Asbestos Policy. 1.0 Introduction What is Asbestos? 2.0 Where can asbestos be found?

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1 Asbestos Policy ` 1.0 Introduction What is Asbestos? 1.1 Asbestos is a term used for a number of naturally occurring minerals which are made up of small crystallised fibres. There are six regulated types of asbestos, but the three main types in use in the UK are: Crocidolite (blue); Amosite (brown); and Chrysotile (white). 1.2 Asbestos Containing Materials (ACMs) were widely used in the construction industry throughout the 20 th century due to their high tensile strength and chemical, electrical and heat resistance. The peak of Asbestos import and use was between 1955 and 1980 (approximately 45% of SNH s stock was built during this period) and many homes across the UK in both the private and social housing sectors contain asbestos. 1.3 Although asbestos is a hazardous material, it is only dangerous if the fibres become airborne and are then inhaled. ACMs will only release fibres into the air if disturbed and it is important to note that when in good condition, ACMs are not considered an immediate risk to health. Asbestos should therefore always be handled carefully and treated with the utmost caution. 1.4 Asbestos related diseases are currently responsible for up to 3,000 deaths a year in the UK and kill more people than any other single work related illness. Research conducted in the mid 1990s showed that the largest group of workers with Asbestos related diseases were those who worked in the construction and building maintenance industry; in particular carpenters electricians and cable layers. Nevertheless, anyone who disturbs asbestos that has deteriorated or been damaged and is releasing fibres can be at risk. 2.0 Where can asbestos be found? 2.1 SNH s knows that some of its stock contains Asbestos. A Type 2 survey of 100% of the stock (visual inspection and sampling based assessment) was undertaken by RPS between 1999 and Over this period South Northants Council (as the association was then) embarked upon a major programme of asbestos removal and disposal. However, a small amount of asbestos was left to be managed in situ and information on the location and condition of known asbestos (in addition to what has been removed) has been maintained by SNH on an access database. This is made available to all contractors (both internal and external) prior to any work being undertaken. It has also been provided to the tenants, so that they are aware of any asbestos within their homes. 1

2 2.2 It is possible that further unidentified asbestos remains in some of the stock. Thus, where in doubt, SNH staff should always assume that a material contains asbestos. SNH staff are most likely to find asbestos in the following materials: Sprayed asbestos and loose packing in fire breaks to ceiling voids; Lagging for thermal insulation of pipes and boilers; Sprayed asbestos used as fire protection in ducts, fire breaks, panels, partitions and asbestos cement sheets around structural steel work; Insulating boards used for fire protection; thermal insulation, partitioning and ducts and as soffits, ceiling or wall panels; Ceiling tiles; Millboard, paper and paper products used for insulation of electrical equipment. Asbestos paper can also be used as a fire proof facing on wood fibre board; Asbestos cement products such as corrugated sheeting used as roofing and wall cladding, gutters, rainwater pipes and water tanks. Textured coatings (such as artex); Bitumen roofing felt; and Vinyl or thermoplastic floor tiles. 2.3 Due to the specialist knowledge required for the effective identification, assessment and management of asbestos, detailed procedures are required from organisations such as SNH. Failure to comply with the Health and Safety legislation on reporting, handling or working with asbestos can result in both heavy fines and imprisonment. 3.0 Legal Duty 3.1 The Control of Asbestos Regulations 2012 (regulation 4) does not normally apply to domestic premises (instead focussing on non-domestic areas such as the common parts of flat blocks or office buildings etc.), however, the Health and Safety at Work Act 1974, sections 2, 3 and 4 places a legal duty on SNH to ensure that any employees or visitors to a work place (which includes domestic premises such as social housing) are not subject to health and safety risks. SNH is therefore required to provide information about the work place that might affect health and safety to anyone conducting work on the premises. In addition, the Health and Safety at Work Regulations 1999 require employers to assess the health and safety risks to any third parties, such as tenants, who may be affected by their activities and to make appropriate arrangements to protect them. 3.2 To comply with these requirements SNH will undertake the following: Review the assessment of any ACMs present in their premises, along with their precise location and condition; Undertake a programme of demolition/refurbishment asbestos surveys prior to any major works being undertaken to further enhance the data held by the association; Continue to maintain and update it s records of the location and condition of all identified and presumed asbestos and ensure it is kept up to date; Presume materials can contain asbestos unless there is strong evidence they do not; Assess the risk posed by the materials; 2

