Employer Guide · CAR 2012
Licensed vs NNLW asbestos work: which medical do your workers need?
The Control of Asbestos Regulations 2012 split asbestos work into three categories and each has different medical surveillance rules. Getting the category wrong means either paying for medicals you don’t need, or putting workers on site illegally.
The three categories of asbestos work
1. Licensed work — higher-risk work requiring an HSE licence: most asbestos removal, work on asbestos insulation and asbestos coating, and most work with asbestos insulating board (AIB). If the work needs a licence, every worker needs a current asbestos medical.
2. Notifiable non-licensed work (NNLW) — non-licensed work that still must be notified to the HSE because of its nature: for example, removal of asbestos cement products where the material is substantially degraded, or short-duration work on AIB. NNLW also triggers medical surveillance.
3. Non-licensed, non-notifiable work — sporadic, low-intensity work where exposure stays below the control limit and the material is in good condition: typically short-duration maintenance, encapsulation of materials in good condition, or removal of intact, non-degraded asbestos cement. Where work is genuinely non-licensed and not notifiable, sporadic, low-intensity work with exposure kept below the control limit, CAR 2012 does not require medical surveillance.
Which medical, how often, and who can do it
| Category | Medical required? | Who examines | Frequency |
|---|---|---|---|
| Licensed | Yes — before exposure starts | HSE Appointed Doctor only | At least every 2 years |
| NNLW | Yes — before work begins | Any registered Doctor | At least every 3 years |
| Non-licensed, non-notifiable | No | — | — |
The distinction people miss: a licensed-work medical from a GP or a nurse-led clinic is not valid — it must be an HSE Appointed Doctor. Many contractors put NNLW workers through the Appointed Doctor route too, so one certificate standard covers all your operatives regardless of which jobs they rotate onto. See our asbestos medicals service for what the examination involves.
Your record-keeping duties
- Keep a health record for 40 years from the last entry for every worker under surveillance
- Keep each certificate of medical examination for at least 4 years
- Medicals happen in work time, at the employer’s cost
- Licence assessments and site audits will ask for current certificates — a recall system prevents stand-downs
Deciding the category
The HSE’s decision flowchart in the CAR 2012 Approved Code of Practice turns on three questions: is the work licensable, is exposure sporadic and low-intensity, and will the control limit be exceeded? If you’re unsure where your method statements land, send them to us — we’ll confirm the category and the medical requirement before you book anyone in.
This guide is general information for employers in Great Britain, not legal advice. Reviewed by Dr Gillian Hawkley, HSE Appointed Doctor for asbestos medicals.
Common questions
Does non-licensed, non-notifiable asbestos work need a medical?
No. Where work is genuinely non-licensed and not notifiable — sporadic, low-intensity work with exposure kept below the control limit — CAR 2012 does not require medical surveillance. But the classification decision must be defensible: if the work turns out to be notifiable, workers needed a medical before it began.
Can a GP do an NNLW asbestos medical?
Legally yes — an NNLW medical can be carried out by any registered Doctor. In practice many GPs decline them, and a Doctor unfamiliar with asbestos surveillance may miss what the examination is for. Many contractors use an HSE Appointed Doctor for both categories so every worker is covered to the licensed standard.
What happens if a worker’s asbestos medical expires mid-contract?
They cannot legally continue licensable or notifiable asbestos work until re-examined. On licensed sites an expired certificate is typically picked up at audit and the worker is stood down. A recall system that flags medicals before expiry is the practical fix.
Related
Asbestos Medicals
Licensed & NNLW medicals by an HSE Appointed Doctor — in Stirling or on your site.
Book or enquireIs Health Surveillance a legal requirement?
The wider surveillance duties beyond asbestos.
Read the guideAll employer guides
Plain-English guides to medicals and surveillance.
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