Property Services Policies & Procedures Asbestos Management Plan

Transcription

1 Property Services Policies & Procedures Asbestos Management Plan Date Approved May 2017 Effective Date 18 May 2017 Review Due April 2018 Version 1.1 Author Andrew Connolly

2 ASBESTOS MANAGEMENT PLAN RESPONSIBLE DIRECTOR: RESPONSIBLE OFFICER: Technical Services Director Head of Maintenance & Asset Management LAST UPDATE: May 2017 NEXT UPDATE: April PURPOSE This Procedure supports the Asbestos Policy. It describes how NCHA will manage asbestos in its properties 2. GLOSSARY ACM = HSE HSG264 HSG210 Asbestos Containing Material Health and safety executive Guide produced by HSE reference asbestos/surveying Asbestos Essentials tells employers, managers and sole-traders what to do when they need to work on or near asbestoscontaining materials CAR Control of asbestos regulations 2012 CDM Construction design and management regulations RISKS The Health and Safety of our residents, their visitors, NCHA staff, its contractors and agents visiting a home with unmanaged ACMs. 4. REFERENCES External THE DEFECTIVE PREMISES ACT 1972 The Defective Premises Act 1972 places duties on NCHA to take reasonable care to see those tenants and other people are safe from personal injury or disease caused by a defect in the state of the premises. THE ENVIRONMENTAL PROTECTION ACT 1990

3 Any premises in such a state as to be prejudicial to health constitute a statutory nuisance under section 79 of the Environmental Protection Act An abatement notice can be served by local authorities on the owner or occupier of premises requiring prevention or restriction of the THE HEALTH AND SAFETY AT WORK ACT 1974 The Health and Safety at Work Act requires NCHA to conduct work in such a way that its employees will not be exposed to health and safety risks, and to provide information to other people about their workplace which might affect their health and safety. Section 3 of the Health and Safety at Work Act imposes general duties on NCHA in respect of people other than its own employees. Section 4 contains general duties for anyone who has control to any extent of a workplace. THE MANAGEMENT OF HEALTH AND SAFETY AT WORK REGULATIONS 1999 The Management of Health and Safety at Work Regulations 1999 requires NCHA to make an assessment of the risks to the health and safety of employees and people not in its employment arising out of or in connection with the conduct of its business and to make appropriate arrangements for protecting those people s health and safety. THE CDM REGULATIONS 2015 The Construction (Design and Management) Regulations 2015 (CDM) require NCHA (Client) to pass on information about the state or condition of any premises (including the presence of hazardous materials such as asbestos) to the planning supervisor before any work begins and to ensure that the health and safety file is available for inspection by any person who needs the information. (Extract :Asbestos removal and CDM 2015: Clients legal responsibilities Magazine Planning and building control today) Construction (Design and Management) Regulations 2015 (CDM 2015) place explicit responsibilities on clients. (NCHA) For a project to be successful good coordination and cooperation between all parties is a must. Clients decisions, actions and inaction have an enormous impact on how work can be delivered. They could cause contractors to fail to meet industry and legal standards, and therefore potentially leaving themselves with substantial criminal and civil liabilities, lengthy delays and disruptions to projects. Clients (NCHA) are not expected to be experts in either construction work or asbestos work and do not need to directly manage or supervise the work themselves. However, they are responsible for ensuring appropriate arrangements are in place to manage and organise projects during both the

4 pre-construction and construction phases of the project. What does this mean when appointing an asbestos contractor? This means clients (NCHA) need to appoint suitably competent people by making reasonable enquiries to satisfy themselves that contractors are appropriately resourced and competent for the work. Clients should also provide contractors with sufficient information, time and resources to do the job properly. For example, an asbestos removal contractor will need appropriate pre-construction information in order to prepare a suitable work plan, and contractors need time (and access) to assess the premises properly and discuss key site information with the client (NCHA) Also for licensed asbestos work, an analyst must be appointed, (it is desirable that the analyst is employed directly by the client) to verify that a work area has been thoroughly cleaned and that airborne fibre in the work area is as low as reasonably practicable, prior to handover for reoccupation or demolition etc. In summary, to comply with the law when appointing an asbestos contractor the Client must: Ensure adequate welfare is in place. This requires cooperation, coordination and communication between all parties. Allow adequate time and space. Clients (NCHA) must allow sufficient time for asbestos surveys to be carried out, for example, an effective refurbishment and demolition survey cannot be carried out in an occupied building. Ensure an adequate plan is in place for the work. For any kind of work with asbestos, clients must ensure there is a written plan of work in place. For very simple un-licensed jobs, the kinds of work methods described in the Asbestos Essentials guide (available on the Health and Safety Executive web site) may suffice. For licensed work a suitable and sufficient plan of work is always required and is a standard condition placed on all licence holders. It must be prepared prior to work being notified to the enforcing agency, at least 14 days prior to work starting. The written plan of work should very clearly describe the scope of work and explain: what is being removed, where it is located and how is it fixed. In addition, it should state how it will be accessed and what removal methods will be used to prevent/control exposure. A good plan should be self-explanatory and able to provide the client with confidence that the project has been thoroughly assessed and resourced. Where generic assessments and method statements are presented in a plan

