Licensed, notifiable non-licensed or non-licensed?
Every record you keep follows from one question: what type of asbestos work is this? The regulations split work into three types, and the paperwork goes up a level each time.
- Licensed work - the highest-risk work, such as removing sprayed coatings, pipe lagging and asbestos millboard, or clearing significant amounts of debris. Only an HSE-licensed contractor can do it.
- Notifiable non-licensed work (NNLW) - work that doesn't need a licence but does need notifying, medicals and records. HSE's examples include removing asbestos cement that will be substantially broken up.
- Non-licensed work - sporadic, low-intensity work done so that exposure stays within the control limit of 0.1 fibres/cm³ averaged over four hours, and which meets one of HSE's set conditions. It still needs a risk assessment and properly trained workers.
HSE says the decision is "based on the risk", and its non-licensed work page walks through the tests. Record your decision for each job, and why, so you can show your reasoning later.
| Record | Licensed | NNLW | Non-licensed |
|---|---|---|---|
| Risk assessment & plan of work | Yes | Yes | Yes |
| Notification | ASB5, 14 days before | Online, before work starts | No |
| Medical examination | At least every 2 years | At least every 3 years | No |
| Health record / register of work | Yes, kept 40 years | Yes, kept 40 years | No |
| Training | Licensable level, refreshed every year | Non-licensable level, refreshed every year | Non-licensable level, refreshed every year |
| Four-stage clearance | Yes, by an accredited analyst | No | No |
Your HSE licence and renewal
Doing licensable work without a licence is an offence. According to HSE's licence application page, a first licence is granted for one year, and renewals are normally granted for three years. If you held a licence but did no licensable work during it, you will normally only get a one-year renewal.
HSE's Asbestos Licensing Unit emails you about four months before your licence expires. The renewal assessment looks at how you run health and safety, and at your asbestos-specific arrangements, including training, medical certification, RPE and face-fit tests, equipment such as negative pressure units and decontamination units, and how you keep your records. Keeping those records current all year makes renewal far easier.
Notification: the ASB5 and NNLW forms
Licensed work - the 14-day rule
Under regulation 9, licensed work must be notified to the enforcing authority in writing at least 14 days before it starts, or within a shorter time if the enforcing authority agrees. HSE's licensed contractor page says this is done on the ASB5 form. Which authority you notify depends on the premises: HSE for construction and demolition sites, factories and hospitals, for example, and the local authority for shops, offices and hotels.
If anything material changes - including the work stopping - you must notify the change without delay. Keep the submitted ASB5 and any change notifications in the job file.
Notifiable non-licensed work
NNLW must be notified before the work starts, but there is no minimum notice period. HSE's NNLW page says the online form is the only way to notify - not by phone or post - and you don't need to wait for approval. You get a PDF copy, which belongs in the job file. Licensed contractors doing NNLW must notify it too.
Medicals and health records
Regulation 22 sets out medical surveillance and health records.
- Licensed workers need a medical examination no more than 2 years before they start licensed work, then at least every 2 years after that - or more often if the doctor says so. The examination includes a chest examination and is carried out by a doctor appointed for the purpose.
- NNLW workers need a medical no more than 3 years before they start NNLW, then at least every 3 years. HSE says the examination includes a chest examination and a lung function test. HSE's FAQs say a licensed worker's medical also covers NNLW, but not the other way round.
- Medical certificates. After each examination the doctor issues a certificate to the employer and the worker. The employer must keep it for at least 4 years from the date it was issued.
- Health records. Keep a health record (HSE calls it a register of work for NNLW) for each exposed worker, covering the type and length of their asbestos work, estimated exposure and medical dates. It must be kept for at least 40 years from the last entry. If your business closes, the records must be offered to HSE or the worker.
Air monitoring records follow a similar rule under regulation 19: 40 years where a health record is required, 5 years otherwise. These records need to survive a change of office, staff or computer.
Face-fit testing of RPE
Tight-fitting masks only protect people if they seal to the face. HSE's guidance on fit testing, INDG479, says the Approved Codes of Practice for several sets of regulations, including the asbestos regulations, require tight-fitting RPE to be fit tested as part of selecting it. HSE also says operatives must have appropriate RPE and face-fit testing before any licensable work is carried out.
