Notifiable Non-Licensed Work (NNLW): What Every Tradesperson Needs to Know
You do not need an HSE licence to carry out NNLW. But you do have three specific legal duties before you start. Most tradespeople who get prosecuted under CAR 2012 are not rogue operators — they simply did not know these rules applied to them.
Speak to a Surveyor: 07345 062075Why This Matters to You as a Tradesperson
If you work in properties built before 2000 — and most tradespeople in Surrey, London, and the South East do — you will encounter asbestos. Not occasionally. Regularly. The HSE estimates that around 1.8 million tradespeople in the UK are exposed to asbestos each year, and that tradespeople account for the majority of the 5,000 asbestos-related deaths recorded annually in the UK.
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.
You do not need an HSE licence to carry out NNLW. But you do need to notify the HSE before you start, ensure your workers are under health surveillance, and keep COSHH records for 40 years. Failing to do any of these is a criminal offence. The HSE's enforcement data shows that prosecutions for NNLW breaches are increasing — and that the most common defence ("I didn't know") carries no weight in court.
What Notifiable Non-Licensed Work Actually Means
NNLW is defined in Regulation 2 of CAR 2012 as asbestos work that does not require a licence but where the exposure to asbestos is not sporadic and of low intensity. In practice, this means work where you are disturbing asbestos-containing materials (ACMs) in a way that releases fibres — drilling, cutting, sanding, scraping, breaking — but where the exposure is unlikely to exceed the Workplace Exposure Limit (WEL) of 0.1 fibres per cubic centimetre (f/cm³) averaged over four hours.
The distinction between NNLW and non-licensed work comes down to the nature of the disturbance. Handling an intact asbestos cement sheet without breaking it is non-licensed work. Drilling through it to fix a bracket is NNLW. Painting over Artex is non-licensed work. Sanding or scraping it off is NNLW. The material is the same — the difference is in what you are doing to it.
And the distinction between NNLW and licensed work comes down to the material and the exposure risk. Most work on asbestos insulating board (AIB), sprayed coatings, and lagging is licensed work regardless of duration or scale, because these materials release fibres readily and exposures routinely exceed the WEL. If you are not certain which category your job falls into, arrange a survey before you start.
Which Materials Trigger NNLW Status
The table below covers the most common materials tradespeople encounter. The trigger is always the activity — not the material alone.
| Material | Common examples | Activity that triggers NNLW |
|---|---|---|
| Asbestos cement products | Corrugated sheets, flat sheets, downpipes, guttering, flue pipes | Drilling, cutting, or breaking — not simply handling intact sheets |
| Textured coatings (Artex) | Ceilings and walls in properties built before 2000 | Sanding, scraping, or mechanical removal — not painting over |
| Asbestos floor tiles and adhesive | Vinyl floor tiles, thermoplastic tiles, bitumen adhesive | Breaking, grinding, or sanding — not lifting intact tiles carefully |
| Asbestos rope and gaskets | Boiler door seals, pipe gaskets, fire rope | Cutting, tearing, or disturbing — not visual inspection |
| Asbestos insulating board (AIB) — low risk only | Ceiling tiles, partition boards, fire doors | Short-duration, low-disturbance work only. Most AIB work is licensed. |
Your Three Legal Duties Under NNLW
These duties apply to every employer or self-employed person who carries out NNLW. They are set out in Regulations 9, 22, and 24 of CAR 2012.
Notify the HSE
You must notify the HSE before starting NNLW. Notification is made online via the HSE's NNLW notification portal. There is no minimum notice period for NNLW (unlike licensed work, which requires 14 days), but notification must be submitted before work starts.
Health surveillance
Workers who carry out NNLW must be under health surveillance. This means a medical examination by an employment medical adviser or appointed doctor, with records kept for 40 years. The examination must take place before the worker first carries out NNLW and then at intervals of no more than three years.
COSHH records
You must keep records of the NNLW carried out, the workers involved, and the exposure levels. These records must be kept for 40 years and made available to the HSE on request.
HSE notification: no minimum notice period, but must be before work starts
Unlike licensed work — which requires 14 days' advance notice — NNLW notification can be submitted immediately before starting. But it must be submitted before you begin disturbing the material. Notification is made online at hse.gov.uk/asbestos/nnlw. You will need the site address, the type of material, the planned start date, and the names of the workers involved.
Four Mistakes That Lead to Prosecution
Assuming non-licensed means no legal duties
Non-licensed does not mean unregulated. NNLW has three specific legal duties — HSE notification, health surveillance, and COSHH records — that do not apply to ordinary non-licensed work. Failing to comply is a criminal offence under CAR 2012.
Starting work without a survey
If you are not certain whether the material you are about to disturb contains asbestos, you must treat it as if it does, or arrange a survey before starting. Disturbing a material that turns out to be asbestos without prior notification is an immediate CAR 2012 breach.