5 of work, this may raise legitimate questions about the adequacy of the contractors planning process. Ensure that good communication and coordination is maintained throughout the project. The client must confirm that effective arrangements have been made to coordinate the work, for example, asbestos contractors transit and waste routes must not be obstructed. HSE Regulations It could be argued that the new Regulations will struggle to achieve the HSE s stated aim of increased efficiency and reduced costs, bearing in mind the broadening of application CDM 2015 to include minor works simply because they are being undertaken by more than one contractor. Ultimately, asbestos surveys, and the requirement to undertake them has not changed. Intrusive works to any property constructed before the year 2000 should be preceded by a planned, properly scoped and scheduled asbestos Refurbishment Survey. It is categorically the case that the only risk assessment one can possibly undertake in relation to asbestos is to undertake a Refurbishment Survey of a type which will, under controlled conditions, reveal any potential asbestos materials which might be in the vicinity of the area where works are planned. A visual inspection, or reference to a Management Survey, is completely insufficient simply because the Management Survey is not intrusive and has not been undertaken to account for any changes to the building (even of a non-structural nature). Undoubtedly, CDM 2015 will have implications for a large range of individuals and Organisations throughout the UK, however from the perspective of asbestos companies it is very much business as usual; asbestos legislation has not changed. nuisance. Any premises in such a state as to be prejudicial to health constitute a statutory nuisance under section 79 of the Environmental Protection Act An abatement notice can be served by local authorities on the owner or occupier of premises requiring prevention or restriction of the nuisance. THE CONTROL OF ASBESTOS REGULATIONS The Control of Asbestos Regulations 2012 came into force on 6 April 2012, updating previous asbestos regulations to take account of the European Commission's view that the UK had not fully implemented the EU Directive on exposure to asbestos (Directive 2009/148/EC). In practice the changes are fairly limited. They mean that some types of nonlicensed work with asbestos now have additional requirements, i.e. notification of work, medical surveillance and record keeping. All other requirements remain unchanged.

6 HSE ADVISORY NOTE GUIDANCE FOR SOCIAL LANDLORDS ON THE REFURBISHMENT OF HOUSING STOCK LIKELY TO CONTAIN ASBESTOS - 26 MAY This advisory note provides guidance to social landlords including local authorities, housing associations and social housing management companies and sets out how to manage the risks of exposure of workers to asbestos to comply with current legislation. HSG HSE - ASBESTOS - THE SURVEY GUIDE. HSG 227- HSE A COMPREHENSIVE GUIDE TO MANAGING ASBESTOS IN PREMISES HSG 210- ASBESTOS ESSENTIALS The document establishes the levels of compliance that should be achieved by RSL s and it clearly sets out best practice for housing associations and other social housing providers Extract HSG264) Management of asbestos in domestic premises The duty to manage asbestos requirements of regulation 4 of CAR 2012 do not normally apply to domestic premises. However, the requirements do apply to common parts of premises, including housing developments and blocks of Flats, but do not place any direct duties on landlords for individual houses or flats. Examples of common parts would include foyers, corridors, and lifts and lift shafts, staircases, boiler houses, vertical risers, gardens, yards and outhouses. The requirements do not apply to rooms within a private residence which are shared by more than one household, such as bathrooms, kitchens etc. in shared houses and communal dining rooms and lounges in sheltered accommodation. The Health and Safety at Work etc. Act 1974 sections 2, requires all employers to conduct their work so their employees will not be exposed to health and safety risks, and to provide information to other people about their workplace which might affect their health and safety. Section 3 places duties on employers and the self-employed towards people not in their employment and section 4 contains general duties for anyone who has control to any extent, over a workplace. In addition, the Management of Health and Safety at Work Regulations require employers to assess the health and safety risks to third parties, such as tenants who may be affected by their activities, and to make appropriate arrangements to protect them.

