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University of Worcester ARM Policy and Procedures v1 11-03-13 MW463 Page 1 POLICY AND PROCEDURES FOR THE SAFE MANAGEMENT OF ASBESTOS CONTAINING MATERIALS (ACMs) July 2014

POLICY AND PROCEDURES FOR THE SAFE MANAGEMENT OF ASBESTOS …€¦ · 15.0 protocol for analytical works 16.0 specifications for abatement works 17.0 management of asbestos removal

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Page 1: POLICY AND PROCEDURES FOR THE SAFE MANAGEMENT OF ASBESTOS …€¦ · 15.0 protocol for analytical works 16.0 specifications for abatement works 17.0 management of asbestos removal

University of Worcester ARM Policy and Procedures v1 11-03-13 MW463 Page 1

POLICY AND PROCEDURES FOR THE SAFE MANAGEMENT OF ASBESTOS

CONTAINING MATERIALS (ACMs)

July 2014

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CONTENTS

1.0 INTRODUCTION

2.0 POLICY STATEMENT

3.0 ASBESTOS – RISKS AND HEALTH HAZARDS

4.0 LEGISLATION AND CONTROLS FOR ASBESTOS

5.0 MANAGING ASBESTOS IN BUILDINGS

6.0 ORGANISATIONAL ARRANGEMENTS – RESPONSIBILITIES

7.0 CIRCULATION OF THE POLICY AND PLAN

8.0 THE ASBESTOS REGISTER AND RECORDS

9.0 RISK ASSESSMENT AND MANAGEMENT PLAN

10.0 ACQUISITIONS AND DISPOSALS

11.0 REGULAR REINSPECTIONS OF RETAINED ACMs & RETENTION OF CONTROL

MEASURES

12.0 PROTOCOL FOR ASBESTOS SURVEYS

13.0 ACTIONS TO PREVENT EXPOSURE TO OR ACCIDENTAL RELEASE OF

ASBESTOS

14.0 PROTOCOL FOR LABELLING OF ACMs / PRESUMED ACMs

15.0 PROTOCOL FOR ANALYTICAL WORKS

16.0 SPECIFICATIONS FOR ABATEMENT WORKS

17.0 MANAGEMENT OF ASBESTOS REMOVAL / ENCAPSULATION WORKS

18.0 PROCEDURES FOR CAPITAL WORKS AND REFURBISHMENT WORKS

19.0 PROCEDURES TO BE FOLLOWED FOR REACTIVE MAINTENANCE WORKS

20.0 TRAINING AND INDUCTION

21.0 PERMIT TO WORK SYSTEM

22.0 EMERGENCY PROCEDURES

23.0 MONITORING AND PERIODIC REVIEW OF THE ASBESTOS POLICY AND

PROCEDURES

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1.0 INTRODUCTION

1.1 This document is intended to describe how proactive asbestos risk management

arrangements operate in University of Worcester premises. It also demonstrates how

statutory obligations are satisfied with respect to the Health and Safety at Work Act 1974

and the Control of Asbestos Regulations 2012 (CAR2012).

1.2 The following details specify the procedures that are to be followed to implement the

requirements of CAR2012.

1.3 The presence of an asbestos containing material (ACM) in itself does not constitute a

danger. However, there is a potential risk to health if such material is disturbed and

damaged. An isolated accidental exposure to asbestos fibres for a short duration is

extremely unlikely to result in the development of asbestos related diseases. However,

regular exposure – even at relatively low levels – can present a risk. As well as people

employed in the building trades, inadvertent exposure (and consequent risk) can occur in

other groups of people e.g. installers of IT systems, fire alarm systems etc.

1.4 Working with, and managing, ACMs is controlled by legislation, primarily the CAR2012.

Responsibility for ensuring compliance with this legislation has been delegated to the

Estates Services Department.

1.5 The University of Worcester is committed to the safe management of ACMs across the

portfolio and the safety of staff members, students, contractors, and members of the public

across the campuses.

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2.0 POLICY STATEMENT

2.1 The dangers of exposure to asbestos in the construction and maintenance industries are

well documented. The University of Worcester recognises the problem and has

implemented procedures to ensure the identification and management of ACMs is

undertaken in a controlled manner in the premises that are owned, controlled, and/or

operated by The University of Worcester.

2.2 As part of the building management, development, and refurbishment process, works on

the building structures and services will be necessary. The University of Worcester is

committed to providing awareness, information, instruction, and advice to its own

employees and others, who may be exposed to the dangers of asbestos on University of

Worcester premises.

2.3 The University of Worcester will engage a specialist asbestos consultant to assist in the

identification and safe management of ACMs in its premises.

2.4 The University of Worcester will expect all persons who can authorise works in any of its

premises to advise those who will be completing the work exactly where ACMs or

suspected ACMs are likely to be found.

2.5 The University of Worcester, as part of its Health and Safety Policy, require that all

contractors will ensure that suitable asbestos awareness training has been provided to all

staff at risk and maintain an asbestos risk management system. All contractors will be

required to produce a Risk Assessment for the works that includes consideration of

asbestos risks and they will need permission to proceed from the Estates Services

Department in advance of the works commencing.

2.6 The University of Worcester policy is that only contractors who have had specific approval,

and who hold a current and valid HSE license to work with asbestos are permitted to

conduct work on ACMs in University of Worcester premises. The University of Worcester

will not proceed with any maintenance and refurbishment work in pre-2000 build premises

without the involvement of the Asbestos Consultant.

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2.7 Aims of the Policy:

To ensure, so far as is reasonably practicable, that no person comes to harm from the

continued presence of ACMs in University of Worcester controlled premises through strict

adherence to the requirements of the Health and Safety at Work Act 1974, Management of

Health and Safety at Work Regulations 1999, CAR2012, and CDM Regulations 2007.

To prevent the exposure of persons to asbestos and to prevent the spread of asbestos on

University of Worcester sites.

To ensure that all ACMs removed from University of Worcester controlled premises are

handled, stored and transported in accordance with all legislative requirements and are

disposed of at sites holding the required permits in strict accordance with the Environmental

Permitting (Amendment) Regulations 2013

2.8 Objectives of the Policy:

To ensure that:

All University of Worcester premises constructed pre-2000 have an up-to-date asbestos

risk assessment and register.

All University of Worcester sites where ACMs have been identified have a suitable action

plan for managing that risk and that the plan has been suitably actioned.

All contractors engaged to undertake work which could conceivably disturb ACMs /

presumed ACMs on University of Worcester sites are suitably competent and have robust

procedures to identify and manage such risks in accordance with the CAR 2012.

Suitable information on the location and condition of ACMs on University of Worcester

controlled sites is provided to all persons likely to disturb them through easily accessible

and updatable systems.

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All University of Worcester employees who could conceivably disturb asbestos during their

normal, everyday working activities, or who supervise / influence such persons, are

provided with regular asbestos awareness training.

Only approved and HSE licensed contractors can conduct ‘work with asbestos’ on

University of Worcester premises – i.e. disturbance, repairing / sealing, and removal of

ACMs.

Uncontrolled disturbance of asbestos does not occur on any premises at any time; but in

the event that it does, to ensure that robust emergency arrangements are in place to

manage the situation and reduce risk.

The University of Worcester are in full compliance with the requirements of the CAR2012 at

all times, so far as reasonably practicable, and that no enforcement action is taken by HSE

or Local Authorities in relation to asbestos risk on any University of Worcester site.

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3.0 ASBESTOS – RISKS AND HEALTH HAZARDS

3.1 University of Worcester premises are distributed across campuses in Worcester:

St John’s Campus

Riverside

City Campus

3.2 The University of Worcester owns a number of residential, domestic, educational and

commercial buildings, some of which are leased and occupied by others - for all of which the

University of Worcester is responsible for maintenance. The full schedule of buildings which

are owned or leased by the University of Worcester is held by the Estates Services

Department.

