Asbestos in old roofing felt: what commercial owners should know
Updated 23 October 2026 · SEO Dons Editorial
This guide is for owners and managers of commercial or industrial buildings with a felt roof from before 2000, or of uncertain age. It covers felt and bitumen products only. Asbestos cement sheets, gutters and downpipes follow different rules, set out in the asbestos cement roof guide. If the roof is sheeted rather than felted, see fibre cement or asbestos roof sheets.
Can old roofing felt contain asbestos?
HSE treats roofing felt as a material that can. Its Asbestos essentials task sheets include A21, “Removing asbestos-containing bituminous products, such as roofing felt, gutter linings or damp-proof courses”, and A22 for metal cladding lined with asbestos-containing bitumen, which matters on older industrial units. HSE’s examples of non-licensed work also name bitumen roof felt.
None of the HSE pages checked says how many felt roofs contain asbestos, so this guide gives no figure. Felt cannot be judged by eye either: HSE says it “can be difficult to identify asbestos, as it is often mixed with other materials”. HSE also says that when asbestos is in good condition and not disturbed, the risk of exposure is extremely low. That is why the law centres on finding out, recording and managing it.
Which commercial buildings are most likely to have it?
HSE says asbestos may be present in any commercial or domestic building built or refurbished before the year 2000, and that buildings constructed after 2000 are unlikely to contain it. Its advice to a dutyholder is to assume it is there in anything older. Asbestos was banned in 1999.
On a flat roof the date that counts is the date of each layer. For example, a warehouse built in 1988 and re-covered in 2012 may still have its 1988 layers under the new membrane, and a refurbishment survey exists to find material hidden within the building fabric. Start with the records HSE lists: survey reports, site plans, the asbestos register, the health and safety file and papers on earlier removal work. Check that any register covers every pre-2000 building on the site.
What does the law ask of the owner?
Regulation 4 of the Control of Asbestos Regulations 2012 puts the duty to manage on the dutyholder: anyone with a contract or tenancy obligation, of any extent, to maintain or repair non-domestic premises. Where there is more than one, each person’s share depends on their repair obligation. On a let building the lease therefore matters, and the guides on who pays for a commercial roof and dilapidations cover that side. HSE summarises the duty as:
- assess whether asbestos-containing materials are present, how much, where and in what condition, presuming they are unless there is strong evidence they are not;
- keep a register and a management plan, reviewed every 12 months or sooner if necessary;
- give the information to anyone who may work on or disturb the material.
The last point is where roof projects go wrong. Regulation 4 requires the information to be provided to every person liable to disturb it, so the survey report belongs in the tender pack and in the pre-construction information, and should reach whoever attends a leak.
Why does it matter before strip-out or hot works?
Before a contractor disturbs any layer, regulation 5 requires an assessment of whether asbestos is present or, where there is doubt, an assumption that it is. Regulation 6 requires a risk assessment and regulation 7 a written plan of work. For final demolition or major refurbishment the plan must, so far as reasonably practicable, specify that asbestos is removed before other major works begin, unless removal would cause a greater risk than leaving it.
The HSE pages checked do not define major refurbishment, so whether a re-roof counts is for the surveyor and the contractor’s plan. HSE does say that refurbishment which disturbs the fabric where asbestos could be hidden needs a more intrusive survey before work can start.
The same survey informs the fire decision. NFRC’s Safe2Torch guidance says all fire risks should be identified at the survey stage. The HSE pages checked do not say whether heating old bitumen releases fibres, so this guide does not claim it does. The point is that assessment comes before method. The hot works guide covers permits and alternatives to a flame.
What is the right order of events?
- Gather the records, then commission the right survey. A management survey covers external areas including roofs. A refurbishment or demolition survey is the one needed before major refurbishment; it involves destructive inspection, so the area is vacated. HSE’s survey guide is HSG264.
- Leave sampling to the surveyor. HSE says the only way to confirm a suspect material is to analyse a sample. Sampling should be done by a suitably trained person, with a competent surveyor the route if in doubt, and analysts must be accredited. HSE strongly recommends accredited surveyors and names UKAS as the sole recognised accreditation body.
- Check the report. Areas the surveyor could not inspect are presumed to contain asbestos until they can be inspected.