7 These requirements mean that organisations such as local authorities, housing associations, social housing management companies and others who own, or are responsible for, domestic properties, have legal duties to ensure the health and safety of their staff, (and others) in domestic premises used as a place of work. As employers, the organisations also have duties under the general requirements of CAR 2012 to identify asbestos, carry out a risk assessment of work liable to expose employees to asbestos and prepare a suitable written plan of work. Internal Asbestos Register Asbestos Policy 5. NCHA ASBESTOS SURVEY PLAN NCHA is required to have a fully populated asbestos register for its entire property portfolio. During 2015 an asbestos cloning programme commenced which will provide NCHA with a fully populated Asbestos Register. In order to produce robust asbestos register sufficient initial surveys will be commissioned to satisfy ourselves that the cloned information is correct. Should cloned data be shown to be inaccurate ( via refurbishment survey or other) additional surveys will be carried out per architype to further satisfy ourselves of the accuracy of the data The cloning programme will be extended into 2016/17 to allow for properties which require surveys and are situated within NCHA S No Access Policy Moving forward with the archetypal data, a removal programme will be identified and items with re-inspection frequencies of less than one year will be addressed with a view to removing the re-inspection requirement. A programme of reviewing presumed asbestos data will also be carried out and further sampling or surveying will be conducted prior to deciding on whether to incorporate these locations within the asbestos removal programme. ASBESTOS REGISTER Asbestos information from the Management Surveys is held within the Capita Housing System These groups of properties will be allocated a colour category via our Asbestos Register, held within Capita, so each property will be easily identified via Capita and on the works order received by our contractors, along with the inspection sheet received by NCHA Technical Officers. The categories will be:

8 The Categories are Green Amber and Red The categories indicate the following and are used as a guide only the Green amber and red categories are not to be given as the results status for a particular property. The asbestos register will always be consulted and that information relayed to the enquirer. ** IT IS NOT TO BE PRESUMED THAT JUST BECAUSE A PROPERTY HAS BEEN ALLOCATED A GREEN STATUS THAT IT IS FREE FROM ASBESTOS Green- Asbestos free (hsg264) Only in the areas sampled Post 2000 built property. Where a completed survey of certain areas has not identified ACM, s (This means that in the areas sampled asbestos was not found, The contractor or tenant must seek further advice if unsure how to proceed) (EXTRACT HSG264) 38 Materials cannot be presumed to be asbestos free (i.e. contain no asbestos) unless there is strong evidence to conclude that they are highly unlikely to contain asbestos. There are obvious materials which are not asbestos, e.g. wood, glass, metal, stone etc. There are also many examples of asbestos being present inside Materials, e.g. a sandwich layer inside doors, inside columns or under column casings, on the hidden side of items, e.g. wood panelling, ceiling tiles, under veneers. Reasons to conclude that a material does not contain asbestos would be: non-asbestos substitute materials were specified in the original Architect s/quantity surveyor s plans or in subsequent refurbishments; the product was very unlikely to contain asbestos or have asbestos added (e.g. Wallpaper, plasterboard etc.); post-1985 construction (for amphibole ACMs such as asbestos insulating board, see Appendix 1); post-1990 construction for decorative textured coatings (formulations containing asbestos were prohibited in 1988 and some suppliers voluntarily Ceased using asbestos in 1984); post-1999 construction (some chrysotile products were prohibited in 1993 and nearly all were prohibited in 1999). 39 It is not always straightforward to conclude that ACMs are absent. The regulations require that reasonable steps are taken. While original specifications may not have included ACMs in certain building locations, workers may have used them for their convenience. For example, work on building systems (e.g. CLASPsystems14 has shown that ACMs, e.g. asbestos insulating board (AIB) offcuts were used as filler/packing and support items in places where their presence was not recorded. There are also many examples of poor removal practice leaving asbestos-containing debris and residues. Therefore areas where asbestos has been

9 RED Contains ACM,s Certain areas were sampled and ACM, s has been found in those samples. Amber- There is a potential of ACM,s existing This is the default setting of properties constructed prior to year 2000 or newly acquired properties requiring a survey. It s also the default position for properties cloned from others. It will be assumed that ACM, s could be present and a survey will be required before carrying out works that may be intrusive. When giving advice over the telephone, to operatives or residents, regarding the presence of asbestos the asbestos register will always be referenced. Where a property has a green rating, details from the register of the specific areas that were sampled will be provided to contractors, operatives or residents. The following caveat applies with regards to the accuracy of information: Whilst ever effort will be made to give accurate information regarding the presence of asbestos you will be aware that asbestos containing materials could exist in any property. These could have been introduced by a resident carrying out DIY using older materials such as aertex If there is any doubt surrounding the data held within the asbestos register, a survey will be commissioned prior to any further activity 6 ASBESTOS MANAGEMENT PROCEDURES Background Information If existing asbestos containing materials are in good condition and are not likely to be damaged, they may be left in place; their condition monitored and managed to ensure they are not disturbed In the majority of cases, work with asbestos needs to be done by a licensed contractor. This work includes most asbestos removal, all work with sprayed asbestos coatings and asbestos lagging and most work with asbestos insulation and asbestos insulating board (AIB) Non-licensed asbestos work also requires effective controls. Training is mandatory for anyone liable to be exposed to asbestos fibres at work. All of NCHA DMS operatives will have working with asbestos training which will be renewed annually. These certificates of training will be checked on an Annual basis by NCHA responsible staff. All outside contractors working on behalf of NCHA must, as a minimum, have had asbestos awareness training as described in HSG 210 regardless of the work they carry out for the organisation. (Extract HSG264) Health and safety issues

