The compelling case for mandatory UKAS accreditation in asbestos surveying

The asbestos surveying industry stands at a crossroads. After more than two decades of voluntary standards and widespread quality concerns, compelling new evidence from the Health and Safety Executive (HSE) has definitively demonstrated that UKAS-accredited surveys significantly outperform their non-accredited counterparts. The time for half-measures and commercial convenience has passed – public safety demands mandatory UKAS accreditation for all organisations providing asbestos surveying services.

A brief history of regulatory failure

Before the implementation of the UK’s ‘Asbestos Duty to Manage’ regulations, asbestos surveying was a niche activity undertaken by a handful of organisations, typically staffed by former analysts or removal operatives who had gained hands-on experience with asbestos materials. Training was largely on-the-job, and reports were hand-produced by people who genuinely understood what they were looking for.

The introduction of the P402 Surveying and Sampling Strategies for Asbestos in Buildings qualification around 1998 marked a turning point, but not necessarily for the better. Concerns were immediately raised that 2–3 days of classroom training was woefully insufficient preparation for inspecting buildings for a carcinogen with no known safe threshold of exposure. The qualification maintained an 80 per cent pass rate, leading some early training providers to stop offering it due to the poor quality of candidates who were passing solely to become asbestos surveyors.

Individuals with minimal classroom training can still obtain a gateway qualification that permits them to set up as ‘asbestos surveyors’. Photograph: iStock

The industry expanded rapidly, with many acquiring skills as they went along. For surveyors who had received basic, rudimentary surveying training, locating and identifying obvious, low-risk asbestos-containing materials was a relatively straightforward process; but locating, identifying and assessing the condition of the higher-risk, more challenging products presented significant difficulties. It remains surprising that with minimal classroom training, individuals can still obtain a gateway qualification that permits them to set up as ‘asbestos surveyors’ and inspect for a carcinogen with no known safe threshold of exposure.

The scale of misrepresentation

Today’s internet is awash with organisations making misleading claims to the public. Companies routinely claim accreditation from bodies that don’t actually provide it. Some state they are ‘British Occupational Hygiene Society (BOHS) accredited’ or suggest that customers should ‘ensure that the surveyor is accredited by a recognised body, such as the United Kingdom Asbestos Training Association (UKATA) or the Asbestos Removal Contractors Association (ARCA)’.

The truth is stark: while neither UKATA nor ARCA claim to be accreditation organisations for asbestos surveying, this doesn’t stop companies from claiming to be ‘accredited’ by them. Similarly, BOHS does not offer accreditation for surveying services. Only UKAS can provide accreditation for asbestos surveys, yet we clearly have a widespread issue with organisations misrepresenting themselves to the general public. This isn’t a recent phenomenon – it’s been occurring for over two decades.

Some operators have even claimed that ISO 9000 quality management accreditation means they operate to the same standard as a UKAS-accredited asbestos inspection and surveying body. While the value of proper accreditation is understood by those surveying businesses and surveyors who have achieved it, the effort required to obtain it is apparently deemed undesirable by many surveying companies and their surveyors.

The evidence base: HSE research delivers definitive proof

A recent data-gathering exercise by HSE of 62 survey reports has delivered a resounding verdict: UKAS accredited surveys consistently deliver higher quality results than their non-accredited counterparts. Using a scoring system with a maximum of 760 points, accredited surveys achieved a mean score of 554 points compared to just 454 for non-accredited surveys – a substantial 100 point difference, representing a 22 per cent performance gap.

The statistical evidence is overwhelming. The probability that this performance difference occurred by chance is just 0.016 per cent – equivalent to odds of one in 6,250. This represents extremely strong statistical evidence that UKAS accreditation genuinely produces better survey quality, far exceeding scientific standards for statistical significance.

Importantly, HSE has informed us that survey reports were collected from premises visited during inspection programmes focused heavily on schools and local authorities. This means the non-accredited surveys studied likely came from the better-performing end of the non-accredited market – organisations subject to procurement processes and basic competency checks – rather than from operators who might target private homeowners with less rigorous selection processes. The true difference between the quality of accredited and non-accredited surveys is therefore likely even greater than the research has shown.