3.3 The building portfolio is composed of buildings of various ages, including new build

construction and listed buildings. Asbestos materials were extensively used in buildings

constructed before the year 2000. It is recognised by the University of Worcester that

there will be ACMs within those buildings owned or leased that were constructed before the

year 2000.

3.4 There is an asbestos register of all known retained asbestos materials within the estate.

3.5 The University of Worcester will manage retained ACMs ensuring that they are

maintained in a good state of repair or remediated where necessary and as such ensure

that they do not pose a risk to building users or contractors

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4.0 LEGISLATION AND CONTROLS FOR ASBESTOS

4.1 Health & Safety at Work etc. Act 1974

Section 2 (1)

It shall be the duty of every employer to ensure, so far as is reasonably practicable, the

health, safety and welfare at work of all his employees.

Section 2 (2) d (the same duty extends)

To any place of work under the employers control to be maintained in a condition that is

safe and without risk to health.

Section 3 (1) requires that every employer is to conduct his undertaking in such a way

as to ensure that persons not in his employment who may be affected are not exposed

to risk of health and safety.

4.2 Defective Premises Act 1972 / Environmental Protection Act 1990

Places duties on landlords to take reasonable care to see that tenants and other people

are safe from personal injury or disease caused by a defect in the state of the

premises.

Any premises in such a state as to be prejudicial to health constitute a statutory

nuisance under Section 79 of the Environmental Protection Act 1990.

4.3 The Management of Health & Safety at Work Regulations 1999

Regulation 3

Every employer shall make a suitable and sufficient assessment of:

a. Risks to his employees.

b. Risks to persons not employees but affected by his undertaking.

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4.4 Workplace, Health & Safety Welfare Regulations 1992

Regulation 5 (1)

The workplace shall be maintained in an efficient state, in efficient working order and in

good repair.

4.5 Occupiers’ Liability Act 1957

The occupier of a premises owes a duty of care to all his visitors in respect of dangers

due to the state of the premises or to things done or omitted to be done on them.

4.6 Environmental Protection Act

Defines contaminated land as:

“any land which appears to the local authority in whose area it is situated to be in such

a condition, by reason of substances, on or under the land, that:

a significant harm is being caused or there is a significant possibility of such harm

being caused, or;

b pollution of controlled water is being or is likely to be caused.”

4.7 Guidance on dealing with asbestos is given in:

a. Department of the Environment, Transport and the Regions Asbestos and Man-

made Mineral Fibres in Buildings Practical Guidance February 2000.

b. Health & Safety Executive Health and Safety Guidance (HSG) HSG264 Asbestos:

The Survey Guide January 2010.

c. Health & Safety Executive Health and Safety Guidance (HSG) HSG227 A

Comprehensive Guide to Managing Asbestos in Premises 2002.

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d. Interdepartmental committee on the Redevelopment of Contaminated Lane. ICRCL

Guidance Note 64/85 Second Edition. October 1990 Asbestos on Contaminated

Sites.

4.8 The Control of Asbestos at Work Regulations 2012

For regulatory purposes in Great Britain, work with asbestos containing materials is strictly

controlled by the CAR2012. CAR2012 apply to all activities which will or potentially may

disturb asbestos materials.

Regulation 4 of CAR2012 ‘Duty to Manage Asbestos’ in Non-Domestic Premises (21 May

2004) requires duty holders to:

a. take reasonable steps to find materials in premises likely to contain asbestos and to

check their condition;

b. presume that materials contain asbestos unless there is strong evidence to suppose

they do not;

c. make a written record of the location and condition of asbestos and presumed

asbestos-containing materials (ACMs) and keep the record up to date;

d. prepare a plan to manage that risk and put it into effect to ensure that:

(i) any material known or presumed to contain asbestos is kept in a good state

of repair;

(ii) any material that contains or is presumed to contain asbestos is, because of

the risks associated with its location or condition, repaired or if necessary

removed; and

(iii) information on the location and condition of the material is given to anyone

potentially at risk.

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Before starting any work with asbestos, or where asbestos is present, CAR2012 Regulation

6 requires an assessment to be made by a competent person with respect to the likely

exposure to employees.

There is no known ‘safe level’ of exposure to asbestos and the CAR2012 requires the

following to be complied with:

a Regulation 11 – Prevention or reduction of exposure to asbestos.

b Regulation 16 – Duty to prevent or reduce the spread of asbestos.

CAR2012 Regulations 19 and 20 states that air sampling, fibre counting, sample analysis

and 4-stage clearance procedure must only be carried out by laboratories which can

demonstrate they conform to ISO17025 by accreditation with a recognised accreditation

body such as UKAS (the United Kingdom Accreditation Service).

Regulation 3 of CAR2012 specifies conditions under which certain types of work on ACMs

may be conducted by appropriately trained persons under controlled conditions without a

HSE licence.

In addition to the above the University of Worcester operates a ‘restriction of access’

procedure for access and/or work in areas presumed or known to contain damaged

asbestos or asbestos debris. The main purpose of the system is to help prevent exposure

to and the spread of asbestos by ensuring that workers do not enter areas where they may

be exposed to concentrations of asbestos unknowingly or where workers may easily disturb

ACMs unknowingly.

It is generally recognised the first priority is to prevent the release of asbestos fibres to air.

This is achieved by:

a. identification as to the type, condition and extent of the asbestos

b. conducting risk assessments for identified or presumed ACMs

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c. actioning containment by encapsulation, enclosure or abatement where

materials are damaged or are likely to be damaged

d. restricting access and work in areas where ACMs could be disturbed

e. monitoring the condition of retained ACMs to ensure they remain in good

condition and are not damaged.

f. airborne fibre levels in concentrations greater than 0.01 f/ml should be

investigated to identify their source.

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5.0 MANAGING ASBESTOS IN BUILDINGS

5.1 OUTLINE

5.1.1 The measures available to manage ACMs include:

a. leaving the asbestos material in place without sealing and introducing a

monitoring system.

b leaving the asbestos material in place, effectively seal (encapsulate or

enclose) and introducing a monitoring system.

c removing and disposing of the asbestos material.

5.1.2 Where ACMs have been identified, appropriate remedial measures will be carried

out in accordance with the relevant regulations and guidance.

5.1.3 No material or equipment containing asbestos will be installed or specified for any

existing or new building.

5.1.4 Any works affecting ACMs are to be carried out using procedures which safeguard

the operatives, the occupants of the buildings, other members of the public and the

environment. The relevant regulations are to be followed when dealing with these

materials.

5.1.5 The following information should be used for guidance purposes only and the

Consultant or Contractor employed shall comply with all relevant current legislation

when dealing with asbestos materials.

5.1.6 The removal of materials, which will generate exposure levels above the control limit or the

10 minute peak exposure limit and/or are not classed as being sporadic and low intensity,

requires those persons carrying out work hold a licence granted by the Health and

Safety Executive. Advice on complying with these regulations is provided in the Approved

Code of Practice L143 ‘Managing and working with asbestos’. Practical advice and

guidance on removing sprayed asbestos coating, thermal insulation and asbestos

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insulating board are set out in the Health and Safety Executive Guidance HSG 247

Asbestos: The Licensed Contractors Guide.

5.2 RE-INSPECTIONS

5.2.1 Asbestos materials will be inspected annually to check for damage or deterioration;

this may alter the original Risk Assessment. Retained asbestos materials are inspected at

the interval frequency identified by the risk assessment, as a minimum retained

asbestos materials will be inspected at least annually. Information relating to the condition

of the ACMs is returned to the Estates Services Department who will update the

register and institute corrective actions as required.

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6.0 ORGANISATIONAL ARRANGEMENTS – RESPONSIBILITIES

6.1 The University has responsibility for compliance with The Health and Safety at Work etc.

Act. (1974) and all associated legislation. This includes specific legislation relating to

asbestos, primarily the CAR2012. This Management Plan and the Policy for the

Management of Asbestos should be read in the context of the University’s Health and

Safety Policy.

