Housing Landlord Compliance – Asbestos Management Policy - Report
Renfrewshire Council · 28 October 2025
Back to Communities and Housing Policy Board — 28 October 2025 and its agenda
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PUBLIC ___________________________________________________________________ To: Communities and Housing Policy Board On: 28 October 2025 ___________________________________________________________________ Report by: Director of Environment, Housing, and Infrastructure ___________________________________________________________________ Heading: Housing Landlord Compliance – Asbestos Management Policy ___________________________________________________________________ 1. Summary 1.1 All social landlords must ensure they meet all duties in relation to tenant and resident safety and have an effective system in place to ensure compliance with statutory, legislative, and regulatory responsibilities. 1.2 The Housing Landlord Compliance Strategy 2025-2028, which sets out the strategic approach to compliance across the six key areas of compliance relating to Council Housing assets (gas safety, electrical safety, fire safety, lift safety, asbestos management and water safety) was approved at the Communities and Housing Policy Board on 11th March 2025 along with the first two of six policies – the Gas and Carbon Monoxide Safety Policy and the Electrical Safety Policy. The Fire Safety Policy and Lift Safety Policy were approved at Board on 13th May 2025. The Water policy was approved on the 19th of August 2025. 1.3 This report presents the sixth policies associated with the Strategy; the Asbestos Management Policy, which describe how Renfrewshire Council will meet the statutory, contractual, and regulatory requirements in relation to asbestos management relating to our housing assets. 1.4 Details of an independent external review of the policies by a specialist consultant are included within the report. ___________________________________________________________________
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PUBLIC 2. Recommendations It is recommended that the Communities and Housing Policy Board: 2.1 Approves the Asbestos Management Policy, set out at Appendix A of this report. (note this is Appendix 3 of the Landlord Compliance Strategy). 3. Background 3.1 The Housing Landlord Compliance Strategy and associated policies were completed in 2021 and are subject to 3 yearly reviews. An internal review of the Asbestos Management Policy was completed which has been followed up with an independent external review. 3.2 The independent external review of the Asbestos Management Policy has been undertaken by ACS Learning and Consultancy led by Professor Willey who along with his team are highly qualified, knowledgeable and experienced in asbestos management in both domestic and commercial properties in Scotland. 3.3 The Scottish Housing Regulator Engagement Plan for 2025/26 states that the Regulator is “engaging with Renfrewshire to seek further information and assurance about its asbestos management processes and planned improvements.” Renfrewshire Council are required to send the Regulator an update on the actions they are taking in relation to asbestos management by 30th September 2025. 3.5 ACS Learning and Consultancy have been engaged to provide external support and expertise with, not only the review of the Asbestos Management Policy document but also with the following: • Review of the Asbestos Management Plan and Asbestos Operational Guidance • Gap Analysis • Review of Asbestos Management Working Practices • Review of Training Provision and Requirements • Review of Elected Members’ Roles and Responsibilities The Scottish Housing Regulator have been notified of these actions. 4. Housing Landlord Compliance Policies 4.1 The Asbestos Management Policy is set out in Appendix A of this report, outlining how the commitment to asbestos management will be met and how assurance of compliance will be provided to the duty holder. The policy sets out the scope, processes, data management and performance monitoring.
