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Asbestos in RC?_IDE LEEDS 23.2.18
Wayne Bagnall Ltd Birchwood WA3 4FS
www.waynebagnall.co.uk 07712 767744 1
IDE Leeds Seminar 23 Feb 2018
Wayne Bagnall MBE
MSc CMIOSH MIDE MCMI
Is there asbestos in your RC?
• Specialist in asbestos & demolition safety
management for advice, solutions & training
– Please visit my Web Site
– Allows access to downloads
– Provides updates
www.waynebagnall.co.uk
Content
1. Introduction & background
2. Findings of an Asbestos R&D Survey
3. History of asbestos cement products in concrete
4. Position of the Health & Safety Executive
5. Position of the Environment Agency
6. Protocols and control measures during the
demolition & processing of the arisings
Mill demolition + poor survey = gross asbestos
contamination in recycled aggregate (40K m³)
Asbestos Insulation Board (licensable)
also identified in the recycled aggregate After demolition building slab lifted ACMs found in the
sub-base material (1960 building)
CL:AIRE soil
guidance 7.16 Ciria C733 (2014) Ciria C765 (2017)
Asbestos in RC?_IDE LEEDS 23.2.18
Wayne Bagnall Ltd Birchwood WA3 4FS
www.waynebagnall.co.uk 07712 767744 2
(Poor) Asbestos Survey;
CAF gaskets & refractory only
Recommended a controlled
drill through steel shell
Lining of Asbestos Insulating
Board (~40% Amosite)
Projection UK annual mesothelioma deaths
Part 2:
HSG 264
Asbestos R&D Survey
&
findings
Client engaged UKAS
Accredited Surveyors
(ISO 17020) for part of PCI
Asbestos Refurbishment
& Demolition Survey
(HSG 264)
Typical 1960’-70’s 7 storey reinforced concrete frame building built
behind a 1900’s façade (400m³ concrete / floor x 7 = circa 6,500t)
(Asbestos) Cement Spacers are only visible when
they had tipped over (typically 3 or 4 / m²)
Asbestos in RC?_IDE LEEDS 23.2.18
Wayne Bagnall Ltd Birchwood WA3 4FS
www.waynebagnall.co.uk 07712 767744 3
The hole in the
spacer was useful
to take a sample.
Confirmed as a
very hard Asbestos
Cement
~5% Chrysotile
(white)
These shaped
spacers were
identified, sampled
& confirmed as
Asbestos Cement
~5% Chrysotile
(white) ~50mm x 50mm x ?
NB: Some spacers
were fibre cement
and others plastic!
Extract from Derisk
Asbestos R&D Survey
NB They have found these on
another project
Assuming ALL spacers are Asbestos Cement, which they’re not;
(<4 spacers/m²) with 7 floors x 1600m² (400m³) concrete / floor
circa 6,500t arisings assuming no removal during the demolition
(asbestos range from 0.002% to 0.03% w/w)
Asbestos in RC?_IDE LEEDS 23.2.18
Wayne Bagnall Ltd Birchwood WA3 4FS
www.waynebagnall.co.uk 07712 767744 4
Core sample:
Lab unsuccessfully
attempted to separate
the spacer from the RC
Material was extremely
hard & bonded in RC
Part 3:
History of Asbestos Cement
Spacers
Plus other spacers as used in
reinforced concrete
I carried out a
web search; Blue
Circle, Lafarge,
Concrete Society
& also enlisted the
help of Steve
Sadley – ARCA
Attempts to
contact the
Concrete Society
via their website
failed, however...
Answer:
Frank advertised (via Creteco) asbestos spacers in 1977, see attached. Similar adverts in 1984 omitted the word asbestos for just fibre. Unfortunately we don't have the directories between 77 and 84 to see when the change occurred.
Frank is now Max Frank and I believe Creteco is part of the same organisation. http://www.maxfrank.co.uk/uk/contact-us/index.php
Click here to respond
Richard Day The Concrete Society Ltd
Please note that The Concrete Society is a membership organisation and, as such, in-depth advice is generally only provided to members of The Concrete Society.
The Concrete Advisory Service is operated by the employed staff or nominated agents of The Concrete Society Ltd. Any advice, guidance, opinion or recommendation must not be interpreted as being representative of the collective view of The Society's membership. The Concrete Society responded to ARCA with;
Asbestos Spacers were advertised in 1977 (Creteco)
1984 similar adverts were out but omitted the word
asbestos for just fibre (no records between 1977 – 84)
CRETECO
Manufactured Asbestos
Cement products
(in 1cwt / ~50kg bags)
I polled several construction
specialists; one person from
Fairclough used to make their
own Cement spacers for RC
with wires for fixing by;
• Mould set to required depth
• Trowel in a strong mix &
scored before setting
• Left overnight then broken
into pieces (squares)
Asbestos in RC?_IDE LEEDS 23.2.18
Wayne Bagnall Ltd Birchwood WA3 4FS
www.waynebagnall.co.uk 07712 767744 5
Current products
for spacers
include;
Fibre reinforced
concrete, plastic
and metal
RC + fibre reinforced concrete spacer/tube
NB older spacers are likely asbestos (AC)
Modern non-asbestos fibre spacers
Examples of
plastic spacers to
provide sufficient
cover to metal
rebar
http://www.southcoa
ststeel.co.uk/index.p
hp
We found these plastic spacers in precast units and waffle slabs
Asbestos in RC?_IDE LEEDS 23.2.18
Wayne Bagnall Ltd Birchwood WA3 4FS
www.waynebagnall.co.uk 07712 767744 6
Parts 4 & 5:
HSE & Environment Agency
opinion on these Asbestos
Cement Spacers
CAR 2012 (Asbestos Regs)
and
WM3 & REACH (Registration, Evaluation, Authorisation and
Restriction of Chemicals)
Haz Waste 05 REACH 07 Others….