6.2 All Heads of Institute/Department, Managers and any other employee of the University

undertaking or organising any work which might interfere with the fabric of any of the

University’s premises is responsible for ensuring that the Estates Services Department is

notified in advance (by e-mail [email protected]) of any intended works and

permission obtained prior to any works commencing.

6.3 Managers will ensure that all of their staff familiarise themselves with the contents of the

Asbestos Policy and Procedures, insofar as it is relevant to their roles and responsibilities.

6.4 Responsibility for the implementation of the Asbestos Policy and Procedures, along with the

management of ACMs in premises is delegated to the Director of Facilities and Estates and

the Head of Estates Services.

6.5 Director of Facilities and Estates

Responsible for:-

The University’s compliance with the Asbestos Policy and Procedures and appropriate and

relevant legislation.

Reporting on legal compliance and any concerns/issues at University Board level.

Ensuring that the overall strategy for the safe management of asbestos issues within the

University is under the Estates Services Department’s control.

Delegating the principal functions of asbestos management to the Head of Estates

Services, the Contracts and Compliance Co-ordinator, and the Health & Safety Coordinator

for appropriate action by them and their staff and/or nominated consultants.

Managing this responsibility through the Facilities and Estates Management Team

meetings and membership of the University Health, Safety & Wellbeing Committee.

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Supporting applications for necessary or anticipated resource allocation from the

University’s central bodies.

Ensuring that appropriate Estates Services Department staff have sufficient and suitable

initial and update training with respect to asbestos issues.

6.6 Head of Estates Services

Responsible for:

Implementation of the Asbestos Policy and Procedures across the estate – at building level.

Maintaining the University’s Asbestos Register.

Carrying out management priority risk assessments on ACMs identified in the Management

and Refurbishment /Demolition asbestos registers.

Ensuring that the Asbestos Register is readily available to appropriate staff and contractors

and that a signed record is kept that they have seen it and been made aware of its

contents.

Identification and organisation of any remedial works necessary following survey/testing

programmes

Maintenance of Approved Licensed Asbestos Contractor (LAC) list

Liaison with accredited analyst/surveyor and LAC during both planned asbestos removal

and emergency procedures.

Implementing and managing survey/testing programmes.

Organisation of annual inspections of identified ACMs in each building.

6.7 Contracts and Compliance Supervisor

Responsible for:

Assisting the Head of Estate Services, Projects Managers and Building Services Manager

in the planning, management, delivery, and commissioning of refurbishment and

infrastructure upgrade projects across the University.

Reducing risks and disruption on such projects – as described above – and monitoring

quality throughout project delivery.

Monitoring ongoing projects to ensure that they are carried out safely and in accordance

with all Health and Safety principles.

Ensuring that all external contractors have suitable asbestos related competence and have

been inducted onto the University campuses.

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Ensuring that external contractors have been provided with suitable and sufficient asbestos

risk information to support the planned works.

Making sure that external contractor RAMS have been reviewed before works commence

and have been provided permission to proceed before works commence through the RAG

permissioning system operated by the University.

Providing technical knowledge and taking an active role in managing the University’s

statutory compliance and ensuring that the Asbestos Policy and Procedures are adhered to

at all times during inspections and works.

6.8 Projects Managers (Capital Projects)

Responsible for:

Compliance with the Asbestos Policy and Procedures during Capital Projects

Ensuring the competence of directly appointed contractors and consultants to identify and

manage asbestos risks during building works.

Issuing of relevant asbestos registers and marked site plans for routine maintenance and

major works to both contractors and project designers.

6.9 Building Services Manager

Responsible for:

Ensuring that the Operational Estates Team conduct planned, reactive, and small works in

a safe manner and in accordance with legal requirements.

Ensuring compliance with the Asbestos Policy and Procedures during all works undertaken

by the Operational Estates Team.

Ensuring that University Maintenance Teams have received suitable Asbestos Awareness

Training in line with Regulation 10 of CAR2012.

Assisting in the development of appropriate control procedures for all aspects of front line

delivery by the Estates Services Team.

Ensuring that the Operational Estates Team have full and uninhibited access to the

University’s asbestos register.

Ensuring that the Operational Estates Team are aware of the University’s Emergency

Procedures relating to asbestos disturbance.

Supporting the Contracts and Compliance Supervisor in the appointment of competent

external contractors and consultants, as appropriate, to support day to day FM works.

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6.10 Health & Safety Coordinator

Responsible for:

Investigating and reporting to the University Health, Safety & Wellbeing Committee on any

alleged incident of accidental asbestos exposure and for ensuring reporting of incidents

under Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 2013

(RIDDOR), where appropriate.

Notifying and referring to the University’s Occupational Health Service any member of staff

who may be involved in an incident of accidental asbestos exposure in order that medical

advice can be given.

Providing information on asbestos regulations/legislation/guidance notes and good practice

to the University.

Monitoring & auditing the effectiveness of the University’s Asbestos Policy and Procedures.

Providing the Health and Safety Executive with details of asbestos management

procedures if/when requested.

6.11 University Health, Safety & Wellbeing Committee

Responsible for:

Periodically reviewing the effectiveness of the Asbestos Policy and Procedures.

Reporting via the University Personnel Committee to the Board of Governors on the

effectiveness of the Policy

6.12 Occupational Health

Responsible for:

Providing occupational health advice to management and staff on issues relating to

asbestos.

Ensuring that any exposure is recorded on the employee’s personnel and medical notes

and retaining the notes for a period of forty years after the date of final exposure.

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6.12 Project Managers / Designers / CDMCs (including Externally Appointed)

Responsible for:

Ensuring that the University Asbestos Policy and Procedures and any associated guidance

is adhered to.

Ensuring that, before feasibility/design work is started on a project, the Asbestos Register is

consulted and sufficient information is obtained on any ACMs within the working area to

safely carry out the works. Where ‘intrusive’ works are planned, the Asbestos Consultant

must be commissioned by the University to undertake a HSG264 Refurbishment /

Demolition asbestos survey including CAD drawings to identify concealed ACMs. A

minimum of 6 weeks should be allowed to enable surveys, sampling, analysis and

reporting to take place.

Ensuring that the extent of the survey requirements are clearly communicated to the

Asbestos Consultant and to include areas outside of the main works area where service

connections may be made.

Ensuring that the outcomes of any survey are, as soon as they are received, passed to the

Head of Estates Services for uploading to the Asbestos Register.

If no asbestos is identified then the works can proceed with caution, bearing in mind the

possibility that the Asbestos Register and/or any additional surveys might not have

identified all ACMs.

Stopping any works and informing staff if suspected materials are discovered during the

course of the works and immediately seeking advice from Estates Services Department.

Ensuring that if asbestos is identified, which will be disturbed during the works, that the

Asbestos Consultant is commissioned, where appropriate, to prepare a scope and

specification including a schedule of all ACMs to be removed as a set of separate tender

documents.

Ensuring that only HSE licensed asbestos contractors and UKAS accredited consultants

from the University’s Preferred List are used, and that the asbestos elements of work are

exempted from any value engineering processes.

Ensuring that separate contracts are issued for asbestos remediation works and

subsequent asbestos testing/monitoring.

Informing all relevant staff, Contractors and Sub Contractors of the presence of any known

asbestos, which may affect the works. Additionally, contractors are to be instructed to

consult the Asbestos Register in order to familiarise themselves with the location of any

known asbestos, non-accessible areas, or restricted areas in the premises.

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Ensuring that all Risk Assessments, Method Statements and Notices (as may be required

under the Control of Asbestos Regulations 2012) are in place, and copies submitted to the

Asbestos Consultant for assessment, before any work is allowed to start on site. Copies

of all such documentation must be available for inspection on site at all times for the

duration of any asbestos related works.