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PUBLIC Implications of the Report 1. Financial – Employee costs associated with the Housing Landlord Compliance team and maintenance costs associated with carrying out statutory and regulatory compliance works are included within the Housing Revenue Account (HRA) approved budget each year. 2. HR & Organisational Development - None. 3. Community/Council Planning – • Our Renfrewshire is safe – ensuring tenants have a safe place to live. To manage risk to for staff, contractors, or members of the public within council housing properties. 4. Legal – None. 5. Property/Assets - Ensuring assets are protected from risk. 6. Information Technology - None. 7. Equality & Human Rights - (a) The Recommendations contained within this report have been assessed in relation to their impact on equalities and human rights. No negative impacts on equality groups or potential for infringement of individuals’ human rights have been identified arising from the recommendations contained in the report. If required following implementation, the actual impact of the recommendations and the mitigating actions will be reviewed and monitored, and the results of the assessment will be published on the Council’s website. 8. Health & Safety - The strategy and policies align with the Council’s Corporate Health and Safety Policy. 9. Procurement – None. 10. Risk - The absence of policies could put the Council at risk of failing to comply with statutory duties for landlord compliance and could be reputationally damaging. . 11. Privacy Impact – None. 12. Climate Risk – None. 13. Children’s Rights – None. 14. Cosla Policy Position – None. _______________________________________________________
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PUBLIC List of Background Papers Appendix A – Housing Asbestos Management Policy ___________________________________________________________________ Author: Karen Sillars, Housing Asset & Investment Manager Email: karen.sillars@renfrewshire.gov.uk
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1 PUBLIC Housing Landlord Compliance Strategy Appendix 3 HOUSING SERVICES ASBESTOS MANAGEMENT POLICY
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2 PUBLIC Table of Contents 1. Introduction 3 2. Policy Statement 3 3. Asbestos Risk 5 4. Duty to Manage Asbestos 6 5. Roles and Responsibilities 6 6. Competence – Information, Instruction and Training 7 7. Document Control 7 8. Implementation 7 9. Consultation 7 10. Equality and Human Rights Impact Assessment 8 11. Monitoring Performance 8 12. Review 8 13. Amendment Log/Version Control 9
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3 PUBLIC 1. Introduction 1.1 This document sets out the Asbestos Management Policy for Renfrewshire Council’s Housing Services who have responsibility for the management of domestic premises owned and managed by the Council. 1.2 This Policy, along with the associated Asbestos Procedure documents and Operational Guidance documents, are intended to facilitate compliance with the asbestos related duties defined and implied in the Control of Asbestos Regulations 2012 (CAR12). 1.3 This Policy, along with the associated Asbestos Procedure documents form part of Renfrewshire Council’s Health and Safety Management arrangements. Therefore, this document should be read in conjunction with the organisation’s Corporate Health and Safety Policy. 1.4 This policy describes how Renfrewshire Council’s Director of Environment, Housing and Infrastructure Services, as duty holder, will receive assurance of statutory, legislative and regulatory compliance. 1.5 At the time of policy approval, Renfrewshire Council (Renfrewshire) owns and manages 11,992 residential properties for let. There are 2783 blocks which contain domestic properties, and approximately 1900 common areas. 11,727 of these properties were built prior to the year 2000 (when all asbestos was banned in the UK) and may have been built or refurbished using asbestos containing materials (ACMs). 2. Policy Statement 2.1 It is recognised that the Council has a duty under the Health and Safety at Work Act 1974, as supported by subordinate legislation, to ensure, so far as is reasonably practicable, the health, safety and welfare of its employees, service users, contractors, the general public and others who may be affected by its undertakings. 2.2 It is also recognised that the management of asbestos related risk falls within the organisation’s general responsibilities set out in point 2.1, above. 2.3 To this end, the organisation will comply with the Asbestos Management duties defined and implied in the Control of Asbestos Regulations 2012. It is the policy of the Council to ensure that, as far as is reasonably practicable, no persons will be exposed to risks to their health due to exposure to any asbestos containing materials that may be present in any of the properties it owns, manages or occupies. 2.4 Renfrewshire aims to: (i) ensure the prevention of exposure to risks associated with asbestos containing materials;
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4 PUBLIC (ii) ensure that any asbestos containing materials that may be present in any of its buildings are maintained in a condition so as to prevent the possibility of any harm to health occurring; (iii) promote awareness of the risks from asbestos containing materials and asbestos management procedures, through training and induction of relevant staff; (iv) provide adequate resources to ensure the provision of appropriate information, instruction and training; (v) ensure a commitment to comply with all relevant asbestos legislation, Approved Codes of Practice, Health and Safety Executive Guidance Notes and to commit to the safe disposal of any asbestos waste in accordance with relevant legislation; (vi) ensure that a representative proportion of properties built pre 2000 are subject to an Asbestos Management Survey Programme and an Asbestos Register for these buildings is prepared and maintained. This Register will undergo regular reviews and will be updated after any remediation and/or removal works have been undertaken; (vii) ensure that an appropriate system is installed, maintained and implemented for the management of all asbestos containing materials identified in the Register. Such a system is to be capable of recording the risk and also the needs and priorities for