Asbestos - no hiding place
survey and manage asbestos in buildings now
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The Health and Safety Commission (HSC) has just consulted, for a second time, on the duty to survey and manage asbestos in commercial buildings. Because, uniquely, this is a second consultation, it is expected that the key points of the final regulation and HSC approved code of practice, will differ little from those now proposed. It is expected to become law by 2004. The proposed new regulation, and approved code of practice, will cover only 2 million commercial premises out of an estimated total of 4.4 million buildings that may contain asbestos.
The pressure must be maintained, by the trade unions and others, to get all buildings and homes containing asbestos surveyed and managed. The more responsible local councils are already surveying all their properties for asbestos and removing or managing the asbestos they find. Trade unions must push for this to be the case for all councils.
The Health and Safety Commission (HSC) admits that
It is known that of the over 5,000 asbestos-related deaths each year, one in four are building workers. The HSC claim that new regulations will save around 3,800 deaths during the next 100 years.
There will be the usual problems of lack of enforcement and low fines with these new regulations. Also, it has not yet been decided whether the HSE or local council Environmental Health Officers (EHOs) will enforce these regulations. Either way, it is vital that trade union safety representatives make their employers aware of them now, if the true savings from asbestos-related diseases are to be realised in this century.
The Proposed Regulations and Approved Code of Practice (ACoP)
In summary the new asbestos Regulations, and HSC Approved Code of Practice (ACoP), will require the owner/renter of any commercial premises:
Consultation with Safety Representatives
By law, trade union safety representatives must be consulted by their employer, in good time, about the way in which the survey is to be conducted and what is to be done as a result of the survey. The accompanying Approved Code of Practice (ACoP) to the new asbestos regulations will make this quite clear in several ways:
In practice, trade union safety representatives will be essential in ensuring that these regulations are applied effectively and thus save lives.
Responsibility of employer/owner/renter of premises
The new regulations will ensure that someone is responsible for the surveying and management of asbestos in all commercial premises. In practice many employers or owners/renters of premises will employ a consultant to carry out the asbestos survey. However, the Approved Code of Practice will note that,
Employing an asbestos surveyor/consultant
And, of course, the safety representative must be consulted 'in good time' about the employment of any asbestos surveyor or analyst. Surveying for asbestos is a specialist job and there is a shortage of good asbestos surveyors. The best guide to a 'good' consultant is: whether your trade union knows of them, their familiarity with the law, whether or not they are prepared to consult, meet and listen to safety reps and give details of any previous union-organised work they have completed, with the name and phone number of a safety rep to contact.
The willingness to talk to safety reps is good, but not a foolproof guide to honesty, competence etc. Membership of a trade association, such as the Asbestos Removal Contractors' Association (ARCA), the Asbestos Control and Abatement Division (ACAD) of the Thermal Insulation Contractors' Association (ARCA) or even a laboratory accredited by the UK Accreditation Service (UKAS) is not a guarantee of safety and good work either. But, if they are not members of these bodies, avoid them.
The asbestos survey
As the diagram above indicates, a full asbestos survey of a building can be quite an exercise! Hence the vital need for a fully qualified asbestos surveyor.
The Approved Code of Practice will note the assessment should also include: warehouses, sheds, yards, outbuildings, underfloor service ducts, corridors, vertical risers, external runs of pipes and bridges - 'in fact any part of the premises where asbestos might have been used'. Fixed plant and machinery like printing machines and parts of process plant and mobile units are also included. The only exclusion is heavy trucks that may have asbestos containing brake linings and which are covered by other regulations.
Any material that is thought to be asbestos should either be analysed or assumed to be asbestos. A drawing of each room or part of a premises, as near to scale as possible, should be made and it will need to include at least:
Even if the survey shows no asbestos, this should be recorded and the person(s) and methods used to survey noted, and the date of the survey.
The Approved Code of Practice will note:
When asbestos is found - the assessment
Asbestos of greater risk according to the draft Approved Code of Practice is that which:
It's worth repeating the HSC statement:
Repair or remove the asbestos?
This is sometimes a difficult decision, if there is a lot of asbestos present in a building. If the asbestos is not removed, it will have to be managed as it may deteriorate through wear and tear, maintenance activities and or fire or water damage. It will have to be removed sometime, either when it does decay, or when there is extensive refurbishment or demolition of the building. And there is always the worry factor of asbestos being present in a building and the lower value of those premises. The option to remove all the asbestos in premises should always be the first one to be considered seriously, it may be the best long-term option, although if there is damaged asbestos in a building, it should certainly be removed first.
The Approved Code of Practice will say the following factors should be taken into account when deciding whether to remove or repair and manage, and gives some more discussion of their applications:
Managing any asbestos left in place
The Approved Code of Practice will recommend the following procedures:
Air samplingThe Approved Code of Practice will advise that:
But the Approved Code of Practice will add,
The HSC admits that:
Yet the regulations say little about the safe disposal of any asbestos that has been removed. Asbestos waste is very dangerous and can only be removed by a specially licensed contractor and disposed of at a site licensed by the Environment Agency to receive it.
There is a special page on this campaign on the HSE website, at www.hse.gov.uk/asbestos/index.htm
Revised proposals for amendments to the Control of Asbestos at Work Regulations and a new supporting Approved Code of Practice, HSC Consultative Document CD 176; free
Managing asbestos in premises, HSE INDG223 (rev2); free.
Surveying, sampling and assessment of asbestos-containing materials, MDHS 100, HSE (July 2001); £18
Introduction to asbestos essentials - comprehensive guidance on working with asbestos in the building and maintenance trades, HSE, HSG12; £12.50
Asbestos essentials, task manual - task guidance sheets for the building maintenance and allied trades, HSE, HSG210; £8.50
HSE publications are available from: HSE Books, PO Box 1999, Sudbury, Suffolk, CO10 2WA. Tel: 01787 881165; Fax: 01787 313995
A very useful, updated reference work for your employer to get and thus the safety representative to have access to is: Croner's Asbestos Risk Management, £131, Croner CCH Group Ltd, 145 London Road, KT2 6BR, Price £130.75, Tel. 0207 247 1175. www.croner.cch.co.uk
Many trade unions publish guidance and help on asbestos - check with yours.
The TUC publishes material on asbestos and gives safety rep training, contact: TUC, Congress House, Great Russell Street, London, WC1B 3LS. www.tuc.org.uk/h_and_s
Stay up to date by viewing Risks at www.tuc.org.uk/risks/
The Hazards Campaign has affiliated asbestos help and advice groups and centres up and down the country and they can often help on asbestos issues. Contact: Hazards Campaign, c/o Greater Manchester Hazards Centre, 25 New Mount Street, Manchester, M4 4DE or check the directory at www.hazardscampaign.org.uk
Nancy Tait's Occupational and Environmental Diseases Association (OEDA, PO Box 26, Enfield, EN1 2NT; 0208 360 8490, www.oeda.demon.co.uk) gives advice and carries out fibre analysis on lung sections at very reasonable rates.
An Asbestos Exhibition is available for display at meetings, for further details contact Mick Holder at London Hazard Centre tel: 0207 794 5999, email firstname.lastname@example.org
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