Wandsworth Borough Council
Health and Safety Manual
Chapter 19
Control of asbestos
Contents
This Chapter contains the following topics:
1.
Introduction ............................................................................................................... 3
2.
Definitions ................................................................................................................. 3
2.1
Asbestos .......................................................................................................... 3
2.2
Management survey. ........................................................................................ 3
2.3
Refurbishment/demolition surveys. ................................................................... 4
2.4
Types 1, 2 and 3 surveys. ................................................................................. 4
3.
Key Responsibilities .................................................................................................. 4
3.1
Chief Executive ................................................................................................ 4
3.2
Governing Bodies, Head teachers and Heads of Establishment ....................... 4
4.
Duties of owners and occupiers ................................................................................. 4
5.
What has to be done and how ................................................................................... 5
5.1
Delegating the task ........................................................................................... 5
5.2
Finding ACMs and assessing their condition .................................................... 5
5.3
Assessing the risks ........................................................................................... 6
5.4
Managing the risk and preparing a plan ............................................................ 6
5.5
Monitoring arrangements .................................................................................. 7
6.
Advice to staff regarding display work........................................................................ 7
7.
Inadvertent exposure to asbestos .............................................................................. 8
8.
Action on damage to suspected ACMs ...................................................................... 9
9.
Voluntary Asbestos Register ................................................................................... 10
10.
Further advice...................................................................................................... 10
11.
Annex A - Outline Asbestos Management Plan ................................................... 11
12.
Annex B – Voluntary Asbestos Register form ...................................................... 14
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Version
The table below shows the history of the document and the changes that were made at each
version.
Version
0.1 (draft)
0.2 (draft)
1.0
1.1
1.2
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Date
17 Jan 2012
13 Feb 2012
04 April 2012
23 Oct 2012
23 April 2013
Summary of changes
First issue draft for consultation
Amendment to Annex B
Initial issue
Amendment to room numbers
Annual review
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1.
Introduction
1.1
Products containing asbestos have been used in the construction of buildings for
many years. The most common areas where asbestos can be found are:








insulation to pipe work and ducts;
boilers;
ceiling tiles and composite panels to certain walling;
panelling to fire doors and service ducts;
roofs;
sprayed insulation to ceilings and structural components, such as steel
structure;
textured decorative coatings to ceilings, e.g. “Artex”;
fixed equipment e.g. kilns, ovens, heaters etc.
1.2
The presence of an asbestos containing material (ACM) does not in itself
constitute a danger. However, the ACM may become hazardous when disturbed
or damaged and must be treated accordingly. Activities which give rise to
airborne dust, e.g. breaking, sawing, cutting, drilling etc. are most likely to
present risks.
1.3
Work with ACMs is tightly regulated by the Control of Asbestos Regulations 2012
(CAR 2012) and accompanying Health and Safety Commission Approved Codes
of Practice.
2.
Definitions
2.1
Asbestos
There are three main types of asbestos found in premises; crocidolite, amosite
and chrysotile, commonly known as blue, brown and white respectively.
2.2
Management survey.
This is the standard survey, the purpose of which is to locate, as far as is
reasonably practicable, the presence and extent of any suspect ACMs in a
building. Depending on the premises this type of survey may involve minor
intrusive work and some disturbance.
A management survey should include an assessment of the condition of the
various ACMs and their ability to release fibres into the air. The survey may
involve sampling and analysis to confirm the presence of ACMs however the
survey can also involve presuming the presence of asbestos. Whether by
analysis or presumption the condition of any ACMs must be assessed.
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2.3
Refurbishment/demolition surveys.
This type of survey is used to locate and describe, as far as is reasonably
practicable, all ACMs in a building. This may involve destructive inspection to
gain access to all areas so that samples may be taken for analysis.
2.4
Types 1, 2 and 3 surveys.
Surveys prior to 2010 were conducted as either Type 1, 2 or 3. The old Type 1
and 2 surveys are more or less replaced by the management survey and a Type
3 survey is replaced by the demolition survey.
3.
