AchievingAsbestos Compliance - BHSEA (James Bradley) 30.4.19.pdf · 2019-05-13 · Removal Phase Clearance & Handover 15 days 1 day 12 days 2 days The Reality VP (Day 1) Removal Phase

Your Asbestos Management Partner

Surveys. Management & Consultancy. Removal Specification. Analytical Support. Training.

Achieving Asbestos ComplianceYou’re doing it right -…aren’t you?

Presented by James Bradley

Managing Asbestos Compliance

You’re doing it right … aren’t you?

Agenda

_01

Surveys

Removal Specifications

Management & Consultancy

Analytical Support

Training

HSG248 The Analyst Guide Update



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Use of asbestos

Use of asbestos

Use of asbestos

8

Use of asbestos

9

Use of asbestos

The foundations of management plan

Step1

• Immediate

• Confirm what you already know

Step 2

• Immediate

• Stop work on your premises that may disturb the fabric of the building

Step 3

• Immediate

• Carry out an initial inspection for damage/disturbance of materials

The foundations of management planStep 4

• Continuing Action

• Develop a strategy for compliance

Step 5


• Carry out a risk assessment of your ACMs

Step 6


• Develop a long term management plan

Step 7


• Monitor and review the management plan



Surveys

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Why survey?

• CAR 2012

• CDM Regulations 2015

• Management of Health & Safety at Work Regulations 1999

• Health & Safety at Work etc. Act 1974

HSG264 The Survey Guide

• Greater emphasis placed on “pre-survey communication”

• Scope & area of survey to be fully understood by all parties



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Selecting a competent surveyor

Surveys can be carried out by in-house personnel or a third party, in each

case the surveyor must be competent for the task:

• Sufficient training, qualifications, knowledge and experience & recognise their limitations

• Sufficient knowledge of the specific tasks and the risks which the work will entail

• Able to demonstrate independence, impartiality & integrity

• Adequate quality management system

• Carry out the survey in accordance with recommended guidance (HSG264)

HSE strongly recommend the use of accredited or certified surveying companies



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UKAS Accreditation?

Source: UKAS

HSE: Strongly recommend

using UKAS accredited

surveying organisations



Surveys

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Survey

Management

Survey

Refurbishment or

Demolition Survey

Asbestos register

plan /drawing

Risk assessment

Management

Plan

Regulation 4 – Duty to manage asbestos in non domestic premises

• Duty to locate ACMs• Presume positive where not sampled• Make & maintain written records of the locations of sampled

and presumed ACMs• Assess the risk of likelihood of exposure• Prepare a plan to manage the risk• Choose your management options according to ACM condition and

location• Inform everyone (internal or external) who is potentially at risk of

exposure• Audit the AMP on a regular basis to ensure effectiveness (at least

annually)



Surveys

_05

Survey

Management

Survey

Refurbishment or

Demolition Survey

Asbestos register

plan /drawing

Risk assessment

Management

Plan

Regulation 5 – Identification of the presence of asbestos in premises

• An employer must not undertake work in demolition, maintenance, or any other work which exposes or is liable to expose employees of that employer to asbestos in respect of any premises unless either:

• A suitable & sufficient assessment has been carried out or,

• Assume ACMs are present.



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Survey types

Management survey;• Standard survey

• Purpose is to locate (afarp) the presence, extent and condition of any suspect ACMs which could be damaged or disturbed during normal occupancy, including maintenance activity

• Minor intrusive work

• Involves sampling, presuming or both

• Any area not accessed should be presumed to be asbestos containing

• Not suitable for refurbishment and demolition works



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Survey types

Refurbishment & Demolition survey (R&D);• Needed before ANY refurbishment and/or demolition work

• Purpose is to locate and describe (afarp) all ACMs in the area where the R&D work will be carried out (targeted / project specific)

• Fully intrusive / destructive inspections

• Also used prior to intrusive maintenance and repair tasks or plant removal / dismantling

• Condition not normally considered (other than to indicate areas of damage where additional asbestos debris may be found), unless removal work is not taking place for more than 3 months

• This survey information should be supplied by the client to designers and contractors bidding for the work



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Survey types

Re-inspection Surveys• Condition survey of known ACMs and an opportunity to inspect

previous ‘No Access’ areas.