3 Prepare and implement a plan that sets out in detail how the risks will be managed; Set up a system for providing information on the location and condition of asbestos to anyone likely to work on or disturb it; and Regularly review and monitor the arrangements used for managing the risk. 3.3 The Duty to Manage is central to SNH s obligations. The Control of Asbestos Regulations 2012 (CAR 2012) assigns these obligations to the role of a Duty Holder, who is: Every person who has, by virtue of a contract or tenancy, an obligation of any extent in relation to the maintenance or repair of non domestic premises or any means of access thereto or egress there from; or In relation to any part of non-domestic premises where there is no such contract or tenancy, every person who has, to any extent, control of that part of the nondomestic premises or any means of access thereto or egress there from. 3.4 For SNH, the Managing Director together with the Assistant Directors will act collectively as the nominated Duty Holder. The Duty to Manage remains under regulation 4 of The Control of Asbestos Regulations 2012, as long as the Association has maintenance responsibilities for the relevant premises. 3.5 Those persons nominated to discharge the responsibilities of the Duty Holder whilst not themselves named as the duty holder have legal obligations under the Health and Safety at Work Etc Act 1974 and the Control of Asbestos Regulations 2012 in particular. 4.0 Asbestos Policy Statement 4.1 SNH, in recognition of its duties under the Health and Safety at Work Act 1974 towards its tenants, employees, visitors, contractors, customers and members of the public, undertakes to protect all persons on its premises from asbestos exposure by ensuring safe premises and systems of work, so far as is reasonably practicable. The Association will operate in accordance with all current legislation and approved codes of practice. 4.2 Specifically, SNH will: Set up and maintain a new electronic register of the location and condition of all ACMs (Asbestos Containing Materials) found in SNH s buildings, whether owned, leased or managed. This register will be held on the SNH s IBS database, with the full survey details held on SNH s new AMS database; Set up clearly defined responsibilities for asbestos management and ensure all relevant staff are trained to an appropriate level and given sufficient resources to carry out their duties diligently; Ensure all other employees, voluntary workers and contractors attend regular courses in Asbestos Awareness; Complete suitable and sufficient Asbestos Risk Assessments on all non-domestic properties and communal areas as required under Regulation 4 of the Control of Asbestos Regulations 2012; 3

4 Complete suitable risk assessments prior to any works being carried out, (including works on tenanted properties which are not subject to Regulation 4 of the Control of Asbestos Regulations 2006); Presume materials contain asbestos unless there is strong evidence to suppose otherwise; Re-inspect positive findings in non-domestic premises on a regular basis. The frequency of re-inspections to be determined by the location, condition, and type of asbestos present; Provide information about the presence, location and condition of ACM to all those who are likely or liable to disturb it including employees, tenants and contractors and ensure it is being used appropriately; Prioritise asbestos removal and treatment works in accordance with an asbestos risk classification scheme that will form part of the procedure documents for asbestos management; and Ensure all works to asbestos are carried out in accordance with the Control of Asbestos Regulations 2012 by competent contractors. Works undertaken requiring a license to be undertaken by accredited contractors. 5.0 Policy Objectives 5.1 To ensure the Association fulfils its legal requirements with regards to asbestos. 5.2 To protect tenants, employees, visitors, customers, contractors and members of the public through managing all known installed asbestos based products responsibly and in accordance with regulations. 6.0 Organisation structure 6.1 Assistant Director (Property Services) The Assistant Director (Property Services) has overall responsibility for Asbestos Management for the association, in respect of the technical and physical aspects of asbestos management and for the preparation, maintenance and publication of the necessary records and registers. 6.2 Major Works Manager / Responsive Repairs Manager The Assistant Director (Property Services) has nominated the Major Works and Responsive Repairs Managers to assist in discharging their duties as the Duty Holder under Regulation 4 of the Control of Asbestos Regulations The Major Works and Responsive Repairs Managers will assist the Assistant Director (Property Services) as directed, and deputise when the Assistant Director (Property Services) is absent. The Major Works and Responsive Repairs Managers have responsibility to ensure compliance with this plan and ensure that best current practice is followed at all times. 4

