Navigating Asbestos Material Risk Assessments vs. Priority Risk Assessments: What You Need to Know as a Duty Holder

Adam Fox • 5 May 2023

As a duty holder, it is your legal obligation to ensure that AMRAs and PRAs are conducted where necessary and that any risks identified are managed effectively

Asbestos is a hazardous material that was widely used in the construction industry until November 1999. It is now known to cause several diseases, including mesothelioma, lung cancer, and asbestosis. As a result, there are strict regulations in place to manage the risks associated with asbestos-containing materials (ACMs). Duty holders, such as building owners, employers, and managers, have a legal obligation to ensure that any asbestos on their premises is managed safely, including conducting asbestos material risk assessments (AMRAs) and priority risk assessments (PRAs).

In this article, I will discuss the differences between AMRAs and PRAs, the legal requirements for both, and provide tips for successful assessments.

Understanding Asbestos Material Risk Assessments (AMRAs)

An asbestos material risk assessment (AMRA) is undertaken as part of a detailed survey of a building to identify the presence, location, and condition of ACMs. AMRAs are essential for ensuring the safety of anyone who may come into contact with asbestos-containing materials. The survey should include a visual inspection of the building, followed by sampling and analysis of any suspected ACMs. The results of the AMRA will determine the level of risk posed by the ACMs and inform the development of a plan for managing the risks.

There are three types of survey that will provide you with AMRAs: asbestos management surveys, asbestos refurbishment surveys and asbestos demolition surveys. Management surveys are used to identify the presence, location, and condition of ACMs that may be disturbed during normal occupancy of a building. Refurbishment/demolition surveys are more intrusive and are required when a building is being refurbished or demolished. The survey will identify any ACMs that need to be removed or sealed before the work can proceed.

What is a Priority Risk Assessment (PRA)?

A priority risk assessment (PRA) is a risk assessment that is conducted after an AMRA. The purpose of the PRA is to assess the level of risk posed by the identified ACMs and to determine the priority for managing those risks. The PRA will consider factors such as the location and condition of the ACM, the likelihood of disturbance, and the potential for exposure. The assessment will determine whether the ACM presents a high, medium, or low risk and inform the development of a plan for managing the risks.

Differences between AMRAs and PRAs

The main difference between AMRAs and PRAs is their focus. AMRAs are concerned with identifying the presence, location, and condition of ACMs, while PRAs are concerned with assessing the level of risk posed by those ACMs. AMRAs are a prerequisite for PRAs, as the results of the AMRA will inform the PRA.

Another difference is the level of detail. AMRAs are typically more detailed than PRAs, as they involve sampling and analysis of any suspected ACMs. PRAs may use the results of the AMRA to determine the level of risk, but they do not involve further sampling or analysis.

Legal requirements for AMRAs and PRAs

The Control of Asbestos Regulations 2012 places a legal obligation on duty holders to manage the risks associated with ACMs. This includes conducting AMRAs and PRAs where necessary. The regulations require that AMRAs are conducted on all non-domestic buildings constructed before 2000, and on the common areas of domestic buildings, such as communal stairwells and corridors. Refurbishment/demolition surveys are required before any refurbishment or demolition work is carried out.

PRAs are required following an AMRA to assess the level of risk posed by the identified ACMs. The duty holder must then develop a plan for managing the risks and ensure that this plan is reviewed and updated regularly.

Who is responsible for conducting AMRAs and PRAs?

The duty holder is responsible for ensuring that AMRAs and PRAs are conducted by a competent person. A competent person is someone who has sufficient training, knowledge, and experience to carry out the assessment. The duty holder must also ensure that the assessor has access to all areas of the building and any relevant information, such as building plans, occupancy information and maintenance records.

How often should AMRAs and PRAs be conducted?

The frequency of AMRAs and PRAs will depend on the nature and condition of the ACMs. Management surveys should be reviewed regularly to ensure that the information remains up to date. Refurbishment/demolition surveys should be conducted before any refurbishment or demolition work is carried out.

