Education Infrastructure Service Asbestos Management Process Version 9 All rights reserved. No part of this publication may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electronic, mechanical, photocopying, recording or otherwise without the prior written permission of the Ministry of Education. This document is the property of the Ministry of Education and may not be disclosed to a third party or copied without consent. Copyright 2016 Ministry of Education
EIS Ministry-contracted Work Asbestos Process Contents 1. Ministry-contracted Work Asbestos Process... 3 1.1. Glossary... 4 1.2. Process Diagram... 5 1.3. Procedures... 6 1.4. Asbestos Isolation Procedures... 8 2. Asbestos Survey... 10 2.1. Survey Process... 10 2.2. Appointing an Asbestos Consultant or Assessor... 11 2.3. Preparation... 11 2.4. Scope of Survey... 12 2.5. Sampling, Testing and Assessment/Reporting... 14 2.6. Survey Report Requirements... 15 3/05/2017 Ministry-Contracted Works Asbestos Procedure 2
EIS Ministry-contracted Work Asbestos Process 1. Ministry-contracted Work Asbestos Process Introduction The Health and Safety at Work (Asbestos) Regulations 2016 impose duties on Persons Conducting a Business or Undertaking (PCBU) in relation to work involving asbestos. This includes managing asbestos risks, removal of asbestos through use of licensed asbestos removalists. All structures that are involved in a Ministry-run project in a school must be inspected for asbestos before work commences. The following process outlines the steps that should be taken to check for and manage the presence of asbestos for Ministry of Education-contracted projects within schools. It may also be used as a guide for schools, boards of trustees and other persons carrying out non-ministry contracted projects. This process should be read in conjunction with the Health and Safety at Work (Asbestos) Regulations 2016. Escalation Colour Coding Issues arising from this process should be escalated from the >MoE Local Office Staff > EIS Health and Safety. If the issue cannot be resolved internally, i.e. it is outside of EIS capability, it can be escalated to an Asbestos Consultant. The tasks in the procedures are colour coded based on the role responsible for their completion. Where multiple roles are assigned to a task the task can be completed by a person in either role. Which role is most appropriate is determined by the level of risk confirmed or suspected asbestos presents based on work planned. Anyone This can be any of the parties below, or any other person. Building Contractor The main contractor in control of the building site. The party managing the project for the MoE. EIS Point of Contact The EIS Staff member the reports to. EIS Health and Safety Team An EIS Health and Safety Advisor EIS.HealthandSafety@education.govt.nz. Asbestos Consultant The asbestos specialist who designs the asbestos management strategy for high risk work. Asbestos Assessor A person who provides air quality monitoring during removal work, inspects the finished job and provides a clearance certificate. Asbestos Removalist/Contractor The qualified/certified party undertaking work with asbestos. For removal over 10m2 this must be a licence holder. Asbestos Surveyor The party engaged to undertake an asbestos survey. IANZ Accredited Lab An IANZ accredited lab must assess all samples taken from a survey. They may also undertake air testing during work. 3/05/2017 Ministry-Contracted Works Asbestos Procedure 3
EIS Ministry-contracted Work Asbestos Process 1.1. Glossary Term ACM Asbestos Management Plan Asbestos Removal Control Plan Asbestos Survey Asbestos Related Work Certificate of Competence Competent Person Hazard Management Plan Licensed asbestos removal work Suitably Qualified/Certified or Experienced Party Description Asbestos Containing Material The diarised plan for the monitoring and maintenance of asbestos at a school. The plan identifies the specific controls the licence asbestos removalist will use to make sure people are not put at risk. It should include details on the removal methodology, equipment and PPE, details about the location, type and condition of the asbestos, air monitoring points and details of the means of transport and disposal of the asbestos waste. A Survey of assumed asbestos or ACM. Work involving asbestos (other than asbestos removal work). The certification administered by WorkSafe NZ for restricted work involving asbestos. This certification has changed under the Health and Safety at Work (Asbestos) Regulations 2016 from April 2016. Information on how this transfers to the new licensing scheme can be found here: http://www.business.govt.nz/worksafe/information-guidance/guidance-byhazard-type/asbestos/asbestos-rules-change-in-april-2016/certificate-ofcompetence-holders A person who has the knowledge, experience, skills and qualifications to carry out a particular task. This could be the Site Specific Safety Plan, Hazard/Risk Management Plan, Task Analysis, Job Safety Analysis or other documents used