How the UK Highways Agency Ensures Compliance with Asbestos Regulations

Asbestos, once a popular construction material due to its fire-resistant and insulating properties, is now recognized as a major health hazard. Its presence in older infrastructure presents a significant risk, especially during maintenance, upgrades, or demolition. In the UK, the Highways Agency (HA)—now part of National Highways—has implemented a rigorous and strategic plan to manage asbestos risks in the national strategic road network. This blog explores in detail how the UK Highways Agency ensures compliance with asbestos regulations through its General Asbestos Management Plan (GAMP).

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Understanding the Legal Framework: Control of Asbestos Regulations (CAR)

At the heart of the UK’s asbestos management strategy is Regulation 4 of the Control of Asbestos Regulations 2006 (CAR 2006). This regulation outlines the Duty to Manage Asbestos, requiring organizations to:

  • Identify asbestos-containing materials (ACMs).
  • Assess the risk of exposure.
  • Take appropriate action to manage those risks.

The Highways Agency must ensure that its providers—contractors and service partners—comply with these legal requirements throughout the infrastructure lifecycle.

The Role of the General Asbestos Management Plan (GAMP)

The General Asbestos Management Plan (GAMP) acts as an umbrella strategy guiding the Highways Agency’s overall asbestos management across its extensive asset base. It covers approximately:

  • 7,500 km of highways
  • Over 16,000 bridges and highway structures
  • 100,000+ electrical and communication installations
  • Depots, weather stations, tunnels, and control centers

GAMP lays out the methods, processes, and timelines for:

  • Identifying and recording asbestos-containing materials.
  • Producing and managing Asbestos Action Plans (AAPs) and Area Asbestos Management Plans (AAMPs).
  • Ensuring consistency and compliance through monitoring and audit systems.

Planning for Compliance: A Long-Term Vision

The HA adopted a 20-year implementation period, targeting full compliance by March 2025. The approach includes:

  • Annual production of AAPs for 5% of the network.
  • Prioritization of older infrastructure and sites scheduled for maintenance.
  • Exclusion of post-2000 assets from survey mandates, as asbestos use was banned in the UK in November 1999.

Each year, providers are responsible for preparing management plans covering at least 5% of their area. This ensures a gradual but systematic coverage of the entire strategic road network.

Detailed Mapping of Asbestos Risk Areas

Asbestos can be present in a wide variety of structures and components, including:

In Structures:

  • Bridge deck formwork and joint filler materials
  • Bitumastic coatings on culverts
  • Bearings, mastics, gaskets, and drainage systems

In Road Systems:

  • Drainage and communication ducts
  • Electrical cabinet panels and lighting column insulation

In Buildings:

  • Roofing, lagging, insulation, wall panels, and electrical fuse boxes

In Tunnels:

  • Rope gaskets, insulation on ducts, and legacy dust deposits

Recognizing these risks allows the Agency and its partners to create targeted action plans and conduct safe interventions.

Coordinated Action through Asbestos Action Plans (AAPs)

The production of AAPs is central to the GAMP process. These plans are generated for:

  • Nominal 5 km lengths of highway
  • Specific structures such as depots, toilets, tunnels, and picnic sites

The AAPs are uploaded to national databases like SMIS, HAPMS, and TPMS to ensure accessibility and traceability across all teams. These plans must be updated post-surveys, post-maintenance, or as new information becomes available.

Integration with Project Lifecycle: Scheme Asbestos Management Plans (SAMPs)

Major projects initiated by the Major Projects Directorate (MPD) require separate but complementary Scheme Asbestos Management Plans (SAMPs). These are initiated at the “Preferred Route Announcement” stage and updated through the construction phase. Upon completion, these plans are integrated into the HA’s main systems, ensuring continued compliance and data integrity.

Monitoring, Review, and Accountability

The HA performs regular audits and compliance checks through the Performance Audit Function (PAF) to ensure that the plan is working. They evaluate:

  • Whether safe working practices are in place
  • The completeness of AAP submissions
  • Ongoing training and awareness across all stakeholders

Monthly reporting by providers is mandatory, documenting progress against targets and the status of AAP uploads.

Roles and Responsibilities

Multiple stakeholders collaborate to fulfill the GAMP requirements:

  • MACs and TechMACs: Manage local network sections and technology infrastructure.
  • External Providers: Responsible for submitting compliant AAPs.
  • HAAMT (Asbestos Management Team): Oversees the national compliance framework and conducts reviews.
  • Business Services (BS) Estates Team & PFM: Handle properties directly owned by the HA.

Providers must cooperate not only internally but also with external stakeholders like emergency services, local authorities, Network Rail, and utility companies.

Excluded Assets

Certain assets fall outside the GAMP’s purview, including:

  • Properties acquired under blight provisions
  • Buildings used by HA staff
  • Private finance infrastructure such as transmission stations
  • Motorway service areas and leasehold properties

In these cases, the “Duty to Manage” lies with the asset owner or leaseholder, not the HA.

Training and Capacity Building

Providers must nominate trained AAP Owners who understand their legal responsibilities. While the HA previously offered training, it now mandates that each provider ensure its team is trained according to CAR 2006 Regulation 10. The HAAMT can share training materials upon request.

For internal staff, a structured training program is implemented, with attendance logs maintained and reviewed annually.

Recordkeeping: Ensuring Consistency and Traceability

All AAPs must be recorded in PDF format and uploaded using standard templates from IAN 63/05. This allows for:

  • Centralized access to asset information
  • Uniform reporting formats
  • Streamlined communication across multiple contractors and agencies

This recordkeeping system supports transparent compliance verification and easy access during audits or emergencies.

Final Thoughts: A Model for Infrastructure Risk Management

The UK Highways Agency’s General Asbestos Management Plan exemplifies how a public infrastructure authority can tackle complex health and safety issues with methodical planning and cross-organizational coordination. By implementing a multi-decade compliance strategy, incorporating digital tracking systems, and mandating stakeholder cooperation, the HA is effectively minimizing the risk of asbestos exposure across its vast and aging network.

As the March 2025 deadline approaches, the HA’s model may serve as a reference point for other infrastructure bodies aiming to align with stringent health and safety regulations.

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