PRAs should be conducted following an AMRA to assess the level of risk posed by the identified ACMs. The plan for managing the risks should be reviewed and updated regularly to ensure that it remains effective.

Importance of accurate asbestos identification in AMRAs and PRAs

Accurate identification of ACMs is essential for effective risk management. Failure to identify all ACMs could result in inadequate measures being taken to manage the risks. Similarly, misidentification of non-ACMs as ACMs could result in unnecessary costs and disruption.

The surveyor conducting the AMRA should have sufficient knowledge and experience to identify all types of ACMs. They should also be aware of the common materials that may be mistaken for ACMs, such as textured coatings and certain types of insulation.

Common challenges in conducting AMRAs and PRAs

One of the main challenges in conducting AMRAs and PRAs is gaining access to all areas of the building. This can be particularly challenging in occupied buildings, where tenants may be reluctant to allow access to their premises.

Another challenge is the identification of ACMs in difficult to access areas, such as behind walls and ceilings. The surveyor may need to use specialist equipment, such as borescopes and endoscopes, to access these areas.

Tips for successful AMRAs and PRAs

1. Ensure that the assessor is competent and has sufficient knowledge and experience to carry out the assessment.

2. Provide the assessor with access to all areas of the building and any relevant information, such as building plans and maintenance records.

3. Use specialist equipment, such as borescopes and endoscopes, to access difficult to reach areas.

4. Review the AMRA regularly to ensure that the information remains up to date.

5. Develop a plan for managing the risks identified in the PRA and ensure that it is reviewed and updated regularly.

Conclusion and the importance of prioritising health and safety

Managing the risks associated with ACMs is essential for protecting the health and safety of anyone who may come into contact with them. As a duty holder, it is your legal obligation to ensure that AMRAs and PRAs are conducted where necessary and that any risks identified are managed effectively.

By following the tips provided in this article and working with a competent assessor, you can ensure that your AMRAs and PRAs are successful and that the risks associated with ACMs are managed effectively. Remember, prioritising health and safety should always be your top priority.

If you require assistance with conducting an AMRA or PRA, contact us today to speak with one of our super friendly experienced consultants.