to establish and coordinate health and safety activity on site. Asbestos removal work for which a Class A asbestos removal licence or a Class B asbestos removal licence is required. Asbestos A person who provides air quality monitoring during Assessor removal work, inspects the finished job and provides a clearance certificate. Asbestos A person/organisation with the capability to provide overall Consultant management or advice on work relating to asbestos. Asbestos For removals this must be a licensed removalist. Removalist/Co ntractor Asbestos Surveyor IANZ Accredited Lab See WorkSafe NZ guidance available here: http://www.business.govt.nz/worksafe/informationguidance/all-guidance-items/interim-guidance-for-workinvolving-asbestos/asbestos-interim-guide.pdf A laboratory that holds the International Accreditation New Zealand approval to test for asbestos type asbestos into the keyword search field on this page: http://www.ianz.govt.nz/directory/ or a laboratory approved by WorkSafe to test samples under the regulations for up to 12 months while the laboratory is in the process of obtaining accreditation under the above. 3/05/2017 Ministry-Contracted Works Asbestos Procedure 4
EIS Ministry-contracted Work Asbestos Process 1.2. Process Diagram 1. Obtain a copy of the Schools Risk Register and review. 2. Does the planned work involve refurbishment or demolition of a building or infrastructure? YES NO 3. The or School to arrange for an Asbestos Survey and sampling of material to be analysed for the presence of asbestos or ACM. 4 Do the test results confirm the presence of asbestos or ACM? YES 10. Continuously monitor and remain alert to the possibility of previously unidentified asbestos. 5. If the material poses a risk to health, ensure the work area is isolated, follow the Asbestos Isolation Procedures (1.4). 6. Prepare an Asbestos Management Plan and Asbestos Removal Control Plan (ARCP only if removal works being carried out). NO 7a. Asbestos Removal Control Plan reviewed. 7b. Perform and monitor work (including conducting relevant air testing before, during and after). 8. Provide or School with Clearance Certificate 9.. Update risk register and any other records if required. 3/05/2017 Ministry-Contracted Works Asbestos Procedure 5
1.3. Procedures Introduction This section outlines the tasks to be undertaken at each step of the Process Diagram (1.2). 1. Obtain a copy of the school risk register and review it. If the School does not have a risk register, then one should be put in place immediately. The Risk Register should include whether any asbestos or asbestos containing material has been identified and if so, the location, condition and quantity of such asbestos. 2. DECISION: Does the work involve refurbishment or demolition of a building, plant or infrastructure? Decision Action No Proceed to step 10. Yes Proceed to step 3. Demolition or refurbishment cannot occur until the structure has been inspected to determine whether asbestos or ACM is fixed to or installed. If material cannot be identified but it is reasonably believed that the material is asbestos or ACM, it must be assumed to be asbestos. Delivery Manager/ Delivery Manager/ 3. Arrange for an Asbestos Survey. Samples taken must be analysed by an accredited laboratory. 4. DECISION: Is the presence of asbestos confirmed? Decision Action No Proceed to step 10. Yes Proceed to step 5. 5. If it is discovered that material will either pose a risk to health in its current form or if it is disturbed as a result of work about to commence then you must ensure the work area is isolated; Delivery Manager/ IANZ Accredited Laboratory PCBU with management or control of the workplace 3/05/2017 Ministry-Contracted Works Asbestos Procedure 6
6. Prepare an Asbestos Management Plan and Asbestos Removal Control Plan (if removal is occurring) for the workplace. The Asbestos Management Plan should include information about the following: - Identification of location of any asbestos or ACM; - Decisions, and reasons for decisions, about the management of the risk arising from asbestos; - Procedures for detailing incidents or emergencies involving asbestos (i.e. procedures to mitigate any risk posed by previously unidentified asbestos if it is uncovered during work; - Detail about the workers who carry out work involving asbestos including information and training, roles and responsibilities and any health monitoring of the workers that has or will be undertaken; An Asbestos Removal Control plan should include: - Asbestos survey/lab results; - Condition and quantity to be removed; - Proof of notification to WorkSafe NZ; - Details of asbestos enclosures; - Air monitoring detailed before, during and after removal; - Types of respirator and clothing to be worn; - Detail decontamination procedures; - Site risk register; - Confirmation that works will be carried out out of school hours where possible. If the works cannot be performed outside of school hours then evidence to show how the works can be performed safely must be demonstrated via Risk Assessment during the review process; - Confirmation that the school has been informed of the removal; - Confirmation that the school has effectively informed persons who may be affected by the works (see guidance); - Completed task analysis or removal methodology which outlines a step by step process for removal; - Site plan detailing location of security fencing, warning signage, decontamination unit location, location of air monitors and location of asbestos waste storage; - Waste disposal processes; and - Clearance requirements. 