Asbestos and the pre-redevelopment audit before demolition
Two exercises happen to the same building before demolition and they are often confused. What each covers, how contamination removes reuse options, and how to sequence them against the programme.
Before anything is knocked down, two separate exercises have to happen to the same building, and they are often confused. A refurbishment and demolition survey under the asbestos regulations finds hazardous materials so that people are not harmed. A pre-demolition audit asbestos survey is only part of the wider material audit, which records what is in the building so that as much as possible is reused or recycled rather than skipped.
The first is health and safety law and is not negotiable. The second is what the planning system asks for, and increasingly conditions.
What a pre-redevelopment audit covers
The audit is an inventory of the building as a material resource. It records the structure, the envelope, the internal fit-out, the services, and the external works, with quantities, condition and a route for each stream.
Useful streams are the ones with a genuine second life. Structural steel sections, precast units, bricks where lime mortar allows clean recovery, raised access floors, doors and ironmongery, sanitaryware, light fittings, external paving and kerbs, and topsoil. Concrete is usually crushed for site fill, which is recycling rather than reuse, and reporting it as reuse is the most common overstatement.
For each stream the audit should give an estimated quantity, the condition, the intended route, and any contamination or hazardous content that restricts the options. A Pre-redevelopment Audit prepared before the demolition strategy is priced has some chance of changing what happens. One prepared to discharge a condition after the contractor is appointed does not.
Refurbishment and demolition surveys
Under the asbestos regulations there are two kinds of survey, and only one of them is adequate before demolition.
A management survey locates asbestos containing materials that could be disturbed during normal occupation and maintenance. It is not intrusive and it is not sufficient for demolition. A refurbishment and demolition survey is fully intrusive, covers areas that would not normally be accessed, and is carried out with the premises vacated and the area under the survey isolated.
The survey has to cover everything that will be disturbed. Asbestos is found in insulating board, sprayed coatings, pipe lagging, cement sheets, floor tiles and their bitumen adhesive, textured coatings, rope seals, toilet cisterns and window putty, among many other products. Buildings constructed before 2000 are the concern, with the highest risk in stock from the 1950s to the 1980s.
Commission the survey early. It takes time, it needs access, and its findings change both the demolition method and the programme.
Duties under the Control of Asbestos Regulations 2012
The regulations place a duty to manage asbestos on whoever controls non domestic premises, and that duty includes finding out whether asbestos is present, assessing its condition, keeping a record and providing that information to anyone liable to disturb it.
Work with asbestos falls into three categories. Licensed work, which covers higher risk materials such as sprayed coatings and insulating board, must be carried out by a contractor holding a licence from the health and safety regulator, and the regulator must be notified in advance with a statutory notice period. Notifiable non licensed work has its own notification and record keeping requirements. Lower risk non licensed work still requires trained operatives and controls.
None of this is enforced through planning. The health and safety regulator enforces it, and a planning condition cannot substitute for compliance. Where a planning document describes asbestos removal, it should describe it as a matter governed by the regulations rather than as something the council is approving.
Asbestos waste is hazardous waste, and its movement requires consignment documentation and a permitted receiving site. Those records are also the evidence a circular economy condition will be checked against.
Hazardous materials other than asbestos belong in the same survey scope. Lead paint on older joinery and metalwork, refrigerant gases in chillers and split systems, oils in transformers and lifts, fluorescent tubes, smoke detectors containing radioactive sources, and fuel or chemical residues in tanks all carry their own removal and disposal rules. Each one can also stop a reuse claim in its tracks.
Set the scope of the survey in writing before it is commissioned. A survey scoped to asbestos alone leaves the rest to be discovered during the strip, which is exactly when a programme slips.
Recording materials for reuse and recovery
The material audit and the asbestos survey have to be read together, because contamination removes options.
A floor slab with bitumen adhesive containing asbestos cannot be crushed and reused until the coating is removed and disposed of separately. Insulating board behind a panel removes that panel from the reuse list. Soil contaminated by demolition debris may need testing before it can be reused as fill, which brings the ground investigation into the picture alongside the measures described in our note on ground gas protection and BS 8485 measures.