< Older Post Newer Post >

Mail

Asbestos and the Circular Economy: Why It's Time to Stop Burying the Problem

by Adam Fox • 9 April 2025

Asbestos and the Circular Economy: Why It's Time to Stop Burying the Problem Twenty-five years after asbestos was banned in the UK, we’re still digging a hole—literally and metaphorically. Every day, across the country, asbestos waste is double-bagged, labelled, loaded into skips, and driven to landfill, where it will sit indefinitely, taking up valuable space, creating ongoing liability, and adding to our already bloated environmental burden. And yet, 2025 presents a different path. A smarter one. One that replaces disposal with repurposing, and turns a dangerous waste product into a useful, circular resource. The technology exists. So the question we should be asking isn’t “Can we recycle asbestos?” It’s “Why the hell aren’t we doing it already?” Landfill is Failing Us—But We’re Still Relying On It Let’s start with the basics. There are still over 1.5 million buildings in the UK that contain asbestos, most of them now approaching the end of their useful life. As these structures age or undergo refurbishment, the volume of asbestos waste is only going to increase. Right now, we handle that waste the same way we did decades ago: • Identify it • Remove it (usually under fully controlled conditions) • Seal it in heavy-duty plastic • Drive it to landfill • Bury it • Forget about it Except we don’t forget, do we? Because landfill space is running out. Disposal costs are going up. And the environmental cost? We’re only just starting to count it. There’s a Better Way—and It Already Works Here’s what most duty holders don’t realise: We no longer have to bury asbestos. Thanks to recent advances in thermal treatment technology, we now have a method that can safely denature asbestos, breaking down its fibrous structure and rendering it harmless. Companies like Thermal Recycling in the UK are already proving this is not science fiction. They’re using high temperatures to transform asbestos cement products—like corrugated roofing sheets—into an inert ceramic material that’s completely safe. But here's the best bit: That material isn’t just neutral. It’s useful. It can be crushed and graded into aggregate, which can be used in road construction, paving, and concrete mixes. Instead of creating a waste burden for the next generation, we’re creating a valuable, low-carbon building material. Why Aggregate Matters in the Carbon Equation The production of virgin aggregates—through mining and quarrying—is energy-intensive and environmentally damaging. It contributes significantly to CO₂ emissions and destroys natural landscapes. So by replacing some of that demand with recycled aggregate from denatured asbestos, we: • Cut carbon emissions • Reduce dependence on extraction • Shrink the environmental footprint of infrastructure projects • Extend the life of quarries and reduce waste tonnage That’s not just a win for waste management. That’s a win for the entire construction supply chain. And yet most people in the industry don’t even know it’s possible. Why Are We Still Burying What Could Be Reused? As someone who’s worked in asbestos compliance for over 20 years—and now helps business leaders manage risk more intelligently—I’ve seen the same patterns play out time and time again: • “We’ll just do what we’ve always done.” • “This project’s tight on budget—landfill’s cheaper, right?” • “We’re just following the usual route—it’s less risky.” Let’s be honest. That mindset is outdated, short-sighted, and lazy. Cost may always be a factor, but the belief that landfill is “cheaper” needs to be challenged. Once you factor in: • Long-term environmental costs • Reputational risk • Rising disposal fees • And the public pressure for sustainable practices Thermal recycling is already starting to make sense. Especially when the output is something usable, not something buried. Licensed Contractors: You Don’t Get a Free Pass Either This isn’t just about clients or duty holders. Licensed Asbestos Removal Contractors (LARC’s) have a moral obligation here too. And I say that not from a place of opinion—but from first-hand experience, day in and day out for over two decades. Too often, LARCs put profits over progress. They default to landfill because it’s faster, easier to price up, and keeps their margins clean. They know the alternatives exist—but they don’t explore them, let alone offer them to their clients. When you hold a licence from the HSE, you’re not just a business—you’re a guardian of public health. That comes with responsibility. Choosing the most sustainable, forward-thinking disposal route should be part of that. Especially when the technology is available, proven, and legal. It’s time for the industry to stop hiding behind what’s convenient and start leading from the front. A Moral Obligation for Everyone Involved Whether you’re a: • Local authority managing public buildings • Developer under pressure to go green • Commercial landlord looking to reduce liability • Or a licensed contractor with influence over disposal routes —you have a responsibility to look beyond the cheapest or fastest option. If there’s a proven, safe, and more sustainable way to manage asbestos, you have a duty to understand it before choosing to ignore it. Because let’s be honest: “We didn’t know” isn’t going to wash when the public starts asking why we’re still filling landfill sites with a problem we already have the technology to eliminate. So What Can You Do Differently? No one’s asking you to overhaul your entire waste strategy overnight. But you can—and should—start asking better questions: • “Is landfill our only option here?” • “Could this waste stream be recycled instead of buried?” • “What suppliers, contractors, or experts do we know who can help us explore this?” You don’t have to be a global pioneer. But if you’re in a position of responsibility, you should at least be aware that the old way isn’t the only way anymore. Final Thought: The Future Is Circular—Whether You Join In or Not Asbestos will be with us for decades to come. That’s a fact. But how we handle it—and whether we choose to keep repeating the past or do something smarter—is up to us. Thermal recycling and other denaturing technologies offer a rare opportunity to do something that actually moves the industry forward. Not just ticking the compliance box. Not just burying the problem. But solving it—and turning it into something useful in the process. If you’re involved in asbestos management in even the slightest way, ask yourself this: Are you part of the problem, or part of the solution?