INDG479 doesn't give a fixed retest interval. It says a fit test should be repeated whenever:
- the RPE type, size, model or material changes; or
- something about the wearer changes that could affect the fit, such as weight loss or gain, substantial dental work, scars or other facial changes around the seal, facial piercings, or new head-worn PPE.
Many firms set their own routine retest date - sensible, but that's company policy, not a fixed legal interval. If your licence inspector or adviser expects a particular cycle, follow it. Record the make, model, type and size of facepiece each person passed in, so the same one is issued to them. INDG479 also says records of RPE examinations and tests should be kept for at least five years. And remember stubble: HSE is clear that facial hair stops a tight-fitting mask sealing, so a pass on paper is no use if the operative turns up unshaven.
Refresher training
Regulation 10 requires training to be given at regular intervals and updated when the work or methods change significantly. HSE's training page says refresher training for licensable and non-licensable work should be provided every year, or more often if work methods, equipment or the type of work change, or gaps in competence are found. Practical elements such as decontamination, RPE use and face-fit testing should be included where a training needs analysis shows they're needed.
Awareness training is different: HSE says there's no legal requirement to repeat a full formal awareness course every 12 months, though some suitable refresher should be given. Awareness training doesn't qualify anyone to work on asbestos.
Demolition cards
Demolition operatives commonly hold a CCDO card (Certificate of Competence for Demolition Operatives), a CSCS partner scheme run by the National Demolition Training Group for the National Federation of Demolition Contractors. Cards have levels and expiry dates, so track them alongside medicals and face-fits. Check the current entry requirements with NDTG.
Plans of work - and proving people read them
Under regulation 7, no asbestos work can start without a suitable written plan of work. It must cover the nature and likely duration of the work, its location, the removal methods, and the equipment for protecting and decontaminating workers and others nearby. A copy must be kept at the premises while the work goes on, and the work must follow the plan and any written changes to it.
That's where things slip: the plan is revised after an extra find or a changed enclosure, but the crew are still working from the first version. Brief every revision and keep evidence of who has seen which version.
Enclosures, air monitoring and four-stage clearance
On a licensed job, a set of tests and certificates builds up around the enclosure. Who produces each one matters, because you can't sign off some of them yourself.
- Enclosure inspection and smoke test. Before removal starts, the enclosure is inspected and smoke tested for leaks. This is normally done by the contractor's supervisor, sometimes witnessed by an analyst. Record the result, the time and who did it.
- Air monitoring. Personal sampling and leak or background testing during the job. Anyone measuring fibres in air must work to ISO 17025, and if you commission monitoring the analyst must be accredited to it (regulation 20).
- Four-stage clearance. At the end, an accredited analyst carries out a preliminary check of the site, a thorough visual inspection inside the enclosure, clearance air monitoring, and a final assessment once the enclosure has been dismantled. The method is set out in HSE's HSG248, Asbestos: the analysts' guide.
- Certificate for reoccupation. Issued by the accredited analyst (ISO 17020 for this part) once all four stages pass - never by the removal contractor. HSE guidance advises that the analyst should be independently sourced and employed by the client or building owner.
In November 2025, HSE consulted on changes, including making the analyst's independence in four-stage clearance a requirement and clarifying what counts as NNLW. At the time of writing we couldn't confirm that any amendment had been made, so check HSE for the current position.
The record-keeping burden as you grow
With five operatives, a lever-arch file can just about work. With twenty-five, each with a medical, one or more face-fits, annual refresher training and a card or two, you're tracking over a hundred expiry dates on different cycles.
Every job also adds its own file: notification, plan of work and revisions, enclosure checks, air tests and the clearance certificate. Records kept for 40 years can't depend on one person's spreadsheet or a WhatsApp group. And the usual failure isn't missing paperwork - it's someone sent to site without anyone checking their dates.
Asbestos removal compliance checklist
- Decide and record whether each job is licensed, NNLW or non-licensed - and why.
- Keep the current HSE licence and any conditions on file; diary the renewal well before expiry.
- Submit the ASB5 at least 14 days before licensed work, or notify NNLW online before it starts. File the copy.