App. Code
of Practice
L143 (2nd edition)
Asbestos ACOP
App. Code
of Practice
Guidance Guidance
Health and Safety at Work Act 1974
Control of Asbestos Regulations 2012 (changes e.g. NNLW etc. into force 6.4.12)
CAR 2012, L143 ACOP & Demolition work
• Reg 7: plans of work; ACOP & Guidance
In the case of demolition or major refurbishment, the plan of
work must specify that all asbestos is removed before any
major work begins, where this is reasonably practicable & does
not cause a greater risk to employees than if the asbestos had
been left in place (paragraph 190)
• Where removal of ACMs is time-consuming and resource-
intensive & only involves lower risk material such as textured
decorative coatings containing asbestos, then removal may not
be reasonably practicable (paragraph 191)
• Remember ‘Duty of care’ where known asbestos left in
• Limit of quantification for testing = 0.001% w/w
HSE also referred me to
this old 2008 guidance
1. AC spacers at ~5% white asbestos & very hard; 1. Asbestos has not been deliberately added (REACH)
2. It was not reasonably practicable to remove in advance
3. Ensure conventional dust suppression for RCS (wetting)
4. Opinion was that the health risks were extremely low
5. Remote / mechanical demolition was suitable
6. Suitable control measures and sporadic testing
7. This activity would NOT be defined as work with asbestos
2. Must ensure the following: 1. Identify spacers; paint to identify & remove pieces >demo
2. Ensure controls to minimise exposure & spread (as above)
3. Could be processed & crushed (keep damp)
4. Process & use arisings sensibly (e.g. under slabs)
HSE: Demolition & health risks from AC spacers
Asbestos in RC?_IDE LEEDS 23.2.18
Wayne Bagnall Ltd Birchwood WA3 4FS
www.waynebagnall.co.uk 07712 767744 7
Respirable crystalline silica (SiO²) = Silicosis** Quarries video; http://youtu.be/sWLPMgpMQCU
Crushing, scabbling, sawing & drilling stone with high silica (quartz) e.g.
Concrete Dust exposure must NOT exceed 0.1 mg/m3 (WEL)
**Similar effect as Asbestosis: Silicosis killing 900 persons/year**
Pictorial Depiction of WEL
IOSH & HSE campaigns; Shadows on X-rays indicates silicosis**
6. Asbestos fibres
(a) Crocidolite
CAS No 12001-28-4
(b) Amosite
CAS No 12172-73-5
(c) Anthophyllite
CAS No 77536-67-5
(d) Actinolite
CAS No 77536-66-4
(e) Tremolite
CAS No 77536-68-6
(f) Chrysotile
CAS No 12001-29-5
CAS No 132207-32-0
1. The manufacture, placing on the market and use of these fibres and of articles and mixtures containing these fibres added intentionally is prohibited.
However, Member States may exempt the placing on the market and use of diaphragms containing chrysotile (point (f)) for existing electrolysis installations until they reach the end of their service life, or until suitable asbestos-free substitutes become available, whichever is the sooner.
By 1 June 2011 Member States making use of this exemption shall provide a report to the Commission on the availability of asbestos free substitutes for electrolysis installations and the efforts undertaken to develop such alternatives, on the protection of the health of workers in the installations, on the source and quantities of chrysotile, on the source and quantities of diaphragms containing chrysotile, and the envisaged date of the end of the exemption. The Commission shall make this information publicly available.
Following receipt of those reports, the Commission shall request the Agency to prepare a dossier in accordance with Article 69 with a view to prohibit the placing on the market and use of diaphragms containing chrysotile.
2. The use of articles containing asbestos fibres referred to in paragraph 1 which were already installed and/or in service before 1 January 2005 shall continue to be permitted until they are disposed of or reach the end of their service life. However, Member States may, for reasons of protection of human health, restrict, prohibit or make subject to specific conditions, the use of such articles before they are disposed of or reach the end of their service life. Member States may allow placing on the market of articles in their entirety containing asbestos fibres referred to in paragraph 1 which were already installed and/or in service before 1 January 2005, under specific conditions ensuring a high level of protection of human health. Member States shall communicate these national measures to the Commission by 1 June 2011. The Commission shall make this information publicly available.
