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Printable version (pdf) ¦ Back to Asbestos Information Inadequate Management Plans Undermine Asbestos Compliance From the oil platforms of the North Sea to the public lavatories of Derby City, every non-domestic building and structure in the UK should by now have given up its secrets. The concealed hazards of asbestos containing materials (ACM’s) in floor tiles and pipe insulation, in boiler roping and decorative finishes should now be safely recorded in accessible registers up and down the country, with plans and procedures in place which effectively render it harmless. In reality, the asbestos revolution is far from over. Most companies and organisations will now have noted the likely location of suspected ACM’s in shops and offices and factories, and done a rudimentary management plan as demanded by the Control of Asbestos at Work Regulations 2002 (CAWR). Many will only really be sure that they are compliant when the inspector calls. The CAWR introduced the new duty to manage asbestos in May last year with dutyholder responsibility resting with those who manage the maintenance and/or repair of non-domestic premises. In reality the responsibilities often fall between health and safety and facilities management, and have created a fervent demand for training amongst people with little previous knowledge of the issue. Getting to grips with their new duty to manage, they discover that it starts with finding out if asbestos is present in their buildings, and ends with the legal requirement to provide this formation to anyone likely to disturb it. The stages causing the most concern are the preparation of a comprehensive management plan, the steps necessary to put the plan into action, and the regular review of the document to keep it current. Uncertainly about the duty to manage has prompted the launch of an association designed to assist dutyholders with their responsibilities and advise and assist in all aspects of compliance. The Asbestos Safety Association provides dutyholders from any discipline with a range of resources to ensure compliance and proper asbestos management. The association will help with the management plan, and provides free initial compliance audits for members. The organisation has seen examples of even major companies making rudimentary mistakes and failing to reach compliance for a variety of reasons. A leading industrial processing company now faces HSE prosecution for the contamination of unlicensed workers who were removing redundant pipe work embedded in a factory wall. The company had done a type 2 survey - the standard sampling, identification and assessment survey - when only a full access type 3 survey would have discovered the asbestos packing around the pipes. And an international oil company with land based facilities and North Sea oil drilling platforms learned from NATAS Group that it was almost certainly non-compliant due to an inadequate management plan. NATAS was quickly retained to oversee surveys, handle broad and specific staff training and develop a new asbestos management plan for the multinational, putting in place a permit to work system to ensure short term compliance. The management plan is an organic piece of work which evolves and renews as the situation changes. It defines how you monitor asbestos and keep it in good condition; it is a record of work carried out on the material and the estimated levels of exposure of the personnel involved. The plan explains about asbestos, what it is and the risks it poses. It outlines legislative obligations, and the procedures put in place to monitor everyone entering the site to do work which may bring them in contact with asbestos. It is a tool for use at all staff levels, and should assume little prior knowledge. The survey is not the key or even legally required, but rather a valuable and sometimes essential tool. It may be enough to walk through a premises and record the location and condition of ACM’s. And where there is doubt and no testing is done the law is clear that the material must be assumed to contain asbestos. The HSE defines three survey types. Type 1 locates all materials which could contain asbestos and without testing, presumes that they do. Type 2 is a standard identification, sampling and assessment survey of accessible ACM’s. And Type 3, a mandatory requirement before refurbishment or demolition of a building sets out to find every ACM in the structure before work commences. Although enforcement date for the new Regulation 4 was May 2004, many organisations are still unable to provide employees and contractors with the information they are legally required to have. Nuaire is one the world's largest manufacturers of ventilation equipment, and has a thriving installation business. It does much work in the public and private sector, and often struggles to obtain information about asbestos from duty holders. Stephen flood, Health and Safety Officer with Nuaire said: ‘We are surprised at how many organisations are unable to provide adequate information. Some seem unclear about the regulations, and others are still struggling to come into compliance. We are working with the Asbestos Safety Association on procedures which include asking the appropriate questions when we take orders from such organisations. The company’s own compliance was a matter of gaining the right training and support. All Nuaire contractors received asbestos awareness training. Its Health and Safety Advisor took P405 and P402 BOHS courses and the company joined the ASA. Its factory dates back to the 1970’s and ACM’s in decorative coatings and an old boiler were removed during a refurbishment project; remaining ACM’s are safe and regularly checked. Some local authorities may seem behind but others are well ahead of the game. Solihull Community Housing is surveying its 12,000 community homes over five years even though this is not a legal requirement, and its 180 maintenance and engineering staff have all received asbestos awareness training from Natas:group. When complete, the system will issue to maintenance workers a detailed description of ACM’s likely to be encountered with every job ticket. Derby City Council responded to the looming asbestos issue by recruiting a specialist from the asbestos industry. Will Deverill has been Asbestos Manager with the council since November 2003 and has overseen the regulatory compliance of more than 1000 council buildings from the Town Hall to public toilets. Policy, procedure and other guidance documents are now being finalised with the assistance of the Asbestos Safety Association into a Derbyshire Council Management Plan. This is a central reference point for any asbestos issue, and the task now is to communicate the availability of this information and how it should be used. Training is essential, and all council staff now have access to training relevant to their level of need. Despite the enormous HSE campaign over many years, Derby City Council still confronts the lack of asbestos knowledge amongst contractors and professionals every day. ‘The vast majority have only a very basic understanding of asbestos and the dangers which come from poor working practices,’ said will Deverill. ‘They don't seem to know how to plan a project and have no idea of the operations of the asbestos industry. Derby City Council was one of the first members of the Asbestos Safety Association, which has advised on training issues and the development of its management plan. The association has also been used as a conduit into the HSE and the asbestos liaison group. The council has remained compliant, and pre-empted problems by starting early and getting help when it was needed. ‘My advice would be to directly employ or get a working arrangement with a group or association that can provide straight professional advice at the highest level. Secondly, the full survey of your building stock is the most powerful tool you have got, and provides the information upon which everything is based. Lastly, proper planning and incurring the necessary costs up front will save money in the long run; doing everything at the last minute is expensive. Appendix The Asbestos Safety Association is the only organisation designed to assist dutyholders in their duty to manage, and provides information and guidance on a wide range of asbestos related issues. Some of the services include:
Further information is available from www.asbestossafety.org.uk or 0870 751 1888. |
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