10 16 Surveying and sampling ACMs can give rise to exposure to asbestos. These Work activities are covered by the more general requirements of CAR The Regulations require employers to carry out a risk assessment (regulation 6) and prepare a plan of work (regulation 7), setting out the control measures and personal Protective equipment (PPE) to be used. The regulations also require that adequate Information, instruction and training (including refresher training) (regulation 10) Are given to the sampling personnel. Training should meet the requirements for non-licensable asbestos work as set out in the approved code of practice, Work With materials containing asbestos. Sampling ACMs is, however, exempt from the regulations covering licensing (regulation 8), notification of work with asbestos (Regulation 9) and health surveillance (regulation 22) by virtue of regulation 3(2), as the exposure is sporadic and low intensity and is unlikely to exceed the control Limit. Other hazards may also be present, such as working at heights and electrical cables. A risk assessment will need to be carried out before starting work on site (See paragraphs 83 87). It should include any safety aspects and record any safety protocol to be observed on site as well as fire alarm and evacuation procedures. As of 6 April 2012, some non-licensed work needs to be notified to the relevant enforcing authority As of 6 April 2012, brief written records will be kept of non-licensed work, which has to be notified e.g. copy of the notification with a list of workers on the job, plus the level of likely exposure of those workers to asbestos. This does not require air monitoring on every job, if an estimate of degree of exposure can be made based on experience of similar past tasks or published guidance As of April 2015, all workers/self employed doing notifiable non-licensed work with asbestos must be under health surveillance by a Doctor. Workers who are already under health surveillance for licensed work need not have another medical examination for non-licensed work. BUT medicals for notifiable nonlicensed work are not acceptable for those doing licensed work Works shall be carried out in accordance with NCHA s asbestos procedures medical examination for non-licensed work. BUT medicals for notifiable nonlicensed work are not acceptable for those doing licensed work Works shall be carried out in accordance with NCHA s asbestos procedures 6.1 Contract documentation Pre-tender Details of NCHA s asbestos management plan will be made available to any contractor as part of pre tender documentation on large contracts where specific property details are unknown.

11 For known property locations details from the asbestos register will be included in the pre tender documentation. Where detailed asbestos information is not available for a specific property address; archetypal survey information will be utilised on similar archetype, build date, estate code and build type. Where archetypal information is not available and works are required that may disturb the fabric; NCHA will commission a localised refurbishment/ demolition survey before carrying out any work that may disturb the fabric of any of its properties to locate ACMs so that they can be removed before the refurbishment work starts. Tender Response In all circumstances the contractor selected must provide risk assessments, if generic assessments are submitted they need to be reviewed to ensure that they address the presence of ACM when relevant, and a detailed method statement. This information must be submitted giving at least four working days notice prior to the proposed start of the work, to allow assessment of the documentation. Contractors will be asked to supply details of the accredited training on asbestos provided to their workers. Any member of contractors staff not in possession of a valid training certificate will not be able to carry out any works where there is a risk on exposure of release of ACM. Copies of training certificates will be provided to NCHA and the Project manager will manage this. HSE Licensed Contractors Licensed work will be done by a licensed contractor3]. This work includes most asbestos removal, all work with sprayed asbestos coatings and asbestos lagging and most work with asbestos insulation and asbestos insulating board (AIB). Non-licensed asbestos work will be undertaken to HSE Asbestos Essentials [4] which is a task manual for building, maintenance and allied trades on how to safely carry out non-licensed work involving asbestos. Annual Training[5] is mandatory for anyone liable to be exposed to asbestos fibres at work. This includes annual training for maintenance workers and others who may come into contact with or disturb asbestos (e.g. cable installers), as well as those involved in asbestos removal work. From 6 April 2012, some non-licensed work needs to be notified to the relevant enforcing authority. HSE link [6]From 6 April 2012, brief written records should be kept of non-licensed work, which has to be notified e.g. copy of the notification with a list of workers on the job, plus the level of likely exposure of those workers to asbestos. This does not require air monitoring on every job, if an estimate of degree of exposure can be made based on experience of similar past tasks or published guidance.

