Asbestos Management Plan

Management Plan Statement The following management plan has been produced and will be implemented so that the risks associated with known or presumed asbestos containing materials may be reduced to a minimum and that all persons whether employed by, subcontracted to or visitors to Norwood are protected from the risk or exposure to airborne asbestos fibres. This management plan has been produced with reference to the following HSE s publication Control of Asbestos at Work Regulations (CAWR) 2002 Asbestos (Licensing) Regulations 1983 as amended 1999 Hazardous Waste Regulations 1996 It is the attention of Norwood that, where Asbestos Containing Materials (ACM s) exist within or upon property or properties whether owned or under the control of this company that the following regulations, where applicable, will be adhered to: Control of Asbestos at Work Regulations (CAWR) 2002 Asbestos (Licensing) Regulations 1983 as amended 1999 Construction Design Management Regulations 1994 Special Waste Regulations 1996 Areas within a property or properties belonging to or under the control of Norwood, where, asbestos containing materials in a poor condition are present and where it is not possible or practicable to implement actions to repair and seal or remove them, will have access to them denied until actions as detailed in appendix B can be implemented. Type of Asbestos Recognised in this Report Crocidolite Blue Asbestos Amosite Brown Asbestos Chrysotile White Asbestos Removal All ACM's that are either in a poor condition and that cannot be safely or satisfactorily repaired and/or encapsulated will be removed. ACM's within a location where, the nature of work within that location has caused damage to or is likely to cause damage to the ACM's and where such materials cannot be satisfactorily protected, will be removed. Prior to any works, be it routine or incidental maintenance, planned refurbishment or other works, a risk assessment will be carried out to establish the likelihood of disturbance of any ACM's that may give rise to airborne asbestos fibres. Where there is a likelihood of disturbance to ACM's 2

and no methods of protection are available, the susceptible ACM's will be removed prior to the works being carried out. The removal of ACM's as designated by the Health and Safety Executive (HSE) as being licensed materials will be carried out by an HSE licensed removal contractor. All contractors will be required to show evidence of - A valid HSE issued license to carry out such works All relevant insurance for this type of work Proof of training and health monitoring of all operatives employed by the removal contractor during the removal project on this organisations site/sites Membership to a recognised trade organisation The removal of non-licensed materials The removal of non-licensed materials (see appendix E) may where possible be carried out by employees of Norwood. All removal will be carried out in line with the Control of Asbestos at Work Regulations (CAWR) 2002 and using the guidance of the HSE s "Working with Asbestos Cement" (HSG189/2). An assessment of the risk of airborne fibre likely to be produced will be carried out prior to the work. Where necessary, air monitoring will be carried during the removal work or results from air monitoring during similar works may be used to endorse the assessment Repair/remedial Works All work will be undertaken in compliance with the Control of Asbestos at Work Regulations 2002 and if applicable the Asbestos (Licensing) Regulations 1983, as amended 1998. An HSE licensed removal contractor will be contracted to carry out work if the material is Asbestos Insulation Board (A.I.B), asbestos pipe lagging, asbestos sprayed laggings or coatings, textured ceiling coating, textured wall coating, or any material which work upon is regulated by the Asbestos (Licensing) Regulations 1996. Management of ACM's (Where leave in situ and manage is advised) This refers to the monitoring and or implementation of any control measures concerning materials that are found to contain asbestos. Materials, which, are deemed to be in a good condition and are unlikely to be disturbed/damaged during normal day to day activities, may be left in situ but will be periodically inspected for signs of damage, wear or dilapidation. Periodic inspection of all ACM's identified within the survey report. During the re-inspection, further risk assessments of ACM's will be carried out. Any findings during the re-inspection that differ from the original survey will be included within the re-inspection report. Manage also refers to the protection of people from the risk associated with ACM'S. This includes maintenance personnel (internal and/or external) other personnel working, visitors and members of the public. The following methods may be implemented to achieve this:- 3

Informing all relevant personnel of the location of ACM's and instructing them not to disturb the material/s Labelling ACM's with warning labels Enforcing a permit to work system Ensuring ease of access to the survey report via holders of the report Where it is recommended that remedial work be carried out on ACM's, control measures may be enforced to protect personnel from associated risks until the work has been carried out, such as restricting access to key personnel only. Re-evaluation of materials risk assessments will be carried out if a change of use is applied either to the material or its surrounding. The management process will also ensure that any work on ACM's and or its disposal is carried out in line with all relevant regulations. Licensed Materials Any asbestos containing material having a density less than 1 tonne per cubic metre are classed by the HSE as licensed material. (See appendix E) Asbestos insulation, asbestos coatings and A.I.B are classed as licensed materials and work on these materials is regulated by the Asbestos (Licensing) Regulations 1983 as amended 1999. The Asbestos (licensing) Regulations 1983 as amended 1999 ban anyone from carrying out work with asbestos insulation, asbestos coatings and A.I.B unless they hold a license granted by the HSE. (See the Asbestos (licensing) Regulations 1983 regulations for exemptions to this rule) Non Licensed Materials Asbestos containing materials with a density greater than 1 tonne per cubic metre are classed by the HSE as non-licensed material. Asbestos cement products are a mixture predominantly of cement and asbestos that has been compressed or moulded to a high density and in a dry state has a density greater than 1 tonne per cubic metre. Products made from asbestos cement include corrugated and flat sheet, rainwater gutters and down pipes and W.C. cisterns. Work on asbestos cement products is not regulated by the Asbestos (licensing) Regulations 1983 as amended 1999, nor are articles made from rubber, plastic, resin or bitumen, but which also contain asbestos (e.g. vinyl floor tiles, electric cables, roofing felt etc). Other exemptions include ACM s used at high temperature but which have no insulation purpose, such as gaskets, washers, ropes and seals. Work done on any material containing asbestos must conform to the Control of Asbestos at Work Regulations 2002. 4