6.13 University Maintenance Staff / Technicians

Required to:

Ensure that they have a clear understanding of the University Asbestos Policy and

Procedures.

Ensure that they are fully familiar with current legislation relating to the management of

ACMs.

Ensure that all staff working under their control have received an appropriate level of

asbestos awareness training.

Consult the University asbestos registers for the premises before work starts and feed into

the RAMS for the work.

Progress all works diligently but, if any suspect materials is encountered, to immediately

suspend operations and to contact Line Manager for further instruction.

6.14 Other University Employees

All persons employed by the University of Worcester will be responsible for:

Reporting to their Line Manager and the Estates Services Department any materials

suspected of containing asbestos where the material has become disturbed and/or

damaged.

Ensuring that the fabric of a building is not disturbed without prior approval from the Estates

Services Department.

6.15 General Contractors and Sub-Contractors

Required to:

Ensure that they have a clear understanding of the Asbestos Policy and Procedures.

Ensure that they are fully familiar with current legislation relating to the management of

ACMs.

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Ensure that all staff working under their control have received an appropriate level of

asbestos awareness training.

Ensure that all staff employed to work on the University’s Estate have been formally

inducted onto the campuses.

Consult the University asbestos register for the premises before work starts.

Ensure that where work may be affected by, or involves disturbance of, ACMs that one of

the University’s preferred HSE licensed contractors is engaged to carry out the work.

Ensure that any relevant risk assessments, method statements and statutory notices are in

place before work commences and submitted to the Estates Services Department at least 7

working days prior to the due commencement date.

Not to commence work until the appropriate permission has been given to proceed by the

University of Worcester.

Progress all works diligently but, if any suspect materials are encountered, to immediately

suspend operations and to contact Estates Services Department for further instruction.

Provide copies of all test certificates, Certificates of Reoccupation and evidence of correct

waste disposal within 10 (ten) working days of the completion of the work.

6.16 Asbestos Removal Contractors & Sub-Contractors

Asbestos Removal Contractors must be approved by the Duty Holder or their nominee

before any order is placed or contract awarded.

Are responsible for:-

Ensuring all works shall be undertaken in accordance with the requirements of the CAR

2012 and any other relevant regulations, Approved Codes of Practice and Guidance Notes

issued by the Health and Safety Executive, and any revision to them.

Providing statutory notice to the Health and Safety Executive as may be required prior to

the commencement of any asbestos related works or, by agreement with the Project

Manager, applying for a waiver to the statutory notice period. Copies of all such notices

must be submitted to the Head of Estates Services before work commences.

Ensuring that prior to the commencement of any works that the Estates Services

Department is notified of the areas to be isolated for the works and as necessary under the

statute the appropriate warning signs are to be erected.

Ensuring that the work area be completely enclosed to contain airborne asbestos fibres.

On rare occasions where enclosures may not be reasonably practicable, a written method

statement shall be prepared and agreed prior to the commencement of any works.

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Ensuring that the enclosure is kept under negative pressure. The extraction equipment

should be fitted with high efficiency filters, the filtered exhausted air should, where possible

be vented outside the building. If this is not possible air monitoring around the exhaust

area should be carried out.

Ensuring that entry to the work area whether enclosed or not is suitably restricted. Only

adequately trained personnel wearing suitable protective equipment are allowed to enter

the work area.

Ensuring that before work begins the enclosure has been given a thorough visual

inspection and control measures and equipment has been inspected to ensure they are in

good working order and have current certification. The area should then be smoke tested

where practicable. The contactor is to prove all smoke devices. The contractor is not to

commence stripping until the smoke test/site inspection approved certificate has been

issued.

Ensuring that when work has started:

1. The enclosure should be properly maintained

2. A thorough visual inspection of the enclosure and negative pressure equipment

should be carried out at the beginning of each shift and any defects found should be

repaired immediately.

3. The negative pressure equipment should run throughout the work including breaks

and for at least 60 minutes at the end of each shift.

4. Where buildings are occupied or a fully sealed enclosure is not possible, air

monitoring outside the enclosure should be carried out.

5. A record of inspections, defects etc. should be kept available for inspection.

6. All equipment practice procedures and facilities provided for the work are to be in

accordance with the current Regulations and ACOPs.

7. The contractor shall contact the Head of Estates Services to organise the four-stage

clearance testing upon completion.

8. The contractor is required to notify the relevant enforcing authority, as required.

9. The plan of work, medical examination certificates, face fit tests and training records

for all employees working with asbestos should be available on site throughout the

duration of the works.

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6.17 Asbestos Consultant

Is responsible for: -

Maintaining, and demonstrating UKAS accreditation to ISO17020 and ISO17025.

Maintaining adequate insurance cover for the tasks to be undertaken.

Providing support to the Head of Estates Services as may be required.

Reviewing and commenting, when requested by the Head of Estates Services on asbestos

works such as: specifications, Contractor’s and/or Sub Contractor’s Method Statement,

work procedures, etc – as required by the University of Worcester.

Conducting asbestos surveys and inspections in line with HSG264 and HSG227.

Carrying out analytical works and inspections as agreed with the Head of Estates Services.

Where site conditions alter, the Asbestos Consultant will be required to amend the level of

testing and inspections to ensure that all information relevant to the continued health and

safety of the Contractor and building occupants is obtained.

Reporting to the Head of Estates Services or his representative, any defect or non-

compliance relating to the Contractor’s and/or Sub Contractor’s performance, including

suitability of the work area, adherence to the Method Statement, Statutory Instruments, and

the University Asbestos Policy and Procedures. Where the Head of Estates Services is not

immediately available the surveyor/analyst will be expected to take such measures as may

be deemed necessary to ensure the continuing health and safety of Contractors and Sub

Contractors and building occupants. These actions must be reported to the Project

Manager as soon as reasonably practicable.

Checking areas on completion of asbestos remedial works to ensure that the contractor has

completed his scope of works and all affected areas have been left in a satisfactory

condition.

Carrying out air monitoring tests as may be required by the Project Manager or his

representative, or as identified in the Risk Assessment.

Reporting to the Head of Estates Services and others as may be appropriate, any aspects

of asbestos management encountered on site which could give rise to health risks e.g.

breaches of the Asbestos Policy and Procedures, suspect or damaged asbestos.

Issuing formal reports, including Certificates of Re-occupation, to the Project Manager on

completion of any site works

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6.18 Responsibilities for Records

Activity Responsible Manager

Production and maintenance of survey programmes

Head of Estates Services

Raising of orders for programmed survey work

Head of Estates Services

Issue of notification letters/memo to properties being

surveyed

Head of Estates Services

Production of Asbestos Register document

Head of Estates Services

Maintenance of Asbestos Register

Head of Estates Services

Payment records for programmed survey work

Head of Estates Services

Issue of orders to contractors for remedial works

Head of Estates Services

Payment records for remedial works

Head of Estates Services

Issue of Asbestos Register documents to properties

Head of Estates Services

Maintenance of records of samples tested for the presence

of asbestos

Head of Estates Services

Production of air testing documents and clearance

certificates

Accredited Analyst

Issue of air testing documents and clearance certificates

Head of Estates Services

Waste Carriage Documentation Licensed Asbestos

Contractors

Maintenance of University Asbestos Policy and Procedures

Health & Safety Coordinator

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7.0 CIRCULATION OF THE POLICY AND PLAN

7.1 A master copy of the Asbestos Policy and Procedures will be held electronically on the

University Intranet and a hard copy will be held in the Estates Services Office.

7.2 The Asbestos Policy and Procedures will be circulated in 2 ways:

o The intranet for those staff that can access the email system

o For those staff that cannot access the email system a hard copy will be sent on

request.

7.3 Copies of the Asbestos Policy and Procedures will be circulated as per the prevailing

Circulation List maintained by the Head of Estates Services.

