Policy for the Management of Asbestos in the Workplace

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1 Southwark Council Management of Asbestos in the Workplace November 2011 Page 1 of 15

2 CONTENTS 1. INTRODUCTION POLICY STATEMENT ASBESTOS RISK CLASSIFICATION SCHEME SAMPLING OF ASBESTOS BASED PRODUCTS MANAGEMENT OF ASBESTOS CONTAINING MATERIALS BUILDING AND REMOVAL OPERATIONS WHERE ASBESTOS IS PRESENT EMERGENCY PROCEDURES REVIEW AND AUDIT APPENDIX 1 LEGISLATION AND GUIDANCE APPENDIX 2 GLOSSARY OF TERMS APPENDIX 3 EMERGENCY PROCEDURE FLOWCHART November 2011 Page 2 of 15

3 1 INTRODUCTION 1.1 Asbestos is a strong, durable, non-combustible material that although now banned for use in the United Kingdom has been widely used in the past in buildings as wall and roof linings, partitions, pipe covers, and as pipe lagging in plant and boiler rooms. The Control of Asbestos Regulations 2006 has placed on employers and occupiers of buildings a duty to manage asbestos in all non-domestic properties and the communal areas of domestic premises. This requires duty holders to: Assess whether premises contain asbestos Assess the risk from asbestos; and Take action to manage the risk from asbestos Southwark Council fully accepts its duties under the revised legislation and will also extend this policy to domestic property owned by the Council. 2 POLICY STATEMENT 2.1 The Council, in recognition of its duties under the Health and Safety at Work etc. Act 1974 (and all other relevant legislation) towards its tenants, employees, visitors, customers, contractors and members of the public, undertakes to manage all installed asbestos containing materials responsibly. The Council will not differentiate between the health risks presented by the three most commonly used types, Crocidolite (blue), Amosite (brown) and Chrysotile (white). 2.2 The owning departments with the lead role for the implementation and monitoring of compliance with this Policy shall be: i) Finance and Resources in respect of the buildings contained in the municipal portfolio of properties, and other commercial lettings. ii) Children s Services in respect of education establishments where the Local Education Authority is the employer or owns the buildings, not included in the list in i) above. iii) Housing Services in respect of domestic properties owned by the Council and other Housing non-domestic premises not included in the list in i) above. 2.3 The Council will confirm the presence of known asbestos containing materials at all premises for which it is the duty holder and to review how the risk is currently managed. This may include an initial inspection to identify damage/disturbance and immediate action to control potential hazards. Where there is currently no information held from past surveys and records, surveys will be conducted for the presence of asbestos containing materials. November 2011 Page 3 of 15

4 These will be conducted in accordance with HSG 264 and unless agreed otherwise will be Management surveys. The presence of asbestos must be assumed unless there is strong evidence to suppose otherwise. 2.4 Removal of asbestos based products will be undertaken when indicated by the Asbestos Risk Classification Scheme and priority assessed or as part of a planned refurbishment scheme. Removal of asbestos will only be carried out by a licensed asbestos removal contractor who is on the Approved Contractor List (See Section 6). 2.5 Registers/databases will be maintained by designated officers in owning departments, containing details of the presence of all asbestos containing materials in premises under their control. Access to this information will be available to Health and Safety Representatives and other interested parties. 2.6 Risk assessments of all asbestos containing materials must be conducted by a competent person and priorities set for removal or management. The Council recognises its management responsibility for asbestos containing materials and will prioritise all asbestos treatment works in accordance with the Asbestos Risk Classification Scheme that forms part of this Policy Document. 2.7 Where it is decided to retain and manage asbestos containing materials, arrangements will be made to draw up a management plan to ensure that the materials are not exposed or damaged by future activities. To achieve this the Council will not undertake or contract out any planned work to any building without adequate information on the nature, condition and extent of any installed asbestos containing material likely to be disturbed. Asbestos database/registers will be consulted in all cases and details passed by the client to the contractor both in respect of works specified in the Construction (Design and Management) Regulations 2007 and other building/maintenance contracts. Contracts/works orders/written work instructions shall indicate that this has occurred. The presence of asbestos will be identified on these documents. Note: Where the job is in progress, and suspected asbestos is discovered, please refer to Section 7. Works may be undertaken at locations where asbestos containing materials have been identified as present, providing that the materials have not been previously disturbed and the works concerned will not damage or disturb the identified materials. These requirements will equally apply to an external contractor and to the internal Direct Labour Organisation. 2.8 The Council will not carry out any planned work that exposes or is liable to November 2011 Page 4 of 15