Hazardous Waste Any material that has an asbestos content greater that 0.1% by weight will be disposed of (when removed) as hazardous waste in accordance with the Hazardous Waste Regulations 2005 5

Appendix A List of Asbestos Containing Materials, Their Location and Risk Category (in order of risk) as Identified in the Asbestos Inspection Report 6

Location High Risk Immediate Attention Required Asbestos Material Description Type Comments 7

Location Medium Risk Encapsulate/Remedial Works/Remove Asbestos Material Description Comments Type 8

Location Low Risk Manage: Plan Remedial Works/Encapsulate/Removal Asbestos Material Description Comments Type 9

Location Very Low Risk Manage Asbestos Material Description Type Comments 10

Appendix B Asbestos Containing Materials and Actions Required Following Initial Inspection 11

Risk Category New Risk Category Asbestos Containing Materials and Actions Required Following Initial Inspection Area/Room Number Material Description (and location where applicable) Action Required Date Required Date Carried Out 12

Appendix C Asbestos Containing Materials and Actions Required Following Periodic Inspection 14

Risk Category New Risk Category Date of Inspection Asbestos Containing Materials and Actions Required Following Periodic Inspection Area/Room Number Material Description Action Required Date Work Required Date Work Carried Out 15

Risk Category New Risk Category Date of Inspection Area/Room Number Material Description Action Required Date Work Required Date Work Carried Out 16

Page17 Appendix D Work Log Issue Date 07/03/2017 Issue 1 Document No: 011 Uncontrolled when copied

Page18 Work Log Location Material reference and its location:- Date Action Required :- Description of Work :- Method Statement :- Work Authorised by Work Carried out by Date Work Started Further Actions Required :- Date Work Finished Issue Date 07/03/2017 Issue 1 Document No: 011 Uncontrolled when copied

Page19 Appendix E Pre-Work Flow Chart (Example) Issue Date 07/03/2017 Issue 1 Document No: 011 Uncontrolled when copied

Page20 Pre-Work Flow Chart Operative/Supervisor Name Contractors Name Location / Building No Nature/Description of Work Operative/Supervisor Signature Works Manager Name Works Manager Signature Date A) Has the building, structure or area where the work is planned been inspected or surveyed for Asbestos Containing Materials (ACM) B) Is the proposed work being carried out on or within building, structure or area identified in the survey/ inspection report as containing ACM s C) Has the operative or supervisor viewed the asbestos report covering the working area? D) Does the asbestos survey report identify any asbestos containing materials within this area? E) Is the proposed work liable to disturb this material? F) Can the asbestos containing material be protected from the work so that any damage/disturbance will be prevented G) Are the asbestos containing materials classed as HSE licensed materials? (See list of licensed and unlicensed materials in Appendix E) H) Will or is the damage/disturbance of the non-licensed ACM s likely to produce debris or give rise to airborne asbestos fibres I) If Yes Has the operative received guidance on working with these types of material, including methods of dust suppression, use of Personal Protective Equipment (PPE) & Respiratory Protective Equipment (RPE) and the disposal of Hazardous waste materials. Y N If Yes Go to B) If No an inspections or survey must be carried out prior to the work commencing Y If Yes Go to C) N If No The proposed work may be carried out Y If Yes Go to D) If No the named Operative/Supervisor must view the N asbestos survey report. After reading the report go to D) Y If Yes Go to E) N If No The proposed work may be carried out. Y If Yes Go to F) N If No The proposed work may be carried out. Y N Y N If Yes the work may be carried out after a detailed method statement for the protection of the material has been created and approved. If No Go to G) If Yes - Contact Norwood asbestos management plan manager. The work must not be carried out without the permission of this person. If No Go to H) Y If Yes Go to I) If No The work may be carried out, but proof will be required. Background air testing during the work is advised or the results N of air tests conducted during previous work carried out on a similar material using the same method of work should be referred to. Y N If Yes The proposed work may be carried out using appropriate control measures If No guidance/training must be carried out prior to this work being carried out. Referral should be made to the Working with asbestos containing materials which do not require a license Issue Date 07/03/2017 Issue 1 Document No: 011 Uncontrolled when copied

