Camden’s Asbestos Management Policy
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Health & Safety Management System: Doc 32
Camden Health & Safety Service
Simple, sensible, safe
Camden’s Asbestos Management Policy
Camden Health & Safety Service
Simple, sensible, safe
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Date printed: 29/07/2017
Camden’s Asbestos Management Policy
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Health & Safety Management System: Doc 32
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Contents
CONTENTS......................................................................................................................................... 2
INTRODUCTION................................................................................................................................. 3
LEGAL IMPLICATIONS ..................................................................................................................... 3
STATEMENT OF INTENT .................................................................................................................. 5
RESPONSIBILITY FOR IMPLEMENTING THE POLICY AND ARRANGEMENTS ......................... 6
DUTY HOLDER ................................................................................................................................... 6
STRATEGIC MANAGEMENT.................................................................................................................. 6
THE RESPONSIBLE PERSON(S) ........................................................................................................... 6
IDENTIFICATION OF THE RESPONSIBLE PERSON ................................................................................... 8
NOMINATED RESPONSIBLE PERSON FOR SHARED, LET OR RENTED PREMISES ..................................... 8
NOMINATED RESPONSIBLE PERSONS FOR NEWLY ACQUIRED PREMISES .............................................. 8
THE APPOINTED PERSON(S)............................................................................................................... 9
IDENTIFICATION OF THE APPOINTED PERSON(S) .................................................................................. 9
OVERALL REQUIREMENTS OF EMPLOYEES, VISITORS AND CONTRACTORS ...................... 9
ARRANGEMENTS WITHIN SCHOOLS, PUPIL REFERRAL UNITS, THE STATUTORY YOUTH
SERVICE AND PLAY CENTRES ..................................................................................................... 10
COMMUNITY SCHOOLS, COMMUNITY SPECIAL SCHOOLS, VOLUNTARY CONTROLLED SCHOOLS,
CHILDREN’S CENTRES, PUPIL REFERRAL UNITS AND YOUTH SERVICE. ............................................... 10
ASBESTOS RISK MANAGEMENT ORGANISATION .................................................................... 12
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Introduction
It has been recognised for some time that asbestos poses a serious threat to human
health. The Health and Safety Executive estimates that over four thousand people a year
die from exposure to asbestos. While deaths have been attributed in the past to working
directly with asbestos, it is now widely accepted that deaths are occurring to contractors
who may inadvertently disturb asbestos, for example electricians and plumbers and
persons present in buildings where asbestos isn’t being managed properly, for example
office workers.
The London Borough of Camden (Camden) will ensure that:

Asbestos containing materials in areas or buildings either owned or controlled by
Camden are identified.

Identified asbestos is subject to risk assessment, the results of which will be used to
identify suitable control measures whether this is to manage in situ or remove.

The findings of asbestos surveys and risk assessments are be communicated to
relevant persons, for example those who could be working on or in the vicinity of
asbestos such as contractors or members of staff.

Where work is due to take place on or in the vicinity of asbestos, suitable precautions
are taken which comply with HSE guidelines.

Directorates with responsibility for the management of asbestos within their premises
designate an asbestos responsible and appointed person. Their duties are to
coordinate and manage all of the asbestos activities for their directorate, making sure
there is a standardised approach and up to date requirements are met.
Legal Implications
Under the Control of Asbestos Regulations 2006 (CAR 2006) there is a requirement within
Regulation 4 to manage the asbestos risk in workplace premises (this includes all common
areas of communal housing etc). This duty specifically requires a management procedure.
The overall CAR 2006 requires management and control of asbestos including its
disturbance and work with it together with any work which involves asbestos materials,
directly, indirectly, incidentally or accidentally. This regulation is focussed on all non
domestic premises.
The Management of Health and Safety at Work Regulations 1999 requires that risks are
assessed and The Health and Safety at Work etc. Act requires a regime in place to avoid
risk to individual employees and others as part of work. These regulations define
assessment of risk and therefore the requirement for asbestos surveys before work
commences in domestic and non domestic areas. A register of all existing surveys within
domestic and non domestic dwellings will be maintained and where surveys of these
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dwellings have not been undertaken a programme is to be implemented to undertake
surveys of these. Void Properties will also form part of this ongoing survey programme.
The Construction Design and Management Regulations 2007 require the client to identify
hazards, and define the requirement for understanding hazards and where they are
located, asbestos is a significant hazard which must be identified and managed.
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Statement of Intent
The London Borough of Camden (Camden) recognises its duties under the Health and
Safety at Work etc. Act 1974 and The Control of Asbestos Regulations 2006 (CAR 2006)
and all associated approved codes of practice and guidance.
Camden is committed to effective management of asbestos.
Camden also recognises its roles, duties and responsibilities in providing a pro-active
management approach in order to protect employees, contractors, visitors and customers
from the hazards posed by asbestos containing materials and to ensure that no-one is
exposed to asbestos beyond the realms of what is reasonably practicable.
This policy is reinforced by various duties under several regulations including the duty
under Regulation 4 of CAR 2006 and the requirements of the ‘duty holder’. The attached
management strategy & procedure sets out how Camden will achieve these requirements.
Camden’s asbestos management strategy consists of two parts. The first being a policy /
overriding strategy, and the second being the working arrangements.
This document is to be available to all staff as a working procedure. CAR 2006 requires
that Camden ensures that.

