AchievingAsbestos Compliance - BHSEA (James Bradley) 30.4.19.pdf · 2019-05-13 · Removal Phase...
Transcript of AchievingAsbestos Compliance - BHSEA (James Bradley) 30.4.19.pdf · 2019-05-13 · 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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_02
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_02
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
• Continuing Action
• Carry out a risk assessment of your ACMs
Step 6
• Continuing Action
• Develop a long term management plan
Step 7
• Continuing Action
• Monitor and review the management plan
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Surveys
_06
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_03
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_03
UKAS Accreditation?
Source: UKAS
HSE: Strongly recommend
using UKAS accredited
surveying organisations
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Surveys
_04
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)
Managing Asbestos Compliance
You’re doing it right … aren’t you?
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.
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_03
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_03
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_03
Survey types
Re-inspection Surveys• Condition survey of known ACMs and an opportunity to inspect
previous ‘No Access’ areas.
• Air testing?
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_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
Assessing and prioritising ACMs
Product: Floor tiles containing Crocidolite
Location: Small cleaners storeroom (8m²) at a high school
Assessing and prioritising ACMs
Product: Damaged raw AIB to wall panel containing Amosite & Chrysotile
Location: Store cupboard for electrical consumer unit in a council house
Assessing and prioritising ACMs
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Surveys
_03
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Surveys - Communication
_08
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_09
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Surveys -The Asbestos Management Plan
_12
• 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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Surveys -The Asbestos Management Plan
_13
• 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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
So, you are doing it right………………………?
Really?
_16
Avoidable Exposures, Breaches of Regulations leading to Prosecutions and Damage to Reputation
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Removal Specifications
_17
Is it possible to price removals from this?
Managing Asbestos Compliance
You’re doing it right … aren’t you?
No specification?
_18
Wide
Ranging
Pricing
spread
Potential
for
variations
Risk of
Job delays
and liquidated
damages
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Removal Specifications
_19
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Specification Process
_21
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Specification Process
_22
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.
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Analytical Support
_25
• ’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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Analytical Support
_26
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_03
Stage 1: Preliminary check of site condition & job completeness Waste left on transit route, also not double bagged
Analytical Support
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_03
Stage 2: Examples of dust & debris left in enclosures
Analytical Support
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_03
Stage 2: Examples of dust & debris left in enclosures
Analytical Support
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_03
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_03
Stage 4: Final assessment post enclosure / work area dismantling Waste generated post scaffold removal – acceptable storage?
Analytical Support
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_03
Stage 4: Final assessment post enclosure / work area dismantling Remaining duct tape and expanding foam not cut back
Analytical Support
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Training
_27
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.
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Training
_28
Managing Asbestos Compliance
You’re doing it right … aren’t you?
Training
_31
ALFA LeadershipSafely, Honestly, Ethically
Above and Below the line
Blame
Excuses
Denial
Ownership
Accountability
Responsibility
You
You
Decision
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_37
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_38
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
The Analysts guide update
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_39
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
The Analysts guide update
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_42
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
The Analysts guide update
*Leaks have previously been considered an optional extra – the new emphasis will
therefore, have an impact on cost for some jobs
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_48
HSG248
4-Stage clearance – Stage 2 Visuals
The Analysts guide update
How Long??
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_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*
The Analysts guide update
*It is not currently a legal requirement for a laboratory to hold UKAS accreditation for quantification of
asbestos in soils
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_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.
The Analysts guide update
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
_60
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
Managing Asbestos Compliance
You’re doing it right … aren’t you?
“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