Document control. Document Reference / Version Number Version 2 January Document Status. Asbestos Policy V.1 - Approved February 2014

Transcription

1 Asbestos Policy

2 Document control Document Reference / Version Number Version 2 January 2017 Title of Document Authors Name(s) Noreen Aslam Authors Job Title(s) Health & Safety Manager Directorate(s) Resources Document Status Supercedes (Version & Date) Approved By Final V.1 - Approved February 2014 EMT delegated to Strategic Compliance Group Date of Approval 10 th January 2017 Publication / Issue Date January 2017 Date of Annual Review January 2018 Changes Made at Last Review Significant rewrite to capture legislation updates and RBH team changes Full Review Date January 2020 Distribution Intranet Rochdale Boroughwide Housing Limited is a charitable community benefit society. FCA register number 31452R. Registered Office: Sandbrook House, Sandbrook Way, Rochdale OL11 1RY. Registered as a provider of social housing. HCA register number: 4607

3 Contents Section Page Introduction 4 Asbestos Background 4/5 Statement of Intent 5/6 Roles and Responsibilities 7-9 Provision of Information and Training 9/10 Legislation and Regulations 10 Monitoring 11 Review 11 Links to other RBH strategies, policies and procedures 11 Equality and Diversity 11 Appendices 12-28

4 1. Introduction 1.1 The purpose of this document is to set out in a clear and precise manner Rochdale Boroughwide Housing s (RBH), policy on managing Asbestos Containing Materials (ACM s) in its properties in Rochdale as part of its duties under the Control of Asbestos Regulations 2012 and the Management of Health and Safety At Work Regulations Asbestos Background 2.1 Asbestos is a silicate mineral, which occurs in nature as long thin crystalline fibres. The fibres have high tensile strength, flexibility, chemical resistance, heat resistance, thermal insulation and electrical insulation properties. Consequently asbestos has been widely used in many building materials. The period between covered the most extensive use of Asbestos Containing Materials (ACM s) in buildings because it was cost effective and there was limited appreciation of the risks it posed to health. 2.2 The risk to health from asbestos occurs when fibres are released into the air and then breathed in. Provided that ACM s are intact and in a position where they will not be damaged they will not pose a significant risk to health. 2.3 The health effects attributed to asbestos have been well researched and documented at both national and international level. In general it is accepted that asbestos, in its many and varied forms, where damaged or likely to be damaged or disturbed in the future, should be removed and substitute materials installed in its place. 2.4 Asbestos containing materials are more hazardous in some forms and conditions than others. 2.5 As asbestos was so commonly used for many years in widely differing situations, the creation of an asbestos free environment would be unrealistic, financially impossible to achieve and in some cases, unnecessary. 2.6 There is, as yet, no statutory requirement to remove asbestos containing materials; therefore its discovery and identification may not necessitate removal. There is, however, a statutory duty to prevent asbestos creating a risk and the method of achieving this will require careful consideration in each individual case identified. 2.7 Risk from asbestos arises either through general use of buildings or more often as a result of carrying out other works to a building. 2.8 This policy has therefore been based on a balanced approach, which gives priority for treatment and / or removal, according to the degree of risk to people working in or occupying RBH properties in which asbestos containing materials are present. 2.9 The asbestos statement is that all three types of asbestos must be treated equally and all ACM s whether licensable (works that require notifying to the HSE e.g. Asbestos Insulating Board) or non licensable (works that is not notifiable to the HSE, e.g. Artex materials/cement products) will be dealt with by approved contractors for asbestos removal. RBH does not expect any of its employees to work directly with any known asbestos. 4

5 All employees, in construction based teams will receive asbestos awareness training so that they are able to recognise potentially suspect material for further analysis to be undertaken. All managers and employees will be offered training appropriate to their role. This will be monitored by a training matrix It must be stated that the majority of known asbestos in RBH properties is in good condition and does not pose a risk to health. It is only when asbestos is damaged, and fibres become airborne, that they are hazardous. 3. Statement of Intent 3.1 This policy covers all RBH properties including; homes, shops, community facilities, garages, garden tenancies 3.2 Since November 1999, no ACM s, with the exception of a few specialist applications, should have been used in the UK. Therefore, all RBH properties, built post 2000 shall not form part of this management plan (which is set out in Appendix 4) as it a reasonable assumption that ACMs have not been used in the building or maintenance of buildings since this date Existing Buildings - ACM s within the loft spaces of buildings existing pre 2000 shall be managed in accordance with their risk assessment rating as stated in the Asbestos Survey information. The rating has been determined in accordance with HSE document HGS264-The Survey Guide). Policy aims and performance monitoring: Policy Aim How Monitored Target Prevent, as far as is Maintain a live Asbestos Monthly report on % of reasonable practicable, Register which is accessible surveys to date exposure to asbestos at RBH. Any breaches reported zero breaches To develop live Register Linked to Capita Ensure regular re-inspection surveys are undertaken Ensure that the information is disseminated successfully to those who may be affected or are potentially at risk and to provide this information on request; Implement a management plan which details how RBH aims to manage asbestos and aims to control the risk from ACMs through remedial works Programme in place for reinspections As part of Management Plan See Appendix 4 As part of Management Plan See Appendix 4 Re-inspection spreadsheet and % undertaken annually Included in 3 year audit plan Monthly reports on any breaches Formal 12 month review by Senior Technical Officer Asbestos (STOA) 5