A strategy has been developed to safely manage the risks that may arise from
asbestos.

Manage and maintain asbestos in a good state of repair or remediate if this is not
possible.

All contractors are aware that they are not permitted to undertake works which either
impact directly on, or are in the vicinity of asbestos materials. Where there is likelihood
that asbestos materials may be disturbed as a result of the execution of such works,
such works will be controlled and assessed by competent personnel.
The overriding strategy is to maintain asbestos in a good state of repair, either by repair,
removal, sealing or encapsulation and without disturbance caused by localised work.
Where such work could disturb the asbestos it will either be protected, removed or suitable
control measures put in place beforehand by those competent to do so.
Matthew Green
Health and Safety Manager
London Borough of Camden
Date: November 2011.
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Responsibility for Implementing the Policy and Arrangements
In order to comply with Camden’s asbestos policy and arrangements it is necessary to
allocate certain responsibilities to specific individuals and these are named in this
document.
This document is based on the guidance laid down in the various HSE documents,
including ‘A Comprehensive Guide to managing Asbestos in Premises’ (HSG 227).
Duty Holder
Full and final responsibility for ensuring that Camden has an effective system for
controlling asbestos risk which is compliant with CAR 2006 and ‘A Comprehensive Guide
to managing Asbestos in Premises’ (HSG 227) rests with the chief executive.
The health and safety manager is responsible for establishing a health and safety
management framework and the provision of competent advice.
Corporate responsibility for ensuring that the duties relating to asbestos are met by
directorates will be overseen by the health and safety management system and reported
to the Executive on an annual basis.
This policy document will be owned by the Camden Health and Safety Service based
within HR.
Strategic Management
Directors whose directorates manage property can be viewed as 'owning' the property on
behalf of the Council.
Directors are responsible for ensuring adequate resources are made available for the
effective management of asbestos risks.
The Responsible Person(s)
The Control of Asbestos Regulations 2006 (CAR), particularly Regulation 4, requires the
appointment of duty holders. For the purposes of Camden these will be referred to as the
responsible person(s).
The responsible person may wish to delegate some of their responsibilities to a competent
contractor or member of staff, but they remain responsible for the actions of any contractor
or member of staff appointed by them.
The responsible person is required to:

Develop and maintain an asbestos management strategy and procedure for properties
under their control.
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
Take steps to undertake an assessment of all Camden sites for which they are
responsible, identifying buildings and premises which require an asbestos survey and
risk assessment.

Work together with other duty holders where sites, buildings and premises are shared,
let or rented with regard to asbestos; taking all relevant information into account.

Implement systematic and regular asbestos surveys to identify and record the location
and condition of known or suspected ACMs.

Ensure a minimum of a sampling management survey is undertaken for every building
under their control.

In conjunction with specialist advisors, as appropriate, undertake a risk assessment of
all known or suspected ACMs within properties under their control.

Co-operate with other duty holders where sites, buildings or premises are shared, let
or rented.

Ensure that all conclusions, findings of all asbestos surveys, assessments and all
other relevant information is held at a central and accessible location and that this
information is updated regularly, with all updates fully recorded.

Undertake all necessary steps to ensure that the asbestos information is made readily
available to all parties who may be affected by the presence of such ACMs, both
internal and external.

Undertake suitable regular training to fulfil the role of responsible person.

Ensure any managers, employees, and third parties where necessary are suitably
trained to fulfil their role.

Ensure that the information is effectively distributed.

Develop and monitor safe systems in order to protect those who may disturb asbestos
during the course of their work, or those that may be affected by its presence.

Ensure for specific projects that refurbishment and demolition surveys are conducted
when undertaking refurbishment or demolition works or where otherwise deemed
necessary.

Ensure for specific projects where a refurbishment and demolition survey is required
that adequate allowance is made in programme and scheme budgets and that the
overall findings are used as part of an overall assessment before work commences.

Ensure that priority assessments are completed and updated and include
recommended actions.
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
Maintain documentation for the required length of time relating to asbestos including
air monitoring data, tender information, and waste disposal notes, etc.

Compile and comply with a table of priority for action with regard to remediation of
ACMs on site.

Control the activities of appointed persons.
Identification of the Responsible Person

Within Corporate Property the responsible person is the head of corporate property.

Within Children, Schools and Families, the responsible person(s) are outlined in the
section ‘Arrangements within Schools, Pupil Referral Units, the Statutory Youth service
and Play Centres.’