Confusing NNLW with licensed work
Some materials — particularly asbestos insulation board (AIB) in poor condition, sprayed coatings, and lagging — require a licensed contractor regardless of the duration or scale of the work. If in doubt, arrange a survey. The cost of a survey is far lower than the cost of a prosecution or a remediation.
Disposing of NNLW waste as general waste
Asbestos waste from NNLW is still classified as hazardous waste. It must be double-bagged in red asbestos waste bags, labelled correctly, and transferred to a licensed waste disposal site with a hazardous waste consignment note. Fly-tipping asbestos waste carries an unlimited fine.
PPE and Control Measures for NNLW
The PPE requirements for NNLW are set out in Regulation 11 of CAR 2012 and the associated Approved Code of Practice (L143). As a minimum, you need an FFP3 disposable respirator — not a standard dust mask, which does not provide adequate protection against asbestos fibres. You also need disposable coveralls (Type 5/6), disposable gloves, and disposable overshoes.
The work area should be isolated from the rest of the building to prevent fibre spread. Wet methods — dampening the material before cutting or drilling — reduce airborne fibre release significantly. Tools should be cleaned with a damp cloth or a Type H vacuum (not a standard vacuum, which will spread fibres through its exhaust). All PPE, disposable tools, and cleaning materials must be double-bagged in red asbestos waste bags and disposed of as hazardous waste.
Air monitoring during NNLW is not a legal requirement, but it is strongly recommended for any task where fibre release is likely to be significant. An independent analyst can carry out personal air monitoring during the work and provide a clearance air test on completion. This gives you documented evidence that exposures were controlled — which is valuable both for COSHH records and for any future dispute about liability.
When to stop and call a licensed contractor
Stop work immediately and call a licensed contractor if any of the following apply:
- The material is in poor condition, friable, or crumbling
- You suspect the material may be asbestos insulation board (AIB), lagging, or sprayed coating
- The scale of disturbance is greater than you anticipated
- You do not have the correct PPE or equipment on site
- You have not yet notified the HSE and work cannot be delayed
How We Support Tradespeople and Contractors
Pro Asbestos Removal works with tradespeople across Surrey, London, and the South East on a regular basis. Plumbers, electricians, joiners, and builders contact us when they encounter materials they are not certain about — before they start work, not after. That is the right approach, and we make it as straightforward as possible.
A pre-work survey takes one to two hours and gives you a written report identifying every ACM in the work area, its type, condition, and risk category. If the material is NNLW, the report gives you the documentation you need for your COSHH records. If it is licensed work, we can carry out the removal before you start, so your job proceeds without delay. If it is non-licensed work, you get written confirmation that you can proceed safely.
We also carry out NNLW removal for tradespeople who prefer not to handle it themselves. This is increasingly common for kitchen and bathroom refits in pre-2000 properties, where floor tile adhesive, Artex ceilings, and pipe lagging are routinely encountered. We remove the material, provide the waste transfer documentation, and issue a clearance certificate — so you can start your work on a clean, documented site.
Frequently Asked Questions
What is the difference between NNLW and licensed asbestos work?
Licensed work involves the most hazardous asbestos materials — insulation, sprayed coatings, lagging — and requires an HSE licence, 14 days' advance notification, and an independent 4-stage clearance. NNLW involves lower-risk materials where exposure is unlikely to exceed the control limit of 0.1 f/cm³, but the work still requires HSE notification, health surveillance, and COSHH records. Non-licensed work involves the lowest-risk materials and has no notification requirement, though proper procedures and PPE are still required.
Do I need to notify the HSE before every NNLW job?
Yes. Every NNLW job must be notified to the HSE before work starts, using the HSE's online NNLW notification portal. There is no minimum notice period, but notification must be submitted before you begin disturbing the material. Failing to notify is a criminal offence under Regulation 9 of the Control of Asbestos Regulations 2012.
How long must health surveillance records be kept?
Health surveillance records for workers who carry out NNLW must be kept for 40 years. This is because asbestos-related diseases have a latency period of 20 to 50 years. The records must be made available to the HSE on request and must be transferred to a new employer if the worker changes jobs.
Can I carry out NNLW on asbestos insulating board (AIB)?
Only in very limited circumstances. Most AIB work is licensed because AIB releases fibres readily when disturbed. NNLW on AIB is only permitted where the work is genuinely short-duration and low-disturbance — for example, removing a single undamaged ceiling tile without breaking it. If the AIB is damaged, in poor condition, or if the work involves cutting, drilling, or breaking, it is licensed work and requires an HSE-licensed contractor.
What PPE is required for NNLW?
As a minimum, NNLW requires an FFP3 disposable respirator (not a dust mask), disposable coveralls (Type 5/6), disposable gloves, and disposable overshoes. The work area should be isolated to prevent fibre spread, and tools should be dampened where possible to suppress dust. All PPE and disposable tools must be disposed of as asbestos waste after use.
Not sure whether your job is NNLW or licensed work?
A pre-work survey gives you a written report before you start. Same-week appointments available across Surrey, London, and the South East.