Management of Asbestos: HSG264 Content Reminder what is asbestos? - - PowerPoint PPT Presentation

Management of Asbestos: HSG264

Content

Reminder – what is asbestos? Where can asbestos be found? The law relating to asbestos HSG 264 – Asbestos: The Survey Guide

What is Asbestos? (cont)

6 types of asbestos. 3 common ones..

Blue (crocidolite) Brown (amosite) White (chrysotile)

blue White brown

Where does asbestos come from?

Properties

Rot Proof Heat insulator Electrical insulator Resistant to chemical attack Resistant to chemical attack High tensile strength High melting temperature Resistant to fire Suitability for friction and sealing materials Etc etc etc

Sprayed Asbestos Coating

Asbestos filter cigarettes!

HSE Campaign- “You are more at risk than you think”

Damaged asbestos Insulating Board

Why do we need asbestos training?

Doll & Peto (1995); Peto et al (2006) Incidence of asbestos disease increasing for construction and maintenance trades

Health Surveillance

Health Surveillance

Asbestos issues now….

Over 50% of UK buildings contain it Biggest single occupational killer Disease incidence is increasing in

maintenance workers

Progressive Prohibitions

1985 statutory ban on blue and brown and all

use as lagging / spraying

1992 statutory ban on other amphiboles and 1992 statutory ban on other amphiboles and

higher risk use of white

1999 total ban (with some exceptions)

A Bit About Legislation

General health and safety legislation Asbestos specific legislation

General Health and Safety Legislation

– Health and Safety at Work etc Act 1974 – The Management of Health and Safety at Work

Regulations 1999 Regulations 1999

– The Construction (Design and Management)

Regulations 2007

CDM 2007

ACoP L144 on Asbestos Survey Assessments “Clients should carry out the necessary surveys in advance and provide the surveys in advance and provide the necessary information to those who need it”

Asbestos Law Framework

Current Approved Codes of Practice are:

L143 (main ACoP) L127 (Support to Regulation 4 duty to

manage asbestos)

Asbestos Legislation, ACoPs and Guidance

Act Approved Code of Practice (ACoP)

Health and Safety Guidance (HSG)

Main classifications.

Licensed Work Training ( People working

in the licensed asbestos industry)

Non-Licensed Work Training (Workers

CAR 2006: Asbestos Training Non-Licensed Work Training (Workers carrying out occasional lower-risk tasks with asbestos)

‘Asbestos Awareness’ training

(Anyone at risk i.e. those who work on, or coordinates non-new build work).

Why do we need asbestos training?

(Regs 5 & 6 of CAR 2006):

Presume or identify the presence of asbestos Ensure risk assessments tackle the issue of

asbestos during maintenance & demolition Planning Work and Risk Assessment Maintenance & Refurbishment Work asbestos during maintenance & demolition

Must also consider people other than

employees

Duty to manage asbestos

Reg 4 0f CAR 2006

Identify or presume asbestos Assess the risks Assess the risks Communicate the information Manage the risks Monitor the condition of the asbestos Review the plan

When will enforcement action be taken?

No system to warn or provide information to people at risk…

Enforcement Action For Landlords and Social Housing

Reg 4 of CAR may not apply but other law does

• Other parts of CAR 2006
• The Housing Act 1985

Suitable checks and surveys required before refurbishment etc

Duty to Identify Asbestos Before Work Starts – Reg 5

An employer shall not undertake work in

demolition, maintenance, or any other work which exposes or is liable to expose his employees to exposes or is liable to expose his employees to asbestos in respect of any premises unless either – carried out assessment – or if doubt assumes asbestos is present and observes the provisions of the regulations

Why Change

• Predates DTM
• Limited Client guidance on surveys
• Experience not captured
• No guidance for domestic

housing sector

HSG 264 – Asbestos The Survey Guide: Who does it apply to?