12 By April 2015, all workers/self employed doing notifiable non-licensed work with asbestos must be under health surveillance by a Doctor. Workers who are already under health surveillance for licensed work need not have another medical examination for non-licensed work. BUT medicals for notifiable nonlicensed work are not acceptable for those doing licensed work. Work Completion Contractors involved in the removal or disturbance of an ACM must certify the areas to be safe for reoccupation, this may require atmospheric testing and this will form part of the method statement for any works where removal or disturbance of an ACM is possible. NCHA will provide details of the information contained within the asbestos register as part of the works order for properties. The contractor shall provide adequate resources to ensure the provision of appropriate information, instructions and training and the provision of these shall be checked by NCHA staff as required. All information requires recording and the asbestos risk register updated to reflect any removal, inspection, encapsulation or repair of asbestos and the risk reviewed and updated on the register. The process to update the register forms part of the asbestos management plan. 6.2 Responsibilities The Head of Maintenance and Asset Management is to ensure that staffs are familiar with the contents of the Policy and this procedure; insofar as it is relevant to their roles and responsibilities. 6.3 Training and information Different groups of people will require training and different levels of information. NCHA is committed to providing a safe and healthy workplace and as a responsible organisation aims to be open and responsive with regards to the management of ACM. The following four groups have been identified and this section deals with the type of training and information appropriate for each group; all staff, all residents, maintenance and building operatives and then those with specific responsibilities. All staff Where considered appropriate staff shall be informed of the following; That a person can only be exposed to asbestos if the fibres are disturbed into the air and inhaled

13 If asbestos is in good condition it may be appropriate that it could be left in place and managed appropriately. That any exposure to airborne asbestos fibres is to be avoided and that the risk increases as the level, duration and frequency of exposure increases That the increased risk to health from a one-off accidental exposure is negligible What procedures are in place if they find asbestos or a damaged material which they think could contain asbestos What to expect from maintenance and building operatives What procedures are in place to ensure that the presence of ACM is checked prior to any maintenance or building work commencing? All residents A resident s information leaflet, with an extract of any asbestos information held on their property, will be developed and sent to them notifying them if any ACMs are present and where they are located. DMS tradesmen and contractors DMS trades shall all have had the relevant working with asbestos training which will be renewed annually, all external contractors shall, as a minimum, have had asbestos awareness training, which will be renewed bi-annually as outlined in the Approved Code of Practice to the Control of Asbestos Regulations 2012, and as described in HSG 210.AND HSG264 (SEE PREVIOUS EXTRACTS REF: TRAINING) Those with specific responsibilities In addition to the points mentioned above, further training will be given to those who have responsibility for all or part of the Asbestos Management Plan, those who supervise, plan and manage building and maintenance work and those who carry out inspection and surveys. Additional training for supervisors will cover the items extracted: Information, instruction and training section 10 of the Control of asbestos regulations (Extract from CAR 2012) 10. (1) every employer must ensure that any employee employed by that employer is given adequate information, instruction and training where that employee:

14 (a ) Is or is liable to be exposed to asbestos, or if that employee supervises such employees, so that those employees are aware of. (i) The properties of asbestos and its effects on health, including its interaction with smoking,. (ii) The types of products or materials likely to contain asbestos,. (iii) The operations which could result in asbestos exposure and the importance of preventive controls to minimise exposure,. (iv) Safe work practices, control measures, and protective equipment,. (v) The purpose, choice, limitations, proper use and maintenance of respiratory protective equipment,. (vi) Emergency procedures,. (vii) Hygiene requirements,. (viii) Decontamination procedures,. (ix) Waste handling procedures,. (x) Medical examination requirements, and. (xi) The control limit and the need for air monitoring,. In order to safeguard themselves and other employees; and (b) Carries out work in connection with the employer s duties under these Regulations, so that the employee can carry out that work effectively.. (2) The information, instruction and training required by paragraph (1) must be (a) Given at regular intervals;. (b) Adapted to take account of significant changes in the type of work carried out or methods of work used by the employer; and. (c) Provided in a manner appropriate to the nature and degree of exposure identified by the risk assessment, and so that the employees are aware of. (i) The significant findings of the risk assessment, and. (ii) The results of any air monitoring carried out with an explanation of the findings. Senior managers will instigate advanced training courses for managers, project managers, and Technical offices to cover the areas not covered by a simple asbestos awareness course and to deliver the Asbestos management plan. ASBESTOS PROCEDURES Routine Repair and Maintenance Work (See Appendix 1) Because of the large number of repair and maintenance orders issued daily, it is not reasonable or practicable to carry out full surveys for each order as a matter of course. The procedure is as follows and is consistent with the guidance provided in HSE Document HSG264 ASBESTOS: The Survey Guide. (An extract is provided below)

