1.2 This policy explains how Greenfields manages asbestos-containing materials that are either identified or presumed to exist within its assets.

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1 Asbestos Policy Policy holder Asset and Senior Contracts Manager Approval date September 2016 Review date September 2021 Contents 1. Policy statement 2. Background 3. Policy details 4. Eligibility criteria 5. Equality considerations 6. Review and monitoring Appendix 1: Asbestos Management Plan 1. Policy statement 1.1 Asbestos is potentially hazardous and a clearly defined approach to asbestos management is essential to adhere to legislative requirements and ensure asbestos-containing materials are located, identified, recorded and maintained. 1.2 This policy explains how Greenfields manages asbestos-containing materials that are either identified or presumed to exist within its assets. 2. Background 2.1 This policy applies to all domestic dwellings properties where Greenfields has a maintenance responsibility. It also applies to any associated common areas, garages, commercial buildings and fly-tipped asbestos waste on Greenfields land. 2.2 This policy should be read in conjunction with other relevant policies and procedures published by Greenfields. 3. Policy details 3.1 Greenfields Asbestos Management Plan (Appendix 1) details Greenfields approach to the management of asbestos-containing material within Greenfields property assets. 1

2 3.2 In relation to asbestos-containing materials, Greenfields will comply with all relevant current legislation, including but not limited to the Health and Safety at Work Act, the Defective Premises Act as well as the Control of Asbestos Regulations and other relevant regulations, approved codes of practice and guidance. 3.3 Greenfields will identify and categorise asbestos through our survey and reinspection programme. 3.4 We will hold and maintain an asbestos register detailing the type of asbestos, its location, condition, quantity, re-inspection and management recommendations. 3.5 We will protect those working on the fabric of the building and those working and living in our properties, and will provide appropriate asbestos training to relevant employees. 3.6 We will share information about the location and condition of identified asbestos-containing materials with those who are likely to disturb them and effectively control works that are likely to affect asbestos. 3.7 We will monitor and maintain the condition of identified asbestos-containing materials in line with the risk assessment recommendations. 4. Equalities considerations 4.1 An equality analysis has been carried out for this policy. impacts have been identified. 5. Review and monitoring 5.1 This policy will be reviewed every five years or as legislation changes. 2

3 Appendix 1 Asbestos Management Plan Author Date of Initial Issue Date of revision Duty Holder Responsible Person Asset and Senior Contracts Manager Draft Director of Property Services Asset and Senior Contracts Manager 1. Review of the Asbestos Management Plan 1.1 The Asbestos Management Plan will be reviewed every two years or more frequently where there has been a change in legislation, change in organisational structure or if arrangements within the plan are no longer considered to be adequate. 1.2 This plan must be read in conjunction with Greenfields Asbestos Policy. 2. Managing asbestos 2.1 Greenfields recognises the importance of effectively managing and dealing with asbestos that may be present within its property assets, and the duties and obligations imposed by legislation. 2.2 Greenfields aim is to ensure that asbestos materials are not disturbed, except in a controlled environment during the removal process. 2.3 Appropriate employees are required to read and understand Greenfields Asbestos Policy and this management plan, and act appropriately in line with this and all current legislation. 2.4 All materials within Greenfields property assets MUST be presumed to contain asbestos and treated accordingly unless, or until, strong evidence is established to the contrary. 2.5 However, properties known to have been constructed from the year 2000 onwards are reasonably expected not to contain asbestos material. 3. Asbestos information, distribution and communication 3.1 Location of and access to the Asbestos Register All information regarding the type of asbestos, its location, condition, quantity, re-inspection and management recommendations will be recorded within the Asbestos Register which is held on Greenfields Asset Management System. Access to the register is available to all staff. 3