• Surveyors – Technical requirements
• Clients – Responsibilities and

information

Prosecutions for inexperienced/ incompetent asbestos surveyors

HSG 264: Aims and objectives

Surveyors

• More competent (experience and

accreditation)

• More aware of clients needs
• Better quality reports (more detail and

less caveats) less caveats)

• Prevent exposure

Clients

• More informed
• Greater understanding of surveyors

needs

• Recognise need for different surveys

during building life span

• Better asbestos management

Other Users

• Demolition contractors
• Asbestos contractors
• Asbestos contractors
• Building professionals

CDM (13)

• “It is not acceptable to make general
• “It is not acceptable to make general

reference to hazards that may exist”

• “site – specific asbestos surveys

should be carried out in advance of construction work”

Managing Asbestos -Appointed Person (14)

• Duty holder to identify a person responsible for

managing asbestos – clear lines of responsibility managing asbestos – clear lines of responsibility

• Resources, skills, training, authority
• Essential if large/complex portfolio

Surveyor Health and Safety (16)

• Surveys fall within CAR 2006
• Non licensed work
• Reg 6 – Risk Assessment
• Reg 6 – Risk Assessment
• Reg 7 – Plan of work
• Reg 10 – Non licensed worker training
• Other hazards

HSG 264 : Application of Asbestos Law

• Workplaces – Reg 4 directly

applicable

• Common areas of blocks of flats

etc – Reg 4 directly applicable etc – Reg 4 directly applicable

• Domestic living spaces – Reg 4

not applicable HOWEVER S2 and S3 of HSWA 1974, Reg 5 (identification) of CAR 2006 and risk assessment requirement under MHSWR 1999 do apply

HSG 264 : Survey Accreditation

HSE strongly recommend clients use accredited surveyors i.e.

• ISO 17020 (surveying companies)
• ISO 17024 (individual surveyors e.g. sole

traders) ie ISO 17024 recommended where “the scale and volume of work dictates not

• nly individual competency but also the

need for formal quality management systems”

Surveyors

1.

Training, qualifications and knowledge

2.

Knowledge specific to task

3.

Independent, impartial, integrity

4.

QM system

5.

Surveys to approved standard – ie HSG 264

Strongly recommends Accredited/Certificated

Surveyor

Good Looking?

BOHS BOHS Modules Modules P402 P402 S301 S301 CoCA CoCA

Royal Society for Public Health Level 3 Cert in Asbestos Inspection Procedures

Surveyor Knowledge (18 - 21)

• Products
• Building construction & components
• Fire protection
• Shafts, plenums, undercrofts, risers
• Oversprays, residues, debris
• Ad hoc uses

Asbestos Packers

Snots on Walls Snots on Walls

Simple Type 1 surveys disappear The presumption of ACM’s is incorporated into

management surveys

Strong presumption because:

Known recognised material which used asbestos Same as other similar sampled ACM (cross-referenced)

Asbestos Surveys

Same as other similar sampled ACM (cross-referenced) Visible asbestiform fibres

Presumption where:

Area not accessed Material not known and not sampled

Always errs on the side of caution

Some materials may be presumed to be asbestos when

actually asbestos-free

HSG 264 : Types of Survey

Survey types have been re-named

• Type 2 survey is now a ‘management’

survey

• Type 3 survey is now either a

‘refurbishment’ or ‘demolition’ survey ‘refurbishment’ or ‘demolition’ survey

• “The type of survey will vary during the

lifespan of the premises and several may be needed over time”

• At larger premises a mix may be

appropriate e.g. refurb survey of one part where work is being carried out and management survey of the rest.

HSG 264 : Management Survey

• Purpose is to identify ACM’s within

buildings and prevent exposure

• Is not destructive but may involve minor

intrusive inspections and future planned maintenance maintenance

• Will normally involve sampling, should

assess condition and provide recommendations for client

HSG 264 : Management Survey (cont)

• Areas not accessed should be stated in

report

• Details of inspected areas should be

recorded

• May be sufficient for minor surface
• May be sufficient for minor surface

refurb & maintenance

• Risk assessment scoring system

remains unchanged from MDHS 100

HSG 264 : Refurbishment/demolition Survey

• Used where more extensive refurbishment is

carried out e.g. partitions removed or work behind fixed boxing etc.

