duty to manage asbestos in non-domestic premises … · •bohs p405 - management of asbestos in...

DUTY TO MANAGE ASBESTOS IN

NON-DOMESTIC PREMISES

IOSH SOUTH WEST BRANCH – 11/09/2019

G&L Consultancy Ltd:

• Specialist Asbestos Management Consultancy

• Offices in Somerset & Northern Ireland

• UKAS Accredited for:

• Surveying

• Reinspections

• Bulk Sample Analysis

• Air Monitoring

• Certificates of Reoccupation

G&L Consultancy Ltd:

• Asbestos Management Services

• Non-Licensed Asbestos Removal Services

• Training Services

• Licensed

• Non-licensed

• BOHS

• Asbestos Awareness & Duty to Manage

• Bespoke Asbestos Training

Asbestos Consultant & Lead Trainer

P402, P403, P404, P405, P407

M: 07718 185 412| E: [email protected]

Operations Manager

CoCA (Asbestos), AFOH

M: 07791 528 771| E: [email protected]

The Duty to Manage:

CAR2012 – Regulation 4 (L143)

What are the Duties?

• Take reasonable steps to determine the location

and condition of any materials likely to contain

asbestos;

• Presume materials contain asbestos unless

there is strong evidence that they do not;

The Duty to Manage:

• Make and keep an up to date record of the

location and condition of the asbestos containing

materials (ACM’s) or presumed ACM’s in your

premises;

• Assess the risk of the likelihood of anyone being

exposed to fibres from these materials;

The Duty to Manage:

• Prepare an asbestos management plan, setting

out how the risks from the materials are to be

managed;

• Take the necessary steps to put the plan into

action;

The Duty to Manage:

• Review and monitor the plan periodically;

– Regulation 4 states “never longer than 12 monthly”

• Provide information on the location and

condition of the materials to anyone who is liable

to work on or disturb them and ensure a suitable

safe system of work is put in place to take

account of any work on locations where ACM’s

or presumed ACM’s is to be undertaken.

Appoint person

to manage

asbestos

The Duty to Manage:

Appoint person

to manage

asbestos

The Duty to Manage:

Review current

premises

status

Appoint person

to manage

asbestos

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Appoint person

to manage

asbestos

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

Appoint person

to manage

asbestosSURVEY

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

Appoint person

to manage

asbestosSURVEY

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

No asbestos

present

Appoint person

to manage

asbestos

RecordSURVEY

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

No asbestos

present

Appoint person

to manage

asbestos

RecordSURVEYNo further

action

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

No asbestos

present

Appoint person

to manage

asbestos


action

Asbestos present

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

No asbestos

present

Appoint person

to manage

asbestos


action

Record

Asbestos present

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

No asbestos

present

Appoint person

to manage

asbestos


action

RecordCarry out risk

assessment

Asbestos present

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

No asbestos

present

Appoint person

to manage

asbestos


action


assessment

Prepare /

amend

management

plan

Asbestos present

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

No asbestos

present

Appoint person

to manage

asbestos


action


assessment

Prepare /

amend

management

plan

Manage

Asbestos present

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

No asbestos

present

Appoint person

to manage

asbestos


action


assessment

Prepare /

amend

management

plan

Manage

Asbestos present

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

Damaged ACMs

No asbestos

present

Appoint person

to manage

asbestos


action


assessment

Prepare /

amend

management

plan

Manage

Damaged ACMs

Asbestos present

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

Damaged ACMs

No asbestos

present

Appoint person

to manage

asbestos


action


assessment

Prepare /

amend

management

plan

Manage

Repair /

RemoveDamaged ACMs

Asbestos present

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

Damaged ACMs

No asbestos

present

Appoint person

to manage

asbestos


action


assessment

Prepare /

amend

management

plan

Manage

Repair /

RemoveDamaged ACMs

Asbestos present

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

Damaged ACMs

Repaired ACMs

No asbestos

present

Appoint person

to manage

asbestos


action


assessment

Prepare /

amend

management

plan

MonitorManage

Repair /

RemoveDamaged ACMs

Asbestos present

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

Damaged ACMs

Repaired ACMs

No asbestos

present

Appoint person

to manage

asbestos


action


assessment

Prepare /

amend

management

plan

MonitorManage

Repair /

RemoveDamaged ACMs

Asbestos present

The Duty to Manage:

Review current

premises

status

Stop all

potential ACM

disturbance

Complete initial

high risk

inspection

Review

Damaged ACMs

Repaired ACMs

No asbestos

present

Asbestos Surveys:

SURVEY

Asbestos Surveys:

SURVEY

Management

Survey

Refurbishment

or Demolition

Survey

Asbestos Surveys:

SURVEY

Management

Survey

Refurbishment

or Demolition

Survey

Asbestos

Register &

Plan

Asbestos Surveys:

SURVEY

Management

Survey

Refurbishment

or Demolition

Survey

Risk

Assessment

Asbestos

Register &

Plan

Asbestos Surveys:

SURVEY

Management

Survey

Refurbishment

or Demolition

Survey

Management

Plan

Risk

Assessment

Asbestos

Register &

Plan

Asbestos Surveys:

Asbestos Surveys:

Types of asbestos survey:

• Management Survey

• A management survey is the standard survey.

Its purpose is to locate, as far as reasonably

practicable, the presence and extent of any

suspect ACMs in the building which could be

damaged or disturbed during normal

occupancy, including foreseeable maintenance

and installation, and to assess their condition.

Types of asbestos survey:

• Refurbishment and Demolition Survey

• A refurbishment and demolition survey isneeded before any refurbishment or demolitionwork is carried out.

• This type of survey is used to locate anddescribe, as far as reasonably practicable, allACMs in the area where the refurbishment workwill take place or in the whole building ifdemolition is planned.

LocationProduct

TypeExtent Accessibility Condition

Surface

Treatment

Asbestos

Type

Sample

No.

Level of

Identification

Material

Score

Priority

Score

Action

Store

Room 2,

BC408

ceiling

AIB

Whole

Ceiling

120m2

Medium Good

Painted

one face

only

Amosite 1Sampled

(4 samples)5

12

Manage

Store

Room 2,

BC408 fire

door

AIB 21m2 Medium Good

Encapsula-

ted by

wood in

door

Amosite 2Sampled

(1 sample)5

12

Manage

Meeting

Room 2

BC412

ceiling

AIB 5m2 Medium Good

Painted

one face

only

Amosite 3Sampled

(1 sample)5

13

Manage

Canteen

BC410 lino

on floor

Paper 5m2 Easy

Good –

damage to

edge

Covered

by vinylChrysotile 4

Sampled

(1 sample)4

11

Manage

Corridor

BC411

electrical

switch box

Woven

Cloth

Possibly

4 itemsMedium Medium Unsealed

Chrysotile5

Strongly

Presumed8

14

Remove in

next phase

Plant

Room 2

BC416 lift

motor

Brake

Shoes2 items Difficult Medium Unsealed

Chrysotile6

Strongly

Presumed4

10

‘H’ Vac

dust

Asbestos Surveys:

Asbestos Surveys:

Identified

Inaccessible

(Presumed)

Presumed

Strongly

Presumed

Although the surface treatment score

flags as ‘unsealed (2)’: these items

are in fact encapsulated lagging

residue sealed by ET150

Managing Work / Contractors:

• Controlling work on the fabric of your building

• In a small organisation, one person can benominated to control all work carried out by in-house maintenance workers and all contractors

• Limit the number of contractors who work onyour premises to one or two who are familiarwith the buildings and procedures in use in yourorganisation



• The maintenance or safety department may be

charged with ensuring that information regarding

the presence of ACMs or presumed ACMs is

passed on to contractors who come into your

premises



• A formal, written safe system of workincorporating permits-to-work may be used tocontrol maintenance workers and contractorsalike. This is more likely to be necessary inlarger organisations where it is difficult for oneperson to maintain control over the number ofcontractors on site. It provides a framework forthose controlling the contractors.


