Asbestos Management Retail Sector Forum 11 th March 2004

Asbestos Management

Retail Sector Forum

11th March 2004

Asbestos Management

Objectives Understanding of the requirements of the new regulations

– Background to asbestos– Regulations and duties– How do you meet the requirements

Background to Asbestos

What is asbestos?

Chrysotile

Amosite

Crocidolite

Background to asbestos

“The

Magic

Mineral”


Where and how was it used?

Loose packing/sprayed – generally used as fire

breaks in ceiling voids

Lagging – pipes and boilers

Sprayed - in ducts, panels,partitions,soffits and

steel works

Insulation board – partitioning and ducts

Ceiling tiles


Where and how was it used?

Millboard/paper products – insulation of electrical

equipment and fire proofing wood fibreboard

Cement products – corrugated sheets, gutters

rainwater pipes and tanks etc

Textured coatings - artex

Bitumen products – roofing, coatings

Vinyl or thermoplastic floor tiles


Magic mineral to killer dust

The risks relate to breathing in fibres

Dependant on how much, how long and how many

different occasions you are exposed to it

Asbestos-related lung diseases, mainly cancers

Can take 15 - 60 years to develop

There is no cure for asbestos-related diseases


History in UK

Voluntary and formal bans since 1969

Use of blue asbestos stopped (almost completely)

– 1970

Spray coatings decreased from 1970 – 1980.

Banned in 1985

Use of asbestos insulation board stopped -1985


History in UK

Blue and brown asbestos banned – 1985

Use of asbestos paints and varnishes stopped –

1988

Asbestos in decorative plasters banned – 1992

Use of asbestos cement prohibited - 1999

Current Regulations

The Control of Asbestos at Work Regulations 2002

Duty to manage asbestos in non domestic premises (Regulation 4)

The management of asbestos in non domestic premises (ACoP L127)

A comprehensive guide to managing asbestos in premises (HSG 227)

Current Regulations

Who is the Duty Holder?Regulation 4(a) “every person who has, by a virtue of a contract or tenancy, an obligation of any extent in relation to the maintenance or repair of non-domestic premises or any means of access thereto or egress therefrom: or”

(b) “in relation to any part of non-domestic premises where there is no such contract or tenancy, every person who has, to any extent, control of that part of those non-domestic premises or any means of access thereto or egress therefrom”

Current Regulations

Who is the Duty Holder?

“Where there is more than one duty holder, the relative contribution to be made by each such person in complying with the requirements of this regulation will be determined by the nature and extent of the maintenance and repair obligation owed by the person.”

Current Regulations


Which means what?Owner/Occupier

Managing agent

Tenant

Landlord

Other

Current Regulations


Check your situation

Look at the contracts you have in place

Talk to the others involved

Clearly define who is responsible for what areas

Document it!

Current Regulations

What are your duties?

Take reasonable steps to determine the location and condition of any materials likely to contain asbestos

Presume materials contain asbestos unless there is strong evidence that they do not

Make and keep up to date, a record of the location and condition of the asbestos containing materials (ACM’s) or presumed ACM’s in your premises

Current Regulations


Assess the risk of the likelihood of anyone being exposed to fibres from these materials

Prepare a plan setting out how the risks from the materials are to be managed

Take the necessary steps to put the plan into action

Current Regulations


Review and monitor the plan periodically

Provide information on the location and condition of the materials to anyone who is liable to work on or disturb them

Ensure a suitable safe system of work is put in place to take account of any work on locations where ACM’s or presumed ACM’s is to be undertaken

How do you manage your requirements?

Different people will tell you different things!

HSE has identified a 7 step process, split into 2 sections

i) Immediate actions

ii) Continuing actions


Immediate actions

Step 1

Confirm what you already know about the ACMs in your building(s) and review current management


Organisations fall into 1 of 3 categories

Have been managing and have historic records

Have done something, (maybe some removal in

past)

Have done nothing


Do you have a policy?

What is the age of the building?

Major recent refurbishment?

Previous asbestos records?

Construction records?

Refurbishment / Fit out records?


Immediate actions

Step 2

Prevent work on your premises that may disturb fabric of building until you can control the risks


Immediate actions

Stop short term activity that includes:• Drilling

• Breaking

• Removing

• Sawing etc

Check contractors for their own risk assessments

If you don’t know………………don’t do!


Immediate actions

Step 3

Carry out initial inspections for damage or disturbance and take appropriate actions


Immediate actions

Inspect to identify major risks

This inspection should not be confused with a

survey

You are looking for current problem areas (if any)

or suspect materials that could pose problems


Immediate actions

Steps 1-3 can be carried out individually, or

Undertaken as part of a single review

Whichever way though, you should be doing them

now or better still have done them already!


Continuing actions

Step 4

Develop a strategy for compliance


Continuing actions

You can……..