5 6.3 Project Surveyors The Assistant Director (Property Services) has nominated the Project Surveyors to assist in discharging their duties under Regulation 4 of the Control of Asbestos Regulations 2012, on a day to day basis, at an operational level. Specifically, the Project Surveyors will carry out the following tasks on behalf of the Assistant Director (Property Services): Implement measures to ensure that the competency of external consultants and contractors is assessed prior to engaging their services; Commission suitable asbestos surveys appropriate to the requirement for the information (e.g. works/management) and subsequent risk reviews. Issue to all staff as required; Support the development of and update and maintain an appropriate asbestos survey database/risk register. Issue to all staff and contractors as appropriate; Implement and monitor remedial works as identified by the asbestos risk assessments and any subsequent technical investigations; Ensure that information about asbestos risks & the management plan are made readily available to employees, visitors and contractors; and Implement a system so that all consultations of the asbestos register in IBS and AMS database are recorded in an auditable fashion. 6.4 Responsive Repairs Manager: Responsibilities The Responsive Repairs Manager will ensure that all repairs are carried out in compliance with these procedures, and specifically: Ensure that no repair is carried out on the association s stock (domestic and nondomestic) without prior consultation of the association s IBS/AMS system for the appropriate asbestos survey; Commission a Refurbishment/Demolition asbestos survey for refurbishment work where insufficient data is held on the association s database; Ensure all repair and maintenance personnel and contractors are competent and have received the appropriate asbestos awareness training; and Ensure all relevant risk assessment and remedial action information is passed to the Business Systems Team for updating to the IBS database. 6.5 Responsive Repairs Supervisor for Minor Void Works: Responsibilities Void properties requiring minor works are under the direct control of the Responsive Repairs Supervisor, who is to ensure compliance with this management plan and ensure that current best practice is followed at all times. Specifically: Ensure that prior to all repairs, adaptations and refurbishments; the appropriate asbestos survey located on the IBS system is consulted; Commission a Refurbishment/Demolition asbestos survey for refurbishment work where insufficient data is held on the association s database; and Ensure all relevant risk assessment and remedial action information is passed to the Business Systems Team for updating to the IBS database. 5

6 6.6 Major Works Manager: Responsibilities The Major Works Manager is to ensure that all works are carried out in compliance with these procedures, and specifically: Ensure that all programmed works are not undertaken without prior consultation of the association s IBS system for the appropriate asbestos survey; Commission a Refurbishment/Demolition asbestos survey for refurbishment work where insufficient data is held on the association s database; Ensure all staff and contractors are competent and have received the appropriate asbestos awareness training; and Ensure all relevant risk assessment and remedial action information is passed to the Business Systems Team for updating to the IBS database. 6.7 General Contractors and Partnering Contractors: Responsibilities All contractors working for the Association must comply with the arrangements and procedures specified in this Asbestos Policy Specifically, contractors must: Ensure that the appropriate risk assessment information (Demolition/Refurb survey) exists prior to attending site, either from the IBS system, or commissioned by an asbestos consultant, specific to the task. Ensure that all employees retrieve information only from the association s asbestos register and that this is done in an auditable fashion. Once on site, stop work if there is any suspicion that asbestos may be present, secure and isolate the area and inform the Association and any other relevant parties; Ensure all employees have the appropriate asbestos awareness training and keep records of such training; and Ensure all relevant risk assessment and remedial action information is passed to the Business Systems Team for updating to the IBS database. 7.0 Risk assessment protocol 7.1 Asbestos Surveys HSG 264 stipulates 2 types of surveys available to SNH; Management Surveys and Demolition/Refurbishment Surveys. A Management Survey is the standard survey and will be required during the normal occupation and use of the building. A Demolition/Refurbishment Survey is appropriate when the building (or part of it) is to be upgraded, refurbished or demolished. Cloned data may be used where there is high confidence demonstrated through extensive surveying across similar property types Between 1999 and 2004 SNC commissioned RPS Health, Safety and Environment Consultants to undertake a programme of comprehensive Type 2 Asbestos surveys on the association s stock. Much of the data collected in these surveys is relevant to the 6