treatment and/or removal; (viii) ensure that a clear and consistent process, including front-line engagement and enforcement, is in place to obtain access to properties to conduct asbestos surveys and any subsequent remedial works, which shall include taking legal action and forcing entry when required; (ix) ensure only UKAS accredited asbestos consultancies are used for asbestos surveying works, asbestos air testing and asbestos analysis work; (x) implement an effective asbestos management strategy in order that appropriate measures for the remediation or removal of asbestos containing materials can be carried out without risk to tenants, staff or the general public; (xi) ensure that all Contractors and Sub Contractors engaged to carry out work on any Council owned buildings are provided with adequate information on asbestos which may be disturbed by their works; (xii) ensure Licensed Contractors and/or Sub Contractors carry out Asbestos Licensable Works and Competent Contractors carry out Asbestos Minor Works; (xiii) ensure all Non–Licensed Contractors carrying out Asbestos Non- Licensable Works are trained in safe working procedures and have appropriate insurance cover for the work being carried out;
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5 PUBLIC (xiv) ensure that relevant staff and local contractors are provided with appropriate training in this Policy and associated Procedures; (xv) regularly review the Asbestos Management Policy and Procedures. 3. Asbestos Risk 3.1 It is important to differentiate between the REAL risks associated with asbestos materials and the PERCEIVED risks, as incorrect perception of risk can often result in unwarranted concern over health risks. The perceived risk for asbestos is that ‘one fibre can kill’. The real risk, as shown by the work of Prof Seaton at Aberdeen and Prof Gibb at Cardiff, is that lungs from victims of mesothelioma related deaths contain in excess of 100 million asbestos fibres at the point of death. In lungs associated with lung cancer and asbestosis the loading is respectively some 10x and 100x higher. 3.2 The serious diseases associated with asbestos are all diseases of the deep lung. To contract these diseases, fairly substantial quantities of asbestos have to be inhaled .This means asbestos fibres have to be present in the air and they have to be inhaled. Modern research work has indicated that the risk of disease is related to the total number of fibres in the lung (the lung load). The important factor is, therefore, the cumulative exposure i.e. what is breathed in (f/cc) multiplied by how long it is breathed in for (yrs). The real risks associated with asbestos materials would not, therefore, simply depend upon its presence but on the airborne concentration of fibres in the atmosphere and the duration of exposure. 3.3 Clearly, the presence of an asbestos containing material in itself does not constitute a danger. However, there is a potential risk to health if such material is disturbed and/or damaged. An isolated accidental exposure to asbestos fibres for a short duration is extremely unlikely to result in the development of asbestos related diseases. However, regular exposure, even at relatively low levels, can present a risk as ‘cumulative exposure’ develops over time. As well as people employed in the building trades, inadvertent exposure of this type can occur in other groups of people e.g. installers of I.T. systems, burglar alarms, smoke detectors, etc. Risk can also occur if asbestos containing material is damaged and is not remediated or removed. 3.4 In developing this policy, cognisance was taken of the legislative requirements and good practice set out in the following documents: • Health and Safety at Work Act etc. 1974; • Management of Health and Safety at Work Regulations 1999; • The Workplace (Health, Safety and Welfare) Regulations 1992; • Control of Asbestos Regulations 2012; • Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013 (RIDDOR); • The Construction (Design and Management) Regulations 2015 (CDM); • Special Waste Amendment (Scotland) Regulations 2004;
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6 PUBLIC • HSE Document L143 Control of Asbestos Regulations 2012. Approved Code of Practice and Guidance; • HSE Guidance HSG264 Asbestos: A survey guide; • HSE Guidance HSG227 Managing Asbestos in Premises. 4. Duty to Manage Asbestos 4.1 Renfrewshire recognises the duty imposed by Regulation 4 of CAR12 to ‘manage’ asbestos risks associated with normal occupancy in non-domestic premises and, in particular, the following duties set out in HSG264: • To take reasonable steps to determine the location of materials likely to contain asbestos; • To presume materials to contain asbestos, unless there are good reasons not to do so; • To make and maintain a written record of the location of the ACMs and presumed ACMs; • To assess and monitor the condition of ACMs and presumed ACMs; • To assess the risk of exposure from ACMs and presumed ACMs and prepare a written plan of actions and control measures; • To take steps to see that these actions are carried out. 4.2 Renfrewshire also recognises the wider duties set out in CAR12, particularly in Regulations 5 and 6, in respect of maintenance, repair, refurbishment and demolition work in premises and the need to carry out appropriate, suitable and sufficient inspection/surveys, risk assessments and planning prior to any works on the fabric of premises. 4.3 To ensure compliance with these broad duties, specific roles and responsibilities have been defined, including procedures for addressing joint duties with third parties (e.g. in ‘mixed tenure’ premises) and all relevant personnel will hold the requisite levels of competence to properly discharge their responsibilities. 4.4 This Document, together with the Asbestos Procedures Document defines the Renfrewshire’s policies and procedures to ensure the risks associated with asbestos containing materials are properly addressed, assessed and managed and, in so doing, ensure that all relevant legal duties are discharged. 5. Roles and Responsibilities Key roles within Renfrewshire Housing Services that have responsibility for asbestos management are set out in the “Roles and Responsibilities” section of the Asbestos Procedure Document. This document can be found in the suite of Asbestos Procedures that accompany and support this Policy.