7. Asbestos Removal Control Plan must be emailed to the EIS Health and Safety team and be reviewed by EIS Health and Safety Advisor. Plans are reviewed for compliance against the Health and Safety at Work (Asbestos) Regulations 2016 and Ministry requirements for Asbestos Removal. Work is unable to commence until this plan has been accepted by the EIS Health and Safety Advisor. PCBU with management or control of the workplace EIS Health and Safety Advisor 3/05/2017 Ministry-Contracted Works Asbestos Procedure 7
Ensure Asbestos Management Plan and Asbestos Removal Control Plans are applied during work. Ensure that reoccupation does not occur until formal clearance has been received. Perform work in relation to asbestos. Monitor work and manage relationship between contractor and school as necessary. Ensure that reoccupation does not occur until formal clearance has been received. Carry out air monitoring before and during works and a final clearance inspection once work is complete. If appointed, monitor and provide advice on work as required. 8. Provide EIS Health and Safety team with Clearance Certificate and Tip Disposal Dockets/Receipts. 9. Revise and update School Risk Register. School 10. Continuously monitor and remain alert to the possibility of previously unidentified asbestos being found. If asbestos is suspected at any time, return to step 3. Building Contractor & PCBU with management or control of the workplace Asbestos Removalist/Contractor Delivery Manager/ Asbestos Assessor IANZ Accredited Lab Asbestos Consultant EIS Point of Contact PCBU with management or control of the workplace 3/05/2017 Ministry-Contracted Works Asbestos Procedure 8
1.4. Asbestos Isolation Procedures Introduction Use this page as a Checklist to ensure that all actions have been undertaken. These procedures begin at Step 6 of the Process Diagram (1.2). They apply when suspected asbestos containing material is discovered that either: a. poses a risk to health in its current form should it contain asbestos; or b. will pose a risk to health if it is disturbed as a result of work about to commence should it contain asbestos. This will generally be a building material that is in bad condition (therefore more likely to be releasing fibres) and could occur when undertaking an Asbestos Survey during work onsite, or at a school during normal activity. Step Action Performed By 1. Potential asbestos containing material is identified. Inform the person in control of the site of the potential hazard i.e. School Principal or Building Contractor. 2. a) Where Asbestos or ACM is present and undamaged, it may be left in place and no further action may be required. b) If the material is in poor condition and is likely to release airborne fibres in its current condition or if it is disturbed, isolate the area and/or close the site as necessary. c) Engage a Licensed party to undertake testing of the suspect material d) If appropriate, can direct work to continue in a safe location elsewhere on site. 3. Inform the following parties of the isolation as appropriate: a) MoE Local Office Staff point of contact (phone call followed by written confirmation); b) other contractors engaged in work on site; c) the school Principal or Senior Staff member (who is onsite at the time and can be informed verbally); and d) Board of Trustees (phone call followed by written confirmation). 4. Inform direct manager of circumstances, who will then initiate the appropriate issue escalation (including notification to EIS Health and Safety), keep school updated. 5. DECISION: Does testing confirm asbestos? PCBU in control or management of the workplace or PCBU in control or management of the workplace EIS Point of Contact Decision Yes No Action Proceed to step 5.(f) Proceed to step 5.(g) EIS Point of Contact 6. Add identified asbestos to Asbestos Management Plan. Adjust cost/timeframe as necessary. Document any changes in project file. 7. Once potential hazards have been resolved, risks mitigated and the appropriate clearances have been given, site restrictions can be lifted. 8. Communicate issue resolution to school and other parties as necessary. EIS Point of Contact 3/05/2017 Ministry-Contracted Works Asbestos Procedure 9