5 expose any person to asbestos without ensuring that an assessment of that exposure has been completed. Where the assessment indicates the likelihood that asbestos will be disturbed, a licensed asbestos contractor shall undertake the work. 2.9 Owning departments will instigate formal arrangements for the monitoring and review of asbestos containing materials management plans. Appropriate Health and Safety Representatives will be advised of this process. Employees from all departments will fully co-operate with the management plan and associated arrangements in any building they are occupying or working in The Council aims to prevent the exposure of all employees to asbestos. Where this is not reasonably practicable, the Council will reduce to the lowest level reasonably practicable, the exposure of employees to asbestos by measures other than the use of personal protective equipment. All departments must include the risk of exposure of employees to asbestos as part of their risk assessment process, and implement identified controls The Council must provide guidance and awareness training for all employees who are involved in the management/administration and maintenance of Council property or who potentially may come into contact with asbestos during the course of their employment. All contractors undertaking construction work must be required to show evidence of similar guidance and training to their staff who may be similarly exposed, as part of the vetting procedure for the Approved List The Council will provide information to occupiers of its premises of asbestos containing materials, and will provide advice on the dangers from disturbance of asbestos The Council undertakes not to purchase or install any asbestos based product and will require nominated suppliers to declare that any product they supply is asbestos free. 3 ASBESTOS RISK CLASSIFICATION SCHEME 3.1 All asbestos surveys commissioned by the Council (see 4 below) shall be conducted in accordance with the principles of the HSE preferred methodology contained in the document HSG All survey reports will contain a material assessment that will cover the four parameters of product type, extent of damage or deterioration, surface treatment and asbestos type. November 2011 Page 5 of 15

6 Each parameter is scored as high=3, medium=2 or low=1. Two categories also allow for a nil score. The value assigned to each parameter is added together to give a total score between 2 and 12. Materials with assessment scores of 10 or more are regarded as having a high potential to release fibres, if disturbed. Scores of between 7 and 9 are regarded as having medium potential, and between 5 and 6 a low potential. Scores of 4 or less have a very low potential to release fibres. Non asbestos materials are not scored. The material assessment will identify high-risk materials and will guide management in arriving at the priority assessment of whether to remove or manage the asbestos containing materials. 4 SAMPLING OF ASBESTOS BASED PRODUCTS 4.1 Sampling of asbestos based products will only be undertaken by approved consultants in accordance with HSG Air monitoring for asbestos and fibre counting must only be undertaken by approved consultants. All consultants undertaking this work must be U.K.A.S. accredited. NOTE: Consultants may not supervise or undertake monitoring any works for which they completed the survey and risk assessment. 4.3 Prior to sampling a strategy must be formed to determine where and how many samples are to be taken. The strategy must take into account alterations to the building, repairs to any suspect material and previous asbestos removal projects. 4.4 All sampling must be conducted without releasing dust to the surrounding atmosphere, where possible after wetting the surrounding area. Samples must be taken directly from the material; fallen debris alone must not be collected. All persons carrying out sampling must have carried out a risk assessment of their technique. The appropriate protective equipment must be worn. 4.5 All sampling points must be labelled with the sample number, date and the initials of the sampler. Sprayed coatings and pipe lagging sites must be filled and covered with adhesive tape; insulating boards must be repaired with filler in such a way that they do not present an additional risk of fibre release. All sampling points must be marked on the sketch plan associated with the risk assessment. 4.6 The number of samples taken must be representative of the suspected material: November 2011 Page 6 of 15

