17 Chescombe Road, Yatton, North Somerset, BS49 4EE. 0784 1916 730 01934 832 851 HealthSafetyAndFire@gmail.co.uk www.healthsafetyandfire.co.uk ASBESTOS RISK MANAGEMENT : For those WORKING on buildings.. Page 1 of 6 THE MAIN CONCERNS Asbestos was a widely used product throughout most industries up to the turn of this century when it was finally banned because exposure to minute particles can cause very serious life threatening illnesses some 20 or 30 years after exposure. Medical science is not yet clear on how much exposure or which types of asbestos affect different people and what can lead to such illnesses. Asbestos remains a major threat to many people, especially to those who maintain buildings. Those in control of any building have a legal duty to ensure that asbestos is detected and properly managed to reduce the chance of harm to people. Most buildings built before 2000 contain asbestos (in Artex, DPCs, panels, floor tiles, roof tiles, pipe lagging etc) and it is when the fibres are released into the air that they become extremely hazardous to health. There are different types of asbestos and some forms are mixed with other substances making identification of the presence of asbestos sometimes difficult. Whilst the client has legal obligations toward you as a contractor or builder, you also have clear legal obligations, regardless of anything the client has or has not done. Even if you do not have any intention of handling or disturbing asbestos, these legal duties remain. Every employer must: [42] comply with the Control of Asbestos Regulations 2012, and other legal requirements. Health and Safety at Work Act 1974 (HSAW). Management of Health and Safety at Work regulations 1999. (MHSW). Construction (Design and Management) Regulations 2015 (CDM). carry out a risk assessment in relation to the possibility of asbestos being present. Assess relevant information to determine the possibility of the presence of asbestos [148]. plan the work. provide appropriate information, instruction and training to workers. take measures to prevent exposure and prevent spread of asbestos to employees and others. ensure that anyone working with asbestos is trained and competent to do so. that suitable control measures are in place. ensure that anyone who may possibly disturb asbestos receives asbestos awareness training [232-237]. WHATEVER YOU DECIDE TO DO, YOU MUST.. ensure that exposure is prevented and if this is not possible then reduce it to as low as reasonably practicable. [276] ensure that work which disturbs asbestos is only done when it is unavoidable [277]. Have procedures in place for any unintentional disturbance of asbestos [364-381]. Provide suitable toilets, washing and changing facilities [520]. Numbers in [42] is the section found in L143 Managing and working with Asbestos. The guidance herein are generalisations and for indicative guidance purposes only and can not be relied upon for any specific context where competent professional advice must be sought. Health Safety and Fire Specialists Limited regulated by Companies House, Registration no: 9721426. In association with Health Safety And Fire Limited Registration No: 10072242 both registered in United Kingdom. Regulated by and members of IOSH Institution of Occupational Safety and Health www.iosh.co.uk
ASBESTOS RISK MANAGEMENT : For those WORKING on buildings.. Page 2 of 6 Health, Safety and Fire Specialists Ltd We can support you fulfilling your legal duties by any combination of the following: You may require us to call in and evaluate which elements you may need and we will only advise on what you need to do in a proportionate manner. Examining your project and assessing if a specialist survey is needed by your or by the client. If necessary, procuring an economical specialist UKAS asbestos surveyor. Assisting your client to update their asbestos register. Identifying any areas of unacceptable risk or concerns and identifying asbestos that must be protected, repaired or removed. Procuring an economical specialist company to conduct any vital urgent works to prevent contamination. Writing or developing your management systems to ensure that everyone is doing what they need to do. It isn t difficult, but they need to know and you need to be able to prove that they know. Review how you engage sub contractors to ensure that they have the necessary information, training and competencies. This is a vital aspect of compliance. Conduct asbestos awareness training for staff and contractors who manage or conduct repairs. It isn t complex and doesn t take long. Ensuring that you only spend what you need to in order to manage this area. Write or review your risk assessments, method statements, safe systems of work etc. Write or review your site inductions, company inductions, contracts etc. Write or review your documentation for tendering, clients etc. Write or review your emergency procedures (see last page). TYPES OF WORK Asbestos Cement. Asbestos Cement is usually a mixture of cement with chrysotile and compressed to produce such things as corrugated roofing sheets, rainwater goods, flues etc. Almost all work involving asbestos cement is not licensable because the asbestos is firmly bound in a matrix unless it is badly damaged when a risk assessment will be required to make a determination. [14-16] Textured coatings. Some contain asbestos, around 2 5% chrysotile and hence work with such will not normally be licensable work. [19-21] Sporadic and low intensity exposure This is when exposure is less than 0.6 f/cm3 in the air measured over a ten minute period. [27] Control Limit. f/cm3 airborne fibres averaged over a four hour period. Licensable work includes: Where exposure is not sporadic and of low intensity Where the risk assessment cannot demonstrate that the control limit will not be exceeded On asbestos coatings (except artex) On asbestos insulating board when the risk assessment demonstrates it will not be sporadic and of low intensity, the control limit will be exceeded and it is not short duration work. [30].