2. Asbestos Survey Introduction The steps below carry on from step four of the Process Diagram (1.2) and explain in more detail how a project manager should go about procuring asbestos services for the project. In many cases one company will be able to undertake sampling, testing and the production of a survey report. 2.1. Survey Process Step Action Performed By 1. Procure a suitably qualified/certified or experienced party to undertake asbestos sampling, testing and/or a survey report for the area of work as appropriate. Ensure the type of survey requested is the correct type of survey. Note that for any demolition or refurbishment works, a Refurbishment or Demolition Survey is required. 2. Along with the documents listed below, the surveyor should be briefed with a complete overview of the scope of work to be undertaken as part of the main project. Brief the surveyor on known and potential asbestos identified through the risk register. Documents to be provided to the surveyor could include: Asbestos Register, if any Photos or any other documentation indicating the presence of asbestos. 3. Review documents and visit site to confirm work required if needed before survey is undertaken (for large scale work). Establish sampling methodology and produce Asbestos Management Plan for the work to be undertaken as necessary. 4. As appropriate, ensure that the Asbestos Management Plan for sampling is integrated into any project/site Hazard Management Plan and/or school site Hazard/Risk Register. Asbestos Consultant Asbestos Assessor Asbestos Consultant Asbestos Surveyor Asbestos Consultant 5. Complete sampling and submit samples to IANZ Accredited Lab. Asbestos Surveyor 6. Test samples and provide results to Asbestos Surveyor. IANZ Accredited Lab 7. Provide report to of survey results in the format defined at section 2.6 below. Asbestos Surveyor Asbestos Consultant 3/05/2017 Ministry-Contracted Works Asbestos Procedure 10
2.2. Appointing an Asbestos Consultant or Assessor Once the need for a survey has been confirmed, consider whether it is appropriate to engage an asbestos consultant to oversee all work in relation to asbestos for the project. This decision will depend upon the type and scale of work that is to be undertaken. An asbestos consultant independent from any removal or testing must be contracted if asbestos work involves soil contamination. When procuring asbestos consultancy services, you should have regard to the scope of work this party will undertake and ask for evidence of relevant experience and capability. You should use the escalation framework at section one of this process should you not be able to make a decision independently about when or who to appoint as asbestos consultant. Asbestos consultants offer value in that they can oversee all work in relation to asbestos, develop and assess specifications for work and task analyses, and assess the quality of any work undertaken by a third party. You should consider appointing a consultant when undertaking high risk, complex and high value work with existing buildings and infrastructure that contain a lot of asbestos, especially if it is friable or degraded. An example of a situation where an asbestos consultant would be appropriate would be a redevelopment project that: involves multiple buildings of differing ages and construction, some of which may have been previously renovated. An asbestos consultant does not have to be engaged at the survey stage and does not have to oversee a project end to end however the decision to engage the services of a consultant could be taken as a quality assurance step: following the results of a survey to quality check the survey report; to design a specification for removal or work with asbestos as the basis of a tender for a large or complex demolition/refurbishment; to assist in the selection of contractors for asbestos work; to assess the suitability or design a specification for the technical aspects of an Asbestos Removal Control plan or similar. 2.3. Preparation Prior to visiting site the surveyor should be in possession of all relevant information to inform their testing methodology, survey scope and eventual risk assessment and report. Wherever possible, the project manager or appointed licensed assessors and removalists should accompany the surveyor to the site to confirm the proposed area and scope of work. It may also be appropriate to involve the main project contractor, or relevant subcontractor and school principal in presurvey discussions. In general: a) The must supply the person undertaking survey with all relevant asbestos information and a scope of work to be undertaken in the area to be surveyed. b) Using this information, the surveyor should develop an appropriate Asbestos Management Plan for the survey work proposed, e.g. asbestos PPE, isolation procedures, working at height etc. c) The must notify the school Principal of the site visit at least 24 hours before it commences identifying the company represented, proposed surveyor(s) attending the site, time of arrival, duration of survey etc. d) All attendees must present to the school administration block to be inducted and sign onto the school site. This should include being provided with the hazard register including the asbestos register. 3/05/2017 Ministry-Contracted Works Asbestos Procedure 11