7 new Management Surveys and this is to be loaded on to the IBS database in anticipation of further survey work Where an asbestos survey does not exist, in line with Regulation 4 of the Control of Asbestos Regulation 2012, it is SNH s policy that all items are to be presumed to contain asbestos unless there is strong evidence to prove otherwise Where insufficient risk assessment information is in existence, an HSG 264 compliant Management or Demolition/Refurbishment survey will be commissioned by SNH, according to the requirements of the duty to manage or the major works and repairs programmes In line with the recommendations of HSG 264, SNH will conduct Demolition/Refurbishment surveys on a representative proportion of the properties in the major works programme; until the results demonstrate as far as is reasonably practicable that there is consistency in the range of ACMs in each property type and there is an accurate picture of asbestos presence. This information will be used to conduct an asbestos removal programme (where appropriate) in anticipation of repairs and refurbishment All asbestos survey and risk assessment information will be added to the IBS system. 7.2 Asbestos Register The Project Surveyors are to ensure that the findings of the asbestos surveys are passed to the Group Business Systems Team for update to the IBS Asbestos Register, allowing for independent scrutiny of the data. Similarly, the register will be updated following asbestos removal/remedial work. The relevant module in IBS will be made available to staff and contractors as required. All employees and contractors are to be informed of the location and presence of the IBS Asbestos Register and how to access the information held in it. All relevant drawings and plans marked with ACM locations will be made available through the IBS database. Contractors will be provided with a secure external login for accessing the data. It is a requirement for all contractors to assess and plan their work with reference to the information held on the database. 7.3 Inspection of Asbestos Containing Materials To comply with Regulation 4 of the Control of Asbestos Regulations, the Association will employ a competent person or organisation to re-inspect the known asbestos locations within non-domestic properties on a frequency dictated by the potential for damage, as dictated by the risk assessment, with all re-inspections to take place at least annually. The re-inspection programme will include all asbestos containing materials left in situ. The risk register and recommendations will be updated accordingly. The re-inspection results are an important mechanism by which programs of abatement work are initiated in response to unacceptable deterioration Re-inspection of ACMs within the SNH s domestic premises is not covered by the Duty to Manage. Nevertheless, SNH s aspiration is to maintain a working knowledge of the condition of known ACMs within its domestic stock, though this will be balanced with 7

8 the Tenants right to peaceful enjoyment of their homes. SNH will therefore monitor the condition of known ACMs through feedback from: Tenants; Association Staff; and Contractors Tenants will be educated as to the likely risks from Asbestos through an awareness campaign and provided information regarding the location of known ACMs within their dwelling. Tenants will be encouraged to feed back concerns over the condition of their ACMs to SNH s customer services team SNH Staff and Contractors will be given rolling training on Asbestos Awareness courses and encouraged to review the condition of known ACMs at domestic premises during repairs, planned works and routine visits. 7.4 Risk assessment protocol for the removal of asbestos Specialist contractors undertaking remedial asbestos works must provide a copy of their license. Contractors must also provide a written method statement in response to risk assessment findings detailing: The type of material, location and asbestos content; How the asbestos will be removed including stripping method; The air handling unit to be used; Formation of enclosure; Protective clothing; Decontamination method; Hygiene facilities; Air monitoring; and Waste disposal Where necessary the licensed contractor must provide evidence that the relevant enforcing agent was notified of the intended works 14 days before the intended start date. 8.0 Maintenance of records 8.1 The IBS database will hold all records of asbestos survey and risk assessment information and will be managed by the Business Systems Team. 8.2 The information retained on this database shall be made accessible to all employees and contractors via their Citrix systems/ibs login, for which passwords have been provided. Asbestos information available to general staff and contractors will be read only to prevent unauthorised amendment of the data. The IBS and AMS databases shall hold records of all surveys carried out (whether old Type 2, Management or Demolition/Refurbishment), annual inspection data, and records of all asbestos remedial works. 8