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7 PUBLIC 6. Competence – Information, Instruction and Training 6.1 For a full outline of asbestos specific training required for each role outlined in this Policy and the associated “Roles and Responsibilities” procedure document, please see the “Information, Instruction and Training” procedure document. However, all roles will receive, as a minimum, Asbestos Awareness training may be provided internally by suitably qualified staff or by a UKATA approved training organisation (or equivalent). Training will cover this Policy and the associated Procedure Documents and will highlight specific roles and requirements. 7. Document Control 7.1 The successful management of asbestos relies upon the maintenance of a range of documentation, for which the ARP is responsible. The following summarises the principal components of the system: 1. Asbestos Register 2. Survey Reports Folder 3. Asset Register – incorporating property list / relevant premises (i.e. post 2000) 4. Approved Asbestos Contractors and Consultants List 5. Asbestos Works Records 6. Training Records 7. Incident Records 8. Implementation 8.1 This Policy will be effective from the date of approval by the Communities and Housing Policy Board. 8.2 Staff will be made aware of the Policy through internal staff training and a copy will be available on the Intranet. The Policy will also be uploaded to the Renfrewshire Council website. 8.3 This Policy should be read in conjunction with the Asbestos Procedures and Operational Guidance documents. 8.4 All employees shall co-operate in the implementation of this Policy. 9. Consultation 9.1 This Policy is based on statutory, legislative and regulatory requirements and, as such, consultation with customers has not taken place. There has been consultation with internal teams within Renfrewshire and suitably qualified external asbestos consultants.
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8 PUBLIC 10. Equality and Human Rights Impact Assessment 10.1 This policy has been impact assessed in line with the Council’s obligation to comply with the Equality Act 2010 and the Public Sector Equality Duty. 11. Monitoring Performance 11.1 Performance Indicators 11.1.1 To ensure effectiveness of asbestos management measures and maintain regulatory compliance, the following key performance indicators (KPIs) will be subject to reporting: • Non-domestic areas with a valid asbestos survey and re-inspections of all ACMs (where required) within its due date as a % of non-domestic areas requiring one; • Individual dwellings with a valid asbestos survey and re-inspections of all ACMs (where required) within its due date as a % of dwellings requiring one; • Asbestos remedial actions that are overdue as a % of total outstanding remedial actions (non-domestic); • Buildings with no outstanding and overdue remedial actions as a % of total buildings subject to an asbestos survey; • Number of safety occurrences - including any reported asbestos related occurrence reporting (e.g. to the HSE or Regulator) during the reporting period. 11.1.2 Commentary will be provided for any properties out of date to include the date they became overdue, days overdue and the action proposed to bring them back into a compliant position. Commentary will also be provided if any properties have outstanding overdue actions. Additional context commentary will include information on the proportion of activities within the reporting period that were undertaken before and after their due date. 11.1.3 A detailed performance indicator suite will be defined within the Asbestos Procedures. 11.1.4 The following quality assurance (QA) activities will be undertaken and reported in line with the Asbestos Procedures: • Internal Audit; • Strategic Review; • 3rd Party Assurance. 12. Review 12.1 This Policy will be reviewed at least once every 36 months and/or if there is any change in Legislation or HSE Guidance or advice from the Housing Regulator.
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9 PUBLIC 12.2 The review may be carried out internally or by an external consultant. However, the reviewer must be deemed to be competent by the ARP. 12.3 The review will consider this Policy, Procedures and, in particular, the components highlighted in Section 7.1 above. 12.4 The Corporate Health and Safety team will monitor the effectiveness of this policy, and its associated documentation, to ensure alignment with current Renfrewshire Council plans. 13. Amendment Log/Version Control Date of Revision: Record of Amendments: Reason for Revision: By Whom: Name and Title 03/09/2025 Minor amendments held on file Policy review overdue Asbestos Co-ordinator 25/09/2025 New Policy document drafted External Asbestos Consultant Appointed ACS Learning and Consultancy