- Update the register and plan, choose a route, and put the report in the tender documents.
This is not a roof condition survey of membrane, insulation, falls and drainage. The two are commissioned separately; the commercial flat roof survey guide shows how they fit.
Overlay, leave in place or remove?
| Route | What happens to the old felt | Settle in writing |
|---|---|---|
| Leave and manage | Stays. HSE says material in good condition and unlikely to be damaged should be left in place and the risk managed | Register entry, inspection interval, roof access |
| Seal or encapsulate | Stays, sealed. HSE lists sealing-in work on materials in good condition as non-licensed | Whether the proposed coating counts as sealing-in work |
| Overlay | Stays under new layers. The HSE pages checked do not address overlaying felt | How fixings pass through old layers, and what the next re-roof will face |
| Strip and remove | Leaves as waste, which HSE says must be legally disposed of as hazardous waste | Category of work, plan of work, notification, waste route |
Condition usually decides. HSE says asbestos in poor condition, or likely to be damaged in normal use and not safely repairable or enclosable, should be removed. The overlay and strip-and-recover guide covers the construction side and the felt roof repair guide covers patching. To compare new bitumen systems, see the built-up felt and reinforced bitumen page, or send roof details through the site’s form once the survey is in hand.
Who is allowed to do the work?
The employer of anyone whose work might involve asbestos decides whether a licensed contractor is needed. The owner’s part is to appoint a contractor able to decide properly, and to hand over the survey.
| Category | What HSE says | Relevance to felt |
|---|---|---|
| Non-licensed | Maintenance involving bitumen roof felt is an example, and HSE counts bitumen among materials where fibres are bound in a matrix. Needs a risk assessment, controls and trained workers. Bonded materials in good condition can usually be treated this way | Starting point for felt in reasonable condition |
| Notifiable non-licensed | Applies where bonded materials are significantly damaged. The employer notifies the enforcing authority before work starts, designates areas, arranges medical examinations and keeps registers | Felt in poor condition |
| Licensed | Most higher-risk work needs a licensed contractor, and licensable work without a licence is an offence | Not usual for felt alone, but HSE says most work to remove insulating board needs a licensed contractor, and roofs can include insulating board soffits |
For notification, HSE’s table sends factories and factory offices to HSE, and shops, offices and wholesale and retail storage to the local authority.
The owner’s own rule is simpler: do not cut, scrape, lift or remove felt to find out what it is. HSE says not to repair or remove asbestos materials yourself without training for non-licensed work, and that all roofs should be treated as fragile until a competent person confirms otherwise. The fragile roofs guide covers access.
Sources
- HSE, Asbestos essentials, locations of asbestos, FAQs and introduction (checked 22 October 2026)
- HSE, non-licensed work, notifiable non-licensed work and licensable work (checked 22 October 2026)
- HSE, duty to manage: overview, is asbestos present and arrange a survey (checked 22 October 2026)
- HSE, HSG264 survey guide and fragile surfaces (checked 22 October 2026)
- legislation.gov.uk, Control of Asbestos Regulations 2012, regulations 4, 5, 6 and 7 (checked 22 October 2026)
- NFRC, Safe2Torch (checked 22 October 2026)
Common questions
Is an old felt roof dangerous if it is left alone?
HSE says the risk of exposure is extremely low when asbestos is in good condition and not disturbed. The risk rises when the roof is damaged or worked on, which is why the register and survey come first.
Can I send a piece of felt to a laboratory myself?
No. HSE says sampling should be carried out by a suitably trained person, with a competent surveyor the route if in doubt, and that analysts must be accredited. HSE also lists collecting and analysing samples as work that needs a risk assessment, and cutting into a roof carries a fall risk.
Does a roof built after 2000 need an asbestos survey?
HSE says buildings constructed after 2000 are unlikely to contain asbestos. Where the building is older, or earlier layers remain beneath a newer one, check the date of each layer and ask a competent surveyor if the records are unclear.
Is it illegal to remove asbestos felt without a licence?
Not necessarily. A licence is needed only for licensable work, and HSE lists maintenance involving bitumen roof felt among its examples of non-licensed work. The work is still regulated, so the contractor's assessment decides which category applies.