Notifiable Non-Licensed Work (NNLW): What Every Tradesperson Needs to Know

Tradespeople carrying out maintenance, repair or refurbishment in older buildings can encounter asbestos-containing materials. Building age is a reason to check the asbestos information, not proof that a particular material contains asbestos or that exposure will occur.

The Control of Asbestos Regulations 2012 (CAR 2012) divides asbestos work into three categories: licensed work, notifiable non-licensed work (NNLW), and non-licensed work. Most tradespeople are familiar with the idea that some asbestos removal requires a licensed contractor. Far fewer know that a separate category: NNLW: applies to a wide range of routine maintenance and renovation tasks, and that it carries its own specific legal duties.

NNLW does not require an HSE asbestos-removal licence, but the employer or self-employed person carrying it out has additional duties. These include notification to the relevant enforcing authority before work starts, designated-area controls, the required medical examinations and work/health records. The exact duty follows the classified task rather than a generic prosecution claim.

NNLW is non-licensed asbestos work for which the additional notification, medical-surveillance and record-keeping duties apply. HSE classification depends on the task, material, its condition and the likely fibre release. It is not decided by applying one workplace control-limit figure to the job.

The distinction between NNLW and other non-licensed work depends on the condition of the material and the disturbance created by the task. HSE gives careful work on intact asbestos cement as an example of non-licensed work, while work on substantially damaged material or work likely to cause significant break-up can fall into NNLW. Use the current HSE classification guidance for the actual job.

The licensed-work boundary also depends on the actual material and task. Work on sprayed asbestos coatings, loose asbestos insulation and asbestos thermal insulation such as pipe lagging uses the HSE-licensed-contractor route. Most AIB removal is licensable, while some minor short-duration AIB tasks can be non-licensed or NNLW where HSE criteria are met. If the information is inadequate to classify the job, obtain competent survey or sampling evidence before disturbance.

The table below covers the most common materials tradespeople encounter. The trigger is always the activity: not the material alone.

These additional duties apply when the work has been classified as NNLW. HSE guidance covers notification, designation of the work area, medical examinations and the work/health records that must be kept.

1

NNLW must be notified before work starts. HSE's online notification service routes the notification to the relevant enforcing authority for the premises or activity. There is no minimum NNLW notice period, and you do not wait for permission after submitting the notification.

2

Workers carrying out NNLW need the medical examination required by HSE. It must be in place before the worker starts NNLW unless a qualifying asbestos medical has already been completed within the previous three years, and it is repeated at intervals of no more than three years while NNLW continues.

3

The employer must keep the required NNLW work record and individual health records. HSE guidance requires health records to be kept for 40 years; the work record identifies the type and duration of NNLW and the workers involved.

NNLW must be notified before the work starts. HSE states that there is no minimum NNLW notice period and that you do not need to wait for permission after submitting the notification. Use the current HSE NNLW notification service so the notice reaches the relevant enforcing authority.

Non-licensed does not mean unregulated. NNLW adds notification to the relevant enforcing authority, designated-work-area requirements, medical examinations and a work/health record. The employer must comply with those duties before and during the NNLW task.

Before work starts, the asbestos information and risk assessment must be adequate for the material and task. If the material is uncertain, treat it as presumed asbestos or obtain the competent survey/sampling evidence needed for the planned work. A new formal survey is not automatically required where reliable existing information is already adequate.

Sprayed asbestos coatings, loose asbestos insulation and work that may disturb asbestos pipe lagging use the HSE-licensed-contractor route. Most AIB removal is licensable, while some minor short-duration AIB tasks can be non-licensed or NNLW where HSE criteria are met. Classify the actual material, condition and task rather than using one blanket material rule.

Asbestos waste from NNLW is hazardous waste and must follow the applicable packaging, carrier, authorised receiving-site and hazardous-waste consignment-note requirements. The exact packaging and transport controls come from the work plan and current waste rules, not from a generic website method.

The PPE requirements for NNLW are set out in Regulation 11 of CAR 2012 and the associated Approved Code of Practice (L143). The controls and protective equipment for NNLW come from the job-specific risk assessment and current HSE task guidance. Workers must be appropriately trained and competent. This page does not provide a generic PPE recipe or a work method for disturbing asbestos.

If the correct controls, training, equipment or work category are not established, do not start the asbestos task. This guide deliberately does not provide step-by-step instructions for cutting, drilling, cleaning or removing asbestos-containing material.

Air monitoring is not automatically required for every NNLW task. HSE notes that published exposure information or prior knowledge may be sufficient for many lower-risk tasks, while unusual work may require sampling. Any analyst or air-monitoring scope should therefore be justified by the job-specific risk assessment rather than promised as a standard clearance step.

Stop work immediately and call a licensed contractor if any of the following apply:

• The material or condition changes the task into licensable work after reassessment
• The work involves sprayed asbestos coating, loose asbestos insulation, pipe lagging, or AIB work that is not within a qualifying short-duration non-licensed route
• The scale of disturbance is greater than you anticipated
• You do not have the correct PPE or equipment on site
• The task is NNLW but the required notification or medical/record arrangements are not in place before work starts

Pro Asbestos Removal can support tradespeople who need to identify the appropriate survey, sampling or work-category route before intrusive work. This page does not claim a measured frequency of enquiries or a recurring trade pattern without an approved Experience Input.

Where existing asbestos information is inadequate for the planned work area, a competent survey or sampling instruction can be scoped before the task starts. The provider, access, sampling, report limitations and timing are confirmed for the individual instruction. A survey does not itself authorise work or replace the employer's NNLW notification, medical and record duties; licensable work requires an HSE-licensed contractor.

Pro Asbestos Removal can quote owner-led non-licensed and NNLW work that falls within the confirmed direct scope. The material and task are classified first. Hazardous asbestos waste uses the applicable consignment-note route, while a Certificate for Reoccupation is associated with specified licensed-work clearance and is not a universal NNLW handover document.

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