Page21 The signature of the operative at the top of this page is to signify that all the necessary sections above have been addressed and complied with Issue Date 07/03/2017 Issue 1 Document No: 011 Uncontrolled when copied

Page22 Appendix F HSE Licensed Asbestos Materials in Buildings Issue Date 07/03/2017 Issue 1 Document No: 011 Uncontrolled when copied

Page23 HSE LICENSED ASBESTOS MATERIALS IN BUILDINGS Sprayed coatings applied in the UK were typically a mixture of hydrated asbestos cement containing up to 85% asbestos, mainly Amosite but Crocidolite and mixtures have been used. Primarily used for anti-condensation and acoustic control and fire protection to structural steelwork. It is likely to release fibres, if disturbed especially during repair and maintenance work. As it ages the binding medium of sprayed asbestos may degrade with the consequent release of more fibres. Thermal insulation to boilers, vessels, pipe work, valves, pumps etc also known as hand applied lagging. Lagging may have a protective covering of cloth, tape, paper, metal or a surface coating of cement. All types of asbestos may be found in lagging and the content can vary between 15 and 85% asbestos with the protective papers being up to 100% Chrysotile. The likelihood of fibre release depends upon its composition, friability and state of repair, but it is particularly susceptible to damage and disturbance through maintenance work or the action of water leaks. Asbestos insulating boards usually contain between 16 to 45% Amosite, although boards may be found to contain other types of asbestos and in other quantities. As insulation board is semi-compressed it is more likely to release fibres as a result of damage or abrasion. Work on asbestos insulation board can give rise to high levels of asbestos fibre. Millboard, paper and paper products usually have an asbestos content approaching 100% with all three types of asbestos being used in their manufacture. They were used for insulation of electrical equipment and for thermal insulation. Asbestos paper has been used as a laminate for fireproofing to various fibre panels. Textiles for insulation Ropes, ccloth and yarns etc that have been used for insulation purposes, are usually high in asbestos content, approaching 100% and all three types of asbestos have been used in their manufacture. Examples; Asbestos rope or cloth wrapped around an engine exhaust pipe for the protection against the heat especially in an enclosed space Asbestos rope or cloth wrapped around a heating pipe for insulation Heat/fire resistant packing materials in boilers Textured coatings. Decorative coatings on walls and ceilings usually contain less than 2% Chrysotile. Fibre release may occur when subjected to fine abrasion. NON-LICENSED ASBESTOS MATERIALS IN BUILDINGS Asbestos cement products as in roofing sheets, wall cladding, permanent shuttering, flue, rain water and vent pipes generally contain 10 to 15% of white asbestos fibre bounded in Portland Cement. All three types of asbestos have been used in the manufacture of asbestos cement. The asbestos fibres in asbestos cement are usually firmly bound in the cement matrix and will be released only if the material is mechanically damaged or as it deteriorates with age. Textiles non-insulation Ropes, ccloth and yarns used as gasket material (where their thermal value is incidental to their use) are usually high in asbestos content, approaching 100% and all three types of asbestos have been used in their manufacture. Examples; Pipe jointing and gaskets and flue pipe seals Fire blankets, mattresses and protective curtains, gloves, aprons, overalls Issue Date 07/03/2017 Issue 1 Document No: 011 Uncontrolled when copied

Page24 Seals to oven doors Gaskets between sections in a sectional boiler The risk of fibre release depends upon the structure of the material, bonded gasket material is unlikely to release asbestos but an un-bonded woven material may give rise to high fibre release especially if when damaged or frayed. Bitumen felts and coatings may contain asbestos either bound in the bitumen matrix or as an asbestos paper liner. Thermoplastic floor tiles can contain up to 25% asbestos usually Chrysotile, PVC vinyl floor tiles and un-backed PVC flooring normally 7-10% Chrysotile and asbestos paper backed PVC flooring the paper backing may contain up to 100% Chrysotile. Mastics, sealants, putties and adhesives may contain small amounts of asbestos. The only possible risk is from sanding of hardened material when appropriate precautions should be taken. Reinforced plastic and resin composites, used for toilet cisterns, seats, banisters, window seals, lab bench tops, brakes and clutches in machines. The plastics usually contain 1-10% Chrysotile and were used in for example car batteries to improve the acid resistance. Resins may contain between 20 and 50% Amosite, but because of its composition fibre release is likely to be low, even during cutting. The above is not intended to be an exhaustive or definitive list Issue Date 07/03/2017 Issue 1 Document No: 011 Uncontrolled when copied

Page25 Appendix G Method statements, notification documents, air clearance certificates and waste disposal forms (section 62) and other forms created during the removal of and/or other works involving ACM s Signed for and on behalf of the company Jo Shuttlewood HR Director Issue Date 07/03/2017 Issue 1 Document No: 011 Uncontrolled when copied