Asbestos was widely used in UK buildings until it was fully banned in 1999, so any refurbishment, demolition or clearance of an older property can turn it up. For a small waste business the question is rarely whether asbestos exists, it is what you do when it appears in a skip, on a van or in a load someone wants you to take. This guide explains how asbestos waste is classified, how it must be packaged, who can carry and receive it, and the paperwork that goes with every movement.
We cover the rules in England and Wales, where the Hazardous Waste (England and Wales) Regulations 2005 apply. Scotland and Northern Ireland have their own hazardous waste regulations with the same broad approach. Work with asbestos itself is regulated separately by the Health and Safety Executive (HSE) under the Control of Asbestos Regulations 2012, and this article does not replace the HSE guidance on removing it.
How asbestos waste is classified
All waste containing asbestos is hazardous waste. There is no threshold of fibre content or condition below which it becomes ordinary waste, and asbestos is an absolute hazardous entry on the List of Wastes. The codes you will meet most often are:
- 17 06 05* for construction materials containing asbestos, such as asbestos cement sheets, soffits and floor tiles
- 17 06 01* for insulation materials containing asbestos, such as pipe lagging and insulation board
- 16 01 11* for brake pads containing asbestos, which still turn up in older vehicle parts
The asterisk marks a hazardous entry. Our guide to EWC codes explains the List of Wastes structure, and our overview of hazardous waste regulations in the UK covers the wider regime.
Asbestos waste often arrives mixed in with other demolition or refurbishment waste. The moment that happens the whole load is affected, because the Hazardous Waste Regulations prohibit mixing hazardous waste with non-hazardous waste unless a permit allows it. If you find suspected asbestos in a skip of general waste, stop. Do not tip the load, do not break it up and do not decide it is probably fine. Take advice from a licensed contractor or an accredited analyst and keep a note of what you did.
Identifying asbestos before it becomes waste
You cannot identify asbestos by eye. Materials that look identical can be asbestos-free or not, and the type of asbestos cannot be told without laboratory analysis. Older buildings, broadly those built or refurbished before 2000, may contain it in:
- Corrugated cement roofing, wall cladding and garage roofs
- Soffits, fascias and rainwater goods
- Insulation board, ceiling tiles and partition walls
- Pipe lagging and boiler insulation
- Floor tiles and the adhesive beneath them
- Textured coatings on ceilings and walls
Under the Control of Asbestos Regulations 2012, whoever is responsible for a non-domestic building must manage the asbestos in it, and a refurbishment and demolition survey is needed before major work starts. If your customer is a commercial landlord or contractor, ask for the survey result before you quote. If it is a householder, they may not know what is in their garage roof, and the sensible approach is to recommend sampling by an accredited laboratory before anyone touches it.
Packaging and labelling
Asbestos waste must be packed so that fibres cannot escape during storage, handling and transport. The standard approach set out in HSE guidance is:
- Double bagging. Small pieces and debris go into an inner bag that is sealed, then into a second, outer bag that is also sealed. The bags are heavy-duty polythene and are marked for asbestos waste.
- Wrapping large items. Sheets and larger pieces are wrapped in heavy-gauge polythene sheeting, sealed with tape and, for cement sheets, usually stacked on pallets and shrink-wrapped.
- Labelling. Each package carries the asbestos warning label required by the rules. The HSE guidance describes the labelling expected, so follow it rather than a homemade sticker.
- Keeping it intact. Do not break, crush or compact asbestos materials. Cement sheets should be removed whole and carefully, and wetting the material during handling reduces dust.
A skip firm should not accept loose or open asbestos waste, and should be wary of bags that are torn, damp or unlabelled. If the packaging has failed, the safest answer is to refuse the load and explain why. If you are asked to supply a container, the usual options are a lockable skip or a covered, lockable vehicle that is used only for asbestos on that trip.