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8.0 THE ASBESTOS REGISTER AND RECORDS

8.1 The Head of Estates Services shall compile and maintain the asbestos register to provide an

accurate database of all identified/presumed asbestos locations and conditions.

8.2 Annotated CAD plans are available showing the location of ACMs within the buildings and the

risk level as determined from the risk assessment.

8.3 The Asbestos register, surveys and annotated plans are available on Compliance365; the

University of Worcester web based asbestos compliance management system and the

internal password protected O: drive system. These systems can be accessed by relevant

University staff. The security staff have access to Compliance365 and the internal O: drive and

can provide the information out of hours or for an emergency services attendance.

8.4 Records and documentation pertaining to asbestos removal and remedial works will be

maintained by the Head of Estates Services via the Compliance365 system and internal O:

drive system.

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9.0 RISK ASSESSMENT AND MANAGEMENT PLAN

9.1 Where Asbestos materials have been confirmed or presumed, a risk assessment shall be

undertaken. The risk assessment shall include for:

9.1.1 Material Assessment

a. Product type

b. Extent of damage/deterioration

c. Surface Treatment

d. Asbestos type

9.1.2 Priority Assessment

a. Location

b. Access

c. Amount

d. Exposure (No of people)

e. Use

f. Average Time

g. Maintenance, type and frequency

9.2 Risk assessments are conducted by the Asbestos Consultant in conjunction with the Head of

Estates Services or persons nominated by the Head of Estates Services.

9.3 Where remedial action is required this will be instructed by the Head of Estates Services and

authorised by the Director of Facilities and Estates.

9.4 The risk assessment will determine the required reinspection interval and any further

actions. Reinspections will be undertaken annually as a minimum frequency.

9.5 Where areas are subject to change of use this is flagged to the Head of Estates Services.

Risk Assessments are reviewed for areas which are to be subject to change of use using

the new occupancy/maintenance requirements to determine whether any change of

action is required.

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10.0 ACQISITIONS AND DISPOSALS

10.1 Acquisitions: When the University or any other Business Unit of the University acquires

premises (by purchase, rental, lease or other) the person entering into the contract on

behalf of the University must ensure that all reasonable enquiries and surveys have been

made in order to identify the presence of ACMs. Findings must be recorded in the Asbestos

Register. The results must be acted on in order that the occupants and others remain free

from exposure to the identified hazards.

10.2 Disposals: Where buildings become the subject of disposals, information relating to the

presence of asbestos must be made available to the landlord or purchaser of that building.

Prior to the undertaking of any dilapidations or recovery of technical equipment, plant,

cables, furniture and fittings etc., the Asbestos Register must be consulted, and a detailed

report provided by the Head of Estates Services.

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11.0 REGULAR REINSPECTIONS OF RETAINED ACMs & RETENTION OF CONTROL

MEASURES

11.1 All retained asbestos materials will be inspected regularly to ensure the integrity and state

of repair of the material. Where the risk assessment has required that labels be affixed to

materials it will be ensured during the reinspection that labels are still in place.

11.2 These inspections shall be undertaken at intervals determined by the risk assessment, not

exceeding 12 months.

11.3 The inspections will be carried out by the Asbestos Consultant. Inspections shall be

recorded and the reports uploaded to Compliance365 and internal O: drive.

11.4 The reinspections schedules are managed through Compliance365, which details the

reinspection dates for each building containing ACMs.

11.5 Where the integrity and state of a material has changed or the area has changed use then

the risk assessment will be reviewed following the procedure in Section 9.

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12.0 PROTOCOL FOR ASBESTOS SURVEYS

12.1 HSG264 Asbestos: The Survey Guide is the current HSE guidance document for asbestos

surveying and sampling, and defines 3 types of survey:

a. Management Survey

This type of survey identifies the location and condition of ACMs which could be

damaged or disturbed through normal occupancy. The survey can involve a

combination of presumption and sampling. The use of caveats and survey

limitations accepted under MDHS100 is reduced.

b. Refurbishment Survey

This type of survey identifies the location of all asbestos materials that may be

disturbed during refurbishment works. This survey is required before any

refurbishment work. The use of caveats and survey limitations is highly restricted.

c. Demolition Survey

As above; but for demolition work.

12.2 All University of Worcester buildings constructed pre-2000 have been subjected to a

HSG264 Management Survey conducted by the Asbestos Consultant for normal

occupation.

12.3 Only organisations able to provide evidence of compliance with ISO17020 (General Criteria

for the operation of various bodies performing inspection) through accreditation by UKAS

will be appointed to undertake surveys on behalf of the University of Worcester.

12.4 Only organisations able to provide evidence of compliance with ISO17025 (General

requirements for the competence of testing and calibration laboratories) through

accreditation by UKAS will be appointed to take and analyse samples on behalf of the

University of Worcester.

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12.5 For live electrics which have been presumed to contain asbestos materials these will be

investigated when the annual power downs are undertaken to check the circuits. In

conjunction with the approved electrician, site attendance will be required by the Asbestos

Consultant to investigate the contents for suspected asbestos containing materials.

Where materials are found on surveys that are suspected to contain asbestos and are in a

poor condition/potentially posing a risk then the Asbestos Consultant will inform the Head of

Estates Services / Estates Services Department immediately. Access to the area will be

restricted following the procedure in Section 22.

12.6 Where areas are to be subject to refurbishment or demolition the Head of Estates Services

will ensure that a further HSG264 Refurbishment/Demolition survey is undertaken during the

planning stage of the areas subject to works. The survey will be provided to the contractor, the

Head of Estates Services and where applicable the External Project Manager, Designer

and/or CDM Co-ordinator prior to works commencing.

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13.0 ACTIONS TO BE TAKEN TO PREVENT EXPOSURE TO ASBESTOS OR ACCIDENTAL

RELEASE OF ASBESTOS

13.1 The actions to be taken to prevent exposure to or release of asbestos fibres to air may include

a combination of the following:

a. Identification

b. Labelling

c. Enclosure or Encapsulation

d. Permit to Work

e. Restricted Access

f. Management (Inspection and Procedures)

g. Training

h. Controlled and Monitored Abatement

i. Asbestos Management System updates

13.2 The communication of information on the presence or presumed location of asbestos

materials will be given to employees and contractors affected by the same. This

communication is implemented by the following:

Site Induction Pack

Permissioning (RAG) System

Compliance 365 System

13.3 Instructions on access restrictions in areas containing damaged asbestos or presumed to

contain damaged asbestos will be given to those likely to come into contact with the same

through the access restriction system. Surveys, annotated plans, and the asbestos register

are held on the Compliance365 system and the University of Worcester’s internal O: drive

which shows areas that contain asbestos materials.

13.4 Asbestos awareness training and refresher updates will be given to staff who in the course of

their work activity either come into contact with asbestos or who supervise or influence such

persons.

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13.5 It is a requirement that contractors working for the University of Worcester have current

Asbestos Awareness training – in line with Regulation 10 of CAR2012. This is verified at the

competency assessment stage prior to initial engagement and then at least annually thereafter

for term contracts.

13.6 The management of the asbestos or presumed asbestos will be controlled via a Permit to

Work system. Where any work is required in an area which contains asbestos, specific

permission is required prior to work starting.

13.7 Where a project falls under the Construction (Design and Management) Regulations 2007,

the CDM Co-ordinator ensures that the information relating to location of asbestos

containing materials is included within the Pre-Construction Information which is circulated

to all parties.

13.8 For projects which fall outside the Construction (Design and Management) Regulations

2007, the survey information is provided to the contractor by the client through the

Compliance365 system or via the Projects Manager/Contracts and Compliance Co-

ordinator. Through the work permissioning (RAG) system it is further ensured that persons

are provided with suitable and sufficient information appertaining to asbestos containing

materials in their work areas.