• Air testing?



_03

Domestic properties – local authorities / housing

associations etc

• Firstly, properties should be placed into archetypal groups and the age / probability of ACMs being present assessed…

• Management surveys are required to be carried out on properties that could contain asbestos

• Exact sampling ratios cannot be specified due to variability / non homogenous materials found in housing stock – review data as it comes in for consistency to reach a confidence level

• Refurbishment / Demolition surveys should be conducted prior to any refurbishment or demolition, with a similar strategy to management surveys

• Sampling surveys recommended as presumptions could lead to additional costs / delays

• Management surveys should be “enhanced” with data from refurbishment / demolition surveys

Assessing and prioritising ACMs

• Maximum 12 points per assessment, total no more than 24

• Products can then be put into order of priority for action depending on score

Material Assessment

• Product type

• Extent of damage

• Surface treatment

• Asbestos type

Priority Assessment• Normal occupant

activity

• Likelihood of disturbance

• Human exposure potential

• Maintenance activity

Total Score


Product: Floor tiles containing Crocidolite

Location: Small cleaners storeroom (8m²) at a high school


Product: Damaged raw AIB to wall panel containing Amosite & Chrysotile

Location: Store cupboard for electrical consumer unit in a council house


Analysis of assessment:

• Once you have a score, what does it mean?

• Does a high number automatically mean remove?

• Priority should be given to high scoring ACMs but it could be that

isolating the area and putting a Permit to Work in place could be a

possibility

• It depends on the amount and position of ACMs identified

• It depends on your budget and timescales

• In short you have a choice but you MUST act

Assessing and prioritising ACMsManagement control options:

Manage in Situ (includes re-inspections, PtW & SSOW etc)

Remove

Seal / encapsulate

Mixture of these

Isolate area / restrict access

Label or colour code

Enclose / protect from damage

Repair (minor)

Dutyholders’ use of survey information

• Check the report against the original tender (fit for purpose)

• Check for un-agreed caveats or disclaimers

• Check that they survey is as requested (i.e. management or R&D, or combination)

• Check diagrams are clear and accurate

• Check all rooms and areas have been accessed

• Check sufficient samples have been taken (usually 1-2 per area / room) and that sample

numbers are not disproportionate (e.g. dominated by one ACM type)

• Check sample numbers reflect variations in the same ACMs e.g. different ceiling tiles in the

same room

• Check for any obvious discrepancies and inconsistencies



Surveys

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Surveys - Communication

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Caveats?

• Access cannot be gained above 1.8 metres

• Hatches could not be opened

• Ceiling voids / risers / undercrofts are not typically

accessed

(This is where the asbestos is likely to be!)

Proper planning can avoid these situations:

Clear statement of requirements needed.

Statements you shouldn’t see in a survey report

unless agreed pre survey



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HSG264 States:…Survey restrictions can seriously undermine the management of asbestos in buildings.

…they should be included only when absolutely necessary and should be fully justified.

…most can be avoided by proper planning and discussion. They must be agreed between the

duty holder and the surveyor and documented in the survey report.

Developing the asbestos management planThe Asbestos Register

Source: HSG 264

Developing the asbestos management planThe Asbestos Register

• Live working document

• Electronic or hard copy

• Kept for the life of the building

• Must be kept up to date

• To be accessible & used by all relevant personnel

• Can include no access areas

• Can include non ACMs

• Or use multiple registers



Surveys -The Asbestos Management Plan

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• Policy statement

• Roles and Responsibilities (who does what?)

• Identification of ACMs and survey types

• The asbestos register

• Management Options for dealing with ACMs (Inc. Re-

inspections)

• Health Surveillance

• Provision of information

• Procedures for undertaking normal work and emergencies

• Monitoring & review of AMP

• Training (All employees? Agency staff)

• Training for Contractors (site inductions)

• Selection process for LARCs/Consultancies

Example Contents

The Foundations for Asbestos Management

Survey

Management

Survey

Refurbishment or

Demolition Survey

Asbestos register

plan /drawing

Risk assessment

Management

Plan

Emergency procedure

Never take

anything

contaminated

home

STOP - ISOLATE - REPORT



Surveys -The Asbestos Management Plan

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• Implementation of AMP

• Effectiveness of the AMP

• Quality Assurance Procedures

Periodic Review – Every 12 Months?