Key Responsibilities
3.1
Chief Executive
3.1.1
Under CAR 2012 the Chief Executive is the principal Dutyholder as Wandsworth
Borough Council is ultimately responsible for the maintenance of properties
directly managed by the Council. In practice duties are discharged through the
Technical Services Department and the Head of Facilities Management
Services.
3.2
Governing Bodies, Head teachers and Heads of Establishment
3.2.1
As governing bodies, Head teachers and Heads of Establishment have day to
day control of premises and approve minor works services, including regular
maintenance, they too are seen as dutyholders under CAR2012.
4.
Duties of owners and occupiers
4.1
The duties in regulation 4 of CAR 2012 rest with the person in control of
maintenance activities. The extent of this duty will in most cases be determined
by the degree of responsibility over matters concerning the fabric of the building
and maintenance activities carried out there.
4.2
Specific duties are as follows:
4.2.1
carrying out an assessment as to whether asbestos is present and determining
its condition;
4.2.2
recording the results of the assessment and ensuring they are passed on to the
occupier of the premises;
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4.2.3
collaborating with the occupier and others in the preparation and implementation
of the management plan to control the risk from ACMs; and
4.2.4
ensuring that anyone potentially at risk receives information on the location and
condition of the material, so far as is within their control.
4.3
The majority of Council properties, including schools, have had a Type 2
asbestos survey carried out. Subject to an assessment of risk, management
surveys should be conducted on these premises on a regular basis to ensure the
continued management of the ACMs in situ. Those staff commissioning major
works must ensure a refurbishment/demolition survey is conducted prior to works
starting. (see definitions in paragraph 2)
5.
What has to be done and how
5.1
Delegating the task
5.1.1
Although duties fall to the dutyholder someone else can be nominated to do all or
part of the work but the legal duty cannot be delegated.
5.1.2
If the dutyholder decides to appoint a separate organisation or person to carry
out some or all of the work they should assess whether the individual or
organisation concerned:




has adequate training and experience for such work;
can demonstrate independence, impartiality and integrity;
has an adequate quality management system;
is carrying out any survey in accordance with recommended guidance (i.e.
HSG264 Asbestos:The survey guide).
5.2
Finding ACMs and assessing their condition
5.2.1
To comply with this part of the duty, an assessment will have to be made as to
whether or not there is or may be any asbestos anywhere in the premises and to
check its condition. For example, yards, sheds, outbuildings, under-floor service
ducts, corridors, vertical risers, external pipe runs etc. should all be included.
5.2.2
Everything that can reasonably be done must be done to decide whether there is
(or may be) asbestos in the premises, and if there is some, to find out where it is
or is likely to be. The condition of the material must also be assessed.
5.2.3
During the inspection of the premises, if any material is found that looks as
though it might contain asbestos, it should be presumed that it does, unless
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there is strong evidence that it does not, for example, a sample was taken
previously which showed that the material was not asbestos containing.
5.2.4
A detailed report, together with marked up drawings of the building, must be
made giving as much information as possible and identifying where any ACMs
have been found. Safety representatives are entitled, having given reasonable
notice, to inspect and take copies of any relevant documents.
5.2.5
Where an asbestos survey has been carried out it will need to be reviewed on a
regular basis and following any significant change in the premises.
5.3
Assessing the risks
5.3.1
As part of the assessment of the risk of anyone being exposed to asbestos from
any ACM identified, the survey document must identify both the location and the
condition of any identified material.
5.3.2
Consideration should then be made as to the likelihood of any ACM being
disturbed. Materials which have already deteriorated or been damaged; are
likely to be disturbed in the course of planned work; are very accessible and
likely to be disturbed or damaged in normal use; and those that may be
damaged by vandalism will present a greater risk.
5.3.3
Even where ACMs are in parts of the premises where people work regularly they
will not present a high risk to health, provided that the material is in good
condition and fibres cannot escape into the air, it is not prone to accidental
damage or vandalism and there is a system in place to prevent anyone from
working on it without proper protection.
5.3.4
If the ACMs are in good condition and unlikely to be damaged or disturbed, then
it is better to leave them in place and to introduce a system of management.