6 Raising awareness of the management plan. Treat all asbestos equally, ensuring NO ACMs are removed or worked on by RBH employees, including non-licensable materials; Training Programme for teams On going refreshers via team meetings As part of Management Plan Appendix 4 All identified training carried out in year Training in asbestos awareness set out as part of annual framework and delivered. No breaches By promoting asbestos awareness, encourage all employees to work towards a positive culture where everybody recognises and understands their responsibilities; Clearly outline the roles and responsibilities of RBH employees in relation to Asbestos Containing Materials (ACMs) Construction Related Team and project meetings The policy, Asbestos Management Plan and associated procedures set this out Standing item on team meetings and recorded in minutes 100% of identified relevant employees on training matrix have received Asbestos Awareness Training Outline how the asbestos register is derived, maintained and communicated; Ensure clear emergency procedures Provide guidelines for construction related projects; Management Plan Management Plan - Emergency Plan Incidents logged and reported spot checks Set out in Management Plan Appendices 6 & 6.1 Update monthly meetings with Planning & Programming Manager 100% of identified relevant employees on training matrix have received Asbestos Awareness Training Zero breaches Zero breaches 6

7 4. Roles and Responsibilities Chief Executive The Chief Executive retains overall responsibility for health and safety within RBH but specific duties are allocated to appropriate employees throughout RBH to ensure that all aspects of asbestos management are adequately managed, these include: Directors All Directors are required to: Ensure adequate resources are allocated to manage asbestos which reflects the aims of the Asbestos Management Plan Monitor the performance of teams they are responsible for against the policy Advise the Chief Executive of any problem arising in connection with the management of asbestos Director of Customer Experience: The Director of Customer Experience will assist and deputise for the Chief Executive and is responsible for the overall effectiveness of the asbestos policy in their areas of responsibility. The Director of Customer Experience has the final decision when teams request a deviation from the management plan following any advice provided by the STOA. Head of Customer Experience: Is responsible for the implementation of the. Contracts Manager: Is responsible for ensuring that the Asbestos Register is adequately maintained, ensuring information is given to contractors prior to the commencement of investment work and delivering any planned asbestos removal schemes and the management plan is working. Senior Technical Officer Asbestos (STOA) and the Asbestos Team The Senior Technical Officer Asbestos (STOA) is designated as RBH s competent person and is responsible for monitoring and managing the asbestos process within RBH. The Senior Technical Officer Asbestos all be trained to a minimum standard of BOHS P405 The Management of Asbestos in Buildings to ensure a thorough knowledge of legislative requirements and practical applications of the asbestos management plan, Responsibilities include: To manage and update the asbestos register ensuring that data is maintained and provided on request To manage the programme for surveys and asbestos re inspections surveys To ensure that all recommendations from the asbestos surveys and re inspection surveys are acted upon and a programme of remedial works devised To ensure the progress of the asbestos management plan, monitoring its progress and prioritisation To instruct and liaise with analytical company and asbestos removal contractors 7