2.4. Scope of Survey In general, the scope of a survey should be the area of work for a project however it may be cost effective in some cases to extend this scope to encompass a full building or block. Particularly in small schools or isolated areas, it may be convenient and cost effective to extend the scope of a survey beyond the area of work, or building to be worked on, to encompass a full survey of a school. This possibility should be confirmed with the Ministry Local Office point of contact for the school before commitments are made to contractors or school. Even if testing only focuses on a specific area suspected to contain asbestos, to ensure that no potential asbestos is missed, the surveyor should undertake a walkover of the entire site in order to identify potential asbestos containing materials. Where a surveyor identifies potential ACM that is not within the scope of the survey, but they feel should be tested, they will inform the project manager, who will make the actual determination as to whether testing should occur. 2.5. Asbestos Surveyor Competencies People identifying asbestos should have the knowledge and skills to identify or assume the presence of asbestos through training, qualifications and experience. For asbestos identification, an asbestos surveyor needs to: be trained to take and handle uncontaminated asbestos samples safely; have the knowledge and experience to identify suspected asbestos and work out the risk and control measures; be familiar with building and construction practices to help work out where asbestos is likely to be present; be able to confirm that material may be friable or non-friable asbestos, and evaluate its condition. The asbestos surveyor should be knowledgeable and experienced in: o o o o the types and locations of ACM; eliminating and minimising asbestos exposure risks; correctly using, maintaining and storing personal protective equipment (PPE); and safely using the plant and equipment needed for taking samples. 2.6. Deciding which Survey type? If a structure is going to be refurbished or demolished, it must be determined whether there is any asbestos or ACM present in the structure. The type of survey required will vary during the premises lifespan, and several may be needed over time. A management survey is recommended during normal occupation and use of the building to make sure the existing asbestos and ACM is being managed. A refurbishment or demolition survey may be necessary when the building (or part of it) is going to be refurbished or demolished. Management survey The purpose of the asbestos management survey is to systematically identify and manage all asbestos in the workplace. The survey has to provide sufficient information to indicate the presence and location of asbestos or ACM, carry out a suitable risk assessment, and develop an asbestos management plan. A management survey is the standard survey carried out to identify asbestos in the workplace. Its purpose is to identify, so far as is reasonably practicable, the presence and location of any asbestos or assumed ACM in a building which could give rise to a risk of exposure to respirable asbestos fibres. This includes ACM that could be damaged or disturbed during normal occupancy, including foreseeable maintenance and installation. 3/05/2017 Ministry-Contracted Works Asbestos Procedure 12
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. It may depend on factors such as the type of building, the nature of construction, accessibility etc. Refurbishment and demolition surveys The purpose of asbestos refurbishment and demolition surveys is to locate all the asbestos in a workplace (or the relevant part) before work commences. It is a disruptive and fully intrusive survey which may need to penetrate parts of the building structure. Aggressive inspection techniques are used to lift carpets and tiles, break through walls, ceilings, cladding and partitions, and open up floors. In these situations, the asbestos surveyor needs to put controls in place to prevent the spread of debris. Refurbishment and demolition surveys should only be conducted in unoccupied areas to eliminate or minimise risks to the public or workers on the premises. Ideally, the building should not be in service and all furnishings should be removed. For minor refurbishment, this would only apply to the room involved or even part of the room if the work area is small and the room is large. In these situations, the asbestos surveyor must isolate the survey area (eg full floor to ceiling partition) and move furnishings, including carpet, away as far as possible or protect them with sheeting. The surveyed area must be fit for reoccupation if people are to move back in. This will require a thorough visual inspection and, if appropriate (eg if there was significant destruction), air monitoring. Under no circumstances should workers remain in rooms or areas of buildings when sampling occurs. There may be some circumstances where the building is still in use at the time a refurbishment or demolition survey is carried out. For example, in the educational sector, refurbishment/demolition surveys may be conducted in schools or colleges during a closure period (eg holidays), and the demolition or refurbishment work is not conducted until the next holiday period. When determining the type of survey required, it is important to note that Regulation 19 of the Asbestos Regulations states that demolition or refurbishment does not include minor or routine maintenance work, or other minor work. 3/05/2017 Ministry-Contracted Works Asbestos Procedure 13