• Permit to work “Asbestos Alert”

• This permit has been designed for contractorswho are to work on materials of unknowncomposition or may come into contact withasbestos when an asbestos register may not beavailable, or may come into contact withasbestos when hidden materials are exposed,voids opened, cavities encountered or buriedpipes discovered.


• Permit to work “Asbestos Present”

• This permit has been designed for contractorswho may come into contact with asbestoscontaining materials during the course of theirwork and / or a register / survey document isavailable to substantiate that asbestos is presentin the area where the work is to be carried out.


• Authorisation to Work

• This document has been designed for use inthose workplaces where only a small number ofexternal contractors are utilised and they alongwith all internal maintenance staff are fullytrained.

Options for Managing Work /

Contractors:

• Asbestos Awareness training for employees,

contractors and others

• There are different types of training that you may

need to provide to your employees and others.

• You should aim to have an open and responsive

culture where employees are not afraid of

asbestos and know how it is managed in their

place of work.


• Asbestos Training

• Asbestos Awareness

• Asbestos Awareness Annual Review

• Toolbox Talk

• Online (e-learning)

• Duty to Manage



• Introduction to Asbestos Remediation

• Work with Non-licensed Asbestos

(Task Manual)

• Specific Tasks

• Annual Refresher



• BOHS P405 - Management of Asbestos

in Buildings

• BOHS P407 - Managing Asbestos in

Premises, the Duty Holders

Requirements

Control Measures:

• Protecting / enclosure of ACMs

• Protecting ACMs means the construction orplacing of a physical barrier of some sort toprevent accidental disturbance of the ACM.

• If enclosure is chosen as the desiredmanagement option it is important that theexistence of the ACM behind the enclosure isnoted in the asbestos record and that thecondition of the enclosure is monitored and theresults of the inspection recorded.

Control Measures:

Control Measures:

• Seal or encapsulate the ACM

• There are two types of encapsulants:

• bridging encapsulants which form a durablelayer adhering to the surface of the ACM

• penetrating encapsulants which are designedto penetrate into the ACM before hardeningand locking the material together to give theACM additional strength.

Control Measures:

Control Measures:

• Repair the ACM

• To be readily repairable, the damage must beslight, therefore repair should be restricted topatching/sealing small areas and making goodslight damage to enclosures which areprotecting ACMs.

Control Measures::

Control Measures:

• Remove the ACM

• Where it is not practical to repair, enclose orencapsulate the ACMs, they will need to beremoved

• ACMs will also need to be removed if the area isdue to undergo refurbishment which will disturbthe ACM, or where a building is going to bedemolished.

Control Measures:

Control Measures:

• Labelling

• Where an ACM is going to be left in place, oneoption would be to label the material, or in thecase of pipework colour-code the insulation.

• Labelling and colour coding alone should not berelied on as control measures in themselves.They may become dirty, obscured or fall off andtherefore should only be used as a back-upmeasure.

Control Measures:

Monitoring Asbestos

Management:

• Monitor and review the management plan

• Once the management plan has been made

and recorded, the implementation of the plan

needs to be addressed.

• Monitoring the action plan to make sure that

all remedial work has been adequately

carried out.

Monitoring Asbestos

Management:


• Monitoring of ACMs or presumed ACMs left in

that position

• Frequency of monitoring of ACMs / presumed

ACMs

• Updating the asbestos record following repair

/ removal of ACMs

Monitoring Asbestos

Management:


• Ongoing communication / training of

maintenance workers / contractors

• Continued awareness amongst all employees

• Monitoring of the implementation timetable

Monitoring Asbestos

Management:


• Lessons learned following incidents and

accidents involving ACMs.

• The management plan should be subject to at

least six monthly reviews and a complete top

down thorough annual review.

Monitoring Asbestos

Management:• Monitor the condition of ACMs

• ACMs which are in good condition, sealedand/or repaired, and are unlikely to bedisturbed, may be left in place.

• If they are left in place, the condition of theACMs will have to be monitored regularly andthe results recorded.

Monitoring Asbestos

Management:• Monitor the condition of ACMs

• A useful way of monitoring the condition ofACMs is to take photographs, which can beused to compare the condition over time.