4 3.1.2 Routine back-ups of the Asbestos Register are completed on a daily basis Employees can access the Asbestos Register through Greenfields computer systems, Orchard and Keystone. If the employee does not have access to a computer, they can access the system through a suitable mobile device or by telephoning and enquiring through a colleague at Greenfields offices. 3.2 Requirements for contractors Appointed contractors are expected to request and review relevant information available within the Asbestos Register and take appropriate steps to safeguard their own and the occupant s safety prior to the start of their work The contractor will provide site-specific risk assessments and method statements for all work involving working with asbestos or any work where asbestos may be disturbed or damaged Greenfields will issue contractors with a copy of the current asbestos survey where appropriate. Where the current survey is not deemed appropriate, an appropriate survey will be instructed or commissioned Greenfields will check the competency of contractors through the tender process. Dependant on the type of work, Greenfields will also check the contractor s competency for working with or removal of asbestos-containing materials Where licensed removal forms part of a contract, Greenfields will also view the details of the license and check its validity with the Heath and Safety Executive (HSE). 3.3 Sharing asbestos information with residents and landlord s consent Greenfields residents are made aware of the risks of asbestos material within their home through their Tenants Handbook, Greenfields website and other Greenfields publications If a resident is proposing to carry out alterations that are likely to disturb asbestos, guidance will be provided through the Landlords Consent Process. If an appropriate asbestos survey is available, Greenfields will provide this to the resident. If an appropriate survey is not available, Greenfields will arrange for this to be conducted at the residents cost and the survey will be issued to the resident If the work involves disturbing or removing asbestos-containing material, Greenfields will give guidance to the resident or refuse landlords consent, as appropriate. 4

5 3.4 Sharing asbestos information with Emergency Fire Services Emergency Fire Services will be advised that they can contact Greenfields on if they require more specific information about a particular property they are about to attend for an emergency. 3.5 Approach to labelling asbestos materials Labelling of asbestos-containing materials within Greenfields properties has not been adopted by Greenfields. Labelling is considered unsightly in domestic premises and is not reliable or appropriate control measure. 4. Surveys and re-inspections 4.1 All new Greenfields asbestos surveys will be conducted in accordance with HSE Guidance HSG 264 Asbestos: The Survey Guide. All surveys will be completed by a UKAS accredited surveying company and in line with ISO Greenfields will maintain a programme of asbestos surveys and re-inspections to enable further asbestos-containing material to be identified and provide a monitoring service to check the condition of known asbestos material. 4.3 Following any survey or re-inspection, Greenfields Asbestos Register will be updated. 4.4 Re-inspections will be carried out by Greenfields-approved asbestos consultant or by trained and competent Greenfields staff members. 5

6 5. Risk Assessments and Actions 5.1 An asbestos risk assessment will be carried out after a survey or re-inspection has been completed on a property or before any planned or responsive maintenance is carried out on a property. For the purpose of this Management Plan the following table should be used as a guide to prioritise asbestos remedial work requirements. Overall RA score Overall risk rating Action: access to ACM 16 High Restrict access to the area using a physical barrier and asbestos warning notice Medium Restrict access to the material if necessary Action where works are involved Where practicable remove. If not practicable to remove, encapsulate or remediate immediately Where practicable remove. If not encapsulate or remediate when practical Action where works are not involved In order of preference, but dependant on reasonable practicalities, remove / encapsulate / remediate immediately Schedule for encapsulation / removal / remediation when practical Low immediate action required immediate action required < 9 Very Low immediate action required immediate action required Re-inspection timeframe Unless removed, reinspect every six months Unless removed, reinspect every 12 months Monitor closely, and re-inspect every two years Monitor closely, and re-inspect every three years Reassurance air test frequency Unless asbestoscontaining material is removed, reassurance air test every three months N/A unless instructed by the Duty Holder N/A unless instructed by the Duty Holder N/A unless instructed by the Duty Holder 5.2 Although these are the recommended actions, Greenfields will decide on an individual property basis what the appropriate action will be, and instruct the approved Asbestos Consultant accordingly if any changes are necessary. Individual asbestos-containing materials, their unique risk assessments and recommended actions an can be found in the Asbestos Register. 6

