Conflicts of Interest in the Asbestos Industry
Why the separation of functions between diagnosis, removal, and monitoring protects your health, your budget, and the integrity of every asbestos project.
Why Separation of Functions Matters
Decisions about asbestos diagnosis, removal, and management directly affect people's health and involve significant budgets. When the professional who diagnoses is the same one who removes, there is a direct financial incentive to find more asbestos than necessary and recommend the most expensive intervention.
The separation of functions is not a preference: it is a legal requirement in France (Code du Travail, SS3/SS4), in Spain (RD 396/2006), in the UK (Control of Asbestos Regulations 2012), and in most US states (EPA/OSHA state regulations). Amianto.info, as a neutral platform, makes this separation visible to protect the end user.
Incompatibility Matrix
Can the same company perform both services on the same project?
| Survey | Lab | Removal | Air Mon. | Consulting | Proj. Mgmt | Waste | Training | |
|---|---|---|---|---|---|---|---|---|
| Survey | ||||||||
| Lab | ||||||||
| Removal | ||||||||
| Air Mon. | ||||||||
| Consulting | ||||||||
| Proj. Mgmt | ||||||||
| Waste | ||||||||
| Training |
Role-by-Role Conflict Profiles
Each role in an asbestos project has specific incompatibilities. Understanding them protects you from conflicts that could compromise safety or inflate costs.
Survey & Inspection
Inspects the building, identifies suspect materials, collects samples, assesses condition, and issues a report with recommendations.
Main conflict
If the same company that diagnoses also offers removal, it has a direct incentive to classify materials as more dangerous than they are, recommend removal when in-situ management would suffice, and exaggerate urgency to close the sale.
Rule
The surveyor must not carry out the intervention they themselves recommend.
If the company offering you a survey also offers removal, request an independent second opinion before deciding. A surveyor who does not sell intervention has no interest in overstating the problem.
Laboratory & Analytical Services
Receives material, air, or soil samples and analyses them using microscopic techniques (PLM, TEM, PCM, SEM) to confirm the presence and type of asbestos fibres.
Main conflict
If the laboratory also collects the samples, it controls the entire chain of evidence. It can sample from zones that maximise positive results, omit zones that would test negative, or manipulate the chain of custody.
Rule
The laboratory analyses. It does not collect samples or interpret results with intervention recommendations. Sampling is the surveyor's responsibility; the intervention decision belongs to the owner or their independent consultant.
Verify that the laboratory holds official accreditation (ENAC, COFRAC, UKAS, NVLAP). An accredited laboratory undergoes external audits that guarantee impartiality of analysis.
Removal & Abatement
Physically removes asbestos-containing materials from the building following strict safety protocols: containment, negative pressure, decontamination, waste management.
Main conflict
This is the role with the highest conflict potential. The removal company must not have performed the initial survey (incentive to find more), must not conduct air monitoring during its own works (incentive to produce favourable results), and must not perform the final clearance test (judge and party).
Rule
The removal company carries out the physical intervention. Supervision, monitoring, and final certification must come from an independent third party.
The company that removes asbestos from your building must not be the same one that certifies the air is clean afterwards. If offered a "complete package" including removal and final certification, insist that certification comes from a third party.
Air Monitoring
Measures airborne asbestos fibre concentrations before, during, and after intervention works. Issues the final clearance certificate.
Main conflict
If the air monitoring firm has a relationship with the removal company, it can relax measurement criteria, sample from non-representative zones, or issue premature clearance so works can proceed faster.
Rule
The air monitoring firm must be completely independent of the contractor carrying out the works. This separation is regulated in most jurisdictions.
Ask who will perform the air measurements. If the removal company tells you "we handle everything, including air monitoring," insist on an independent body. Air measurement is the proof that your building is safe -- that proof cannot come from someone with an interest in finishing quickly.
Consulting & Advisory
Advises the building owner on how to manage asbestos: what to do, in what order, which providers to engage, and which regulations apply.
Main conflict
If the consultant has a financial relationship with a removal company or laboratory, they may recommend affiliated providers over the most suitable ones, recommend unnecessary interventions to generate work for their partner, or discourage in-situ management when it would be viable because removal generates more business.
Rule
The consultant advises. They do not execute, subcontract, or earn referral commissions.
Ask the consultant whether they have any commercial relationship with removal companies, laboratories, or suppliers. A truly independent consultant has no referral agreements and will present several options, including the option of not intervening if it is not necessary.
Project Management
Plans, coordinates, and supervises the asbestos management project from start to finish. Drafts specifications, selects contractors, supervises execution, and verifies regulatory compliance.
Main conflict
If the project manager has a connection to the removal contractor, they may favour a specific contractor in the selection process, be less rigorous in supervising a commercial partner, or accept deviations they would not tolerate from an unrelated party.
Rule
The project manager supervises. They do not physically execute nor hold a financial interest in the executing companies.
The project manager is your representative vis-a-vis the contractor. If they have any relationship with the executing company, they lose their value as an independent supervisor. Ask explicitly: "Do you have any commercial link with the contractors you will be supervising?"
Waste Management
Collects, packages, transports, and deposits asbestos waste in authorised landfills. Issues traceability documentation (BSD in France, waste consignment notes in the UK).
Main conflict
Lower than for other roles, but it exists: if the waste manager also performs diagnosis, they can exaggerate quantities to bill more transport. If they have a connection with the landfill, they may divert waste to cheaper but less controlled facilities.
Rule
The waste manager must be authorised by the competent authority. Landfills must hold specific authorisation for asbestos waste.
Always request the certificate of deposit at an authorised landfill. This document proves your asbestos waste was disposed of legally. Without this certificate, you remain legally responsible for that waste.
Training & Certification
Delivers awareness courses, worker training, supervisor certification, and periodic refresher courses.
Main conflict
If the training centre also sells removal or diagnostic services, it can relax training standards to retain students-as-clients, orient training towards its own protocols instead of industry best practices, or certify unqualified workers if those workers are employed by its own removal company.
Rule
The training centre trains and certifies. It does not perform services for the same professionals it certifies.
Verify that the training centre is accredited by your country's official body (INRS in France, UKATA in the UK, etc.) and has no connection with removal companies that employ the students it certifies.
Regulation by Country
The separation of functions is not voluntary. Every major jurisdiction mandates independence between key roles.
| Country | Regulation | Required separation |
|---|---|---|
| Spain | RD 396/2006 | Environmental monitoring by ENAC-accredited entity, independent of the RERA-registered company. |
| France | Code du Travail, Arrete du 19 juin 2024, NFX 46-020 | Surveyor independent of the removal company. Final measurement by an independent COFRAC-accredited body. |
| United Kingdom | Control of Asbestos Regulations 2012, HSG248, HSG264 | Analyst independent of the licensed contractor for clearance. |
| United States | EPA NESHAP, OSHA 1926.1101, state regulations | Most states prohibit the same firm from performing inspection and abatement. Independent air monitoring. |
| Australia | WHS Regulations, Code of Practice for Removal | Licensed assessor independent of the removalist for clearance. |
| Italy | D.Lgs. 81/2008, DM 06/09/1994 | Sampling and analysis by qualified independent laboratories. |