5.3.5
ACMs in poor condition must be repaired or removed. ACMs which are only
slightly damaged can be repaired, encapsulated or enclosed.
5.4
Managing the risk and preparing a plan
5.4.1
Managing the risk means making sure that, as far as is reasonably practicable,
no one can come to any harm from asbestos whilst on the premises.
5.4.2
A written plan, detailing the location and condition of asbestos (based on the
asbestos survey), needs to be prepared detailing the actions that will be taken to
avoid risk. For example, where ACMs have been disturbed or are damaged the
plan will identify the priority for removal or encapsulation and, where ACMs in
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good condition will be left in situ, the means whereby access to them will be
controlled.
5.4.3
Where a decision to remove any ACMs is made consideration should be made to
the original purpose of the ACM. Where it was, for example, installed as part of
the fire protection of the building, a suitable fire-resistant material will need to be
installed in its place.
5.4.4
Where ACMs are to be left in place arrangements need to be made to ensure
that information regarding the presence of ACMs is communicated to those who
may come into contact with them, either accidentally or in the course of their
work.
5.4.5
ACMs may be labelled where practicable or a management scheme introduced,
for example, a “permit to work” system whereby a person coming to the building
to carry out work would need to report to the Premises Officer or other
nominated person who would provide information on the location of ACMs.
5.4.6
No one must work on any asbestos containing material unless the requirements
of the Asbestos Regulations are complied with.
5.5
Monitoring arrangements
5.5.1
Any ACM, identified or suspected, will need to be inspected periodically to check
that it has not deteriorated or been damaged. An assessment should be made
of the likelihood of, for example, accidental damage and the review period should
reflect this.
5.5.2
Arrangements within the plan to control the risk of asbestos exposure should be
checked to ensure that they are working and that all those with a role within the
plan are both aware and are complying with those arrangements.
6.
Advice to staff regarding display work
6.1
In February 2006, The Health and Safety Commission’s Working Group on
Action to Control Chemicals considered the practice of pinning, stapling and
tacking display materials to school walls and ceilings which might contain
asbestos. They concluded that if teachers (and pupils and support staff) carry
out such activities that could cause damage to ACMs, a small but significant
amount of asbestos fibres can be released. They recommended that, as this
potential exposure is avoidable, such activities should cease. This principal
should be extended to all walls and ceilings throughout the Wandsworth estate.
6.2
Staff must not intentionally damage any asbestos containing material. If ACMs
remain undamaged staff are not likely to be at risk from ACMs in the course of
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their normal activities. Purpose made display boards can be fixed to walls as an
alternative to fixing display materials directly to walls and ceilings. Fixing of the
boards must be done in compliance with HSE advice, primarily HSG210,
Asbestos Essentials.
7.
Inadvertent exposure to asbestos
7.1
The procedures adopted in this document above should, as far as is reasonable
practicable, prevent exposure to asbestos. It is, however, recognised that
procedures can sometimes be inadequate, and that they may not be totally
adhered to. Staff, contractors and other members of the public may therefore
become exposed to asbestos dust.
7.2
It is a legal duty under CAW 2012 to have adequate arrangements to deal with
accidents, incidents and emergencies. Where appropriate, therefore, each
department should have procedures, including provision of relevant safety drills.
7.3
In the event of an accident, incident or emergency related to the unplanned
release of asbestos at the workplace, such a plan must ensure that

immediate steps are taken to
o mitigate the effects of the event;
o restore the situation to normal; and
o inform any person who may be affected; and

only those persons who are responsible for the carrying out of repairs and
other necessary work are permitted in the affected area and they are
provided with:
o
o
appropriate respiratory protective equipment and protective clothing;
and
any necessary specialised safety equipment and plant, which shall
be used until the situation is restored to normal.
7.4
The unplanned release of asbestos fibres is a “dangerous occurrence” as
defined by the Reporting of Injuries, Disease and Dangerous Occurrences
Regulations 1995. As soon as the emergency procedures have been taken, the
incident must be notified to the HSE and followed up with a written report within
10 days of the incident. This will be carried out by the Health and Safety Team
following receipt of the relevant TC1297 and supporting paperwork.