- Write a plan of work for every job, keep a copy on site, and brief every revision.
- Check each operative's medical is in date: every 2 years for licensed work, every 3 for NNLW.
- Keep medical certificates for at least 4 years and health records for at least 40.
- Fit test every operative for each tight-fitting mask they use, and retest when anything changes.
- Record the facepiece make, model and size each person passed in.
- Deliver refresher training every year for licensable and non-licensable work.
- Track CCDO, CSCS and other cards with their expiry dates.
- Record enclosure inspections and smoke tests, and file air monitoring results.
- File the analyst's certificate for reoccupation with the job before handover.
- Stop anyone with a lapsed document from being sent to a job.
Common mistakes
- Treating awareness training as enough. Awareness training doesn't prepare anyone to work on asbestos-containing materials.
- Assuming an NNLW medical covers licensed work. It works the other way round only.
- Notifying late. Starting licensed work inside the 14 days without the enforcing authority agreeing to a shorter period.
- Face-fitting once and forgetting. A new mask model, weight change or dental work can invalidate a pass.
- Old plans on site. The office revises the plan of work but the crew are still working from the old one.
- Mixing up who certifies what. The contractor can't issue the certificate for reoccupation - only an accredited analyst can.
- Nobody checks before allocating. Dates are recorded, but nobody checks them when the job is allocated.
How software helps
DuoApp doesn't produce ASB5s, NNLW notifications, air test results or clearance certificates - those come from HSE's systems, your analyst and your own competent people. What it does is hold every record in one place and stop people slipping through. That's what we built our software for demolition and asbestos contractors to do:
- Expiries tracked per operative. Store medical certificates, face-fit results, training certificates, CCDO and CSCS cards and insurance against each person, with expiry dates and warnings before they run out. New documents go into an approval inbox. See Document Compliance.
- Lapsed people blocked from jobs. DuoApp can block work for anyone whose documents aren't current, so a lapsed medical or face-fit is caught before they're sent to site, not afterwards.
- Plans of work read before sign-off. Mark a plan of work, method statement or survey as required reading. People are notified, they can't sign off until they've opened it, and it re-locks for everyone when you upload a new revision. See Document Alerts.
- Staged checks with evidence. Build your own checklists for enclosure inspections, smoke tests and supervisor checks, with pass/fail/N/A, photos, signatures and timestamps. They work offline and sync later. See Quality Control.
- Job files that stay together. Jobs broken into stages or areas, with the notification copy, analyst certificates and photos stored against them, plus a full audit trail. Recurring tasks can remind you about renewals and refreshers. See Projects & Tasks.
DuoApp costs £10 per user per month with every feature included, works on iOS, Android, desktop and browser, and comes with a 14-day free trial and a free onboarding session with a real person. See how it fits your firm on the demolition and asbestos page.
Frequently asked questions
How often do asbestos workers need a medical?
Licensed workers need a medical no more than 2 years before starting licensed work and then at least every 2 years. Workers doing notifiable non-licensed work need one at least every 3 years. The doctor can ask for examinations more often.
How often is face-fit testing required for asbestos work?
HSE guidance requires tight-fitting RPE to be fit tested when it is selected, and repeated whenever the mask type, size, model or material changes, or the wearer changes in a way that could affect the fit, such as weight change or dental work. HSE's fit testing guidance does not set a fixed retest interval, so check what your licence inspector or adviser expects.
When do I need to submit an ASB5?
For licensed asbestos work, at least 14 days before the work starts, unless the enforcing authority agrees a shorter period. Notifiable non-licensed work is notified online before work starts, with no minimum notice period.
How long must asbestos health records be kept?
Health records, or registers of work for NNLW, must be kept for at least 40 years from the last entry. Medical certificates must be kept for at least 4 years from the date of issue.
Who issues the certificate for reoccupation?
An accredited analyst, after the four-stage clearance has been passed. The removal contractor cannot issue it. HSE guidance advises that the analyst is independently sourced by the client or building owner.
Can DuoApp submit my asbestos notifications?
No. DuoApp does not produce ASB5s, NNLW notifications or clearance certificates. It stores them against the job, tracks each operative's medicals, face-fits and training with expiry warnings, and can block work for anyone whose documents are not current.