8 To ensure a quick response to all asbestos related queries and emergency requirements as set out in the service standard and team KPI s Responsive Repairs/Empty Homes/Asset Team Managers: Is responsible for ensuring than appropriate processes are in place to ensure employees and contractors are given relevant asbestos information before completing repairs. Contact Centre Manager: Is responsible for ensuring that all Contact Centre/Planners have a full understanding of the arrangements to be followed in the event of receiving a report of any incident or tenant concerned involving asbestos. Independent & Supported Living/ Homeless Manager: Is responsible for ensuring that a copy of the Asbestos Report for each scheme is kept in the scheme office and made available for contractors etc. Additionally, any asbestos related concerns or observations made during the normal course of work should be reported to the Asbestos Team Health and Safety Team: Provide advice, guidance and support in connection with asbestos in conjunction with the Contracts Manager and Senior Technical Officer Asbestos Include asbestos management plan in routine health and safety audits and advice to teams Facilities Manager: Is responsible for ensuring that, where non-partner contractors are engaged to conduct work on premises under Facilities control (Campus/community buildings) the Asbestos Register is checked and appropriate information is passed to the contractor. All Team Managers, Supervisors and Construction/Related Project Leads: To maintain regular contact with the Asbestos team with regards to asbestos related to works to be undertaken. To disseminate any asbestos information, survey programmes or updates etc from the Asbestos team To raise with the Asbestos team, any asbestos training needs for new employees or refresher training of existing policies To ensure that all employees of their team accept the responsibilities with regards to asbestos To ensure that all employees consider asbestos as a high priority for any new construction related project and to include asbestos as an item in all construction related project meetings To ensure all employees allocate sufficient funds within the project cost plan and allocate sufficient time for any asbestos remedial works to be carried out 8

9 To fully appreciate the timescales involved with asbestos surveys and subsequent remedial works and to support their teams when a project requires a tight timeline to understand and take advice on time scales. To ensure that the appropriate type of survey has been carried out for the works involved. To carry out any asbestos remedial works in line with current asbestos regulations. To outline any proposed works or requests to the asbestos team and to keep them updated and informed at all times. All start dates should be passed onto the asbestos team as soon as possible To consider and accept guidance and recommendations given by the Asbestos team. Deviation from the guidance and recommendations shall be referred to the Director of Customer Experience. To ensure all relevant teams are kept informed about any asbestos works including dates, the site of the decontamination facility and waste skips etc. To ensure that only qualified asbestos removal contractors are used for remedial works, including works managed by external contractors. (As set out in Appendix 5) The Asbestos Survey Report should be read in its entirety and all sections on the report noted. All Employees All RBH employees have duties and obligations in regard to asbestos as part of their responsibility for Health and Safety (set out in the RBH Health and Safety Framework). If these duties and obligations are adhered to, and the asbestos management plan (set out in Appendix 4) followed this which will significantly reduce the risk of asbestos exposure for everybody. All employees of RBH, irrespective of their position, have a responsibility to: Take reasonable care for their own health and safety and that of other persons who may be adversely affected by asbestos works, including members of the public, tenants, visitors and contractors. Co-operate with RBH and its managers to enable compliance with this policy and the legal duties it holds, including attending training and reporting any concerns promptly and appropriately, halting works that, in their opinion, may present a serious risk to health of themselves or others. Isolate and restrict access to areas confirmed or suspected to be contaminated with asbestos until the area has been declared suitable for normal occupation 5.0 Provision of Information & Training 5.1 It is the responsibility of line managers with support and advice from the Health and Safety Team and Learning and Development Team to ensure that appropriate information, instruction, training and supervision is provided for employees in relation to the management of asbestos. This will include induction training and training provision for apprentices and relevant temporary employees 9

10 5.2 The Senior Technical Officer Asbestos will maintain and provide data relating to asbestos within RBH properties upon request and also deliver training as requested (as per 5.1) and agreed as part of the training matrix. 5.3 Training shall include the following: Types and uses of asbestos Recording and management systems Prevention of damage of asbestos Asbestos registers and Permits of work Asbestos removal, repair and encapsulation Asbestos waste disposal Asbestos analysis, sampling and testing Clearance and 4-stage re-occupation certificate 6. Legislation and Regulations 6.1 All works with regard to asbestos shall be carried out in strict accordance with all current United Kingdom legislative / regulatory requirements. Please find in the following sections lists of all current regulations, guidance notes and approved codes of practice that refer to work with asbestos whether in a full or minor capacity. 6.2 Regulations Health and Safety at Work etc Act The Management of Health and Safety at Work Regulations Control of Asbestos Regulations The Hazardous Waste Regulations 2005 Construction, Design, Management Regulations 2015 Reporting of Injuries, Diseases and Dangerous Occurrences Regulations (RIDDOR) Approved Codes of Practice Managing and Working with Asbestos L Guidance Notes HSG 248 Asbestos: The analysts guide for sampling, analysis and clearance procedures. HSG 264 The Survey Guide. HSG 247 Asbestos The licensed Contractors Guide Asbestos essentials task manual HSG53 Respiratory Protective Equipment. HSG 227 A comprehensive guide to managing asbestos HSG 53 Selection, use and maintenance of respiratory protective equipment. 10