7.5
The incident must be fully investigated to determine the cause(s) of the incident
and taking of measures to avoid its recurrence. The latter, therefore, implies
reviewing the asbestos policy and procedures and the management plans.
Assistance can be given by the H&S Team.
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7.6
People who believe they may have been exposed to asbestos are
understandably anxious and concerned about the possible effects on their
health. Many cases of inadvertent, short-term exposure to asbestos will most
likely have been minimal, with little likelihood of any long-term ill effects.
However, although the type of asbestos involved may be known, there will often
be little, if any, reliable information concerning the level and duration of
exposure.
7.7
These are important factors because the more likely an asbestos-containing
material is to release fibres, the greater the risk. It is therefore important to
ascertain the type of asbestos containing material and the type of asbestos fibre.
Some asbestos-containing materials release fibres more easily than others.
Should detailed information on types of asbestos-containing material and the
likelihood of fibre release be required, please consult the Health and Safety
Team.
7.8
If you are concerned about possible exposure to asbestos, you are advised to
consult your GP and ask for a note to be made in your personal record about
possible exposure, including date(s), duration, type of asbestos and likely
exposure levels (if known). In some circumstances, your GP may refer you to a
specialist in respiratory medicine. HSE does not advocate routine X-rays for
people who have had an inadvertent exposure to asbestos. Asbestos-related
damage to the lungs takes years to develop and become visible on chest X-rays.
X-ray examinations cannot indicate whether or not asbestos fibres have been
inhaled
8.
Action on damage to suspected ACMs
8.1
If it is suspected that ACM within a Council premises has been damaged or has
been found to be in a poor condition and it is therefore possible that fibres may
have been released into the air, all work in the area must stop, the immediate
area should be evacuated, all doors shut and locked, and temporary safety
notices fixed to the outside of the doors, prohibiting unauthorised access.
8.2
The Council will then commission the Council’s Design Service, or the instructing
Consultant for the work, to investigate and advise on the appropriate course of
action. Where the presence of ACM continues to be suspected, the affected
area will remain isolated, and accredited and independent specialists will be
employed to carry out air and material sampling and analysis procedures.
8.3
If these tests confirm the presence of asbestos, appropriate remedial action will
be arranged by the Design Service/Consultant, in consultation with the relevant
Council Premises Manager and the service manager who occupies the affected
area. The area will continue to be isolated until such time as a further sampling
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and analysis test, undertaken upon completion of the work, indicates that all
asbestos and air-borne fibres have been removed. The area may be occupied
again only after the accredited specialist has issued a clearance certificate.
9.
Voluntary Asbestos Register
9.1
The Council operates a Voluntary Asbestos Register. The Register holds the
following details of any member of staff who wish to be registered; the name,
designation, staff number, section, department, work location and approximate
dates of exposure.
9.2
The purpose of the register is to keep a permanent record of staff who have
worked within Council buildings, where asbestos products may have been used,
AND who believe they have been exposed to asbestos dusts.
9.3
Paragraphs 7.6 to 7.8 above give general advice to employees who may have
been inadvertently exposed to asbestos fibres. There is also an opportunity to
see the Council’s occupational health physician for further advice via the referral
system by your managers.
9.4
Any member of staff wishing their details to be included in the Register must
complete the corporate incident form first (TC1297A). In addition, the form at
Annex B must be filled in by the employee and sent to the Health and Safety
Team who will enter details on to a Register held by the Health and Safety
Team. A copy of the form will be passed to the HR Service Team and to the
affected member of staff.
9.5
The use of the Register does not mean that the Council would necessarily be in
a position to admit liability if a claim were to be received in future years, but it will
be an historical record available to staff should the need arise.
10.
Further advice
10.1
Asbestos regulation is a necessarily complex area and, where any doubt exists
or further information is required, The Health and Safety Team must be
contacted.
10.2
Any work being carried out on ACMs must be subject to a specific risk
assessment and method statements. Head teachers and Heads of
Establishments are responsible for ensuring the health and safety of their staff,
pupils and visitors. If advice is required on the correct vetting of such risk
assessments and method statements The Health and Safety Team must be
consulted.