7 6. Action Plan Re-survey all Property Assets that do not have an asbestos survey that complies with HSG 264 Asbestos: The Survey Guide, by A property-specific Action Plan will be developed based on the asbestos risk assessments. Actions will be in line with the risk assessment actions as highlighted in Section 6. These actions will be logged on Greenfields Asbestos Register Review the Asbestos Policy and Management Plan in line with Section 2 of this document. 7. Safe systems of work 7.1 Restriction of access Greenfields has a permit to work form which can be used as a control measure by Greenfields employees when they consider it is necessary. 7.2 Work on Greenfields properties Before starting any routine or planned maintenance work, a risk assessment must be undertaken by Greenfields, its designated Designer or Principal Contractor. If the risk assessment indicates it is necessary, the Asbestos Register should be checked for relevant asbestos survey reports relating to the property. If there is no survey report available, an appropriate survey complying with HSG264 must be arranged and the report reviewed before planned work can commence Significant refurbishment or demolition work will require a refurbishment and demolition survey to be completed, unless a suitable survey is already available All materials on site must be presumed to contain asbestos and treated accordingly unless, or until, strong evidence is received to the contrary If a contractor or Greenfields Trades Team is approved to carry out emergency work, they must conduct an asbestos-specific risk assessment before starting work. Their risk assessment may: demonstrate that no further action needs to be taken in relation to asbestos before work can proceed (i.e. no asbestos present or no asbestoscontaining materials will be damaged/disturbed during the work) demonstrate that work can proceed but methods need to be adjusted to account for assumed asbestos-containing materials require them not to proceed with work until they have looked at the survey for the property (note: in this instance work cannot proceed until a survey has been carried out and if the repairs fall into the emergency category the resident may need to be decanted until the work is completed). 7

8 7.2.5 An emergency out-of-hours arrangement is established with Greenfields approved Asbestos Consultant to ensure they are readily accessible to provide asbestos services and work. 7.3 Acquiring new properties for Greenfields housing stock Before acquiring properties, Greenfields will check the properties are compliant with legislation and the relevant information is transferred with the freehold or as part of the lease agreement If the property was built or modified before the year 2000, Greenfields will arrange for an asbestos survey through their asbestos consultant. The survey will be conducted before any work on, or occupation of the property and the relevant details will be added to the Asbestos Register If the property was built after the year 2000, Greenfields will assess the build data, and if the source of materials cannot be ratified a Management Survey will be instructed to validate if any asbestos-containing materials are present. 7.4 Asbestos-containing material uncovered during work If suspected asbestos-containing material is disturbed or uncovered on an unplanned basis during works, the Emergency Procedures should be implemented (please refer to the Emergency Procedures flowchart). 7.5 Fly-tipped asbestos material Greenfields is responsible for the removal of asbestos waste illegally tipped on its land. Any person discovering fly-tipped asbestos waste on Greenfields land should notify Greenfields Customer Services Centre. They will log the details on our systems and notify the Responsible Person of the problem Greenfields approved Asbestos Consultant will be instructed to attend the site and assess the materials. They will arrange for the area to be quarantined and secured, and for any asbestos material to be safely and appropriately removed and disposed of. Warning notices should be posted to prevent access Greenfields will attempt to determine the source of the fly-tipped waste and will take action to recover any costs incurred. 7.6 Asbestos removal, encapsulation and remedial works If licensed work is required, Greenfields will employ a contractor holding a full license with the HSE If notifiable asbestos works are required, including those considered nonlicensable under Sporadic Low Intensity Exposure (SLIE), Greenfields will employ a competent contractor to deal with these materials. 8

9 7.6.3 If asbestos works are non-licensed and non-notifiable, Greenfields will either perform removal, encapsulation or remediation using our own, trained and competent trades or alternatively employ a competent contractor to deal with these materials All work must have site specific Risk Assessments and Method Statements before work is started. 8. Employee training 8.1 Greenfields and their contractors will provide asbestos-awareness training for all personnel who are identified as being liable to be exposed to asbestos, and for their direct supervisors. This course must be refreshed annually. 8.2 Any employee or contractor who is assigned to work with asbestos MUST be appropriately trained and competent 8.3 Greenfields Asbestos Policy and Management Plan and other sources of asbestos information will be included as part of Greenfields employee induction process. 8.4 Greenfields employees whose work could reasonably be expected to expose them to asbestos or who may be involved in directly managing asbestos programmes of work may also be required to attend relevant additional training. 8.5 As a minimum, Greenfields Responsible Person will have completed and passed the BOHS P405 training course and can advise others where necessary. 9