11 7. Monitoring 7.1 This policy will be monitored by the Strategic Compliance Group in conjunction with the Head of Customer Experience to ensure it remains fit for purpose through the reporting of appropriate key performance indicators to Customer Management Team and the Strategic Compliance Group. 7.2 The Board, Audit Committee and EMT will also receive updates on performance as part of the Risk Update. This will include KPI in relation to communal area re-inspections target 100% Progress towards holding surveys for all of our homes long term target of 100% Details of any breaches target of zero breaches. 8. Review 8.1 All RBH policies and procedures are reviewed on an annual basis in order to ensure that they are fit for purpose and comply with all relevant legislation and statutory regulation. 8.2 The Asbestos Management Plan and the will be reviewed on an annual basis by the Senior Technical Officer Asbestos who will consult with the Health and Safety Manager. The review of the Asbestos Management Plan will include (but will not be limited to) the following items: Changes in Asbestos and other Health and Safety legislation Changes in employee roles and responsibilities regarding asbestos Changes in personnel and the introduction of new roles The effectiveness of the Asbestos Management Plan Failures within the procedures and how to prevent them in the future Update on the Asbestos Register and the buildings surveyed 8.3 This policy, including any other related policies and procedures will be reviewed annually in order to ensure its continued appropriateness and formally reviewed and submitted to EMT every three years. 9 Links to other RBH Strategies, Policies and Procedures Health and Safety Policy Asset Management Strategy CDM Policy Responsive Repairs Policy Risk Management Policy 10. Equality & Diversity 10.1 An Equality Impact Assessment relevance test has been carried out for this policy and the outcome was found not to warrant a full Equality Impact Assessment. 11

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15 Appendix 4 1. Asbestos Management Plan 1.1 It is the responsibility of RBH s Senior Technical Officer Asbestos (STOA) to determine the management plan for any ACM s identified in a management survey report. 1.2 In order to manage the risk from ACM s in the properties, it is necessary, first of all, to identify where they are present. RBH shall therefore carry out a management survey for their properties built prior to This includes all properties; homes, shops, garages, community buildings etc. 1.3 Following the management survey, an asbestos register will be maintained, identifying all known ACM s, its condition and risk rating. The Asbestos Register 1.4 The Asbestos Register is a bespoke system (BHI) held in electronic format. The Asbestos Register will be kept up to date with information regarding the removal or repair work of ACM s, new management surveys or additional changes to ACM s found within the asbestos re inspections. (Refer to 7.20) 1.5 If removal or remedial works are carried out by approved removal contractors, the information will be updated on the Register only upon the receipt of official documentation. For notifiable items, a clearance certificate will be required. For all other items, an original method statement will be required. All relevant employees have a responsibility to ensure that copies of documentation relating to asbestos remedial works are sent to the Asbestos Team upon completion, in order to facilitate the updating process. The asbestos register can only be updated by the Asbestos Team. Paper copies of all site paperwork relating to Asbestos Remedial works will be held by the Asbestos Team for at least 40 years. 1.6 Based on the survey assessment, prioritisation can be applied to managing and controlling the risks where they are highest. The response will fall into either short, medium or long term as detailed below: Timescales will be advised by the Asbestos Team Short Term Management This will address those items identified by the assessments/surveys, which require urgent attention. This may mean that the items are removed completely, repaired, encapsulated or enclosed. Any items, which are subject to remedial works, will be reassessed to allow for their subsequent and ongoing management Medium Term Management This concerns those items that require repair or encapsulation, but due to their location, and or condition/material type do not need urgent attention and can be addressed in the normal maintenance schedule of the building by managing in situ Long Term Management This will comprise the vast majority of the work. Items falling into this category, due to their location, condition and material type are best left in situ 15

16 whereby they can be closely monitored. Regular re-inspections of these materials will allow the best course of action to be decided over time. Labelling of Asbestos 1.7 It is good working policy that ACM s be labelled as appropriate, and managed in a controlled manner through this asbestos management plan. Priority for works 1.8 All asbestos related activity will be prioritized to ensure that we remain compliant. The priority for works is listed below and the responsibility for implementing this will be with the Senior Technical Officer (Asbestos). 1. Emergency response works where asbestos has been disturbed (appendix 3) 2. Communal re-inspections due on an annual basis where asbestos is detected and a regulatory requirement. 3. Works in relation to the investment programme/planned works/regeneration works, mainly surveys so that works can progress, but also supporting the teams on site. 4. Day to day surveys on properties where no works are planned, but where no survey is currently in place. This will count towards our objective to have a survey in place for 100% of our properties This type of work should only be undertaken where no works are outstanding in relation to points 1, 2 and 3. Works in relation to point 3 will of course count towards this objective but in a more targeted way. Breaches 1.9 Details of any breaches will be reported to the Board, Audit Committee and EMT. KPI s will also track compliance with the regulatory requirement to re-inspect all communal areas in addition to tracking progress towards our objective of holding management surveys for all of our properties. 2. Inspections and Surveys undertaken by the Asbestos Team or commissioned by external consultant There are two types of surveys: Management Surveys 2.1 This survey is required during the normal occupation and use of a building to ensure the continued management of the ACM s in situ. This survey will locate, as far as is reasonably practicable, the presence and extent of any suspect ACMs in the building which could be damaged or disturbed during normal occupancy, including foreseeable maintenance and installation, and to assess their condition. (Refer to 2.11) 2.2 Areas to be included in the survey are underfloor coverings, above false ceilings, lofts, risers, service ducts, lift shafts, basements, cellars, undercrofts etc. Management surveys should cover routine and simple maintenance work. However, where more extensive maintenance or repair works is involved, a localised refurbishment survey may be required. This should be discussed with the Asbestos Team. 16