The audit reality check

HSE guidance states that five per cent of all surveys need to be audited. In a UKAS-accredited asbestos surveying organisation, this translates to blind audits where surveys are re-performed by another surveyor (from the same company) without sight of the original, and results compared by a competent person. If a surveyor works 240 days a year, roughly 12 days need to be spent undertaking audits of their colleagues’ surveys – a significant cost that introduces genuine quality control.

Robert Southall: "HSE research has demolished arguments that market forces alone can ensure quality."

When questions are asked about how non-accredited individuals comply with this requirement, responses from these individuals and the companies that employ them are typically vague. For an accredited asbestos surveying company, UKAS ensures that blind audits are carried out to ensure appropriate quality control, but no evidence exists to suggest non-accredited operators are complying with the guidance. The same applies to witnessed site audits (where an independent assessor from UKAS observes and checks the work of an accredited surveyor) and annual refresher training – requirements that UKAS rigorously enforces but which appear to be widely ignored elsewhere.

Since 2000, BOHS has issued 25,800 P402 qualifications. If, for example, half were issued to UKAS-accredited inspection (i.e. surveying) bodies, we should expect corresponding levels of refresher training. Yet BOHS reports issuing only 664 RP402 refreshers. This stark disparity suggests widespread non-compliance with training requirements among the non-accredited sector.

The professional standards framework

UKAS accreditation requires organisations to demonstrate comprehensive competence before authorising staff to undertake surveys. Beyond the basic qualification, surveyors need a minimum of six months site-based experience, working with competent colleagues through key stage assessments, culminating in both witnessed
and blind audits.

Many accredited organisations use a cascade approach, authorising staff for less complex buildings and survey types initially, then expanding their skillset over time. Each member of staff has a detailed skills and authorisation matrix, and they’re only assigned tasks within their authorisation scope. UKAS reviews this granular level of authorisation in detail – something that probably doesn’t exist in non-accredited organisations, many of whom claim on the internet that they can undertake all types of surveys in all property sectors.

ATaC: leading by example

The Asbestos Testing and Consulting Association (ATaC) has championed professional standards since its inception over two decades ago. Uniquely among trade associations, ATaC requires all surveying members to hold UKAS accreditation –
a principled stance based on the fundamental belief that public safety demands the highest professional standards.

This wasn’t a commercial decision or barrier to entry, but alignment with ATaC’s mission to provide the best possible support for safe, effective and ethical asbestos management. When you see an ATaC member conducting surveys, you know they’ve met the rigorous standards that UKAS accreditation demands.

The myths and misinformation campaign

Recent social media campaigns have claimed that small non-accredited companies are ‘winning all the work’ because they’re ‘more reactive’, ‘cheaper but better quality’, and can ‘get reports issued within 24 hours if needed’. While such claims generate thousands of online views, they conspicuously lack the one thing that matters most in public safety: evidence.

HSE’s study provides objective, measurable proof that accredited surveys consistently outperform non-accredited ones. The ability to issue reports quickly means nothing if those reports fail to properly identify asbestos or adequately warn of presumed asbestos.

The suggestion that cheaper surveys deliver ‘better quality’ fundamentally contradicts HSE’s findings. Quality costs money in proper equipment, ongoing training, technical review processes and comprehensive insurance coverage. The race to the bottom in pricing inevitably compromises the very elements that ensure survey accuracy and reliability.

Why alternative schemes miss the mark

As mandatory UKAS accreditation gains regulatory momentum, some voices propose alternative approaches including individual competency schemes modelled on post-Grenfell fire safety reforms. These represent dangerous distractions from evidence-based policy making, particularly when even their proponents admit it’s ‘undoubtedly too early to determine whether this is a more effective regulatory approach’.

Individual competency cannot replace organisational excellence. The superior performance of accredited surveys stems not just from individual competence but from robust organisational systems that individual certification cannot replicate – quality management systems, ongoing competence monitoring, independent technical review, adequate insurance coverage and business continuity arrangements.

The legal framework supports change

The requirement for ‘suitable and sufficient’ assessments under Regulation 4 of the Control of Asbestos Regulations 2012 (CAR) provides the perfect legal foundation for mandatory accreditation. Rather than creating enforcement complications, mandatory accreditation provides clear, objective standards that both duty holders and regulators can easily verify.