9 8.3 The Major Works Manager and Responsive Repairs Manager are to keep the following records: A register of all asbestos surveys of premises; Copies of advice given to any staff and contractors; Copies of any advice received from specialist consultant or advisors; Details of all work on ACMs carried out in all premises; and Copies of all incident reports. 8.4 Records of the following are to be kept on the IBS Asbestos Module: Access and review by contractors; Amendments to the Asbestos Register; and Details of inspections of asbestos containing materials. 8.5 Records of the following information shall be kept by the Asbestos Coordinator: All method statements for work on asbestos containing materials; All risk assessments for work on asbestos containing materials; All notifications to the enforcement agency; All air monitoring reports; and All special waste disposal certificates. 8.6 The Association will retain all such documents for a period of not less than 30 years at their central offices. Subsequent to this, all such records will be archived. 9.0 Training 9.1 SNH will ensure that its employees have the training, knowledge, experience and ability to carry out their work without risking harm to themselves or others from Asbestos. SNH will appoint a training provider that is competent and aware of the tasks that are likely to be carried out by its employees. 9.2 The following will attend Asbestos Awareness training and receive refresher training at not greater than 18 monthly intervals: Managing Director Assistant Director - Property Services Assistant Director - Housing Services Major Works Manager Responsive Repairs Manager Project Surveyors Responsive Repairs Supervisors Customer Services Team Works Planners Major Works Team All Maintenance Operatives Housing Officers 9

10 Scheme Managers All contractors employed to undertake works on Association premises. 9.3 The following will be instructed how to retrieve Asbestos information from the Association s IBS database. Refresher training will be conducted as required. Assistant Director - Property Services Major Works Manager Responsive Repairs Manager Project Surveyors Responsive Repairs Supervisors Customer Services Team Works Planners Major Works Team Housing Officers All Maintenance Operatives All contractors employed to undertake works on Association premises. 9.4 Training in Non-Licensed Work will be provided to: Assistant Director - Property Services Major Works Manager Responsive Repairs Manager Project Surveyors Responsive Repairs Supervisors Works Planners All Maintenance Operatives 9.5 P405 (Asbestos Management Surveyor) training will be provided to: Major Works Manager Responsive Repairs Manager Project Surveyors 9.6 Refresher training Refresher training will not be a repeat of the initial training. It will be given to relevant employees as detailed above and will be appropriate to the work undertaken. SNH will ensure it is tailored to meet the training needs of the group, taking into account their experience, skills, knowledge, frequency of the work and their individual performance. Refresher training will focus on good practice. It may be required more frequently if: Work methods change; The type of equipment used to control exposure changes; or The type of work being carried out changes significantly All refresher training intervals will be superseded in the event of changes to the legislation and recommended working practices. 10