17 Refurbishment and/or Demolition Surveys 2.3 A refurbishment and demolition survey is needed before any refurbishment or demolition work is carried out. This survey is used to locate and describe, as far as is reasonably practicable, all ACMs in the area where the refurbishment work will take place or in the whole building if demolition is planned. A refurbishment survey may also be needed when more intrusive maintenance and repair work is to be carried out or for plant removal and dismantling. All ACMs identified will be removed prior to refurbishment or demolition. It is recognised that even with complete access demolition surveys, all ACMs may not be identified and this only becomes apparent during demolition itself. (Refer to 2.11) 2.4 Under the Construction Design & Management Regulations 2015, the survey information should be used to help in the tendering process for removal of ACMs from the building before work starts. The CDM Policy forms part of the Health and Safety Framework and directs how a large scale construction or refurbishment project should be planned and executed. Large scale means any works lasting more than 30 days, involving more than 20 persons or exceeding 500 working days in total (e.g. 18 employees working for 28 days would total 504 days). The survey report will be supplied by RBH to designers and contractors who may be bidding for the work. Refurbishment and demolition surveys should only be carried out in unoccupied areas. Ideally, the building should not be in service and all furnishings removed. 2.5 RBH is undertaking management surveys of all its properties. The RBH Senior Technical Officer Asbestos, managers, supervisors and project lead shall ensure that an appropriate level of asbestos survey is undertaken prior to any works commencing. Guidance on the different type of survey is listed above. It is every employee s responsibility to ensure that they are provided with a copy of this report prior to undertaking any works. The Asbestos team will undertake spot checks to ensure compliance. 2.6 A refurbishment/demolition survey shall only be undertaken where intrusive work is planned, such as demolition, major refurbishment or where the extent or nature of the asbestos in a building cannot be determined by a management survey. Re-inspections 2.7 RBH will re-inspect all communal areas where asbestos is identified on an annual basis. Communal areas requiring re-inspection are identified on the Asbestos Register and an annual programme of work is in place to ensure that RBH is compliant with the Approved Code of Practice L143. A re-inspection programme is in place and on-going. 2.8 The re inspection survey will look at all the ACM s within a building and assess whether the item has deteriorated or changed in any way since the last inspection. All of the remedial options will then be looked at to determine the best way in which to continue to manage the ACM. RBH Asbestos Survey Methodology 2.9 All asbestos surveys carried out to RBH properties shall be carried out in accordance with the HSE document HSG264 The Survey Guide. 17

18 2.10 All sample analysis shall be carried out by a UKAS accredited laboratory in accordance with Regulation 21 of the Control of Asbestos Regulations All surveys shall be carried out by experienced survey teams, with surveyors holding the BOHS P402 qualification as a minimum and with a minimum of 12-month experience within the asbestos industry. The surveyors shall inspect all accessible parts of each property, and look for any installation that potentially could contain asbestos Any suspect materials shall be sampled and subsequently analysed in accordance with HSG 248 Asbestos: The analysts guide for sampling, analysis and clearance procedures. This method identifies the asbestos types present and their estimated percentage content. Sampling 2.13 Under the regulations samples of ACM s or suspected ACM s can only be taken by qualified persons see 2.11 above Samples shall be taken using low - disturbance techniques, whereby a small amount of material will be taken, after firstly wetting the sample location with a polyvinyl acetate (PVA) solution spray. This minimises the release of asbestos fibres during the process. Air monitoring carried out during sampling work of this type has shown airborne fibre concentrations to stay below the clearance indicator level of 0.01 fibres per millilitre of air Sampled materials are immediately placed in sealable, airtight sample bags and appropriately labelled. Sample points will be suitably filled / sealed using PVA spray, Polyfilla or adhesive tape The surveyors shall not disturb any suspected asbestos installation in any other way than to take a representative sample. This measure shall minimise the risk of asbestos fibre release, but shall prevent access above/behind a suspected asbestos installation. It is possible, therefore, that further asbestos materials could be present behind an existing asbestos installation All relevant sample point data shall be recorded and shown in reports e.g. accessibility, condition, extent of material, etc The material risk assessment is an assessment of the ability of the identified asbestos installations to release fibres into the air. It is not an assessment of the likelihood of damage to the materials identified. The likelihood of damage or disturbance would be determined by carrying out a priority assessment. In order to achieve this a thorough understanding of the activities on site is required and therefore this is a responsibility placed on the duty holder as defined in the Control of Asbestos Regulations The Asbestos Survey Report should be read in its entirety and all sections on the report noted. 18