Within Housing and Adult Social Care the responsible person is the asset
management team leader.
Nominated Responsible Person for Shared, Let or Rented Premises
In any premises where Camden is not the duty holder, for example where the landlord
retains the responsibilities and Camden is a lesser occupier, it is necessary that Camden’s
appropriate responsible person who is responsible for the contractual arrangement with
the duty holder puts adequate mechanisms in place to ensure that the premises is meeting
the requirements of the Control of Asbestos Regulations 2006. This will include identifying




The Duty Holder(s).
Availability of asbestos register for the premises.
Availability of the asbestos management and action plans.
Adequate lines of communication to report damage to ACMs and proposed works to
the premises.
Nominated Responsible Persons for Newly Acquired Premises
Where the properties are to be newly acquired by Camden, the person responsible for this
process shall ensure that appropriate and adequate information is obtained on the
presence, nature and extent of any ACMs contained within the site, building or premises
and, where appropriate, undertake additional survey work prior to acquisition.
All proper advice and information shall be sought from previous owners, occupiers or their
duty holders and, if proven to be lacking, make any necessary arrangements to improve
this knowledge and reduce the risks to Camden and its employees, agents or contractors,
etc. Pre-acquisition audits for asbestos may be considered as a prudent course of action
in any event.
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The Appointed Person(s)
The appointed person is the person nominated by the appropriate responsible person. The
appointed person(s) implements the asbestos risk management system(s).

Ensure any persons who have the potential to come into contact with asbestos are
made aware of the asbestos survey and risk assessment and understand the
implications of access to an area where asbestos is present; this should include the
emergency services.

Liaise with other groups and disciplines in respect of building and maintenance works
and liaise with other associated duty holders.

Maintain the asbestos register for their site(s) – update with new information, remove
from the register any asbestos materials that have been stripped away. Make sure that
plans and other asbestos documents are up-to-date.

Hold data in an accessible form, be that for instance paper files, electronic format, and
intra/internet system or prominently displayed drawings.

Regularly inspect and audit asbestos containing materials where appropriate and
review priority assessments on a regular basis.

Liaise with staff and their representatives, health and safety advisors, enforcing
authorities and planning supervisors.

Institute and operate, where necessary, permit to work systems.
Identification of the Appointed Person(s)

Within Corporate Property the appointed person is the property manager.

Within Children, Schools and Families, the appointed person(s) are outlined in the
section ‘Arrangements within Schools, Pupil Referral Units, the Statutory Youth service
and Play Centres.’

Within Housing and Adult Social Care the appointed person is the compliance officer.
Overall Requirements of Employees, Visitors and Contractors

Actively co-ordinate with Camden and its agents in all matters of Health & Safety, and
pro-actively identify potential hazards to London Borough of Camden management
which may affect themselves or other building users.

When working in the vicinity of asbestos, comply with all relevant legislation, policies
and all health & safety procedures.
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
Employees and contractors will ensure they are satisfied with and understand the
asbestos information and recommended emergency procedures. These parties must
be made known, and make themselves known, to the asbestos appointed person for
that site.

Refrain from any activities which may disturb known or suspected asbestos containing
materials; (such as accessing any previously inaccessible areas, undertake any
refurbishment repair, installation, demolition or other works) prior to consultation with
the asbestos appointed person for that site.

Work together with Camden and its representatives to prevent exposure to asbestos.

When working in any London Borough of Camden property or building ensure that the
asbestos management provisions are accessible in order to carry out the work safely.

When considering any alterations, refurbishments, adaptations, building work etc.,
consult with the asbestos appointed person (as a minimum) over any potential
disturbance or changes in circumstances that may affect the risk of damage to ACMs.

All significant works or those that will directly affect ACMs in the immediate vicinity (or
areas that may be used in connection with the planned works) must be advised to the
asbestos appointed person who will then consider further appropriate involvement or
action.
Arrangements within Schools, Pupil Referral Units, the Statutory Youth
service and Play Centres
This section recognises the unique arrangements for managing asbestos within schools,
pupil referral units and the statutory youth service and seeks to establish roles and
responsibilities with regard to asbestos.
Community Schools, Community Special Schools, Voluntary Controlled Schools,
Children’s Centres, Pupil Referral Units and Youth Service.
Camden is considered to be the employer within these settings. The responsible person is
the Head of Property and Contracts and the appointed person is the head teacher.
Within these settings Camden will:


Ensure directly that asbestos surveys and risk assessments have been completed.
Ensure directly that the required actions identified within the survey and risk
assessments are completed.
Foundation, Foundation Special and Voluntary Aided Schools.
Governing bodies are the employer responsible for health and safety in foundation,
foundation special and voluntary aided schools.
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The responsibility for ensuring such surveys and risk assessments take place and all
identified actions have been completed rests with the governing body.
Within these settings the responsible person is the governing body with the appointed
person being the head teacher.
Within these settings Camden will:

Raise awareness with head teachers and governing bodies of their responsibilities with
regard to asbestos.
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Asbestos Risk Management Organisation
Chief Executive
Health and Safety
Manager
Director of Finance
Strategic management
Head of Corporate
Property
Responsible Person
Property Manager
Appointed Person
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Director of Children,
Schools and Families
Strategic management
Director of Children, Schools
and Families / Head of
Property and Contracts
Responsible Person
Person nominated by
Responsible Person
Appointed Person
Director of Housing and
Adult Social Care
Strategic management
Asset Management
Team Leader
Responsible Person
Compliance Officer
Appointed Person