Presume all materials are asbestos containing

Survey your premises to find ACMs

Gather strong evidence to show materials are not

asbestos

Use a combination of the above


Presume all materials contain asbestos

If there are only a few suspect materials this may be an option

If there are many suspect materials, it could be both difficult and costly to manage


Survey your premises

Type 1 Location and assessment survey

(presumptive survey)


Type 1 Survey

Involves a visual inspection only (no sampling)

Materials that could be asbestos must be

presumed to contain it

Advantage – Inexpensive (in the short term)

Disadvantage - All suspect items must be risk

assessed and then managed as asbestos



Type 2 Standard sampling, identification and

assessment survey (sampling survey)


Type 2 Survey

As type 1 survey, but includes sampling

Advantage, you are only assessing and managing

known asbestos

Disadvantage, are more expensive and may

damage otherwise intact surfaces



Type 3 Full access sampling and identification

survey (pre-demolition/major refurbishment survey)


Type 3 Survey

Includes opening up structures completely (Types

1 and 2 don’t)

Advantage, you know where all your asbestos is

Disadvantage, are very expensive and disruptive

Should be considered as part of CDM for major

works


Your surveyor should :-

Have adequate training and experience in this

work (i.e. be P402 Qualified)

Can demonstrate independence impartiality and

integrity

Have an adequate quality management system


Gather strong evidence to show material are not asbestos

Find out as much as practical on your building(s)

Gather together all the relevant information and

verify it

Combine it with an inspection of the building


“If the inspection provides strong evidence to

believe that there is no ACM’s in the building,

nothing else needs to be done, except:”

• Keep a record of your work

• Review it if any new information is received

(para 58 L127)


Continuing actions

Step 5

Undertake a risk assessment of your ACM’s to set

management practices


Risk assessment

Material assessment

+

Priority assessment


Material Assessment

Looks at the type and condition of the ACM and

the ease with which it will release fibres if disturbed

Should be done as part of survey

Will give you a numerical score



Priority AssessmentLooks at the likelihood of someone disturbing the

ACM

Should take account of:-

• Occupancy of the area (normal occupant or visitor)

• Maintenance activities (including cleaning)

• Other activities carried out in the area

• Frequency of the above

Again it is a numerical score



Priority Assessment

“Although a surveyor may have some of the information which will contribute to the risk assessment, and maybe part of the team, the duty holder under the CAW is required to make the risk assessment.”

(MDHS 100)


Risk Assessment

Will give you scores for all yours ACMs

These can then be used to set your priorities for

work

Your priorities can be used as a basis for your

management plan


Ongoing Actions

Step 6

Develop a long term management plan


Your management plan must include:

How to communicate with employees, contractors and others

Your scheme to monitor the condition of the ACMs

A safe system of work for all ACMs

Training

Document your plan and management control information

Step 7

Review and monitor your plan


Ongoing Actions


Ongoing Actions

Frequency dependent on your plan/risk

assessment

If any new information comes to light – review

immediately

Document all reviews


Management options

Label

Colour code

Protect/enclose

Seal/encapsulate

Repair

Remove (last option)

ReviewReview

ResponsibilitiesResponsibilities

Material & Priority Risk AssessmentMaterial & Priority Risk Assessment

Implementing Controls

Implementing Controls

RecordsRecords

PolicyPolicy

ems Asbestos

Management

ems Asbestos

Management

Written SchemeWritten Scheme

TrainingTraining SurveySurvey

CheckingInspectingMonitoring

CheckingInspectingMonitoring


HSE – 10 key facts

If you don’t manage asbestos in your premises,

you could be putting your employees’ and other

peoples’ health at risk

Exposure to asbestos occurs when you or others

disturb it, releasing fibres into the air we breathe

Asbestos in good condition should be left in place

and managed


Most work on asbestos requires a licence, but

some minor work on asbestos can be done without

a licence if the correct precautions are followed

Regulation 4 of the Control of Asbestos at Work

Regulations is a duty to manage, not a duty to

survey


You don’t always have to do a survey, but you do

have to manage your asbestos-containing

materials (ACMs)

A bad survey is worse than not carrying out a

survey

Damaged or deteriorated ACMs should be

repaired or removed, or isolated until remedial

action can be taken


Managing asbestos means maintaining your

(ACMs) in good condition to protect two groups of

people:

• those who work on the fabric of the building (electricians,

plumbers etc); and

• those who work in the building (eg plant and office

workers, cleaners etc) who may come into contact or work

near damaged or deteriorated ACMs


Your Asbestos Management Plan:

• is your way of ensuring that your employees or others do

not disturb your ACMs;

• can take many forms and need not be complex, but it does

need to be effective

AnyQuestions?

Documents

Asbestos Management Retail Sector Forum 11 th March 2004