11 10.0 Approved Contractors and Consultants 10.1 Competency In accordance with HSG 227, HSG 264 and CAR 2012, SNH will require all consultants and contractors engaged to work in any capacity with Asbestos to be: Adequately trained and have relevant experience; Able to demonstrate independence, impartiality and integrity; Have an adequate quality management system; and Carry out their duties in accordance with the regulations and guidance relevant to their field of work SNH will ensure that any contractor or consultant engaged meets these criteria prior to the commencement of any work and may consult the HSE Prosecutions and Notices databases to search for records of conviction, prohibition and improvement notices Any or all of the following may be included when vetting a contractor or consultant: Audit of company health and safety records Audit of staff training References Insurances Health and Safety policy The performance of the approved contractors in relation to their management of asbestos remedial / consultancy works will be monitored as necessary All contractors engaged by SNH shall adhere to these procedures Licensed Asbestos Removal All licensed Asbestos Removal works will be undertaken in compliance with the Control of Asbestos Regulations 2012 and HSG 247: Asbestos The Licensed Contractor s Guide Only Contractors holding a license granted by the Health and Safety Executive (HSE) shall work on or with sprayed asbestos coating, asbestos thermal insulation and asbestos insulating board (AIB) All asbestos removal works in occupied or tenanted properties, regardless of whether the exemptions under Regulation 3(2) of the Control of Asbestos Regulation 2012 apply or not shall be carried out by an approved licensed contractor Non-licensed Asbestos Removal All Non-licensed asbestos removal works will be undertaken in compliance with the Control of Asbestos Regulations

12 Asbestos removal works on asbestos materials normally not requiring a license as defined by the exemptions in Regulation 3(2) of the Control of Asbestos Regulation 2012 can be carried out by the in-house repairs team or other general contractors, in void properties only To remove ACMs not requiring a license, the in-house repairs team/general contractor will: Undertake work in compliance with the Control of Asbestos Regulations 2012; Provide a Risk Assessment in accordance with Regulation 6 of the Control of Asbestos Regulations 2012 (the assessment is to demonstrate consideration of the scope of proposed works. The extent of the potential risks should be established to facilitate the identification of the appropriate legal provisions (including whether the work is licensable). This will determine the most appropriate work methods to comply with the legal duties. More importantly this will ensure that the health of both employees and potential visitors to the site is not put at risk); Provide a Plan of Work in accordance with Regulation 7 of the Control of Asbestos Regulations 2012 Which should always be job specific and should include: I. The nature and probable duration of the work; II. The location of where the work is to be carried out; III. The methods to be applied where the work involves the handling of asbestos; IV. The equipment to be used; V. The protection and decontamination of those carrying out the work; VI. The protection of others on or near the worksite; and VII. The measures intended to be taken in order to comply with the requirements of the regulations. Ensure that the person who prepares both the risk assessment and the plan of work has adequate knowledge, training and expertise and is familiar with the requirements of the relevant regulations and approved code of practice; Provide a statement detailing the reasons why the work with asbestos will fulfil the conditions for regulation 3(2) (work not requiring a licence); and Have appropriate training for non-licensable asbestos work All in-house repairs operatives carrying out non-licensable asbestos work must have been trained to carry out the work in accordance with Regulation 10 of the Control of Asbestos Regulations The training is to be undertaken at regular intervals, at least annually All general contractors carrying out non-licensable asbestos work must provide a written health and safety policy document detailing training records for each individual. This should be reviewed regularly, particularly when work methods change Asbestos Consultants SNH will only delegate the tasks of inspection, sampling and analysis to organisations that can demonstrate compliance with international standards by accreditation by a 12

13 recognised body, e.g. UKAS ISO for inspection and UKAS ISO for testing All air monitoring carried out by an asbestos consultant must be in accordance with HSG 248 The analysts guide for sampling, analysis and clearance procedures and Control of Asbestos Regulations Asbestos consultants will technically supervise all asbestos removal works where instructed to do so. This supervision will be in accordance with The General Specification for Asbestos Removal and Remedial Works, the relevant legislation, HSE guidance and the Asbestos Policy On completion of all asbestos works or when requested, the asbestos consultant must provide certification detailing the works undertaken, all air monitoring results and clearance certification confirming the suitability of an area for re-occupation. For larger projects a Completion File with the relevant and associated information will be compiled. This information is to be passed to the Project Surveyors/Business Systems Team for upload to the IBS database Distribution of this document 11.1 An electronic copy will be made available on the association s internet and intranet. Copies of the document will also be circulated to the following: Directors Responsible persons Deputy Responsible persons Premises log book holders Scheme coordinators 11.2 It is the responsibility of the Responsible person and the Deputy Responsible person to circulate the policy document and to maintain and update the circulation list. OTHER RELATED POLICIES Asset Management Strategy Disabled Facilities Policy Equality & Diversity Strategy Planned Maintenance & Improvement Policy Responsive Repairs & Cyclical Maintenance Policy Risk Management Policy RELATED PROCEDURES Asbestos Procedures MONITORING AND REVIEW By Board through the annual policy review programme RESPONSIBILITY FOR IMPLEMENTATION 13