3. Without prejudice to the application of other Community provisions on the classification, packaging and labelling of substances and mixtures, the placing on the market and use of articles containing these fibres, as permitted according to the preceding derogations, shall be permitted only if suppliers ensure before the placing on the market that articles bear a label in accordance with Appendix 7 to this Annex.
HSE & REACH: As with all the restrictions it was not the intention to change the wording or the meaning of them as they were moved into Annex XVII from their previous homes.
Therefore there is nothing to suggest that the legal advice that you previously received has changed in any way. It is clear from para 1 that the restriction only refers to the intentional addition of the asbestos.
Annex XVII of REACH contains a list of the restrictions, number 6 refers to Asbestos. The legal text is above for
ease of reference.
1. We have discussed this waste with National haz
waste colleagues and we consider the codes 17 09
03*/17 09 04 are appropriate for this waste. As this is
a mirror entry classification an assessment must be
made in accordance with WM3. The assessment
(calculation) you have carried out indicates that in this
case the code would be 17 09 04.
2. However, it is important to stress that even if the
asbestos is below hazardous waste thresholds, it is
still present in the waste. Whenever asbestos is
present there are restrictions for its use under
REACH meaning that the waste CANNOT go
for crushing to form aggregate for re-use.
EA initial position on Waste Classification (1:2)
3. That being so regrettably the waste will have to go to
landfill.
4. The presence of asbestos in the waste must be
legally declared on the duty of care transfer note
where it has been assessed as 17 09 04 so that it
can be managed appropriately.
5. The producers must seek specialist advice around
working with asbestos before it is moved off site.
EA initial position on Waste Classification (2:2) After some lengthy dialogue with the
Environment Agency...
Asbestos in RC?_IDE LEEDS 23.2.18
Wayne Bagnall Ltd Birchwood WA3 4FS
www.waynebagnall.co.uk 07712 767744 8
1. We have not yet had a response in respect of
REACH but my colleague and I are both of the view
that REACH is about products (including products
made from waste) and hence would apply if you were
wishing to produce a recycled aggregate, for example
under the Quality Protocol.
2. If you only wish to retain some of the waste on site for
use under a slab where it would not be disturbed then
this may be able to be achieved under the current
version of CL:AIRE DoWCoP
https://www.claire.co.uk/projects-and-initiatives/dow-
cop.
EA LATER position on Waste Classification (1:2)
3. This would allow re-use of materials that could be
described as having some hazardous properties,
such as minimal asbestos, if used in certain ways on
site.
4. HSE take also reflects this view. The general concern
is long term management.
5. So cover under concrete slabs or hard surfaces has
been acceptable if passed by the relevant
Environmental Health Officer and planning
requirements for the development in question.
EA LATER position on Waste Classification (2:2)
Part 6:
Protocols & control
measures during
the demolition
Including
processing of the
arisings
CL:AIRE guide 7.16 Ciria C733 (2014)
Ciria C765 (2017)
1. Having received PCI; Asb R&D Survey etc; 1. Considered the report issued by the client (<0.1% w/w)
2. Not reasonably practicable to full removal in advance
3. They will identify these spacers where visible
4. Use conventional dust suppression for RCS (light sprays)
5. Mechanical demolition; top down (floor by floor)
6. Any painted concrete would be removed as an ACM
7. Suitable controls + dust testing to prove effectiveness
2. Arisings to be landfilled & recycled: 1. Only separated ACM (painted pieces) to landfill
2. Found a home for the arisings (subject to above protocol)
3. Would be processed & crushed (kept damp)
4. Arisings would be sensibly used (e.g. under slabs)
Demolition Contractors proposed arrangements
Asbestos in RC?_IDE LEEDS 23.2.18
Wayne Bagnall Ltd Birchwood WA3 4FS
www.waynebagnall.co.uk 07712 767744 9
1. Asbestos has not been deliberately added (REACH)
2. It is not reasonably practicable to remove in advance
3. Conventional dust suppression for RCS (wetting)
4. Opinion is that the health risks were extremely low
5. Remote / mechanical demolition was suitable
6. Efforts to remove ACMs during the demolition process
7. Suitable control measures with sporadic testing
8. This activity is NOT defined as work with asbestos
• Arisings (waste & product): 1. Picked ACMs double bagged/disposed (Haz Waste >0.1%)
2. Majority >99% will be processed and used appropriately
It is not an exact science, however, given common sense and honesty there are sensible solutions
Summary and outputs
Private details
This presentation
is on a specific
project with a
preciś of the full
report; it is
provided on the
basis to raise
awareness only.
NB: If you come across
ACMs in RC, please seek
specialist advice before
embarking on a strategy.
Thank you, ANY questions?
If you would like more information on this topic
PLUS
2 day Demolition Management training (21_22/5/18)
and, or,
2 day Asbestos Management training (23_24/5/18)
Please see me or email: [email protected]
Wayne Bagnall Consulting
PO Box 41
Birchwood
WA3 4FS Telephone 01925 767722
Facsimile 01925 767733
Mobile 07712 767744
E-Mail [email protected]
http:// www.waynebagnall.co.uk