7 Sprayed coatings will be sampled once every sq. metres, if the area exceeds 100 sq. metres, one per 25 sq. metres. At least one sample should be taken wherever the material is patched or repaired. Sampling should be approx. 5 sq. centimetres throughout the entire depth of the coating. Pipe lagging will be sampled every 5 metres or more frequently if the insulation obviously changes, for long pipe runs 1 sample every 8 metres will be sufficient. Attention must be given to elbows and valves where the insulation may be different from the main run of the pipe. Samples must be taken as a core of approx. 5 sq. centimetres to the depth of the insulation. Boilers and calorifiers must be sampled at least twice - on the top and at the side. Any patched or repaired areas must also be sampled. Insulating boards must be sampled wherever the suspect material appears to change or every 25 sq. metres in the case of suspended ceilings. Individual panels will be sampled if obviously different or there is evidence of repair. Where possible samples must be taken from near the edge of the sheet to allow repair with filler. Asbestos cement should be sampled only once (i.e. per roof or run of guttering) unless it obviously changes in appearance and is not a uniform material. Textured coatings must be sampled twice every 25 sq. metres. One sample of each colour thermoplastic floor tile must be taken per room or location in which they are laid. 4.7 Where the sampling consultant considers that sampling at the above rates will damage the integrity of the material and it is unnecessary, fewer samples may be taken and this must be indicated in the survey report. 4.8 All analysis must be carried out by a UKAS accredited laboratory. 5. MANAGEMENT OF ASBESTOS CONTAINING MATERIALS 5.1 Any remedial works will be identified as part of the risk classification scheme. However, it will not normally be necessary to further seal, enclose or remove materials containing asbestos that are sound, undamaged and unlikely to release dust. These will be managed as follows: Where undamaged asbestos containing materials are specifically identified, left in situ and managed, information must be available to the occupiers of the building of its location, as should the occupiers of all similar dwellings in the same block. The presence of a material containing asbestos must be noted on premises November 2011 Page 7 of 15

8 records to form the basis of the database/register and updated as soon as removal is carried out. Periodic inspection must be undertaken in accordance with the management plan to ensure the condition of the material has not changed. The inspection will be visual only to avoid unnecessary disturbance or fibre release and will not involve removal of covering material, e.g. duct panels or ceiling tiles. The frequency of inspection should reflect the risk classification score; guidance on the frequency of inspection is given below. Risk Rating Score Inspection Frequency > 19 Once per three months or on reported damage Annually or on reported damage 9-12 Five yearly or on reported damage <8 On maintenance works only Business Unit Managers with responsibilities for premises management either directly or through contracting agency requirements or the Council s managing agents, will ensure the management of asbestos in accordance with the requirements of the departmental management plan and the health and safety management system. 5.2 If, on inspection, any material containing asbestos is found to be damaged or has deteriorated, the person responsible for the management of the premises shall ensure appropriate remedial action is instigated. 6. BUILDING AND REMOVAL OPERATIONS WHERE ASBESTOS IS PRESENT 6.1 When drawing up specifications for any building and maintenance works, the Client will take all reasonable precautions to determine whether asbestos is present including consulting the premises asbestos database/register and management plan. All information regarding the status of asbestos shall be passed onto contractors. 6.2 Consultants may not supervise any remedial works for which they have completed the survey and risk assessment. 6.3 All contractors who propose to carry out any work involving asbestos must be in possession of a licence issued under the Control of Asbestos Regulations All contractors undertaking sampling operations must be accredited to ISO/IEC or ISO/IEC from a Certification Body accredited by UKAS (United Kingdom Accreditation Service). November 2011 Page 8 of 15