14 The responsibility for implementation lies with the Assistant Director, Property Services Customer Consultation: RIF November 2011 Equality Impact Assessment: Person responsible for review: Initial Screen Assistant Director, Property Services Date of review: February

15 ASBESTOS ACTION PLAN Recommendation Priority Comments Implementation Date Person(s) Responsible Implement a programme of Demolition / Refurbishment Surveys for all properties remaining to be visited on the Major Works Programmes for Internal Modernisations and High Level Works (Phase 1) and all communal areas. High Complete. Mark Griffiths / Edward Anton Implement a programme of Demolition / Refurbishment Surveys for all properties to be visited on the Major Works Programme (Phase 2) (As above, but to include the External programme where appropriate). Medium Complete. Mark Griffiths / Edward Anton Implement a programme of Management Surveys for all communal areas where asbestos containing materials are managed in situ. Medium Complete. Mark Griffiths / Edward Anton 15

16 Implement a procedure for the procurement of Demolition / Refurbishment Surveys for Void / Disabled Facilities Works. High Complete. Edward Anton / Gary McNeil / Adrian Hampshire / Fiona Dorman Appoint asbestos removal contractor (for licensed works). Medium Complete Mark Griffiths / Gary McNeil Transfer data from Asbestos Access Database to IBS HMIS. High Complete Edward Anton / Andy Garnham / Jackie Crowder Prepare and Implement a Risk Management Plan for all known ACMs within SNH s stock. High April 2014 Doug Grace / Review and update all asbestos data provided to tenants, ensuring that all tenants are given sufficient data on the location and current condition of any ACMs within their homes. Medium Due to commence June Rolling programme (to work in tandem with updated surveys) To be nominated. 16

17 Review Partner Contractor compliance with updated Asbestos Policy and ensure training records are up to date. High Initial assessment complete, monitoring ongoing. Complete/ongoing. Mark Griffiths / Dean Babbington / Bradley Swingler / Steve Jones / Gary McNeil / John O Neill / Edward Anton Arrange updated Asbestos policy training for: Property Services Department Housing Department High June 2014 Gary McNeil / Mark Griffiths Arrange Asbestos Awareness Training for: Managing Director Assistant Directors Major Works Manager Responsive Repairs Manager Responsive Repairs Supervisors Customer Services Team Works Planners Major Works Team Maintenance Operatives Housing Officers Scheme Managers All contractors High Training outstanding for Housing Department staff. Initial Training Complete / new starters and refresher courses to be complete by April Gary McNeil / Mark Griffiths 17

18 undertaking work on association premises. 18

19 Arrange IBS Asbestos Module training for: Assistant Director (PS) Major Works Manager Responsive Repairs Manager Project Surveyors Responsive Repairs Supervisors Customer Services Team Works Planners Major Works Team Housing Officers Maintenance Operatives All contractors employed to undertake work on association premises. High Complete Gary McNeil / Mark Griffiths Arrange Non- Licensed Asbestos Work training for: Assistant Director (PS) Major Works Manager Responsive Repairs Manager Responsive Repairs Supervisors Works Planners Maintenance Operatives High Requirement reviewed and decision taken to restrict to the DLO workforce only. Complete. Mark Griffiths / Gary McNeil 19

20 Arrange P405 Asbestos Management Surveyor training for: Major Works Manager Responsive Repairs Manager Project Surveyor Medium Complete Gary McNeil / Mark Griffiths 20