The Foundations for Asbestos Management

Survey

Management

Survey

Refurbishment or

Demolition Survey

Asbestos register

plan /drawing

Risk assessment

Management

Plan

How?

• Audit sections to gauge the understanding

• Evidence the plan is being followed

• Are external contractors following the

requirements

The AMP should be a live document constantly evolving over time



So, you are doing it right………………………?

Really?

_16

Avoidable Exposures, Breaches of Regulations leading to Prosecutions and Damage to Reputation




_17

Is it possible to price removals from this?



No specification?

_18

Wide

Ranging

Pricing

spread

Potential

for

variations

Risk of

Job delays

and liquidated

damages




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Specification Process

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Contractor’s Perception

Old Type

2/3 Survey

Goes to ITT

(Pre-VP)

Contract

Awarded

VP

(Day 1)

Removal

Phase

Clearance &

Handover

15 days

1 day 12 days 2 days

The Reality

VP

(Day 1)

Removal

Phase

3 days

STOP!

More material

found

New

Survey

Cost Variation

& Agree

Extra ASB5

Notification

Revised Removal

Phase

Clearance &

Handover

14 days 5 days 14 days 20 days 4 days

60 days



Specification Process

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For a compliant and faster solution – the best practice approach is:

Management

Survey 6 months

prior to VP

Upgrade

survey to R&D

at VP

Create full

specification

from R&D

Create

ITT and

evaluation

Award contract and

14 day asb5

notification

Removal and

clearance certificate /

handover

8 days 1 day 7 days 14 days 15 days

45 days

It might seem counter intuitive to delay your start on site but it will save

time and money in the long run.



Analytical Support

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• ’Background’ – Prior to work commencing

• ‘Reassurance’ – When materials are damaged / following enclosure removal

• ‘Leak’ – During works external to enclosure

• ‘Clearance’ – Following licensable removal works in enclosure

• ‘Personal’ – To ensure compliance, work method and control measures are adequate

Different types of air sampling (monitoring & testing) using PCM method



_03

Enclosure

Skip

DCU

D S C

NPU

3 stage airlock

3 stage baglock

Transit route

Waste route

Site boundary

VP

VP

VP

VP

B

L

L

L

L

R

C

C

C

P

P

C

R

R

Analytical Support



Analytical Support

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4-Stage Clearance

Analyst checks – Pre-enclosure removal

Work area;

paperwork

Visuals;

disturbance tests

Clearance air monitoring

(0.01 f/cm )3

Post-enclosure removal

Clear Hygiene Unit; full

site clearance

Certificate of Reoccupation – All Clear



_03

Stage 1: Preliminary check of site condition & job completeness Waste left on transit route, also not double bagged

Analytical Support



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Stage 2: Examples of dust & debris left in enclosures

Analytical Support



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Stage 2: Examples of dust & debris left in enclosures

Analytical Support



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Stage 3: Air monitoring – Provides confirmation for the visual inspection

• NPU to be switched off and capped during this stage• Analyst to wear RPE & PPE throughout the process• Clearance air test completed (disturbed)• Disturbance typically conducted by brushing all surfaces for a

minimum of 1.5 minutes per sample position at start of the sampling period

• Number of pumps required, depends on the size of the enclosure• Each air test to achieve the clearance indicator / limit of detection

level (<0.01 f/ml). Unless a large enclosure (5 air tests or more) then at least 80% to achieve <0.01f/ml, with no more than 20% permitted to achieve between 0.010 & 0.015 f/ml

Analytical Support



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Stage 4: Final assessment post enclosure / work area dismantling Waste generated post scaffold removal – acceptable storage?

Analytical Support



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Stage 4: Final assessment post enclosure / work area dismantling Remaining duct tape and expanding foam not cut back

Analytical Support



Training

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This is MANDATORY under Regulation 10 of CAR 2012, legally implicit since 1999.

Ensure that all personnel on site have suitable and sufficient asbestos (awareness)

training pertinent to their job role.