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14.0 PROTOCOL FOR LABELLING OF ACMS/ PRESUMED ACMS

14.1 Labels will be applied to presumed/identified asbestos materials in non-public areas.

14.2 The presence of labels will be confirmed by the re-inspections and they will be replaced

where necessary.

14.3 In the event that asbestos containing materials are damaged the area will be padlocked off

and a warning label applied to the access door in accordance with the University of

Worcester’s emergency procedures.

14.4 Asbestos warning labels will comply with the requirements of Schedule 2 of the CAR2012.

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15.0 PROTOCOL FOR ANALYTICAL WORKS

15.1 Air monitoring will normally be undertaken when confirmed asbestos materials are identified

in a state of disrepair and during the course of any remedial works.

15.2 Copies of all analytical monitoring certification/records are to be forwarded to the Head of

Estates Services for inclusion in the premises asbestos records and uploaded to

Compliance365 and internal O: drive. The Asbestos register will be amended accordingly

following receipt of analytical monitoring certification by the Asbestos Consultant and Head

of Estates Services.

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16.0 SPECIFICATIONS FOR ABATEMENT WORK

16.1 Specification and Management

16.1.1 All works involving the disturbance of asbestos requiring a HSE licence will be carried out in

accordance with the site specific Technical Specification and shall take into account all

statutory/general requirements together with the proposed future development of the site.

16.1.2 The specification, plan of work, and the monitoring and clearance testing strategy must be

compiled by the Asbestos Consultant and agreed with the Head of Estates Services prior to

implementation.

16.1.3 The management and monitoring of all licensable works involving the disturbance of asbestos

based materials shall be undertaken by the appointed Asbestos Consultant who will issue a

detailed ‘Description of Works’ which shall form part of the Specification.

16.1.4 The approved, Licensed Asbestos Contractor and the Analyst Consultant shall be appointed

independently by the University of Worcester.

16.1.5 During ‘work with asbestos’ an approved monitoring strategy shall be implemented to monitor

and ensure effectiveness of all control measures being employed on site.

16.1.6 All areas subjected to licensable disturbance of asbestos shall have clearance certification

issued prior to returning same to normal usage. The clearance certification shall be provided

to the Head of Estates Services who will issue a copy to the line manager in whose

department the works were undertaken. The original copy to be kept on file for reference for

40 years. The documentation will be uploaded to Compliance365 and the internal O: drive and

the asbestos register updated by the Asbestos Consultant and Head of Estates Services.

16.1.7 The University of Worcester will permit Licensed Asbestos Contractors to self-certify the

non-licensable abatement of asbestos and will provide the documentation to the Asbestos

Consultant so that the register can be updated.

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16.2 Detailed Working Procedures will be developed to the proposed work prior to work

commencing

16.2.1 Asbestos Removal Contractors

16.2.2 Only specialist, external contractors must undertake work on asbestos. The appointed

contractor must hold a current and valid licence from the HSE Asbestos Licensing Unit (ALU).

16.2.3 In accordance with Regulation 9 of CAR2012 only HSE Asbestos Licence Holders may

undertake certain types of work with ACMs. For these works, license holders are required to

give a minimum 14 days’ notice of intention to work on or remove asbestos to the Enforcing

Authority. Work may commence within the 14-day notice period only at the discretion of the

Enforcing Authority.

16.2.4 HSE has found that competency depends more on local management of a contractor rather

than the company itself. It is for this reason that the Head of Estates Services / Contracts and

Compliance Co-ordinator must satisfy himself/herself that the written Plan of Work and Risk

Assessment are adequate and also that essential precautions are being observed at all stages

of the contract.

16.2.5 Contractors’ Method Statements or written Plan of Work must detail how and where the work

will be carried out. The written Plan of Work will be kept within the premises asbestos file after

the work has been completed. In brief, the plan must include:

a. The nature and probable duration of the work.

b. The location of where the work is to be carried out.

c. The methods of handling asbestos or asbestos materials.

d. Details of the protection and decontamination equipment utilised by the

contractor’s employees.

e. The methods and controls for the protection of staff and others near to the work

site.

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f. The segregation and signage that will be utilised for the work area.

g. Asbestos waste disposal.

16.2.6 The Asbestos Consultant and the Head of Estates Services / Contracts and Compliance Co-

ordinator are responsible for authorising the LAC’s RAMS prior to works commencing.

16.2.7 Where asbestos work is being undertaken, the Head of Estates Services and Contracts and

Compliance Co-ordinator in conjunction with the Health and Safety Co-ordinator will

undertake active Health and Safety Monitoring. Where performance is found not to be

that required by the standards or there is deviation from the agreed method statement

then this will be notified immediately to the Health and Safety Department and the Estates

Services Department.

16.2.8 The minimum level of insurance cover is to be agreed with University of Worcester

representatives in advance of any tendering procedures commencing.

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17.0 MANAGEMENT OF ASBESTOS REMOVAL / ENCAPSULATION WORKS

17.1 See Appendix III for the defined procedure to be followed for all asbestos removal and

encapsulation works across the University Campus. All licensable works are to be

planned and tendered based on a Technical Specification produced by the Asbestos

Consultant.

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18.0 PROCEDURES FOR CAPITAL WORKS AND REFURBISHMENT WORKS

18.1 All planned refurbishment or capital works projects must be organised through the Estates

Services Department and involve the Head of Estates and the Contracts and

Compliance Co-ordinator. There is a strong link between the Feasibility Team and Estates

Services Team.

18.2 The University of Worcester employs a permissioning regime for planned works whereby all

risk assessments and method statements ( RAMS) must be received, reviewed, and

authorised by the Contracts and Compliance Co-ordinator prior to works being permitted to

proceed. The system ensures that contractors are not provided access to the work area by

the Reception/Security Team until the project status has been designated as Green on a

Red, Amber, Green (RAG) system. The projects are denoted on a contractor’s calendar.

Contractors are required to issue their RAMS for the works for review to

[email protected] at least 7 days in advance of works commencing. A red

designation means that RAMS are not received, an amber designation means that RAMS

have been received but have not yet been reviewed /not acceptable, and a green

designation means that RAMS have been received and reviewed as acceptable.

Only fully inducted and competent contractors are permitted to proceed with works on

the University of Worcester estate.

18.3 The University of Worcester will ensure that a dedicated Project Manager has been

appointed. The Project Manger may be either internal to the University or an Externally

Appointed Project Manager.

18.4 The nominated Project Manager will liaise with the Projects Manager, Head of Estates

Services / Contracts and Compliance Co-ordinator who shall check the University of

Worcester’s Asbestos Register and ascertain whether a current Refurbishment or

Demolition Survey has already been carried out for the work area.

18.5 The Head of Estates Services / Contracts and Compliance Co-ordinator, where required,

will instigate the Refurbishment or Demolition Survey to a standard in accordance with HSG

264. All orders for Refurbishment or Demolition Surveys shall:-

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a. be carried out by organisations which meet the qualification standards as detailed in

University of Worcester’s Asbestos Management Policy, Section 12.6. Specifically

they must be accredited to ISO/IEC 17020 and operate a Quality Management

System including a minimum 5% re-inspection by another surveyor, desk top audits

of completed surveys and a quality control scheme for checking survey reports.

Analysis of bulk samples shall conform to the requirements of ISO/IEC 17025 by

laboratories accredited by UKAS.

b. be issued in writing and must include a marked up CAD drawing or drawings clearly

identifying the extent of the survey. The updated CAD file for the building must be

issued electronically to the University.

c. specify the survey report must be received as 1No hard copy and 1No

electronic copy uploaded to Compliance365.

d. specify that the survey company must attempt to survey all areas and that they

are required to liaise with the Head of Estates Services should any areas not be

accessible.

e. specify surveys must be carried out in a diligent and professional manner and that

each area / room shall be cleaned by the surveyors as the survey proceeds.

f. survey reports shall specify details relating to the asbestos present or presumed

and include photographs and marked up floor plans.

g. specify that the surveyors must carry out a risk assessment and plan of work to

ensure the survey is carried out in a safe manner.

h specify insurance cover of £5m to cover injury or death to persons or injury or

damage to property and £5m level of Professional Indemnity Insurance.

i specify that where suspected asbestos materials are found that are in a damaged

condition they must be reported to the Head of Estates Services immediately.