Sequence the work accordingly. Asbestos survey first, then the material audit informed by it, then the demolition method statement, then the waste and circular economy commitments. Running them in parallel produces a set of documents that contradict each other.
Photograph and reference everything. A reuse claim for 200 m2 of paving is checked by someone looking for a photograph and a location.
Interaction with the site waste strategy
The regulations that once required site waste management plans were revoked, but authorities still require the document by condition, and the content expected has not changed much.
A Site Waste Management Plan should set out the forecast arisings by stream and quantity, the management route for each, the targets, the responsibilities, and the records that will be kept. The figures should reconcile with the pre-redevelopment audit and with any Circular Economy Statement submitted for the scheme.
Reconciliation is the point most often missed. Three documents giving three different tonnages of demolition arisings will be sent back, and the fix is a single quantity take-off used by all of them.
Timing against the demolition programme
Work backwards from the demolition start date.
- Vacant possession, since the refurbishment and demolition survey requires the area to be cleared.
- The asbestos survey, allowing time for laboratory analysis of samples.
- The material audit, informed by the survey findings.
- Licensed removal works, allowing for the statutory notification period and for the contractor's programme.
- Demolition notification to the local authority under the building legislation, and any prior approval required for the demolition itself.
- Soft strip, with reusable items removed carefully rather than broken out.
Soft strip is where reuse is won or lost. Doors, ironmongery and light fittings removed carefully have value. The same items pulled out with a machine do not.
What planning can and cannot require
Planning can condition a demolition method statement, working hours, dust and noise controls, a construction traffic management plan, a site waste management plan and circular economy commitments with post completion reporting. It can also require the retention of specific elements, which is the most direct way of securing reuse.
Planning cannot approve or enforce compliance with the asbestos regulations, cannot license removal work, and cannot relieve a duty holder of any obligation. A condition purporting to do so would fail the tests for conditions and should be resisted.
Demolition itself may need prior approval for the method and site restoration, and a separate notice to the local authority under the building legislation. Neither is a planning permission, and both are easy to miss on a site where the demolition runs ahead of the main application.
This is general guidance, not legal advice. Check the position with your local planning authority or a qualified professional before relying on it.
Enter your postcode on PlanScope to see which demolition and waste documents your scheme is likely to need. PlanScope provides AI-assisted draft reports for planning applications. Reports should be reviewed before submission. We do not guarantee planning approval.
Frequently asked questions
What survey is needed before demolition?
A refurbishment and demolition survey under the asbestos regulations. It is fully intrusive, covers areas not normally accessed, and is carried out with the premises vacated and the survey area isolated. A management survey, which locates materials that could be disturbed during normal occupation and maintenance, is not sufficient before demolition work begins.
What is the difference between the asbestos survey and the material audit?
The asbestos survey finds hazardous materials so that people are not harmed, and is required by health and safety law. The material audit records what the building contains as a resource so that as much as possible is reused or recycled. The audit depends on the survey, because contamination removes reuse options from specific streams.
Who can remove asbestos?
Higher risk materials such as sprayed coatings and insulating board are licensed work, which must be carried out by a contractor holding a licence from the health and safety regulator, with advance notification. Notifiable non licensed work has its own notification and record keeping duties. Lower risk non licensed work still requires trained operatives and controls.
Can a planning condition control asbestos removal?
No. The asbestos regulations are enforced by the health and safety regulator, and a condition cannot approve compliance or relieve a duty holder of any obligation. A condition purporting to do so would fail the tests for conditions. Planning can condition demolition method statements, waste plans, hours, dust and circular economy commitments.
Does demolition need its own approval?
Often. Prior approval may be required for the method of demolition and site restoration, and a separate notice to the local authority is required under the building legislation. Neither is a planning permission for the redevelopment, and both are easy to miss where demolition runs ahead of the main application.
Sources and further reading
This article is general guidance about the planning system in England and, where stated, the rest of the UK. It is not legal or professional advice. Check your local planning authority’s validation requirements and take professional advice for your specific site.