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11.
Annex A - Outline Asbestos Management Plan
1. Name of premises
2. Employee responsibilities
Name, date and signature of premises
manager.
The Premises Officer or nominated person should sign
to show that he or she is aware of the contents of this
management plan.
Name of person that produced this plan.
Name of the person responsible for
managing asbestos in the premises, for
updating the asbestos register (if any)
and for reviewing this plan.
Usually Head teacher or Head of Establishment but
may be the Premises Officer
3. Reviewing this management plan
Date this management plan was first
produced.
Date for review.
4. How the location and condition of asbestos-containing material is recorded
State how information about asbestos in
the premises is recorded.
State if there is an asbestos register (should be a part
of the type 2 or management survey) for the premises.
If there isn’t, state any asbestos information you have.
State where information about asbestos
in the premises is kept.
State where the asbestos register or asbestos file is
kept. A suitable place would be the reception or the
Premises Officer’s office. This plan should be kept with
the register.
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5. Results of the risk assessments and action required (if any)
Briefly state the results of your visual
inspection and risk assessment and the
approximate date it took place. Any work
that you have identified that still remains
to be done should be added to the Action
Plan.
This assessment should be carried out on all asbestoscontaining materials that you know about.
A great deal of this information is to be found in the
Type 2 or management survey
6. Monitoring arrangements for asbestos
State the arrangements for monitoring the
known or presumed asbestos-containing
materials to ensure that they remain in
good condition and that there is no
increased risk of disturbance.
The time between inspections will depend on the type
of material, where it is and its condition, but it should be
at least every six to twelve months. However, some
materials may need inspecting more frequently (for
example asbestos insulating board panels on the walls
of a constantly used corridor may need inspecting
monthly).
7. How information about asbestos is passed to those that need it
Staff need to be made aware of the
location of any asbestos-containing
materials only if they are liable to disturb
them.
State how staff have been informed. Staff
should also be asked to report any
damage.
Premises Officers and others with specific
responsibility for the maintenance of a building must
be made aware of any asbestos containing materials in
the premises.
Take care when communicating with staff – asbestos
should be respected but not feared.
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State here what system is in place to
control maintenance or building work.
What is the procedure for ensuring that
contractors and others check the
asbestos register before starting work?
Does the procedure allow for staff
absence due to illness?
If the premises do not have a register the
arrangements should make sure that no-one does any
work without being informed of this and that the
materials they are working on may contain asbestos. .
State here if warning labels have been
used to alert workers to the presence of
known asbestos.
Labels are not essential and may not be appropriate
(eg in classrooms or on ceilings). The decision to label
or not will, in part, depend on whether you are
confident that communication with your staff and
contractors is effective.
8. Training
State here who has received training on
asbestos management, and
approximately when it took place.
9. Action plan
Location and brief
description of the
asbestos-containing
material
(or survey reference taken
from the asbestos register)
Action decided
(after taking advice from H&S Team if
required)
Date work
proposed (approx.)
Date
completed
This template identifies the key headings of an asbestos management plan. Boxes may be
enlarged but all detail is required. Much of the information forms part of a management
survey and this may be used as an asbestos register as well as the basis of risk
assessment.
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Annex B – Voluntary Asbestos Register form
12.
(This form must be completed in full – please use block capitals)
Voluntary Asbestos Register
I wish my name to be added to the Voluntary Asbestos Register following a
suspected exposure to asbestos fibre as a direct consequence of my work for
Wandsworth Council.
Full name: ……………………………
Staff no.: ………………………
Department ……………………………
Section. …………………………
Location(s) of suspected exposure:
……………………………….…………….………………………………………..
…………………………………..……………………………………………………
Date(s) of suspected exposure:………………………………….
Type of asbestos: Blue
Brown
White
(delete as necessary)
Signed: …………………………………
Date: …………………………
Departmental stamp:
When complete return form to the Health and Safety Team, Room 263, Wandsworth Town Hall
For H&S Team use
Voluntary asbestos register annotated by…………………………………………on………………
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