9 6.4 Prior to the commencement of any building or maintenance work, the contractor shall ensure that a suitable and sufficient risk assessment is completed as required by Regulation 3 of the Management of Health and Safety at Work Regulations The assessment shall be carried out by a person competent to carry out assessments, having received adequate information, instruction and training. Generic assessments are acceptable for repetitive tasks carried out in the same manner in similar locations, so long as they reflect the hazards and the risks associated with the activities. 6.5 Prior to the commencement of any building or maintenance operations, involving work with asbestos insulation and coatings, work with asbestos insulating board or other asbestos-containing material or removal of asbestos from any plant, the licensed contractor shall complete a plan of work. 6.6 For operations involving work with asbestos insulation and coatings, work with asbestos insulating board or other asbestos-containing material or removal of asbestos from any plant, the assessment and plan of work must be in writing and submitted to the client. Written approval of the assessment and plan of work must be obtained before commencement of any work with asbestos. Generic assessments and plans of work are acceptable for repetitive tasks carried out in the same manner in similar locations. N.B. This is in addition to any statutory notification required of the contractor. 6.7 Where the work method is varied due to a change in specification or an instruction to carry out additional works, an amended assessment and plan of work must be prepared and approved before commencement of any work with asbestos. 6.8 The Council and every contractor shall aim to prevent the exposure of employees to asbestos. The following measures shall be implemented wherever possible to reduce the risk of exposure to asbestos: The removal of asbestos containing materials before any major work begins; Work methods which minimise breakage, abrasion, machining or cutting of asbestos containing materials; Dust suppression by wetting where appropriate; Segregation by not carrying out asbestos work and other work in the same place at the same time. 6.9 Any contractor engaged as a domestic sub-contractor who is carrying out any work with asbestos based material in any building to which this policy applies, must be included within the appropriate financial range of the current approved list of contractors of the Council All contractors carrying out work with any asbestos containing materials in any building to which this policy applies, must have the following documents November 2011 Page 9 of 15

10 available for inspection on site: 1. Copy of the plan of work 2. Copy of licence for work with asbestos, where appropriate 3. Copy of the ASB5 notification form, where appropriate 4. A copy of the waiver, where appropriate 5. A copy of the work programme 6. A copy of the current Employers and Public Liability insurance scheme 7. Copies of all relevant medical certificates, where appropriate 8. Copies of all relevant training certificates 9. Copies of all relevant plant test certificates 10.A copy of the waste carrier s registration, where appropriate 11.Copies of all consignment notes, where appropriate 12.COSHH assessments for all products in use 13.Risk assessments appropriate for the proposed work 14.Copies of air monitoring certificates and bulk sample analysis, where appropriate 6.11 All contractors carrying out work with any asbestos containing material in any building to which this policy applies, must keep a site log of the activity on the site, including any incidents of procedure, system or plant failure. 7. EMERGENCY PROCEDURES 7.1 If suspected asbestos is discovered once work has commenced and the material is undamaged, no further work should be undertaken that could cause the deterioration of the asbestos. The client must be contacted immediately. If the asbestos is damaged, the area should be evacuated and sealed. 7.2 Upon notification of the discovery of suspected asbestos material, the local manager/client should contact the Council s asbestos consultant so that samples can be taken and shall liaise, as appropriate, with the client. 7.3 If the material is confirmed as containing asbestos, an assessment by the Asbestos Consultant shall be carried out to determine whether any of the works will result in people being exposed to asbestos. 7.4 If the assessment indicates no exposure is likely, the works may continue. The asbestos data base/register should be updated. If the assessment indicates that exposure is likely, the asbestos consultant shall make recommendations as to the appropriate action required. On receipt of the consultant s recommendations all relevant risk assessments must be reviewed. 7.5 In the event of any member of staff or contractor inadvertently damaging a product thought to contain asbestos or discovering damaged asbestos, the November 2011 Page 10 of 15