19 2.20 When requesting an inspection/survey The Asbestos Team manage the Asbestos Register and will provide asbestos information prior to any building work being carried out upon request. Anyone undertaking any relevant works in the home/building MUST be fully informed of any known or suspect asbestos materials in the vicinity of proposed work areas in order to increase awareness and to ensure work activities do not lead to fibre release. This data will be provided to third party contractors in the form of an asbestos survey (either Management or Refurbishment and Demolition depending on the nature of the works). This will be provided in an electronic copy in the form of a PDF so that it cannot be altered or adjusted. This is provided to the manager, supervisor or construction project lead and it is their responsibility to ensure that this is provided to the contractor along with all other works documentation. With non-priority works undertaken by RBH s in house teams the survey is supplied as a PDF to the team manager/supervisor once they have identified that the proposed works may fall within the remit of the regulations. Minor works such as replacing a kitchen door, replacing a window panel, fixing a plug socket would not fall within the remit of this policy. As part of the Responsive Repairs Team, Where a survey is not available an inspection will be arranged so that a survey can be produced. It is crucial, therefore, that as much notice as possible is given in relation to planned works. For Responsive Repairs, this is covered as either non priority or emergency. With non priority they need to obtain a survey if relevant. With emergency they need to get a survey or request Asbestos to attend if not available. In both cases the Senior Technical Officer Asbestos will undertake spot checks to ensure the documentation is on site and that the regulations are being adhered to. Breaches will be recorded and reported to Board, Audit Committee and EMT. With emergency works which fall within the scope of this policy, where a survey is not available, the Asbestos Team will attend the property as a priority to undertake an on site assessment and agree a safe system of work. This is requested by the supervisor managing the works. If in doubt as to the composition of any materials uncovered during building works or maintenance operations, the Asbestos Team must be informed immediately and samples will be taken by RBH asbestos surveyors and submitted for analysis prior to commencement of work. An example of the lead in time required for more large scale works is included at appendix Remedial Options 3.1 Following any new or updated survey, a list of high, medium and low risk priority areas will be compiled and maintained. The high priority list will include all areas that are identified as requiring immediate attention and properties will either be locked off or 19

20 access restricted until remedial action has been undertaken. The asbestos team will advise on expected timescale for this. The high priority list will be further prioritised, in order to determine which areas will be dealt with first. If a high risk area has been found within a project where asbestos needs to be removed in order for the project to proceed, the Asbestos Team will endeavour to co-ordinate any works with the construction related project lead where possible. The Asbestos Team will advise on the timescale and if the timescale within the project permits and other higher priority areas are not compromised as a consequence. 3.2 Medium and low priority works will generally be carried out after all high priority areas have been deemed fit for re-occupation. If a medium or low risk area has been found within a project where the asbestos needs to be removed to facilitate the project, it is likely that these will need to be incorporated within the project budget. High Risk Medium Risk Low Risk No Risk High risk material in poor condition: Restrict access and remove as soon as practicable Medium risk material possibly damaged or in poor condition: Remove/encapsulate/repair and seal damaged areas within 6 months, then monitor condition periodically. Remove prior to maintenance or planned works. Low risk material: encapsulate/repair and seal any damaged areas within 6 months then monitor condition annually within non domestic (communal) areas. Remove prior to maintenance or planned works. Very Low risk material: monitor condition periodically. Remove prior to maintenance or planned works No Asbestos detected No Action 3.3 Prior to any work being undertaken, the Asbestos Team will be consulted. Remedial options will vary according to the risk assessment of the ACM. Some low risk ACM s may be removed together with ACM s with a high risk rating. This has long term cost benefits. The remedial options to choose from are: Remove Encapsulation Seal 20