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18.6 The Head of Estates Services must ensure adequate time, resource, and project

information are available to the surveyor to allow a thorough survey to be conducted prior to

any site works beginning.

18.7 The Head of Estates Services must liaise with the survey company to ensure wherever

possible all areas are surveyed. This may entail agreeing return visits and liaising with

other University of Worcester staff to ensure access is gained to previously inaccessible

areas.

18.8 Survey reports will be returned to the Head of Estates Services, the Projects Manager, the

Contracts and Compliance Co-ordinator, the nominated Project Manager, and for CDM

‘notifiable’ projects, the University of Worcester’s CDM Co-ordinator.

18.9 The Head of Estates Services, Projects Manager and/or the Contracts and Compliance Co-

ordinator will review the survey report and highlight significant issues for the nominated

Project Manager. In particular, the CDM Co-ordinator will highlight any areas which have

not been surveyed and hence where asbestos is presumed as well as highlight those

asbestos materials that have been found.

18.10 The nominated Project Manager, in conjunction with the Head of Estates Services, Projects

Manager and Contracts and Compliance Co-ordinator, shall ensure wherever possible

asbestos abatement is undertaken and the area is cleaned and certificated clear before

works commence.

18.11 In the event asbestos cannot be abated before works commence, the CDM Co-ordinator, in

liaison with the nominated Project Manager and Head of Estates Services/Contracts and

Compliance Co-ordinator, shall ensure relevant survey reports are issued to the Principal

Contractor before works commence wherever asbestos is known or presumed to be

present and ensure safe working practices are followed thereafter.

18.12 All management and monitoring of asbestos abatement work shall be carried out by the

Asbestos Consultant (management, monitoring and certification). The Asbestos Consultant

will:

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a. provide one set of Project Completion Documents detailing the asbestos

abatement work carried out, including analytical reports for air monitoring

undertaken within the location, the re-occupation certification issued upon

completion of the abatement works, as well as copies of the licensed asbestos

contractor’s hazardous waste consignment certificates.

b. remove or amend asbestos warning labels and restricted warning signs to reflect

the conditions prevailing after abatement.

c. update the asbestos register to reflect the works completed.

18.13 Where asbestos abatement work is being undertaken, the Head of Estates Services and

Contracts and Compliance Co-ordinator in conjunction with the Health and Safety Co-

ordinator, will undertake active Health and Safety Monitoring. Where performance is found not

to be that required by the standards or there is deviation from the agreed method statement

then this will be notified immediately to the Health and Safety Department and the Estates

Services Department.

18.14 The Asbestos Abatement Project Completion Document will be passed to the Head of

Estates Services and uploaded to Compliance 365 and the internal O: drive. These

documents will be retained within premises asbestos file held in the Estates Services

Department. The asbestos register will be updated following receipt of the Project

Completion Documents.

18.15 For notifiable projects, a copy of the Asbestos Abatement Project Completion Documents

will be passed to the CDM Co-Ordinator by the Head of Estates Services. The Head of

Estates Services and Contracts and Compliance Co-ordinator, in conjunction with the CDM

Co-ordinator, shall ensure the construction phase does not start unless the Principal

Contractor has prepared a Construction Phase Health and Safety Plan. This must be

sufficient to ensure the construction phase is planned, managed and monitored to enable

construction work to be started, so far as is reasonably practicable, without risks to health

or safety.

18.16 The University of Worcester Estates Services Department will ensure that the Health and

Safety file relating to a project includes the asbestos information and is kept available for

inspection.

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18.17 Please refer to Appendix I for a flow process for asbestos management during Capital

Works and Refurbishment Works.

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19.0 PROCEDURES TO BE FOLLOWED FOR REACTIVE MAINTENANCE WORKS

19.1 Reactive and planned maintenance is provided through the Estates Services Department

by Term Maintenance Contractors or internal maintenance teams following the University of

Worcester’s defined procedures.

19.2 External maintenance contractors working across the University of Worcester’s Estate must

be issued with ‘permission to proceed’ via the RAG system described in Section 17 prior to

commencing works.

19.3 The University’s internal maintenance teams must document that the asbestos register has

been consulted prior to commencing such work and detail any known asbestos risks in the

RAMS for the works. If asbestos risks are present that cannot be avoided or the risks

are unknown, then this must be referred to the Building Services Manager for advice and

support.

19.4 Cyclical and planned maintenance is carried out by Term Maintenance Contractors at

predetermined intervals with forethought, control and the use of records to an established

plan.

19.5 Appendix II illustrates the procedure to be followed for reactive maintenance requests.

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20.0 TRAINING AND INDUCTION

20.1 Training requirements are discussed at Directorate Management Meetings. Each Manager will

determine the specific training programme for their Department taking account of their risk

assessments and the risk to their staff.

20.2 All staff whose work could bring them into contact with asbestos materials, or who supervise

or influence such work, will receive Asbestos Awareness Training on a regular basis. The

course content will be:

The nature of asbestos, sources, and properties

Typical uses of asbestos in construction materials

Asbestos related health effects and diseases

Overview of legislation

Safe working procedures

University of Worcester Asbestos Policy and Procedures

Emergency procedures

20.3 All roles identified in the Asbestos Management Procedure and Policy and other staff, as

identified by the line Managers, who will have significant involvement with asbestos will hold

the BOHS (British Occupational Hygiene Society) P405 (Management of Asbestos in

Buildings including Safe Removal and Disposal) qualification.

20.4 Records of training will be maintained by the Director of Facilities and Estates through the

Ecocampus system.

20.5 In accordance with the requirements of Regulation 10 of CAR2012, employees of contractors

working on the University of Worcester premises are required to have current asbestos

awareness training and be able to demonstrate the competence of their employees.

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20.6 All contractors will be assessed for competency by the Contracts and Compliance Co-

ordinator and/or person responsible for the work before entering into a contract or placing an

order for work. As part of the competency assessment as detailed in the University of

Worcester’s Code of Safe Working Practices, details of the health and safety training provided

to operational employees is provided. It will be ensured that evidence of current Asbestos

Awareness training (i.e. conducted within the last year) is provided for those contractors who

are working within the trades stated in Paragraph 233 of the Approved Code of Practice L143

(Managing and Working with Asbestos).

20.7 For term contractors, the information will be provided at the commencement of a contract and

reviewed at periods not exceeding one year.

20.8 Where new projects are initiated (as opposed to existing term maintenance contracts) or a

new Contractor arrives on site the Contractor/Main Contractor/Principal Contractor must report

to the Project Manager controlling the works. No contractor must commence work on the

University’s premises until they have received a site induction, signed the Code of Safe

Working Practices for Contractors and received permission to proceed from the Contracts and

Compliance Co-ordinator. The site induction pack contains the extracts of the Asbestos

Register applicable to those areas which the Contractor will be working in.

20.9 No Contractor/Main Contractor/Principal Contractor will be allowed to work on the University’s

premises until they have been inducted in the University’s Health and Policy arrangements.

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21.0 PERMISSIONING SYSTEM

21.1 All contractors working on the University campuses must be provided with permission to

proceed for their work for their activities by the Contracts and Compliance Co-ordinator – See

Section 17. This enables the University to manage the contractor’s operations in

conjunction with the known or perceived risks across the estate.

21.2 Asbestos risks will be considered, discussed, and documented between the Estates Services

Department and the relevant contractor prior to a permission to proceed being granted – this

includes asbestos risks and the asbestos register for the relevant work area.