Training

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Training

_31

ALFA LeadershipSafely, Honestly, Ethically

Above and Below the line

Blame

Excuses

Denial

Ownership

Accountability

Responsibility

You

You

Decision



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HSG248

Clearer guidance for clients*

• Planning phase is intended to mimic the changes first introduced in HSG264

• Improved Communication between all parties (aims and objectives)

• Reasons for sampling

• Sampling locations – i.e. special arrangements: working at height,

tenanted properties

• Improved levels of detail for the Certificate for Reoccupation*

• Timings – how long certain activities will take (i.e. visual inspections)

The Analysts guide update

*Reports should be designed to satisfy the client’s needs not just perceived

UKAS requirements



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HSG248

Survey sampling requirements – bulk

• Number of samples should not be restricted by cost or contractual

arrangements – could lead to poor choices and false assumptions

• Guidance on the avoidance of single surveyor working altered from

“ideally” to “strongly recommended” – and essential where there is: -

- Working at Height

- Confined spaces




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HSG248

Dust sampling

• Dust sampling – to be avoided except in exceptional circumstances

(i.e. assessing the spread of asbestos fibres)during an incident

• Not to form a routine method during surveys

• Dust in buildings with ACMs – low levels expected but are they significant?

• Expensive SEM testing

• May lead to expensive and unnecessary abatement works




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HSG248

Air Testing – statics

• Daily leak air testing where there are other personnel are in occupation near the

asbestos works

• Testing should be a combination of short and long duration

Short – at commencement of removal works

Long – during the works


*Leaks have previously been considered an optional extra – the new emphasis will

therefore, have an impact on cost for some jobs



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HSG248

4-Stage clearance – Stage 2 Visuals


How Long??



_52

HSG248

Asbestos in made land / soils - Analytical

• Outlines prescribed laboratory method for determining asbestos content of soil

• Confirmation that asbestos is present in samples of suspected ACMs and soil containing

fine fragments of ACMs and unbound asbestos fibres is obtained using the standard

analytical method for identifying asbestos using a combination of stereomicroscopy and

polarised light microscopy (PLM) analysis

• Asbestos in soil is covered by the Control of Asbestos Regulations 2012, and

therefore if a laboratory is offering an asbestos testing service with respect to soil samples

then accreditation to ISO/IEC 17025 is required*


*It is not currently a legal requirement for a laboratory to hold UKAS accreditation for quantification of

asbestos in soils



_53

HSG248

Asbestos in made land / soils - Assessment

• Summarises the requirements for the identification of asbestos in soil and made ground for workers

• Identification of ACMs is part of the risk assessment required under CAR 2012

• An assessment and plan of work are necessary to establish the control measures

and safe systems of work to reduce the risk from asbestos to ALARP

• A survey to identify the presence of asbestos in soils and made ground is only

required where there is a reasonable expectation that asbestos could be present

and could present a risk to workers.




_55

Guidance

• CL:AIRE 2016 –

application of CAR 2012 to soils and

demolition materials

Clarification of removal contractor

type (LW / NLW)

• CIRIA – 2017 Report No. C765 –

Enable safe working for all staff

Reduce potential exposure and

therefore liability

Asbestos in Soils



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Asbestos Management Plan – considering the following areas: -

✓ Project specific risk assessment –

i. What is the nature of the asbestos

ii. What are the exposure pathways?

iii. Who is potentially at risk?

✓ Is the work LW or NNLW/NLW

✓ Do the HSE need to be notified of the work?

✓ RPE/PPE requirements

✓ Training requirements (Awareness / NLW)

✓ Control measures – damping down, material/waste handling,

stockpiling etc.

✓ Decontamination

✓ Waste disposal options

✓ Is Air Testing required?

Asbestos in Soils



“If nothing else works, a total pig-headed unwillingness to look facts in the face will see us through” Blackadder Goes Fourth

_35

Your Asbestos Management Partner

Surveys. Removal Specification. Management & Consultancy. Analytical Support. Training.

Thank youfor your time

Telephone: 0845 456 99553

www.environmentalessentials.co.uk

Documents

AchievingAsbestos Compliance - BHSEA (James Bradley) 30.4.19.pdf · 2019-05-13 · Removal Phase Clearance & Handover 15 days 1 day 12 days 2 days The Reality VP (Day 1) Removal Phase