Asbestos in Roofing: Identifying ACM Cement Sheets, Slates and Safe Removal Obligations

Quick Answer: Asbestos cement (AC) products in UK roofs were standard from the 1940s until the 1999 ban. Any cement sheet roof, garage roof, gutter or downpipe pre-2000 must be assumed to contain asbestos until proven otherwise. The Control of Asbestos Regulations 2012 (CAR 2012) require licensed contractors for high-risk asbestos removal, but Non-Licensable (NL) work, including most asbestos cement removal, can be done by competent non-licensed operatives — provided they follow HSE Asbestos Essentials task sheets, use RPE and PPE, decontaminate properly and dispose of waste at a licensed site.

Summary

UK construction used asbestos extensively in roofing from the 1940s until the importation ban in 1999. The two most common roofing applications were corrugated asbestos cement sheets (garage roofs, agricultural buildings, industrial units) and asbestos cement slates (residential pitched roofs, particularly in the 1960s–80s). Other ACMs found include asbestos cement gutters, downpipes, soakers, eaves troughs, soffit boards and sometimes structural cladding panels.

For a roofing or general contractor, the legal landscape changed with the Control of Asbestos Regulations 2012 (CAR 2012). The duty to manage asbestos in non-domestic buildings (Reg 4) sits with the building occupier; the duty to assess and control before work sits with the contractor. Both ends meet on a typical refurb job: the duty-holder's asbestos register identifies what's there, and the contractor risk-assesses the work and selects the appropriate response.

The single biggest mistake is assuming asbestos cement products are "low risk and you can just take them off". They are lower-risk than friable insulation — but disturbing them releases fibres, the dust is a Group 1 carcinogen, and HSE inspections result in prohibition notices and prosecutions for non-compliant removals. The compliant approach for AC roofing on small jobs is Non-Licensed Work under HSE Asbestos Essentials task sheets — competent training, RPE/PPE, controlled removal, double-bagged waste, licensed disposal site.

Key Facts

• Asbestos ban (UK) — 1999 (white asbestos / chrysotile); blue and brown asbestos banned 1985
• Pre-2000 buildings — assume all cementitious roofing materials contain asbestos until tested
• Asbestos cement sheet — typically 12–14% white asbestos by weight; cement matrix
• Three asbestos types — chrysotile (white, most common), amosite (brown), crocidolite (blue, most hazardous)
• Friable vs non-friable — AC products are non-friable when intact; become friable when broken, drilled, weathered or burnt
• HSE Asbestos Essentials A14 — task sheet for removing asbestos cement roof sheets (non-licensed)
• Three categories of asbestos work — Licensed, Notifiable Non-Licensed (NNLW), Non-Licensed
• Most AC sheet removal — Non-Licensed if intact, NNLW if degraded, Licensed if combined with insulation
• RPE for AC work — minimum P3 disposable mask (FFP3) for short-duration work; powered air respirator for longer work
• PPE — Type 5 disposable coveralls, gloves, footwear cover, single-use
• Asbestos waste classification — hazardous waste, EWC code 17 06 05*
• Disposal — licensed asbestos disposal site only, double-bagged in 1000-gauge polythene with hazard labels
• Waste consignment note — required under Hazardous Waste Regulations 2005
• Air monitoring — recommended for any non-trivial removal; mandatory for licensed work
• Standard — Control of Asbestos Regulations 2012, HSE L143 Approved Code of Practice

Quick Reference Table

Detailed Guidance

Identifying Asbestos Cement Roofing

Visual identification is unreliable on its own. Asbestos cement sheets and slates look identical to non-asbestos ("substitute") cementitious products made after 1999. The only certainty is sampling and laboratory analysis (UKAS-accredited lab). Practical clues:

• Pre-2000 build date — strong indication of asbestos content
• Stencil markings — older sheets occasionally have manufacturer stamps (Eternit, Turner Asbestos, Universal). Absence of marking is not evidence of safety.
• Profile — old "big six" corrugated profile (146 mm pitch, 48 mm depth) is virtually always asbestos
• Slate marks — diamond-shaped asbestos cement slates are typically 600 × 300 mm
• Edge condition — fibrous, frayed edges when broken indicate asbestos; non-asbestos cement breaks cleanly

The compliant path: get a sample taken and tested before disturbing anything. Sample cost is £25–£60 per item. Building Control and most insurers will require a sample report before quoting major refurb on a pre-2000 building.

Decision Tree: What to Do If You Find ACM

Pre-2000 building, suspected ACM?
├── Yes
│   ├── Has the duty-holder provided an asbestos register?
│   │   ├── Yes — work to it
│   │   └── No — request register, refuse to start work without one
│   └── If no register and unavoidable:
│       ├── Stop work, sample, test
│       └── Resume only with appropriate plan in place
└── No (post-2000) → proceed with standard precautions

Non-Licensed Work: Most AC Roofing

Most asbestos cement roof removal falls under Non-Licensed Work — specifically HSE Asbestos Essentials task sheet A14: Removing asbestos cement roof sheets. The required procedure:

1. Risk assessment — site-specific, written, including method, RPE, PPE, decontamination, waste route
2. Notification — for NNLW only (significant removal of degraded ACMs); not required for routine A14 work
3. PPE/RPE — FFP3 mask, Type 5 coveralls, disposable gloves, eye protection
4. Wet removal — sheets damped with low-pressure water + surfactant before and during removal
5. Sheet by sheet — never break, never drop, never drill in place. Unscrew fixings; lift down whole.
6. Lower to ground — using slings or controlled descent. Not thrown, not skipped.
7. Double bag — 1000-gauge polythene, asbestos warning label, sealed
8. Decontamination — boot wash, coverall removal in zoned area, RPE last off
9. Waste consignment — to licensed asbestos disposal facility with hazard waste consignment note
10. Site clearance — visual inspection; no air clearance required for NL work but recommended for NNLW

When Licensed Contractors Are Needed

Licensed work (HSE-licensed asbestos removal contractor) is required for:

• Sprayed asbestos coatings — Limpet on steelwork
• Asbestos insulation (lagging on pipes, calorifiers, boilers)
• Asbestos insulating board (AIB) — Asbestolux, Marinite, Pyrok and similar — boards used as fire protection or partitions
• Friable, severely degraded ACMs — even if originally NL category material

A licensed contractor must hold an HSE licence (renewable every 1–3 years), employ medically-surveilled trained staff, and notify HSE 14 days before work via the ASB5 form.

Notifiable Non-Licensed Work (NNLW)

Some asbestos work is non-licensed but notifiable — sitting between routine NL and full Licensed:

• Removal of weathered, broken or damaged AC products
• Work where exposure significantly exceeds the action level
• Cleanup of large AC debris

Notification via HSE form, training records (specifically NNLW level), medical surveillance for operatives, and 4 hours minimum training (vs. 1 day awareness for NL).

Disposal Route

Asbestos waste is hazardous. Required steps:

1. Double bag in 1000-gauge polythene, asbestos hazard label
2. Use sealed waste skip or lockable site container
3. Hazardous Waste Consignment Note (Hazardous Waste Regulations 2005) — multi-part form
4. Transport by registered waste carrier
5. Disposal at licensed facility — typically £150–£350 per tonne, plus disposal note retention for 3 years

Fly-tipping of asbestos waste is a criminal offence under the Environmental Protection Act 1990. Prosecutions for asbestos fly-tipping carry up to 5 years' imprisonment.

Asbestos Survey Types

Three survey types under HSE HSG264:

• Management survey — non-intrusive, identifies presumed/confirmed ACM for ongoing management. Typical for occupied buildings.
• Refurbishment survey — intrusive, before significant refurb. Locates ACMs that will be disturbed.
• Demolition survey — fully intrusive, before demolition. Identifies all ACMs likely to be encountered.

For any roof refurb on a pre-2000 building, a refurbishment survey is the right tool. Cost £400–£900 depending on building size; should be done before quoting the refurb itself.

Frequently Asked Questions

My customer says the roof is "definitely not asbestos". Can I take their word for it?

No. The contractor's duty under CAR 2012 is independent — you must risk-assess based on the age and material of the building, regardless of what the customer says. If the building is pre-2000 and you're not provided with a refurbishment survey or material test results, you must treat suspected ACMs as asbestos.

Can I refit asbestos cement gutters with new ones without removing the rest of the roof?

Localised replacement of AC gutters/downpipes is HSE Asbestos Essentials A12 task — Non-Licensed but requires the same RPE/PPE and waste route as A14. Work in short bursts, control dust by wetting, double-bag waste. Don't break the gutters during removal — unbolt and lower whole.

What if I find ACM during a job I quoted as "no asbestos"?

Stop work. Notify the customer in writing. Get a sample tested. Re-quote the work with the asbestos handling and disposal costs included. The customer's insurance and your own may both treat continuing work as a serious breach if you proceed without re-assessment.

Does Permit-To-Work apply to small AC removal?

Most asbestos cement work doesn't require formal Permit-To-Work, but a written risk assessment and method statement (RAMS) is mandatory. On commercial sites, the principal contractor's permit system usually requires their own permit for ACM disturbance.

What about Artex and textured coatings?

Pre-2000 textured coatings ("Artex") may contain 1–3% chrysotile asbestos. Removal requires HSE Asbestos Essentials A1 task method — wet steaming, controlled removal, double-bagged waste. Do not sand or grind these coatings dry under any circumstances.

Regulations & Standards

• Control of Asbestos Regulations 2012 (CAR 2012) — the primary legislation

• HSE Approved Code of Practice L143 — managing and working with asbestos

• HSE HSG264 — the three asbestos survey types

• HSE Asbestos Essentials a-series task sheets — non-licensed work procedures (A12 gutters, A14 cement roof, A1 textured coating)

• Hazardous Waste Regulations 2005 — transport and consignment

• Environmental Protection Act 1990 — fly-tipping criminal offence

• HSG247 / HSG250 / HSG258 — HSE technical guidance

• CDM 2015 — overarching site safety regulations

• HSE Asbestos Pages — Health and Safety Executive

• HSE L143 Approved Code of Practice — managing asbestos in workplaces

• HSE Asbestos Essentials Task Sheets — non-licensed task procedures

• UKATA — UK Asbestos Training Association — training providers

• Environment Agency — Hazardous Waste — disposal route compliance

• HSE HSG264 Asbestos: The Survey Guide — survey types and procurement

• asbestos site management — general site context for asbestos

• re-roofing scope and survey — asbestos surveys before re-roof quote

• dust control on construction sites — RPE selection beyond asbestos

• edge protection and access for roof work — combined access + asbestos planning

• pre-demolition asbestos surveys — survey type for full demolition work