Management of Asbestos: HSG264

Transcription

1 Management of Asbestos: HSG264

2 Content Reminder what is asbestos? Where can asbestos be found? The law relating to asbestos HSG 264 Asbestos: The Survey Guide

3 What is Asbestos? (cont) 6 types of asbestos. 3 common ones.. Blue (crocidolite) Brown (amosite) White (chrysotile) brown White blue

4 Where does asbestos come from?

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6 Properties Rot Proof Heat insulator Electrical insulator Resistant to chemical attack High tensile strength High melting temperature Resistant to fire Suitability for friction and sealing materials Etc etc etc

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8 Sprayed Asbestos Coating

9 Asbestos filter cigarettes!

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11 HSE Campaign- You are more at risk than you think

12 Damaged asbestos Insulating Board

13 Why do we need asbestos training? Doll & Peto (1995); Peto et al (2006) Incidence of asbestos disease increasing for construction and maintenance trades

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15 Health Surveillance

16 Health Surveillance

17 Asbestos issues now. Over 50% of UK buildings contain it Biggest single occupational killer Disease incidence is increasing in maintenance workers

18 Progressive Prohibitions 1985 statutory ban on blue and brown and all use as lagging / spraying 1992 statutory ban on other amphiboles and higher risk use of white 1999 total ban (with some exceptions)

19 A Bit About Legislation General health and safety legislation Asbestos specific legislation

20 General Health and Safety Legislation Health and Safety at Work etc Act 1974 The Management of Health and Safety at Work Regulations 1999 The Construction (Design and Management) Regulations 2007

21 CDM 2007 ACoP L144 on Asbestos Survey Assessments Clients should carry out the necessary surveys in advance and provide the necessary information to those who need it

22 CDM Prosecution Designer & Planning Supervisor Client Contractor & Sub-Contracto

23 Asbestos Law Framework Current Approved Codes of Practice are: L143 (main ACoP) L127 (Support to Regulation 4 duty to manage asbestos)

24 Asbestos Legislation, ACoPs and Guidance Act Approved Code of Practice (ACoP) Health and Safety Guidance (HSG)

25 CAR 2006: Asbestos Training Main classifications. Licensed Work Training ( People working in the licensed asbestos industry) Non-Licensed Work Training (Workers carrying out occasional lower-risk tasks with asbestos) Asbestos Awareness training (Anyone at risk i.e. those who work on, or coordinates non-new build work).

26 Why do we need asbestos training?

27 Planning Work and Risk Assessment Maintenance & Refurbishment Work (Regs 5 & 6 of CAR 2006): Presume or identify the presence of asbestos Ensure risk assessments tackle the issue of asbestos during maintenance & demolition Must also consider people other than employees

28 Duty to manage asbestos Reg 4 0f CAR 2006 Identify or presume asbestos Assess the risks Communicate the information Manage the risks Monitor the condition of the asbestos Review the plan

29 When will enforcement action be taken? No system to warn or provide information to people at risk

30 Enforcement Action For Landlords and Social Housing Reg 4 of CAR may not apply but other law does Other parts of CAR 2006 The Housing Act 1985 Suitable checks and surveys required before refurbishment etc

31 Duty to Identify Asbestos Before Work Starts Reg 5 An employer shall not undertake work in demolition, maintenance, or any other work which exposes or is liable to expose his employees to asbestos in respect of any premises unless either carried out assessment or if doubt assumes asbestos is present and observes the provisions of the regulations

32 Why Change Predates DTM Limited Client guidance on surveys Experience not captured No guidance for domestic housing sector

33 HSG 264 Asbestos The Survey Guide: Who does it apply to? Surveyors Technical requirements Clients Responsibilities and information

34 Prosecutions for inexperienced/ incompetent asbestos surveyors

35 HSG 264: Aims and objectives Surveyors More competent (experience and accreditation) More aware of clients needs Better quality reports (more detail and less caveats) Prevent exposure Clients More informed Greater understanding of surveyors needs Recognise need for different surveys during building life span Better asbestos management

36 Other Users Demolition contractors Asbestos contractors Building professionals

37 CDM (13) It is not acceptable to make general reference to hazards that may exist site specific asbestos surveys should be carried out in advance of construction work

38 Managing Asbestos -Appointed Person (14) Duty holder to identify a person responsible for managing asbestos clear lines of responsibility Resources, skills, training, authority Essential if large/complex portfolio

39 Surveyor Health and Safety (16) Surveys fall within CAR 2006 Non licensed work Reg 6 Risk Assessment Reg 7 Plan of work Reg 10 Non licensed worker training Other hazards

40 HSG 264 : Application of Asbestos Law Workplaces Reg 4 directly applicable Common areas of blocks of flats etc Reg 4 directly applicable Domestic living spaces Reg 4 not applicable HOWEVER S2 and S3 of HSWA 1974, Reg 5 (identification) of CAR 2006 and risk assessment requirement under MHSWR 1999 do apply

41 HSG 264 : Survey Accreditation HSE strongly recommend clients use accredited surveyors i.e. ISO (surveying companies) ISO (individual surveyors e.g. sole traders) ie ISO recommended where the scale and volume of work dictates not only individual competency but also the need for formal quality management systems

42 Surveyors 1. Training, qualifications and knowledge 2. Knowledge specific to task 3. Independent, impartial, integrity 4. QM system 5. Surveys to approved standard ie HSG 264 Strongly recommends Accredited/Certificated Surveyor Good Looking?