15 In the domestic sector, local authorities and housing associations have responsibility for very large numbers of properties which need a range of maintenance and repair work, as well as general improvement and upgrading or occasionally demolition. Works can include electrical rewiring, structural repairs and alterations, replacement windows, central heating, insulation, renewal of bathroom and kitchen fittings or complete renovations. The work may be necessary on individual or small numbers of premises (e.g. emergency work due to fire/water/storm damage) or on large numbers where there are major improvement or upgrading schemes. 61 Domestic properties present particular challenges for surveying asbestos. The Main issues are the scale (i.e. large number of properties (and consequently what is Reasonable and practicable)), the real extent of similarity in building materials and the personal nature of the property. Asbestos was extensively used in domestic properties between 1930 and However, the presence of ACMs can now be quite variable and unpredictable even within the same archetypal group. The Content varies for several reasons including: inconsistent/variable initial use; random use of waste pieces and offcuts by builders; previous unrecorded removal of asbestos; Modifications of properties by tenants (present and past) and housing Associations (removing and adding ACMs). Domestic dwellings often fall into particular archetypal groups in terms of style, Design and age, e.g. flats within blocks would generally be similar at construction. These factors can be used to develop the survey strategy. The following paragraphs outline the general strategy to use for surveying domestic properties. There are three components: establish the asbestos status of properties, carry out Management surveys and carry out, as necessary, refurbishment surveys. Establish asbestos status of properties Carry out a desk-top study to establish the probable asbestos status of groups of properties. In this exercise, properties can be placed into archetypal groups based on various parameters including construction date (e.g. estates phases), House design and location. These groups of properties can be separated into the Following categories: asbestos free, contain ACMs and possibly contain ACMs. The main criteria involved here for concluding groups are asbestos free would be Any property constructed in 2000 or later. It may also be possible to conclude Those groups are asbestos free based on other information, such as original Construction information, building material specification, previous asbestos surveys or removals or other records. The evidence for this would need to be strong and records complete. These sources of information would also be used to conclude the definite presence of asbestos in particular property groups. Other properties constructed pre-2000 should be classed as possibly containing ACMs (unless there is evidence to show otherwise (e.g. previous surveys etc.)

16 Management surveys Management surveys should be carried out on properties which contain Or possibly contain ACMs. Asbestos-free dwellings should be recorded as Such in the management plan and do not need surveying. However, workers in Such premises (particularly pre-2000) should always be vigilant. A proportion of Properties in each category (i.e. that contains or possibly contain ACMs) and each Archetypal group should be surveyed. Exact sampling ratios cannot be specified, Asbestos: The survey guide Page 24 of 73 As the proportion will depend on the variability of housing stock. A proportion Should be surveyed until the results demonstrate as far as reasonably practicable That there is consistency in the range of ACMs in the property type. Not every Property will contain all the ACM items but the range of ACMs in the property types will be known. Every non-surveyed property has the potential to contain all the ACMs in the range and the ACMs should be managed on that basis. Where there is considerable variability, the ratio surveyed will be high. 65 Information from the management surveys can be enhanced with data from More intrusive surveys when the circumstances allow, e.g. when properties are Vacant (void). Information from refurbishment and demolition surveys should be used to Update the asbestos register for that particular type of property. 66 Management surveys, supported by refurbishment and demolition surveys, should be used as the primary means of managing routine maintenance work in domestic premises. However, duty holders must recognise that these surveys are limited in their scope and extent of intrusion and therefore do not provide sufficient information on the presence of ACMs for larger scale refurbishment and other improvement projects. Management survey (extract HSG264) A management survey is the standard survey. Its purpose is to locate, as far as 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. Management surveys will often involve minor intrusive work and some disturbance. The extent of intrusion will vary between premises and depend on what is reasonably practicable for individual properties, i.e. it will depend o factors such as the type of building, the nature of construction, accessibility etc. A management survey should include an assessment of the condition of the various ACMs and their ability to release fibres into the air if they are disturbed in some way. This material assessment (see paragraphs ) will give a good initial guide to the priority for managing ACMs as it will identify the materials which will most readily release airborne fibres if they are disturbed.

17 A pre-order risk assessment will be made depending on the IBS Risk category (Red - ACMs confirmed, Amber ACMs presumed or Green Confirmed ACMs not present or post 1999 ). At this stage if Red or Amber a decision will be made by the Technical Officer whether to commission an asbestos survey. This will depend upon the extent of and the location of the works. A Pre-work check should be carried out by the Contractor on all jobs, irrespective of risk category because although properties may have had surveys undertaken asbestos may be found in areas not surveyed. HSE Advisory Note to Social Landlords If suspect materials are found NCHA s Emergency procedure will be initiated. The Contractor should ensure that all Sub-Contractors are aware of and carry out the procedure. It is a requirement under NCHA s Contractor Performance Management Procedures that operatives will have had proper asbestos awareness training and they will be expected to work to the procedures contained in HSE s Asbestos Essentials. Confirmation of the extent of completed work will be recorded by entering the details on Asset Management Console by completing Asbestos Update Form. Planned, Programmed or Major Repair Works (See Appendix 2) This refers to all projects or works which have a technical officer or surveyor s input i.e.. Where drawings, contact action sheets and/or specifications are prepared for quotations prior to issue of a works order or where works are subject to NCHA s Tendering Procedures etc. It is the responsibility of the technical officer or surveyor to manage this procedure for these works. Technical Officers, Team Leaders and Managers have received appropriate Asbestos Awareness Training and will carry out an initial risk assessment during every on site inspection to remove the risk of disturbance associated with full sampling surveys in occupied properties. If suspect materials are found during the works the Emergency procedure should be initiated. The Contractor should ensure that all Sub-Contractors are aware of and carry out the procedure. Emergency procedures disturbed or damaged, assumed or known asbestos ASBESTOS - NCHA EMERGENCY PROCEDURE CHECKLIST SEE APPENDIX 3 STEPS ALL INDIVIDUALS (NCHA or Contractor s) do not leave site until these steps have been completed and have been authorised to do so. 1. Stop all work in the area.

