Asbestos Management Failings: Lessons from Oxford University

A Long-Standing Duty to Manage

Regulation 4, known as the “duty to manage,” was introduced in 2002 and came into force in May 2004. This regulation requires those responsible for non‑domestic premises to locate asbestos, assess its condition, and put a written management plan in place.

Although the regulations have been updated since (now the Control of Asbestos Regulations 2012), the core duty to survey, record, and manage asbestos has been continuous since 2004. Audits conducted in 2019–2020 were reviewing compliance more than 15 years into that compliance regime.

What the Oxford University Case Shows

Internal audits at Oxford University around 2019–2020 found that dozens of asbestos‑containing buildings had not been properly surveyed. Additionally, only a small fraction of buildings with known asbestos had adequate management plans in place.

The auditors also criticised the asbestos data as incomplete and inconsistent. They concluded that staff, students, contractors, and visitors were at increased risk if asbestos‑containing materials were disturbed.

Governance weaknesses were highlighted. The appointed duty holder was, at one point, not fully aware of their responsibilities or the university’s overall compliance status. Furthermore, some staff with asbestos responsibilities had not received appropriate training.

There were additional concerns about transparency. Disputes over access to audit reports led to a finding that the university had breached duties under environmental information legislation. Staff representatives complained that information on asbestos risks and regulatory breaches had been withheld from those working in affected buildings.

Oxford University, however, maintains that its systems now provide suitable protection and that it complies with its legal responsibilities. This case underlines that even globally renowned institutions may take more than a decade to address long‑standing asbestos compliance challenges across large, complex estates.

Why Compliance is Still Problematic in 2025

Set against a clear and long‑standing regulatory framework, several factors help explain why universities and other organisations still struggle with asbestos compliance. These factors include estate complexity, unclear accountability, resource pressures, competence gaps, weak information management, and the perceived low immediacy of asbestos risk.

Complex Estates and Unclear Accountability

Universities typically manage large, historic, fragmented estates with multiple occupiers and decision‑makers. This complexity makes it harder to maintain a single, accurate asbestos register and clear lines of responsibility. Where governance is weak or ill‑defined, the duty holder role can become nominal. There are often blurred boundaries between estates, health and safety, departments, and, in collegiate structures, individual colleges.

Cost, Disruption, and Competing Priorities

Comprehensive surveys, re‑inspections, and data updates after removals can be logistically challenging, costly, and disruptive to teaching, research, and accommodation activities. Asbestos work often competes with other capital and revenue pressures. This competition can lead to under‑resourced, piecemeal, or deferred programmes.

Competence, Culture, and Awareness

The Health and Safety Executive (HSE) and sector guidance highlight recurring weaknesses. These include limited access to competent asbestos management advice, patchy asbestos awareness training, and poor day‑to‑day procedures for checking the register before work starts. In some institutions, asbestos is still seen as a narrow estates issue rather than a strategic health and safety risk that senior leadership owns and reviews.

Information Management and Legacy Data

Many organisations still rely on historic, paper‑based surveys that were never consolidated into a live central register. This reliance makes information hard to use for planning, permits-to-work, and contractor control. High staff turnover, changes in survey providers, and weak processes for updating records after projects all contribute to outdated or inaccurate asbestos data.

Perceived Low Immediacy of Risk and Limited Enforcement

Because asbestos‑related diseases have long latency periods, and many asbestos‑containing materials can be safely managed in situ, some duty holders underestimate the importance of achieving full compliance with surveys, registers, and management plans. While HSE has undertaken targeted inspection campaigns, notably in schools, and issued guidance, Approved Codes of Practice (ACOPs), and enforcement notices, this has not been supported by a national asbestos register or a sustained, sector‑wide inspection programme for all public buildings.

Parliamentary committees, campaign groups, and industry commentators have criticised the Government and HSE response as insufficiently strategic. They note that regulators do not hold comprehensive data on where asbestos is, its condition, or how well it is being managed. This environment can foster a culture where partial compliance becomes normalised, and persistent gaps in surveys or management plans are not treated as priority non‑conformities.

Lessons for University and Multi-Portfolio Duty Holders

Duty holders in universities and other multi‑property organisations can draw several practical lessons from the Oxford case and wider sector experience. The emphasis is on strengthening governance, data, competence, and transparency so that compliance is demonstrable rather than assumed.

Treat Asbestos as a Strategic Risk

Ensure asbestos is explicitly recognised on the corporate risk register or equivalent, not just within estates documentation. Require periodic assurance reports to senior leadership and governing bodies on surveys, registers, management plans, and incidents, with clear progress against any improvement plans.

Clarify Governance and the Duty Holder Role

Formally appoint a competent duty holder with clear authority, resources, and accountability across the whole estate. Document how responsibilities are shared between estates, health and safety, departments, and any collegiate or subsidiary bodies. This documentation ensures there are no grey areas about ownership.

Make the Asbestos Register a Live Tool

Complete a robust baseline of management and refurbishment surveys, prioritising higher‑risk and higher‑occupancy buildings. Keep the register live and centrally accessible. Update the register after every project, removal, encapsulation, or re‑inspection. Review it formally at least annually, as current guidance expects.

Maintain Building-Specific Management Plans

Produce building‑specific asbestos management plans that translate survey data into practical controls, monitoring regimes, and permit-to-work requirements. Review these plans regularly, at least annually or sooner if circumstances change. They should not be treated as static, one‑off compliance documents.

Invest in Competence, Training, and Supervision

Ensure the duty holder and key estates and project staff have appropriate “duty to manage” and asbestos management training, not just basic awareness. Embed checks of the asbestos register and management plan into everyday maintenance and project workflows. Implement permit-to-work or equivalent controls before intrusive work starts.

Fix Information Management and Legacy Data

Consolidate historic survey reports into a single, structured asbestos database or register. This consolidation can drive risk assessment, work planning, and communication. Implement clear procedures so survey updates, removals, and change-of-use information are promptly captured. Avoid leaving data in disconnected PDFs or paper files.

Lead on Transparency and Communication

Proactively provide staff, students, and contractors with clear information about asbestos locations, controls, and what to do if they have concerns. Prepare for environmental information or Freedom of Information (FOI) requests with an agreed approach. This approach should balance transparency and reassurance, avoiding the perception of secrecy that damaged trust in the Oxford case.

Taken together, these lessons reinforce the conclusion that many institutions are still at different stages of a long‑term asbestos compliance journey rather than at a final destination.

In this context, a structured asbestos compliance and gap analysis review can give duty holders independent assurance on how well their current arrangements align with legal requirements and good practice. This review can identify weaknesses in surveys, registers, management plans, and training. It can also support a prioritised programme of corrective action.

How Asbestos Compliance Can Help

Asbestos Compliance delivers both site-level survey and re-inspection services to maintain accurate asbestos registers. We also provide portfolio-level strategic compliance reviews that test governance, data quality, and management plans across multiple buildings. This service offers clear, prioritised actions for duty holders.

For individual sites, this includes management and refurbishment surveys, annual re-inspections, and updated registers to support permits to work and day-to-day contractor control.

For universities and other multi-property portfolios, strategic reviews draw together existing surveys, registers, management plans, and training records. This assessment evaluates alignment with CAR 2012 and good practice, highlights systemic weaknesses, and supports realistic investment and remediation planning across the estate.

In conclusion, addressing asbestos management is crucial for ensuring safety and compliance. The lessons learned from the Oxford University case serve as a guide for all institutions aiming to improve their asbestos management practices.