11 following procedure will apply: Leave the room, or if not in a defined room, the immediate area, closing the door and switching off all ventilation equipment. Report to the local manager or deputy The local manager will then refer to any premises records to determine if the product contains asbestos. If there is any doubt the manager will contact the Departmental Safety Manager for advice. The Premises Manager and the client (if appropriate) will be contacted. The Premises Manager or client (as appropriate) will contact the Council s asbestos consultant, to request attendance to carry out testing and provide advice as to appropriate action. If emergency work is required to make the area safe, the Premises Manager, Departmental Safety Manager, or client (as appropriate) shall contact the Council s approved licensed Asbestos Removal Contractor. The Departmental Safety Manager/Premises Management will carry out any necessary investigations in association with the retained asbestos consultant. 7.6 The procedure is illustrated in the flowchart as Appendix If there has been an uncontrolled release at a concentration that exceeded the appropriate control limits, a record should be made on the employee s personnel file. This record should be retained for 40 years. A copy of this should be given to the employee with instructions that it should be retained indefinitely. 8. REVIEW AND AUDIT 8.1 This policy will be reviewed at intervals of two years or when there is any significant change in legislation, organisational arrangements or best practice. The policy must be read as an addendum to Safety Directive and Guidance Note 311 of the Southwark Safety Reference Manual. 8.2 Departmental management plans and database/registers must be continuously monitored and reviewed annually. 8.3 Compliance with the policy will be monitored by the Health and Safety Strategy Manager as an integral part of the corporate audit programme and by departments as an integral part of local safety audit programmes. Results shall be reported to Health and Safety Committees. All employees who are involved in the management of premises or the November 2011 Page 11 of 15

12 management of building and maintenance works shall monitor compliance with this policy within their area of responsibility. November 2011 Page 12 of 15

13 London Borough of Southwark APPENDIX 1 LEGISLATION AND GUIDANCE Regulations Control of Asbestos Regulations 2006 The Hazardous Waste Regulations 2005 The Construction (Design & Management) Regulations 2007 The Management of Health and Safety at Work Regulations 1999 Approved Codes of Practice L127 The management of asbestos in non-domestic premises L143 Work with materials containing asbestos Other Publications Asbestos: The Survey Guide HSG 264 Health & Safety Executive A comprehensive guide to managing asbestos in premises HSG Health & Safety Executive Asbestos essentials task manual HSG 210 Health and Safety Executive A.R.C.A. Guidance Notes APPENDIX 2 A.C. ACoP A.I.B. A.R.C.A. H.S.C. H.S.E. P.P.E. U.K.A.S. GLOSSARY OF TERMS Asbestos Cement Approved Code of Practice Asbestos Insulating Board Asbestos Removal Contractors Association Health & Safety Commission Health & Safety Executive Personal Protective Equipment United Kingdom Accreditation Service February 2010

14 London Borough of Southwark APPENDIX 3 EMERGENCY PROCEDURE FLOWCHART Discovery, damage or disturbance of suspected asbestos based material Evacuate area if asbestos is damaged. Report facts to local manager or deputy Confirmed as non asbestos Local manager or deputy will refer to premises data base/register No records or confirmation that product contains asbestos REOCCUPY AREA No Asbestos present If emergency work is required to make the area safe, contact Departmental Safety Manager/ Help desk Local Manager contacts Departmental Safety Manager/Retained Asbestos Consultant to investigate and take samples Presence of asbestos confirmed and risk assessment carried out by competent person Risk assessment indicates asbestos can be left as found and managed Risk assessment indicates asbestos requires removal and cannot be left as found Risk assessment indicates asbestos requires sealing Asbestos left in place, presence recorded and management programme implemented REOCCUPY AREA Consultant prepares specification for removal works Contractor selected from Approved List Consultant prepares specification for encapsulation works Asbestos is sealed, presence recorded and management programme implemented Contractor prepares plan of work for asbestos removal Client agrees plan of work Asbestos removal works carried out February 2010 Clearance given by retained analyst REOCCUPY AREA

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