18 2. Remove and keep all persons out of the area. 3. Close or seal and cordon off the area where practicable. 4. Do not remove any equipment or materials. 5. Prepare and prominently display a warning sign(s) with the following wording POTENTIAL ASBESTOS HAZARD - KEEP OUT The lettering is to be a minimum of 50 mm high in capital letters. 6. Telephone a Manager in NCHA and notify your own Line Manager or Team Leader. STEPS LINE MANAGERS and TEAM LEADERS 7. The Line Manager or Team Leader (NCHA) Arrange for a survey, sample(s) and analysis to be carried out, Keep the Head of The Establishment / Responsible Person for the property informed. Complete an Accident Near Miss Report form. 8. On receipt of the Analysis results, NCHA (Technical Officer/Team Leader) will- Assess the potential for Asbestos Fibre Release. Decide the required Asbestos Remedial Action taking into account all site - wide factors. Arrange for the issue of a works order/variation order to an appropriate Contractor or Licensed Asbestos Removal Contractor after receipt of a satisfactory Method Statement if required. Ensure Completion of Asbestos Update Form. Keep the Head of The Establishment / Responsible Person for the property informed. 9. Following the Asbestos Remedial Action including air testing if appropriate NCHA.s Technical Officer/Team Leader will:- Confirm to the Contractor and tenant that the area is clear for recommencement of the original work. Keep the Head of The Establishment / Responsible Person for the property informed. Post Fire, Flood or Collapse or other Incident This procedure is to be carried out by the appropriate NCHA Technical Officer/Team Leader responding after an emergency situation has occurred e.g. Fire, Flood, Collapse etc. involving a property which is known to contain asbestos or suspected to contain asbestos materials.

19 Confirm that the Emergency Services have finished and that all necessary general safety measures e.g. temporary supports, barricades etc. are in place. Consult the Emergency Services and establish the likely area of dust spread e.g. as a result of fire, explosion or wind. Carry out the Emergency on site discovery procedure. Until a full Action Plan is in place, assume a high risk of fibre release and decide the appropriate temporary action to limit or contain the spread of asbestos fibres or dust until the appropriate permanent remedial action has been decided. Contact HSE. Emergency - On site Discovery The following procedure should be carried out for each project. This procedure is to be carried out when unforeseen suspect materials are discovered during the execution of work or as part of an emergency procedure and must follow the basic sequence of:- Inform Control Act/Monitor Record It must be assumed that suspect materials are Asbestos Containing Materials unless proven otherwise by analysis. Only contractors licensed under The Control of Asbestos Regulations 2012 should be employed for any licensed, notifiable or non licensed notifiable works on material containing asbestos unless they are involved in short duration work (within any 7-day period a single job lasts less than one hour per worker or two hours in total). It should be noted that nonlicensed work with asbestos now has additional requirements, i.e. notification of work in certain cases, medical surveillance and record keeping References: page Health and safety HSG 264 Asbestos: The survey Guide 2012 section60-69

20 Appendix 1 ROUTINE REPAIRS AND MAINTENANCE PROCEDURE PRE ORDER CHECKS: ASBESTOS REGISTER ON IBS (Asset Management Console) TECHNICAL OFFICERS LOCAL KNOWLEDGE ASBESTOS IS KNOWN OR SUSPECTED TO BE IN THE WORK AREA. NO KNOWN ASBESTOS IN WORK AREA. TEAM LEADER / TECHNICAL OFFICER TO ARRANGE FOR SURVEY/SAMPLES IF APPROPRIATE COMPLETE ASBESTOS UPDATE FORM. CONTRACTORS PRE -WORKS CHECK SUSPECT MATERIALS DISCOVERED DURING WORKS. ASSESS RISK OF FIBRE RELEASE DECIDE ON APPROPRIATE ACTION REMOVE PART REMOVE & MANAGE & NOTIFY OCCUPANTS. ENCAPSULATE & MANAGE & NOTIFY OCCUPANTS. LEAVE INTACT & MANAGE & NOTIFY OCCUPANTS. STOP WORK, SEAL AREA KEEPING ALL PERSONS AWAY. DO NOT REMOVE ANY MATERIALS, EQUIPMENT OR TOOLS. CONTACT NCHA IMMEDIATELY. See NCHA s EMERGENCY PROCEDURES ENSURE THAT CONTRACTOR PREPARES AN APPROPRIATE METHOD STATEMENT COMPLETE ASBESTOS UPDATE FORM AND SCHEDULE AN APPROPRIATE