21 3.4 If an ACM is damaged or asbestos debris or residues have been found, asbestos removal is the first option. Similarly if asbestos is identified and it is likely to be disturbed during maintenance works, removal may also be the best option. 3.5 If, due to the circumstances and nature of the room, an ACM cannot be removed immediately, it may be temporarily enclosed or encapsulated. However a date for removal must also be confirmed if damaged or likely to hinder works. If an area is contaminated with Asbestos dust or debris the area will require an Environmental Clean. Asbestos identified in a refurbishment or demolition survey for a project must be removed if the area is due to undergo refurbishment or if a building is to be demolished. 3.6 In line with the Control of Asbestos Regulations 2012, Asbestos removal or remedial works carried out by the Asbestos Team will be done via RBH s approved asbestos removal contractor. Where works are undertaken by a contractor as part of a larger body of work the contractor must appoint their own competent person to over see this work. The Asset Management& Development & Regeneration Teams will be responsible for oversight of such works and ensuring that all works are compliant. Any concerns can be raised through the Senior Technical Officer Asbestos who will remain RBH s competent person and who will retain the authority to suspend any works which fall below the standards we expect. Where such works are undertaken as part of the investment programme (Appendix 6) it is Asset Management Team responsibility to send details of any removals to the Asbestos inbox asbestos@rbh.org.uk - so that the register can be duly updated. 3.7 The Asbestos Team will specify which tier of work the removal falls into: 1. Non-Licensed Work Only includes materials which are non-friable where the work does not cause damage to a non-degraded material. 2. Notifiable Non-Licensed Work Non-licensed work, where there is a risk of fibre release will be subject to additional requirements. This involves notification to the relevant enforcing authority, medical examinations on employees and keeping registers of work with asbestos. 3. Licensed Asbestos Removal - The removal of licensed asbestos can only be undertaken by a contractor licensed by the Health & Safety Executive (HSE) and involves a 14 day notification period which is set by the HSE. 3.8 Notification can only be made by the licensed contractor and will include full details of the work involved and the period of the intended work. The 14-day HSE notification period starts from the receipt of documentation. ALL WORK WITH ASBESTOS REMOVALs REQUIRES: A risk assessment Control of exposure (other than the use of PPE) A plan of work Training 3.9 All contractors will be compliant with the Approved Code of Practice (L143). The Senior Technical Officer Asbestos will carry out audits to ensure compliance with all regulations, and in particular with regulations 6 and 7 which relate to the carrying out of 21

22 risk assessments to identify the risks of exposure to asbestos and subsequently the written plans of work on asbestos Asbestos Waste Asbestos containing waste is classed as special waste and must be disposed of at a licensed waste disposal site. The disposal will be organised by the licensed removal contractors HSE Policy on waivers It is HSE policy that waiver requests will be granted only when there is a genuine emergency. 2 examples are:- Cases where there is imminent risk to health, the environment, or where there is public harm and the risk cannot be avoided simply by leaving the area and allowing it to remain undisturbed, and/or the area cannot be sealed. Cases where there is or is liable worry or hardship for domestic clients, including old and infirm persons. Encapsulate 3.12 Encapsulation will take place where the asbestos is in a good condition and repair: 3.13 An ACM may only be slightly damaged for repair work to be carried out, for example, encapsulating the edge of an asbestos board. Leaving Asbestos in situ 3.14 Occasionally the decision may be taken to leave Asbestos in situ if it is deemed impracticable to remove it. This decision must be agreed with the Asbestos Team first. If there are on going works at the location it must be clearly stipulated to all involved with the construction related programme of works which asbestos items are to remain in situ prior to any works commencing. These should be clearly labelled on plans and disseminated to everyone involved with the project, in particular the operatives The construction related project lead, or manager or supervisor in relation to day to day works, must stipulate what measures will be put in place to protect the asbestos material during the works. The project lead, manager or supervisor must have routine air tests carried out whilst the work is being carried out. The project lead, manager or supervisor must make sure that everybody involved with the works is aware of the emergency procedures at appendix 3, should any asbestos items be accidentally disturbed. 4. Discovery of Suspect Asbestos Materials 4.1 If suspect asbestos materials are found in poor condition or damaged during works, at any time and for any reason, the following must be adhered to: All works must cease The Asbestos Team must be contacted immediately (either directly or through a Line Manager). 22