Survey Definitions Demolition The term demolition is defined as completely destroy. The ACOP: Management and removal of asbestos lists examples of demolition: a. completely dismantling decommissioned industrial plant; b. total destruction of a building or part of a building that is load bearing or otherwise; c. related to the physical integrity of the structure; d. total destruction of an old boiler for disposal. Refurbishment The term refurbishment has the following definitions: a. to make clean, bright, or fresh again, and the state of being restored to its former good condition ; b. work such as painting, repairing, and cleaning that is done to make a building look new again ; c. servicing and/or renovation of older or damaged equipment to bring it to a workable or better looking condition ; d. is to rebuild or replenish with all new material and to restore to original (or better) working order and appearance ; and e. to clean and decorate it and make it more attractive or better equipped. Restoration In essence restoration means making a building or structure new again. The ACOP: Management and removal of asbestos (section 22.2) also provides example activities associated with refurbishment that include the partial demolition of: i. a boiler for cleaning and repairing; ii. large plant to access and remove asbestos-containing gaskets for replacing with; iii. non-asbestos-containing gaskets; iv. an asbestos cement roof by removing sections of it; v. part of a building for renovation, as long as it is not related to the physical integrity of the building. Maintenance The term maintenance has the following definitions: a. care or upkeep as of machinery or property; b. the process of preserving a condition or situation or the state of being preserved and the process of keeping something in good condition ; In essence maintenance is about keeping a building or structure in good condition. Appendix E of the ACOP: Management and removal of asbestos states that: a. Minor or routine maintenance work may include routine work that might be unscheduled and short in duration. b. The work may require partially dismantling a structure or plant. c. Minor work may include tasks such as cutting a small hole or hand-drilling a few holes in a cement sheet. It is generally not routine or regular, like planned maintenance. d. It is incidental work that can be done quickly and safely within minimal control measures required to ensure safety. 2.7. Sampling, Testing and Assessment/Reporting All sampling must be undertaken in such a way that any potential asbestos hazard it creates is adequately mitigated for those who may enter an area after sampling has occurred. Sampling and testing methodology needs to be included in the report of the survey. Separate parties may undertake the sampling, testing and the assessment report, or all three actions required for a survey may be undertaken by one individual. For example, for a high risk complex piece of work an asbestos consultant may undertake the specification for sampling based on the scope of works. A specialist company may then be engaged to undertake sampling to the specification, with an unrelated IANZ lab undertaking the testing of samples. The asbestos consultant may then develop the survey report. Alternatively, a specialist asbestos survey company with a laboratory may be engaged to undertake all three elements of a survey. The selection of either approach or a blend is dependent on the particular circumstances of the work to be undertaken and care should be taken to balance independence with objective risk, and market capacity and capability. 3/05/2017 Ministry-Contracted Works Asbestos Procedure 14
2.8. Survey Report Requirements Each survey report should contain the components listed below: School and building details; Name and qualification/experience of surveyor(s) and tester(s) if different; Sampling and testing methodology used; A marked-up plan of the building or area surveyed; Accreditation of Lab assessing samples; Pictures of the specific areas/materials tested with as a minimum: o sample reference number; o confirmed asbestos status (clear, not suspected, suspected, presumed, confirmed); and o type of asbestos found. All survey reports should be forwarded to the /School and recorded in the School s risk register. 3/05/2017 Ministry-Contracted Works Asbestos Procedure 15