• Management survey is NOT sufficient
• Fully intrusive and probably destructive in

areas inspected as “aggressive techniques” areas inspected as “aggressive techniques” are required

• “…should only be conducted in unoccupied

areas….and furnishings removed” from the areas within the survey scope

• Only required in areas where the work is being

carried out – however in housing it is usual to survey the rest of the property

Caveats and Survey Restrictions

HSE really don’t like these as they can seriously

undermine the usefulness of the survey

– May be imposed by either client or surveyor….?

Originally HSE were going to say “NO caveats for a

refurbishment or Demolition survey” refurbishment or Demolition survey”

Clearly not practicable, even for the best refurbishment

• r demolition survey (see bottom of para 57 on P13)

HSE have therefore taken this on board and the paras

55 – 58 are about as severe as they could get

Any caveats or restrictions must be agreed by both

parties and clearly documented

Survey Planning

Much more detailing than in MDHS 100 Detailed checklists for both client and surveyor of

information to be collected and supplied information to be collected and supplied

HSG264 - recommends ‘walkthrough inspection’ as

part of site meeting

– Does this always happen? -

See box 7 (page 17) – as a pre-survey questionnaire? UKAS companies already carry this out as part of the

contract review for ISO 17020

HSG 264 : Planning Process

Survey Asbestos register Management survey Pre-demolition or refurbishment survey Plan/drawing Risk assessment Management plan

Survey Plan

Scope

– Areas to be included or excluded, ACM’s to be excluded?

Survey procedure

– How, when, who, how many samples, photographs, material

risk assessment system, priority assessment (?), method for recording data, building and room identification, quality and assurance checks? assurance checks?

Personnel and safety

– How many staff and when on site, access and authorisation

issues, site safety issues and emergency procedures

Report

– Format, hard copy and/or database, plans and/or drawings,

asbestos register form, how many copies and who to receive them

Risk assessment for surveying

Site safety issues

– Working at heights – Electrical safety – Chemical hazards – Hot work – Slips trips and falls – Live machinery – Biological hazards – Noise – Radiological hazards (hospitals, nuclear power stations, etc.)

Adequate risk assessment of each by a competent

person – and available to the surveyors

HSG 264 : Management Planning HSG 264 emphasises allocating responsibility lines for:

• Carrying out surveys to required

standard standard

• Managing the data
• Monitoring the condition of

asbestos

• Managing the process e.g.

contractor and trades control

HSG 264 : Planning Surveys

• Where keys are required for premises,

clients should assist surveyors in order to reduce the number of ‘no access” areas.

• “for housing improvement schemes and
• “for housing improvement schemes and
• ther project work, surveys should be

incorporated into the planning phase of such work as far as possible. This will avoid delays and disruption”

HSG 264 : Survey Strategy

“The presence of ACM’s can be variable even within the same archetypal group due to

• Inconsistent and variable use
• Random use of waste pieces and off-cuts
• Modifications of properties by tenants (past

and present) and housing associations” “Cloning” can only be justified if there is sufficient supporting evidence e.g. build data showing evidence of complete consistency

HSG 264 : Management of Data

Asbestos register must be actively managed i.e. updating register when

• ACM’s have been removed
• ACM’s have been re-inspected
• New areas have been surveyed (e.g. during

refurbishment surveys) refurbishment surveys) Asbestos surveys must be available to those who plan or initiate maintenance and refurb work

Does your Survey Measure Up? Is it easy to read?

surveys must be easy for non-technical

people to understand

Simple location summaries Hot-spotted plans are useful for more

complex sites. complex sites.

Client’s Responsibilities (Appointed Person)

• Check accuracy of report
• Produce the AMP
• Keep things updated
• Make the information available to all parties

When will enforcement action be taken?

Evidence of maintenance workers being exposed or at risk of exposure. no actual exposure required to prosecute

When will enforcement action be taken?

People working in areas with damaged or friable asbestos materials present

Refurbishment Case Study

FAST RESPONSE UNIT

• Emergency response 24/7
• Ability to carry out bulk identification on site
• Provide supporting services

Thank you for listening….. DMW Environmental Safety Ltd

• Asbestos surveys
• Asbestos training
• Asbestos analysis
• Asbestos removal management

wayne@dmwsafety.co.uk 01902 791565