and the method you intend to use.

Practical Compliance Tips for Trades

• Get the survey before you quote. Build "asbestos survey received" into your pre-start checklist so you never price or start a refurb job blind.
• Classify every job in writing. Record whether the task is licensed, NNLW or non-notifiable and why. If it's licensed, it goes to a licensed contractor — full stop.
• Notify before, not after. NNLW notification is quick online, but it must be done before the work starts. Diary it.
• Keep medicals current. Track every operative's medical examination date and book the three-yearly renewal in advance — an out-of-date medical means that worker can't legally do NNLW.
• Retain records for 40 years. Store health records, medical certificates, plans of work and waste consignment notes securely and for the long term.
• Never improvise RPE. A non-fit-tested mask, or a mask worn with stubble, offers almost no protection. Fit testing and clean-shaven faces are not negotiable.

The Consequences of Getting It Wrong

Asbestos exposure has no safe lower limit, and the diseases it causes — mesothelioma, asbestosis and asbestos-related lung cancer — can take 15 to 40 years to appear. That's why the law treats it so seriously. The HSE prosecutes contractors and individuals who disturb asbestos without the right controls, and penalties under the Health and Safety at Work etc. Act 1974 include unlimited fines and, in the most serious cases, imprisonment. Beyond the legal risk, the human cost is real: the people most at risk today are the trades who unknowingly disturbed ACMs decades ago.

Treating NNLW with the respect it demands — proper survey, correct classification, notification, medical surveillance, records and controls — protects your workers, your business and your future self. When the material or the method is uncertain, stop and test. It's the cheapest insurance you'll ever buy.