• The time period between monitoring will varydepending on the type of ACM, its locationand the activities in the area concerned, butwould not be expected to be more that 12months in most cases.

Asbestos Incidents:

• Discovery of Asbestos

• If asbestos or suspected asbestos is discovered

which is damaged or likely to be damaged

during remedial work the member of staff must

stop working in that area and report the matter to

their supervisor immediately, who must ensure

that the procedures for dealing with the

unplanned disturbance of asbestos are followed.

Asbestos Incidents:

• Evacuation and Room Closure

• The room where the incident occurred must be

evacuated if:

• Any friable (easily crumbled) asbestos

material is damaged

Asbestos Incidents:


• Any asbestos product is damaged to the

extent that visible debris is present.

• There is any doubt about the nature of dust or

debris within the area.

Asbestos Incidents:


• Where these circumstances exist all windows

and doors must be closed and any ventilation

equipment or gas appliances turned off.

• The area should be sealed off and locked if

possible to prevent access.

Asbestos Incidents:


• If it is possible that contamination has spread

to adjacent areas these should also be

evacuated and sealed.

• Signs warning of the hazard must be posted

and entry prohibited to all except authorised

staff who are wearing suitable personal

protective equipment.

Asbestos Incidents:


• All work involving removal of asbestos and

clearance of contaminated areas must be

carried out by a contractor licensed for this

work by the HSE.

Asbestos Incidents:

• Contaminated Clothing

• Staff or others who may have been exposed

to the asbestos dust must not be allowed to

take home clothing that might be

contaminated with asbestos fibres.

Asbestos Incidents:

• Contaminated Clothing

• Clothing that is (or could possibly be)

contaminated by asbestos must be removed

and placed in a polythene bag which is then

sealed for disposal.

• Suitable alternative clothing must be made

available.

Asbestos Incidents:

• Contaminated Equipment

• Any equipment or item that has been

contaminated with asbestos must be

thoroughly decontaminated by a licensed

contractor if it is to be reused.

• If it is to be disposed it must be securely

stored until disposed of by a licensed

contractor.

Asbestos Incidents:

• Clearing of Asbestos Debris

• Asbestos materials should never be left loose

or in a state where they can be trampled or

otherwise spread.

• Asbestos material or debris must only be

removed by a licensed contractor.

Asbestos Incidents:

• Reporting Incidents

• RIDDOR 2013

• Exposure to asbestos is reportable under

RIDDOR when a work activity causes the

accidental release or escape of asbestos

fibres into the air in a quantity sufficient to

cause damage to the health of any person.

Asbestos Incidents:

• Record Keeping

• Records must be made of all possible

exposures of staff to asbestos fibres. All such

records must be maintained for 40 years and

must contain at least the following

information:

Asbestos Incidents:

• Emergency Kit

Managing Asbestos – Key Facts:

• If you don’t manage asbestos in your premises,

you could be putting your employees’ and other

peoples’ health at risk.

• Exposure to asbestos occurs when you or others

disturb it, releasing fibres into the air we breathe.

• Asbestos in good condition should be left in

place and managed.


• Most work on asbestos requires a licence, but

some minor work on asbestos can be done

without a licence if the correct precautions are

followed.

• Regulation 4 of the Control of Asbestos

Regulations is a duty to manage, not a duty to

survey.


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

do have to manage your asbestos-containing

materials (ACMs).

• A bad survey is worse than not carrying out a

survey.

• Damaged or deteriorated ACMs should be

repaired or removed, or isolated until remedial

action can be taken.


• Managing asbestos means maintaining your

(ACMs) in good condition to protect two groups

of people:

• those who work on the fabric of the building

• those who work in the building who may come

into contact or work near damaged or

deteriorated ACMs.


• Your Asbestos Management Plan:

• is your way of ensuring that your employees

or others do not disturb your ACMs;

• can take many forms and need not be

complex, but it does need to be effective.

duty to manage asbestos in non-domestic premises … · •bohs p405 - management of asbestos in...

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