23 Access to this area will be prohibited to all except members of the Asbestos Team, Asbestos Remedial Contractors and Asbestos Analytical Contractors. A list must be compiled of all those involved with the incident. All equipment and site tools must be left where they are. No attempt should be made to re-enter the area to retrieve any items. 4.2 Similarly if asbestos debris or residues is found to be present during the course of an inspection the area will be locked off by the Asbestos Team with a No Access notice fixed. The asbestos contamination will then be scheduled for immediate removal. The same restrictions as above will then apply. 4.3 If upon analysis the Senior Technical Officer Asbestos believes the material to contain Asbestos, a remedial plan put in place by the Asbestos Team. If the material needs to be sent for analysis to ascertain if it contains asbestos, the area will remain sealed off until the results are available. 4.4 Air testing will be carried out as soon as possible by an Asbestos Consultant as this is a crucial method for establishing when a location is safe. 4.5 The area will only be fit for reoccupation when a clearance certificate has been issued by the Asbestos Analytical Contractor. A clearance certificate will only be provided once air test results are received indicating recordings of <0.01fml. 4.6 An investigation into the incident will then be carried out by the Senior Technical Officer (Asbestos). Asbestos Audits 4.7 Asbestos audits are carried by the Asbestos Team on all Asbestos Remedial works. This is to ensure that the contractors are working safely and within the guidelines of the Control of Asbestos Regulations A copy of the Audit will be sent to the Project Manager or person procuring the work as well as the Asbestos Contractor. If there are any discrepancies found whilst the audit is being carried out they will be rectified immediately by the contractor and these will be reported on the audit. If the discrepancy is deemed to be serious, all works will cease and the Senior Technical Officer Asbestos will be informed. 4.8 All Asbestos Works will be assessed on the following: Adequate Method statement / Plan of Works / Risk Assessments Permits to Work Electrical Inspections / Isolations Asbestos Licence Insurance Certificate Face fit, medical and training certificates First aid representative Decontamination Unit hygiene, locks, seals and clearance certificate Equipment testing certificates, pat tests Enclosure integrity, housekeeping, vision panels, signage, polythene gauge 23

24 Airlock / Bag lock warning signs, negative pressure, weighted flaps, washing facility, integrity, vacuum, housekeeping, correct dimensions Skip warning signs, locks Transit routes tidy, signed, logical Parking use of vans, ensuring cars are not used, no parking on grass 5. MONITORING AND REVIEW OF MANAGMENT PLAN Scope To set out a procedure for the monitoring and review of the asbestos management plan in order that RBH are in compliance with CAR Responsibilities It is the responsibility of the Contracts Manager and Senior Technical Officer Asbestos to review the asbestos management plan on an annual basis in order to identify whether the plan is working. Overview In order for the asbestos management plan to work effectively it will require regular review. This will include a regular re-inspection programme of identified ACM s, not specifically confined to reassessment of ACM s following removal/remediation works. The asbestos team shall monitor and review arrangements for asbestos management during visits in the course of their work. This is crucial, as any major change in the condition of an ACM, which is only identified during a scheduled re-inspection shows that the management plan is failing in some way and appropriate action, will need to be taken to ensure that this situation is not repeated. Review As well as ongoing reviews of the plan, it is also subject to at least an annual formal review to be conducted by the Senior Technical Officer Asbestos. This formal review will seek to discover if the asbestos management plan is included in general safe systems of work and whether this information is being communicated externally, so contractors make allowances for the possible presence of ACM s in their works. It is also important to discover if emergency procedures within properties make reference to the asbestos management plan and whether the emergency services are aware of the presence of ACM s properties loft spaces (Independent & supported housing living/temporary accommodation). The formal review will also address how effective the Asbestos Management Plan is in: Preventing exposure; Controlling maintenance workers/contractors; Highlight the need for action to repair/remove ACM s; Raising awareness among employees, tenants and others. 24

25 This review can only be successful if all employees are providing information, i.e. reporting damage etc. that allows the points above to be addressed. RBH personnel / sub-contractors shall be aware that the giving up of any information regarding their personal experiences of ACM s is extremely useful to developing the asbestos management plan. Where the asbestos management plan has been shown to fail, Senior Technical Officer Asbestos shall carry out a thorough investigation. Information which is vital to assess these situations would include: Where procedures have not been followed and reasons why not; Where procedures have been inadequate and reasons why; Where exposure to airborne asbestos fibres has occurred and reasons why and how. 25

26 Appendix 5 Asbestos Removal Contractors RBH appointed asbestos removal contractors are to undertake remedial work or removal of ACM s shall hold the following: HSE asbestos removal license. Full membership of an appropriate asbestos removal association such as ARCA. Hold public liability and Employers liability Insurance details. Waste carriers license. Use of licensed transfer stations. Use of directly employed operatives no sub contracted personnel. Training records and qualifications for all staff involved in the contract. Supply references from similar organisations for whom they have carried out work. Sample method statements for the completion of similar work. 26

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