ASBESTOS RISK MANAGEMENT : For those WORKING on buildings.. Page 3 of 6 LICENSABLE AND NON-LICENSABLE WORKS Table 1 from Managing and working with asbestos : Control of Asbestos Regulations 2012. Approved Code of Practice and guidance (L143) gives a useful summary: Work which requires a licence from HSE Removing sprayed coatings (limpet asbestos). Removal or other work which may disturb pipe lagging. Any work involving loose fill insulation. Work on millboard. Cleaning up significant quantities of loose/fine debris containing ACM dust (where the work is not sporadic and of low intensity, the control limit will be exceeded or it is not short duration work). Work on AIB, where the risk assessment indicates that it will not be of short duration. Work which does not usually require a licence from HSE Small, short duration maintenance tasks where the control limits will not be exceeded. Removing textured decorative coatings by any suitable dust-reducing method. Cleaning up small quantities of loose/ fine debris containing ACM dust (where the work is sporadic and of low intensity, the control limit will not be exceeded and it is short duration work). Work on asbestos cement products or other materials containing asbestos (such as paints, bitumen, resins, rubber, etc) where the fibres are bound in a matrix which prevents most of them being released (this includes, typically, aged/weathered AC). Work associated with collecting and analysing samples to identify the presence of asbestos. WORK WITH ASBESTOS MEANS. The regulations apply to [Regulation 3] duty holders the self employed employer employee Work with asbestos includes: [41] removal repair disturbance any ancillary works relating to the above supervision of any of the above However, Exemptions can apply depending upon [41ff] the type of work being done, the condition and type of ACM, meeting conditions in Regulation (3)(2)(a), (b) and (c). Exemptions remove the need for: Notifying works on asbestos [9 ] Designating and segregating areas work areas [18(1)(a)] Medical surveillance and keeping health records [22] Exemptions do not apply to: [45] Licensable work Notifiable non licensed work
ASBESTOS RISK MANAGEMENT : For those WORKING on buildings.. Page 4 of 6 NOTIFIABLE NON-LICENSED WORK Notifiable non-licensed work (NNLW) This is work that meets the condition in Regulation 3(2) above in sub sections (a) and (b) but NOT (c). For NNLW works, the exemptions above cannot be applied. The decision is the work is NNLW has to be risk assessment based and not blindly following the guidance in the tables. Where works are being done as part of other works then they should be considered collectively for consideration of any exemptions. [59] Employers must (for NNLW) [52] Notify work with asbestos Designate work areas Provide medical examinations every three years [506] Keep health records. NON-LICENSABLE, NOT NORMALLY NNLW.. Table 2 [59] give examples of non-licensable work that will not normally be NNLW Removal of asbestos cement products, (eg roof sheeting and rainwater goods) provided the material is carefully handled/removed without breaking up; this includes work with asbestos cement which is weathered but not otherwise substantially damaged. Maintenance work involving asbestos cement products (eg on roof sheeting and rainwater goods). Removal of small areas of textured decorative coatings using gel/steam, to support other activities such as installation/replacement of smoke alarms and light fittings. Removal without deterioration, of textured decorative coatings (eg if the backing board is carefully cut around to achieve virtually intact removal). Drilling of textured decorative coatings for installation of fixtures/fittings. Encapsulation and sealing-in work on ACMs that are in good condition (eg repairing damaged sealing material). Removal and reattachment of loosely fixed (eg screwed) AIB panels in order to gain access to areas for other maintenance activities (eg under a bath to carry out pipework maintenance, or for access to a ceiling void for repair of lighting). Painting/repainting AIB. Short duration work to repair minor damage to AIB. Short duration work involving drilling holes in AIB (eg when installing shelving). Maintenance work involving asbestos in ropes, yarns and woven cloth. Maintenance work on asbestos gaskets (including removal as part of repair and upkeep of equipment). Maintenance work involving asbestos-containing thermoplastic and vinyl floor tiles, bitumen roof felt, shingles, damp-proofing coatings, mastics. Maintenance of asbestos-containing felt and paper. Continued...