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44 BOHS Modules P402 S301 CoCA Royal Society for Public Health Level 3 Cert in Asbestos Inspection Procedures

45 Surveyor Knowledge (18-21) Products Building construction & components Fire protection Shafts, plenums, undercrofts, risers Oversprays, residues, debris Ad hoc uses

46 Asbestos Packers

47 Snots on Walls

48 Asbestos Surveys Simple Type 1 surveys disappear The presumption of ACM s is incorporated into management surveys Strong presumption because: Known recognised material which used asbestos Same as other similar sampled ACM (cross-referenced) Visible asbestiform fibres Presumption where: Area not accessed Material not known and not sampled Always errs on the side of caution Some materials may be presumed to be asbestos when actually asbestos-free

49 HSG 264 : Types of Survey Survey types have been re-named Type 2 survey is now a management survey Type 3 survey is now either a refurbishment or demolition survey The type of survey will vary during the lifespan of the premises and several may be needed over time At larger premises a mix may be appropriate e.g. refurb survey of one part where work is being carried out and management survey of the rest.

50 HSG 264 : Management Survey Purpose is to identify ACM s within buildings and prevent exposure Is not destructive but may involve minor intrusive inspections and future planned maintenance Will normally involve sampling, should assess condition and provide recommendations for client

51 HSG 264 : Management Survey (cont) Areas not accessed should be stated in report Details of inspected areas should be recorded May be sufficient for minor surface refurb & maintenance Risk assessment scoring system remains unchanged from MDHS 100

52 HSG 264 : Refurbishment/demolition Survey Used where more extensive refurbishment is carried out e.g. partitions removed or work behind fixed boxing etc. Management survey is NOT sufficient Fully intrusive and probably destructive in areas inspected as aggressive techniques are required should only be conducted in unoccupied areas.and furnishings removed from the areas within the survey scope Only required in areas where the work is being carried out however in housing it is usual to survey the rest of the property

53 Caveats and Survey Restrictions HSE really don t like these as they can seriously undermine the usefulness of the survey May be imposed by either client or surveyor.? Originally HSE were going to say NO caveats for a refurbishment or Demolition survey Clearly not practicable, even for the best refurbishment or demolition survey (see bottom of para 57 on P13) HSE have therefore taken this on board and the paras are about as severe as they could get Any caveats or restrictions must be agreed by both parties and clearly documented

54 Survey Planning Much more detailing than in MDHS 100 Detailed checklists for both client and surveyor of information to be collected and supplied HSG264 - recommends walkthrough inspection as part of site meeting Does this always happen? - See box 7 (page 17) as a pre-survey questionnaire? UKAS companies already carry this out as part of the contract review for ISO 17020

55 HSG 264 : Planning Process Survey Management survey Pre-demolition or refurbishment survey Asbestos register Plan/drawing Risk assessment Management plan

56 Scope Survey Plan Areas to be included or excluded, ACM s to be excluded? Survey procedure How, when, who, how many samples, photographs, material risk assessment system, priority assessment (?), method for recording data, building and room identification, quality and assurance checks? Personnel and safety How many staff and when on site, access and authorisation issues, site safety issues and emergency procedures Report Format, hard copy and/or database, plans and/or drawings, asbestos register form, how many copies and who to receive them

57 Risk assessment for surveying Site safety issues Working at heights Electrical safety Chemical hazards Hot work Slips trips and falls Live machinery Biological hazards Noise Radiological hazards (hospitals, nuclear power stations, etc.) Adequate risk assessment of each by a competent person and available to the surveyors

58 HSG 264 : Management Planning HSG 264 emphasises allocating responsibility lines for: Carrying out surveys to required standard Managing the data Monitoring the condition of asbestos Managing the process e.g. contractor and trades control

59 HSG 264 : Planning Surveys Where keys are required for premises, clients should assist surveyors in order to reduce the number of no access areas. for housing improvement schemes and other project work, surveys should be incorporated into the planning phase of such work as far as possible. This will avoid delays and disruption

60 HSG 264 : Survey Strategy The presence of ACM s can be variable even within the same archetypal group due to Inconsistent and variable use Random use of waste pieces and off-cuts Modifications of properties by tenants (past and present) and housing associations Cloning can only be justified if there is sufficient supporting evidence e.g. build data showing evidence of complete consistency

61 HSG 264 : Management of Data Asbestos register must be actively managed i.e. updating register when ACM s have been removed ACM s have been re-inspected New areas have been surveyed (e.g. during refurbishment surveys) Asbestos surveys must be available to those who plan or initiate maintenance and refurb work

62 Does your Survey Measure Up? Is it easy to read? surveys must be easy for non-technical people to understand Simple location summaries Hot-spotted plans are useful for more complex sites.

63 Client s Responsibilities (Appointed Person) Check accuracy of report Produce the AMP Keep things updated Make the information available to all parties

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65 When will enforcement action be taken? Evidence of maintenance workers being exposed or at risk of exposure. no actual exposure required to prosecute

66 When will enforcement action be taken? People working in areas with damaged or friable asbestos materials present

67 Refurbishment Case Study

68 FAST RESPONSE UNIT Emergency response 24/7 Ability to carry out bulk identification on site Provide supporting services

69 Thank you for listening.. DMW Environmental Safety Ltd Asbestos surveys Asbestos training Asbestos analysis Asbestos removal management