21 Appendix 2 ASBESTOS - MAJOR WORKS OR PROGRAMMED WORKS PROCEDURE PRE CONTRACT STAGES RESEARCH BACKGROUND OR HISTORY OF BUILDING(S) (INCLUDED IN DESKTOP SURVEY) ASBESTOS REGISTER DESIGN RECORDS MAINTENANCE INSPECTORS PERSONAL/GROUP KNOWLEDGE TEAM LEADER / TECHNICAL OFFICER SURVEY COMMISSION A LOCALISED INTRUSIVE SAMPLING REFURBISHMENT SURVEY TO AREAS WHERE DISTURBANCE OF FABRIC IS PROPOSED TAKE SAMPLES FOR ANALYSIS. ASSESS RISK OF ABESTOS FIBRE RELEASE & COMPLETE ASBESTOS UPDATE FORM WHERE CDM REGULATIONS APPLY DECIDE ON THE APPROPRIATE INFORMATION TO INCORPORATE INTO PRE CONTRACT CDM HEALTH AND SAFETY PLAN AND DESIGN AND SPECIFICATION DOCUMENTS. DECIDE ON APPROPRIATE ACTION REMOVE. PART REMOVE & MANAGE & NOTIFY OCCUPANTS. ENCAPSULATE & MANAGE & NOTIFY OCCUPANTS. LEAVE INTACT & MANAGE & NOTIFY OCCUPANTS. COMPLETE ASBESTOS UPDATE FORM WHEN WORK IS COMPLETE. CONTRACT STAGES OBTAIN METHOD STATEMENT FROM CONTRACTOR. ENSURE THAT ISSUES SURROUNDING WORKING WITH MATERIALS CONTAINING ASBESTOS HAVE BEEN PROPERLY ADDRESSED. ENSURE THAT MAIN CONTRACTOR & ALL SUB -CONTRACTORS

22 IF ASBESTOS IS FOUND IN AREAS PREVIOUSLY THOUGHT TO BE FREE OF ASBESTOS, STOP WORK, SEAL AREA KEEPING ALL PERSONS AWAY. DO NOT REMOVE ANY MATERIALS, EQUIPMENT OR TOOLS. CONTACT NCHA IMMEDIATELY. ON COMPLETION RECORD SIGNIFICANT INFORMATION ON ASBESTOS UPDATE FORM AND SCHEDULE AN APPROPRIATE INSPECTION REGIME.

23 Appendix 3 ASBESTOS - EMERGENCY PROCEDURE The diagram below describes how anyone working in an NCHA property should approach the building in terms of asbestos awareness.

24 Is the Place of Work Known To Contain Asbestos? Yes Not Known No Suspect Material Identified Remain Alert to the Possible Presence of Asbestos Will the Work Process Disturb the Asbestos? No Employ Safe System of Work No Further Action Necessary Yes Stop Work Secure the Area from Access Inform the resident Inform Management Await Further Instruction but keep the resident informed of progress daily If suspect materials are found during the works the Emergency procedure should be initiated. The Contractor should ensure that all Sub-Contractors are aware of and carry ou

25 ASBESTOS REGISTER Guidance note. Asbestos information from the management surveys is held within Capita Housing system. These Groups of properties will be allocated a colour category via our Asbestos register, held within capita so each property will be easily identified via capita and on the works orders received by our contractors, along with the inspection sheet received by NCHA technical officers. The Categories are Green Amber and Red ** IT SHOULD NOT BE PRESUMED THAT JUST BECAUSE A PROPERTY HAS BEEN ALLOCATED A GREEN STATUS THAT IT IS FREE FROM ASBESTOS** Green- Asbestos free in the areas sampled Post 2000 built property. Where a completed survey of certain areas has not identified ACM,s ( This means that in the areas sampled asbestos was not found, The contractor or tenant must seek further advice if unsure how to proceed) RED Contains ACM,s Certain areas were sampled and ACM,s were found in those samples Amber- There is a potential of ACM,s existing This is the default setting of properties constructed prior to year 2000 or newly acquired properties requiring a survey. It s also the default position for properties cloned from others. It should be assumed that ACM,s could be present and a survey will be required before carrying out works that may be intrusive. When giving advice over the telephone to operatives or residents regarding the presence of asbestos always check the register. If you are advising that a property is green please check the register and advise the caller of the specific areas that were sampled. Finish by giving the following warning. Whilst ever effort has been made to give accurate information regarding the presence of asbestos you should be aware that asbestos containing materials could exist in any property. These could have been introduced by a resident carrying out DIY using older materials such as aertex or could be contained in an area that was not surveyed. If In doubt request a further survey.