ASBESTOS RISK MANAGEMENT : For those WORKING on buildings.. Page 5 of 6 NON-LICENSABLE, NOT NORMALLY NNLW.. CONTINUED. Table 2 [59] give examples of non-licensable work that will not normally be NNLW Maintenance of asbestos-containing felt and paper. Maintenance work involving plastic paint coatings, PVC floors, panels and sealing compounds. Maintenance of asbestos-containing conveyor belts/drive belts, bonded rubber, electric cable. Maintenance of resin-based ACMs such as friction products (eg brake linings). Air and bulk sampling for asbestos fibre. NON-LICENSABLE, NORMALLY NNLW.. Table 3 gives examples of non-licensable work that will normally be NNLW: Removal of asbestos cement products (eg roof sheeting) which are substantially damaged or broken up (eg as a result of fire or flood). Removal of asbestos cement products (eg roof sheeting) where the material will be substantially broken up, creating significant quantities of dust and debris (eg dropping an asbestos cement roof). Large-scale removal of textured decorative coatings using steaming or gelling methods (eg beyond that required for maintenance activities such as installation/ replacement of smoke alarms and light fittings). Short duration (< 2 hours) work to remove AIB as part of demolition or major refurbishment. Short duration (< 2 hours) work on asbestos insulation. EMERGENCIES Employers must have produces in place for accidental, unplanned or uncontrolled release of asbestos fibres. [Regulation 15]. Other regulations require this too. What to do if there is a release [368] In all cases, where there has been an uncontrolled release of asbestos materials into the workplace, employers should take steps to: warn people who may be affected; exclude people from the area, who are not needed to deal with the release; identify the cause of the uncontrolled release; regain adequate control as soon as possible. Continued...
ASBESTOS RISK MANAGEMENT : For those WORKING on buildings.. Page 6 of 6 NON-LICENSABLE, NOT NORMALLY NNLW.. In particular, employers must make sure that: [369] anyone in the work area affected who is not wearing PPE, including RPE, leaves that area immediately; arrangements are made to decontaminate anyone who is contaminated with dust and debris; any clothing or PPE is decontaminated or disposed of as contaminated waste; measures are taken to contain and reduce fibre release. Licensable works have additional procedures for emergencies. See Regulation 15 for details. See our web site for other useful information regarding emergencies and incident management. www.healthsafetyandfire.co.uk WORKING WITH ASBESTOS Just because asbestos is present does not mean you have to get a licensed contractor in. The HSE have issued a task manual for building, maintenance and allied trades for work on non-licensed asbestos. It can be found at: www.hse.gov.uk/asbestos/essentials and each task has a free task sheet you can download. They cover things like Equipment, Method Sheets, Drilling holes in artex, removing a screw from asbestos, removing a single asbestos containing gas or electric heater etc., the vast majority of day to day maintenance tasks are covered. All the task sheets are contained in a single publication HSG210, if you prefer. RESOURCES The Control of Asbestos Regulations 2012 Managing and working with asbestos. Control of Asbestos Regulations 2012. Approved Code of Practice and guidance. Date of publication: 2013. ISBN: 9780717666188. Series code: L143 (Second edition). Asbestos: The survey guide. Date of publication: 2012. ISBN: 9780717665020. Series code: HSG264 (Second edition). Asbestos essentials. A task manual for building, maintenance and allied trades of non-licensed asbestos work. Date of publication: 2012. ISBN: 9780717665037. Series code: HSG210 (Third edition). Managing asbestos in buildings. A brief guide. Date of publication: 2012. ISBN: 9780717664870. Series code: INDG223 (rev5).