London Underground Asbestos Concerns: Understanding the Difference Between Occupational Exposure and Passenger Risk

Recent media coverage has brought asbestos and airborne dust on the London Underground back into the spotlight after an employment tribunal ruled that a former Transport for London (TfL) worker had been unfairly dismissed following protected whistleblowing disclosures about health and safety concerns. The case has prompted wider discussion around London Underground asbestos risks, hazardous dust, and how asbestos should be managed within ageing infrastructure.

While the allegations reported are concerning, they also highlight an important distinction that is often lost in media coverage: the risk to workers carrying out intrusive maintenance is very different from the risk to members of the public.

London Underground asbestos: a legacy of ageing infrastructure

The London Underground is the world’s oldest underground railway network. Large sections of its infrastructure date back more than a century, with continual expansion and refurbishment throughout the twentieth century.

Like many buildings and infrastructure projects constructed before asbestos was banned in the UK, parts of the network incorporated asbestos-containing materials (ACMs), including:

  • Pipe and boiler insulation
  • Fire doors
  • Cable insulation and cable troughs
  • Asbestos cement products
  • Gaskets and rope seals
  • Asbestos insulating board (AIB)

The presence of asbestos within an older asset does not automatically present a health risk. In fact, many ACMs remain safely in place across millions of buildings throughout the UK where they remain in good condition and are properly managed.

Problems arise when asbestos becomes damaged or disturbed.

What do the recent reports actually say?

The recent reporting centres on a former London Underground worker who cleaned accumulated dust from ventilation shafts, lift shafts and cable routes beneath stations. During an employment tribunal, he alleged that workers had insufficient respiratory protection during parts of his employment, that asbestos-containing materials were disturbed during cleaning activities, and that hazardous waste disposal procedures were not always followed appropriately. An employment tribunal found that his whistleblowing disclosures were protected and that he had been unfairly dismissed.

Importantly, however, the tribunal did not determine that passengers had been exposed to unsafe levels of asbestos, nor did it conclude that Transport for London had breached asbestos exposure limits for the travelling public.

Transport for London has stated that it operates strict asbestos management procedures in accordance with the Control of Asbestos Regulations and maintains that passengers and staff are not at risk during normal operation of the network. TfL has also confirmed its intention to appeal aspects of the tribunal’s decision.

Occupational exposure and public exposure are not the same

One of the most important principles in asbestos risk management is understanding who could be exposed, how they may be exposed, and for how long. This typically forms part of the Priority Risk Assessment as per HSG 227: A comprehensive guide to managing asbestos in premises.

Maintenance workers cleaning tunnels, service voids or plant areas may spend entire working shifts in environments that members of the public never enter. They may also carry out activities capable of disturbing settled dust or asbestos-containing materials.

Passengers, on the other hand, experience something entirely different. A commuter travelling through a station for a few minutes each day experiences vastly different exposure conditions to an engineer undertaking intrusive maintenance inside restricted areas over many years.

Why asbestos management matters more than asbestos removal

Stories such as this often prompt calls to “remove all the asbestos”; in reality, wholesale removal is rarely the safest or most practical solution.

Removing asbestos usually creates greater short-term fibre release than leaving stable materials in place under effective management, potentially putting asbestos removal contractors at risk (although they should have strict controls in place to reduce this risk as low as is reasonably practicable). This is why UK legislation focuses on management rather than removal by default.

Good asbestos management includes:

  • Maintaining accurate asbestos registers
  • Undertaking regular re-inspections and actioning recommendations
  • Completing Refurbishment and Demolition Surveys before intrusive works
  • Training maintenance personnel
  • Using competent asbestos removal contractors and surveying consultants
  • Following asbestos waste handling and disposal procedures

These principles apply equally to transport infrastructure, hospitals, schools, commercial buildings and industrial premises, as well as any other non-domestic premises where Regulation 4: The Duty to Manage applies.

The wider issue of airborne dust

The recent articles also refer to other contaminants found within London Underground dust, including iron oxide, chromium and other metallic particulates associated with railway operations. Railway environments naturally generate dust through a variety of operations including wheel, rail, and brake wear.

For organisations responsible for maintaining these environments, suitable risk assessments should consider all occupational hazards rather than focusing solely on asbestos.

Appropriate respiratory protective equipment (RPE), dust suppression techniques, ventilation controls and cleaning methodologies all contribute towards reducing exposure. The HSE has useful webpages about controlling dust in the workplace.

Lessons for every Dutyholder

Although this story focuses on the London Underground, its lessons extend far beyond the transport sector.

Many organisations continue to operate buildings constructed before 2000 that contain asbestos. The key question is not whether asbestos exists, but whether it is being managed effectively.

Dutyholders should regularly ask themselves:

  • Is our asbestos register up to date?
  • Have we completed recent re-inspections and actioned any recommendations?
  • Do contractors receive suitable training and site-specific asbestos information before starting work?
  • Are refurbishment surveys commissioned before intrusive projects?
  • Do maintenance staff understand asbestos risks?

Answering “no” to any of these questions increases the likelihood of accidental disturbance and potential enforcing authority involvement.

Managing asbestos through informed decision-making

The recent media coverage reminds us that asbestos remains a live issue across Britain’s ageing infrastructure. It also demonstrates how occupational health concerns can differ significantly from risks faced by the wider public.

Rather than causing unnecessary alarm, these stories reinforce the importance of competent asbestos management, thorough surveying, clear communication and robust control measures whenever maintenance or refurbishment work takes place.

Whether managing a transport network, hospital, school, office or industrial facility, the same principles apply: identify asbestos, assess the risks, prevent unnecessary disturbance, and ensure anyone working on the premises has the information, instruction, and training they need to stay safe. We can help you implement a robust asbestos management plan.