Licensed vs Non-Licensed Asbestos Work: What It Means for Medicals

Why the category of asbestos work matters

When it comes to asbestos medicals, almost everything follows from one question: what category does the work fall into? The category decides whether a medical is needed at all, how often it is due, and which doctor can carry it out.

Getting this wrong is a common and avoidable mistake. Book the wrong medical and you may have paid for something that does not meet the requirement for the work; miss it entirely and you may be in breach of a legal duty. So before anything else, it is worth understanding the three categories of asbestos work and where the lines between them sit.

The three categories of asbestos work

The Control of Asbestos Regulations 2012 split work with asbestos into three broad groups, based on the risk involved:

• Licensable work, the highest-risk work, which must be done by an HSE-licensed contractor.
• Notifiable non-licensed work (NNLW), a defined group of lower-risk jobs that must be reported to the enforcing authority.
• Non-notifiable non-licensed work, lower-risk work that does not need to be notified.

Medical surveillance applies to the first two groups. The third does not carry the same statutory medical duty, although all asbestos work still needs proper training, risk assessment and controls. The two groups that concern most people day to day are licensed and NNLW, so those are the ones worth understanding well.

What counts as licensed asbestos work?

Licensable work covers the jobs most likely to release high levels of asbestos fibres. Typical examples include removing sprayed asbestos coatings, removing pipe lagging and thermal insulation, and much work on asbestos insulating board.

Workers doing licensable work need a medical at least every 2 years, and it must be carried out by an HSE-appointed doctor. The shorter two-year interval and the specific type of doctor both reflect the higher risk of this work. In most cases, licensable work also has to be carried out by a contractor who holds a licence from HSE.

What is notifiable non-licensed work (NNLW)?

NNLW sits in the middle. It is not licensable, but it is not the lowest-risk work either. It is a defined set of tasks that must be notified to the enforcing authority before work starts, and it comes with its own duties, including health monitoring, keeping records and setting up designated work areas.

Workers doing NNLW need a medical at least every 3 years. Crucially, this medical can be carried out by a wider range of doctors, any suitably registered doctor with a licence to practise, as well as an HSE-appointed doctor. That often makes an NNLW medical easier and quicker to arrange.

Licensed vs non-licensed medicals, side by side

Put next to each other, the differences are easy to see:

• Interval: licensed is at least every 2 years; NNLW is at least every 3 years.
• Who examines: licensed must be an HSE-appointed doctor; NNLW can be a relevant doctor with a licence to practise.
• Both include: a review of history, a respiratory questionnaire, a lung function test and a chest examination.
• Both produce: a certificate of medical examination for the worker and employer.

So the examination itself is broadly similar in both cases. What really changes is how often it is due and who is allowed to carry it out.

Who decides which category a job falls into?

The category is not a matter of opinion, it depends on the material, its condition and the nature and duration of the work. Deciding it is part of planning the job properly, usually through a risk assessment that draws on an asbestos survey or sampling where needed.

This is a different thing from the medical. Working out whether a job is licensable or notifiable is about the work itself; the medical is about the worker's health. If there is any doubt about the category, HSE guidance is the place to turn, and it is better to check before the work starts than to guess.

Can one medical cover both types of work?

There is one rule that often trips people up. A licensed-work medical is accepted as valid for NNLW, because it meets the higher standard. An NNLW medical, however, is not accepted for licensable work.

So if a worker moves from non-licensed into licensable work, they will need the licensed-work medical, even if they already hold a valid NNLW certificate. Planning for this in advance avoids a last-minute scramble when a licensable job comes up.

What about work that needs no medical at all?

It is worth remembering that plenty of lower-risk asbestos work does not require a statutory medical. Non-notifiable non-licensed work, for example, handling well-bonded asbestos cement in good condition, does not carry the surveillance duty that licensable and NNLW work do.

This does not mean the work is risk-free or that it can be done without care. All work with asbestos still needs training, a risk assessment and proper controls. The medical requirement simply tracks the higher-risk categories, which is why identifying the category correctly matters so much.

How to tell which medical you need

The honest answer is that it depends on the work in front of you, not your trade. The same person might need a licensed medical for one job, an NNLW medical for another, and no statutory medical for a third.

If you are unsure, check the task against HSE guidance before you book, or tell us about the work and we will help you identify the right medical. You can also read the full licensed versus non-licensed comparison or start a booking enquiry whenever you are ready.