Who can carry and receive it
Anyone carrying hazardous waste as part of a business must be registered as a waste carrier. Asbestos is hazardous waste, so you need to be sure your registration is the right one for the work, because lower tier registration is limited to specific situations such as carrying your own waste. Check what your own registration allows against our guide to upper and lower tier registration, and check the carrier you hire against the public register before you hand anything over.
On transport safety, the dangerous goods rules (ADR, applied in Great Britain through the Carriage of Dangerous Goods regulations) also have provisions on asbestos. Some bonded asbestos materials, where fibres are fixed in a binder such as cement so that hazardous quantities of respirable fibres cannot escape in carriage, can fall outside ADR, while other forms are classified as dangerous goods. This does not change your hazardous waste duties. If you carry asbestos regularly, take advice from a dangerous goods safety adviser rather than guessing.
The receiving site must hold an environmental permit that allows it to accept asbestos waste. This is normally a hazardous waste landfill or a landfill cell dedicated to asbestos. Before you set off, confirm in writing that the site will accept the waste and check its permit details, because a site that accepts a load it is not permitted to hold has committed an offence, and you may have too. Our guide to waste exemptions explains why an exemption is not the answer here: asbestos is a hazardous waste, and exempt sites are generally not allowed to take it.
Paperwork: consignment notes
Hazardous waste needs a consignment note, not a standard waste transfer note. This is the most common mistake we see when a general clearance firm takes on a job with asbestos in it. Our article on waste transfer notes versus consignment notes sets out the difference in full. For asbestos the consignment note must identify:
- The producer or consignor, the carrier and the consignee (the receiving site)
- The correct hazardous EWC code, such as 17 06 05*
- The hazardous property the waste exhibits
- The quantity and type of container
- The environmental permit of the receiving site and the carrier's registration number
The consignment note travels with the waste. The producer, the carrier and the consignee each keep a copy, and records have to be retained for at least three years, with the consignee subject to additional record-keeping duties of its own. Many asbestos jobs also produce a separate waste transfer note by mistake for the non-hazardous rubble from the same site. That is correct only if the two loads are kept entirely separate, each with its own document.
Waste from a household is treated differently in some respects, and the rules for hazardous waste collected from a home do not mirror those for business premises in every detail. If you collect asbestos from a domestic property, check the current Environment Agency guidance for the paperwork that applies. Many councils also accept limited quantities of bonded asbestos at household waste recycling centres by appointment, so householders have an alternative to a commercial collection, and they should check with their council first.
What goes wrong and what it costs
Asbestos incidents in the waste sector usually follow the same few patterns. A skip is contaminated by a customer who did not mention the asbestos garage roof. A carrier takes hazardous waste without registration for it. A load is tipped at a site that is not permitted to receive it. A consignment note is missing or wrongly completed.
Offences under the Hazardous Waste Regulations can carry unlimited fines and, in serious cases, imprisonment. Beyond the legal risk, a contaminated skip load can mean decontaminating vehicles and sites, which is slow and expensive. Because the HSE and the Environment Agency both have powers in this area, an incident may attract attention from both regulators.
A practical process for skip and clearance firms
- Ask the question every time. For any job in a pre-2000 building, ask whether there is any asbestos and whether a survey has been done. Record the answer on the booking.
- Refuse unsupported asbestos. If the customer says it is just a bit of garage roof, explain that you need it to be packaged and labelled properly and consigned as hazardous waste, or that they should use a specialist.
- Keep asbestos out of general skips. Make this a standing instruction for drivers and put it in your terms.
- Check registrations and permits. Confirm your own carrier registration covers hazardous waste and confirm the receiving site's permit before collection.
- Use the right paperwork. A consignment note for the asbestos and a separate document for any non-hazardous waste in the same job.
- Keep the evidence. Photographs, signed notes and the consignee's confirmation of receipt.
If your work includes demolition or refurbishment, our guide to construction site waste management covers segregation on site, which is where most asbestos problems can be prevented.
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