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22.0 EMERGENCY PROCEDURES

22.1 Action if any Person Suspects Presence of Asbestos

22.1.1 The discovery of a suspect asbestos bearing material shall be notified to the

Head of Estates Services and the Health and Safety Co-ordinator.

22.1.2 If the suspect material is, in the view of the Head of Estates Services / Health and

Safety Department, in poor condition and posing an immediate risk, then the area

containing the material should be isolated by:

a. Closing all doors and windows in the immediate vicinity.

b. Isolating any air conditioning systems.

c. Advising people not to enter the area unless they are appropriately trained and

are wearing protective clothing and respiratory protective equipment.

d. Restrict access, padlocking the door where necessary, and place the area

under the permit to work system.

e. Affix an asbestos warning notice to the area access.

f. If external, cordon off the area with barrier tape.

22.1.3 No person shall interfere with any suspect material.

22.1.4 On receiving notification of suspected asbestos, the Asbestos Consultant will:

a. Inspect the areas as soon as possible;

b. If he/she considers it necessary, arrange for a sample of the materials to be

taken for analysis and conduct air monitoring;

c. Give a written report of the results of the investigation to the Head of Estates

Services/Health and Safety Co-ordinator;

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d. Provide advice on any measures considered necessary to minimise the risk to

health in the interim period.

22.1.5 Action if Presence of Asbestos is confirmed

22.1.6 The action taken will be based on the risk to health posed by the location and

condition. The possible courses of action are:

a. Leave alone and monitor condition on a regular basis - monthly intervals, or

other such period agreed as indicated by the risk assessment.

b. Leave the asbestos product in situ but seal it in an approved manner and

inspect/monitor on a regular basis;

c. Remove asbestos product by a method approved by the Head of Estates

Services and Asbestos Consultant for that particular product and replace with a

non-asbestos-containing substitute.

22.1.7 The consideration on which a choice of options is to be based upon the risk

assessment which will be conducted following the procedure detailed in Section 9.

22.2 Damaged Asbestos Materials

22.2.1 Where an asbestos material or suspected asbestos material has been damaged the

person(s) who have disturbed the material will stop work immediately and notify the

Head of Estates Services and the Health and Safety Co-ordinator.

22.2.2 The Head of Estates Services will provide advice on any required personal

decontamination based upon the guidance give in the HSE publication HSG 210. The

University of Worcester does have an asbestos clean-up kit which can be utilised to

make areas safe where minor contamination has occurred.

22.2.3 The area affected will be locked off with a padlock and a notice prohibiting entry

placed on the door.

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22.2.4 The incident will be logged and investigated by the University of Worcester following

the accident, incident, and dangerous occurrence procedures. Where applicable the

incident will be reported as a Dangerous Occurrence to the HSE Incident Contact

Centre by the Health and Safety Co-ordinator.

22.2.5 The Head of Estates Services will liaise with the Asbestos Consultant and the area will

be remediated.

22.2.6 Following any incident where asbestos or suspected asbestos is disturbed; the

Asbestos Management Procedures will be reviewed taking into account the findings of

the Health and Safety Department investigation.

22.3 Accidents, Incidents, Near Miss Reporting and Investigation

22.3.1 The University of Worcester will ensure, so far as is reasonably practicable, that all

accidents (including disturbance of asbestos materials) and ‘near-miss’ incidents

(including discovery of suspected asbestos materials) are reported internally and,

where appropriate, to the HSE. In addition, all incidents will be investigated and

reasonable measures put in place to prevent recurrence.

22.3.2 Reports can be submitted to the Health and Safety Department through a number of

channels:

Managers, staff or visitors wishing to report an accident can complete an Accident

Report Form and email it to the Department accordingly.

Persons not having access to a computer may record the accident, incident, near

miss on the University’s paper form. Copies are available from the Health and

Safety Department.

22.3.3 A competent person will be identified and appointed to undertake the investigation.

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22.3.4 The investigation will determine the root cause and any corrective actions required.

Accidents, incidents and near misses involving asbestos materials will automatically

trigger a review of the University of Worcester’s asbestos management system. The

findings and recommendations of the investigation will be incorporated into the

review.

22.4 Attendance by Emergency Services

22.4.1 In the event of an emergency, the Fire Service has been offered access to the

Compliance365 system and can also access the information via the girder boxes on

the key buildings across the Estate.

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23.0 MONITORING AND PERIODIC REVIEW OF THE ASBESTOS POLICY AND

PROCEDURES

23.1 The Asbestos Policy and Procedures and any revisions will be agreed with the Health and

Safety Department and the Head of Estates Services prior to implementation.

23.2 The Asbestos Policy and Procedures will be reviewed by the Director of Facilities and

Estates, the Head of Estates Services, the Contracts and Compliance Co-ordinator, the

Health and Safety Co-ordinator, and the Asbestos Consultant every 12 months, or

earlier where there is reason to believe it is no longer suitable or sufficient.

23.3 The review will follow the agenda as outlined in HSG227.

23.4 The review will include implementation of improvements required as identified by any

investigations (with reference to Section 22.3 of this document), changes to best practice

and guidance and proposed changes to buildings.

23.5 The Asbestos Register will be updated regularly by the Head of Estates Services to reflect

further site investigations or abatement actions.

23.6 Asbestos Risk Assessments will be reviewed at least on an annual basis or more frequently

if an area changes use, a material’s condition has been noted to have changed, or works

are required in that area.

23.7 The Health and Safety Co-ordinator will audit the asbestos management procedure

annually.

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Appendix I Flow Process for Management of Asbestos in Capital Works / Refurbishment

Works

asbestos risk no asbestos risk

No asbestos abatement necessary

Asbestos abatement necessary

Key: LAC Licensed Asbestos Contractor AC Asbestos Consultant

Project Manager carries out a desk survey of all asbestos

records for property to determine suitability

The Project Manager advises the Projects

Manager who authorises a suitable survey

AC carries out a Refurbishment/

Demolition Survey

Risk assessment carried out to identify materials

for removal

Removal/encapsulation works carried out by a

LAC

Certificate of re-occupation issued by AC

Works authorised

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Appendix II Flow Process for Management of Asbestos in Routine Maintenance and Minor

Refurbishment

No disturbance of ACMs likely

Disturbance of identified ACMs likely or area not accessed in

the survey

No asbestos removal necessary

Asbestos removal necessary Key: LAC Licensed Asbestos Contractor AC Asbestos Consultant

Contractor reports to Estates Services office and requests a copy of the asbestos register

Projects Manager / Contractor consult register

and assesses whether ACMs are likely to be disturbed

Contractor defers the works and informs the Projects

Manager

Contractor signs Register

Projects Manager informs the Head of Estates Services

who authorises further survey and/or removal of any

relevant asbestos containing materials.

Head of Estates Services organises works and a

certificate of re-occupation is obtained.

Works authorised by the Head of Estates Services

Contractor signs Register and is issued permission to proceed

Works Commence

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Appendix III Flow Process for Management of Asbestos Abatement Works

Key: LAC Licensed Asbestos Contractor AC Asbestos Consultant

Head of Estates Services issues Contract to LAC

LAC Submits method statement to Head of Estates Services

LAC gives 14 days’ notice to Health and Safety Executive

(if required)

Head of Estates Services engages AC to provide monitoring and

support LAC obtains Permit to Work and isolates areas of work

Enclosure erected and/or other control

measures put in place

Smoke test carried out by LAC to check integrity of

enclosure (if required)

Site inspection/approval to commence work certificate issued by LAC

Works to remove/encapsulate ACMs commence AC carries out air monitoring

around work area and extract exhaust area

Completion of removal/encapsulation works. LAC notifies Head of Estates

Services

4-stage clearance procedures carried out by AC

Certificate of re-occupation obtained by Head of Estates Services

Area returned to normal use

Head of Estates Services organises update of Asbestos Register on receipt

of the certificate of re-occupation