This approach already works successfully under Regulation 20(4) of CAR 2012, where mandatory UKAS accreditation for air testing and site clearance certification provides clear regulatory standards. The suggestion that extending this model wouldn’t be effective ignores the fundamental difference between survey quality (now measured by HSE research) and wider regulatory compliance across the asbestos management industry.

The costs of quality vs the price of failure

Those opposing change often raise concerns about costs, with claims that accreditation costs £55,000 over four years. Having discussed this with UKAS, the post-accreditation cost is actually around £5,000 per annum – a small element of running a professional surveying organisation. The real costs lie in compliance with guidance requirements: dedicated audit staff, monthly audit activities per surveyor, comprehensive training programmes and proper quality management systems.

These costs are proportional to business size but represent the true cost of professional competence. Much has been made about UKAS fees, but little about compliance costs – and the evidence suggests little is being done outside UKAS-accredited organisations to comply with wider requirements.

The stakes have never been higher

HSE’s inspection programme results reveal concerning compliance levels with the duty to manage requirements by duty holders. Even schools, with the highest compliance rates, still see more than one in three falling short of legal obligations under the duty to manage. Local authority premises recorded the lowest compliance rates, suggesting widespread challenges across the public sector.

These aren’t abstract statistics but real buildings where real people work, learn and visit daily. When duty holders rely on substandard surveys to fulfil their legal obligations, they may unknowingly fail to properly identify and manage asbestos risks.

UKAS confirms the risks

UKAS’s official guidance explicitly warns that using unaccredited providers creates significant risks, including inaccurate or incomplete asbestos registers leading to dangerous materials being disturbed unknowingly, inconsistent surveys with no recourse mechanisms, compromised objectivity where commercial interests override safety and non-compliance with best practice resulting in enforcement action or liability.

The consequences, as UKAS notes, “can include serious health risks to workers and building users, reputational damage and legal consequences”. These aren’t theoretical concerns, but documented risks identified through sector oversight.

The time for action

The House of Commons Work and Pensions Select Committee’s recommendation in 2022 for mandatory UKAS accreditation wasn’t made lightly. It followed detailed scrutiny of evidence from industry professionals, regulators and safety experts. HSE’s subsequent research has provided the empirical backing that policy-making demands.
The regulatory momentum is building through HSE’s formal policy appraisal process, with extensive evidence gathering and stakeholder engagement completed. The next stage of formal public consultation awaits ministerial approval – representing the most significant reform opportunity in years.

A call for political will

The evidence is overwhelming, the regulatory framework exists and professional consensus is clear. What’s needed now is political will to implement proven solutions while resisting attempts to dilute standards with untested alternatives.

After 25 years of voluntary standards allowing substandard work to masquerade as professional service, HSE research has demolished arguments that market forces alone can ensure quality.

The asbestos industry should stop arguing about whether accreditation is necessary and focus on what really matters: why qualifications haven’t changed in 25 years; why social housing remains excluded from duty to manage requirements despite being in original draft guidance; and why we don’t have a plan to reduce the UK’s asbestos burden.

As Emeritus Professor John Cherrie stated at the most recent FAAM (Faculty of Asbestos Assessment and Management) conference, the current biggest risk from asbestos is exposure in buildings. This is what the industry should be addressing – accepting that accreditation is necessary and absorbing the costs just as every UKAS-accredited organisation has done.

The question is no longer whether mandatory accreditation is necessary, but whether we have the collective will to implement it without distraction. Lives depend on getting this right, and the time for half-measures has passed. When dealing with a carcinogen for which there is no known safe threshold of exposure that continues to kill thousands annually, prevention demands uncompromising professional standards backed by statistical evidence.

The path forward is clear: mandatory UKAS accreditation for all asbestos surveying services, implemented without delay and without compromise.

For more information see:
atac.org.uk
@ATaC_Asbestos
linkedin.com/company/atac-asbestos-testing-and-consultancy-/

Robert Southall is Manager, trainer, assessor and auditor at Asbestos Testing and Consultancy Association (ATaC)