An Overview of Asbestos Risk Mitigation in UK Tunnels and Bridges

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The United Kingdom’s transport infrastructure — comprising over 7,500 km of strategic roads, 16,000+ highway structures, and countless tunnels and buildings — was largely constructed before the year 2000. During this period, asbestos-containing materials (ACMs) were commonly used across various asset types. Today, managing the legacy of asbestos in this infrastructure is critical for public safety, worker protection, and environmental health.

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This blog provides an in-depth look at how asbestos risk is systematically managed in UK tunnels and bridges, focusing on the General Asbestos Management Plan (GAMP) issued by the Highways Agency (HA). It explains the legal requirements, the detailed protocols for assessment, and the coordinated effort to meet the Control of Asbestos Regulations (CAR) 2006.

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Why Asbestos is a Concern in UK Infrastructure

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Asbestos was widely used in construction for its insulation, fireproofing, and durability until it was banned in the UK in 1999. However, the remnants of these materials still pose a threat:

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• Tunnels: Asbestos may be found in dust deposits, ventilation systems, fireproofing linings, rope gaskets, and duct insulation.
• Bridges: Materials such as joint fillers, waterproofing boards, and insulation on water pipes may contain asbestos.
• Other Structures: Electrical equipment, drainage systems, control buildings, and maintenance depots are also potential ACM hosts.

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Given this extensive use, systematic identification and mitigation strategies are crucial.

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GAMP: The Backbone of Asbestos Management

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The General Asbestos Management Plan (GAMP), first introduced in 2004 and revised multiple times, outlines how the Highways Agency and its service providers comply with the Duty to Manage under CAR Regulation 4.

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Key Objectives:

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• Identify and assess the presence of ACMs across all highway-related assets.
• Implement management and remediation plans tailored to risk and urgency.
• Monitor, audit, and update the records annually.

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Scope of GAMP: What Assets are Covered?

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GAMP’s scope is wide-ranging and includes:

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• Bridges, tunnels, culverts, and high structures.
• Maintenance compounds, depots, and workshops.
• Electrical systems, lighting poles, weather prediction stations.
• Associated buildings like control centers and fan rooms.

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Assets built or refurbished after the year 2000 are generally excluded, as asbestos was banned by then.

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Planning and Compliance Timeline

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To meet CAR 2006 obligations, the Highways Agency set a 20-year compliance strategy, running until March 2025.

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Milestones:

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• 2008: Asbestos Action Plans (AAPs) for high-risk assets like tunnels and buildings completed.
• 2009–2025: Annual rollout of AAPs covering at least 5% of the strategic road network each year.
• Priority is given to the oldest infrastructure and those scheduled for refurbishment or maintenance.

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Management Plans: A Multi-Layered Framework

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The structure of asbestos management is broken down into several integrated plans:

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• AAP (Asbestos Action Plan): Created for specific stretches of highway or discrete assets.
• AAMP (Area Asbestos Management Plan): Covers all assets within a defined region.
• SAMP (Scheme Asbestos Management Plan): Applied to major projects from the preferred route announcement stage.
• TNAMP (Technology National Asbestos Management Plan): For electrical and tech assets.
• NRTSAMP (National Roads Telecommunications Services Asbestos Management Plan): For communications infrastructure.

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These plans are uploaded to centralized databases like SMIS, HAPMS, and TPMS for tracking and accountability.

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Where Asbestos is Typically Found

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In Tunnels:

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• Behind cladding and ceiling panels
• In cement-based ventilation ducts
• Fireproofing insulation on cables and ducts
• In debris or lagging within sumps and mechanical rooms

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In Bridges:

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• Gaskets and joint fillers
• Composite waterproofing boards
• Pipes and mastic sealants
• Bitumastic coatings on buried culverts

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Work Programmes Involving ACM Risk

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Regular highway activities that may disturb ACMs include:

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• Bridge repairs and pavement maintenance
• Tunnel equipment upgrades
• Emergency incident responses (fires, fly tipping)
• Major project construction (e.g., realignments and bypasses)
• Routine inspections and winter maintenance

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Every planned and unplanned activity must undergo a risk assessment to determine ACM exposure and require the presence of AAPs before proceeding.

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Excluded Assets

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The GAMP does not cover:

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• HA-owned properties managed by Business Services
• Motorway service areas (where duty rests with leaseholders)
• Transmission stations and national traffic centers under private finance
• Assets outside the remit of HA providers

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Responsibility for these lies with the respective duty holders under CAR 2006.

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Training and Personnel Requirements

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All contractors and service providers must:

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• Nominate trained AAP owners
• Ensure key staff are certified under Regulation 10 of CAR 2006
• Maintain continuous compliance via internal training programmes

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Although the HA no longer conducts direct training, it provides resources and maintains a log of trained personnel.

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Monitoring, Audits, and Feedback

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To ensure effective compliance:

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• Monthly monitoring of progress is required
• Annual plan reviews are conducted by the HA Asbestos Management Team (HAAMT)
• Feedback loops include internal audits, third-party inspections, and system-wide performance reports

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Any discrepancies or non-compliance are addressed through targeted action plans.

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Record-Keeping and Digital Systems

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All AAPs and asbestos survey documents must:

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• Be in PDF format with metadata tags
• Be stored in national databases like SMIS (Structures), HAPMS (Pavement), or TPMS (Technology)
• Follow templates as defined in IAN 63/05 to ensure consistency

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These centralized records serve as the backbone of accountability and hazard communication.

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Final Thoughts

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The UK’s approach to asbestos management in its tunnels and bridges is a benchmark in structured risk mitigation. With legacy infrastructure spanning decades and hundreds of thousands of assets, the General Asbestos Management Plan ensures a comprehensive, compliant, and consistent strategy across all levels of the Highways Agency and its contractors.

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As the March 2025 compliance deadline approaches, the effectiveness of these efforts will be pivotal in ensuring the safety of workers and the travelling public, as well as upholding the UK's legal and environmental responsibilities.

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