10 9. Emergency Procedures Emergency Procedure If presumed asbestos materials are uncovered, damaged during work or found damaged STOP WORK IMMEDIATELY Is there dust or debris present in the area from the suspect material, or on you as a person, or on the clothing you are wearing? E.g. contaminated clothes, hair, footwear, etc. Yes Report the problem to the person in charge of the site as soon as possible. Keep everyone else out of the area, then leave the area by going outside by the shortest route where there is nobody else around. Restrict access to the area The person in charge of the site should arrange for a safe material sample to be taken and analysed through Greenfields approved Asbestos Consultant. Contact your line manager immediately using your mobile phone. (Or alternatively, if they are not available contact the Customer Services Centre, on ) Explain the situation and request that they contact Greenfields approved Asbestos Consultant, Environtec Ltd, on , and arrange for an asbestos specialist to attend site, on an emergency basis, to deal with presumed asbestos contamination. Greenfields approved Asbestos Consultant will arrange for an asbestos specialist, and a mobile decontamination unit if necessary, to attend site to safely deal with any contamination. Does sample contain asbestos? Yes action required Keep a record of the event using Greenfields form Record of Risk of Exposure to Asbestos Dust Greenfields develops an Asbestos Management Plan and decides appropriate removal method / contractor 10

11 Outline of safe systems of works for asbestos-containing material (ACM) Work process Prior to work, check Asbestos Register Does a suitable survey exist? Yes Will the work disturb asbestos or require ACM removal? Yes Is the work notifiable or requires licenced ACM removal? Yes Update register, share survey report / make accessible as appropriate to those who may disturb asbestos Instruct Greenfields Asbestos surveyor to conduct a targeted or full Refurbishment and Demolition survey as appropriate Plan & execute works or service via competent contractor or with caution using competent trained Greenfields staff and approved Site specific Method Statements tify Asset Team. Asset Team instruct removal by an approved licenced contractor Work process complete ACM n-notifiable & nonlicensed ACM Greenfields-approved Asbestos Consultant to complete sample air tests on a minimum of 10% of non-notifiable / non-licensed ACM removal work Licenced contractor notifies with ASB5 form and performs removal Approved Asbestos Consultant will verify whether records are appropriate before they update asbestos register and management plan Send updated survey record, analysts reports and hazardous waste consignment notes to approved Asbestos Consultant 11 Contracts Manager to check the Waste Consignment te and Clearance Certificate Independent Analysts clearance report / clean air test / confirmation area safe for reoccupation

12 Record of risk of exposure to asbestos dust Client: Site: Part A: (Completed by the affected person and issued to the Responsible Person) Name: Job title: Company: Tel. no.: Location of occurrence: Description of material: Brief description of what occurred: Signed (Affected Person) Signed (Manager) Name / Position of Manager: Part B (to be completed by the Responsible Person) Name: Position: Has the area been cordoned off?...yes / NO Were all safe system of work procedures followed?...yes / NO What can be implemented to prevent a re-occurrence? (detail) What remedial action has been implemented to make safe the ACM? What was the estimated level of exposure of asbestos?...f/ml In damaging the ACM, has the control limit or action level been exceeded?...yes / NO If yes to the above, has RIDDOR 1995 been complied with?...yes / N/A Signed: Date: 12

13 12. Permit to Work Asbestos Register Site Signing In / Out Form When specified by Greenfields, this form is to be completed and signed by the Greenfields employees or the contractors before starting their work. Date: Time In: Signed Time Out: Signed Name Job Title Company Greenfields Contract Ref or Order.: Greenfields contact authorising work: Address and description of works: Has the asbestos report been reviewed and understood? Yes Has work been planned in accordance with the Control of Asbestos Regulations 2012? Yes Declaration I have thoroughly read the copy of the asbestos report on site. I am fully aware of the location and content of the areas/materials that contain asbestos. I am aware the exclusions to the surveys which must be presumed to contain asbestos. If the report is a management level survey, I understand the limitations and that it is only suitable for non-intrusive maintenance work. OR asbestos report is available on site. I have contacted the relevant Greenfields Contract Manager for further instruction, and I am now fully aware of how to safely proceed. I have completed an asbestos risk assessment which indicates it is safe to proceed with the work and I understand that an approved and fully HSE licensed asbestos contractor must be employed for access to work within, an area that is likely to contain damaged or friable asbestos materials. The works are fully completed in line with the plan of work and I confirm that the area and all remaining materials are left in a safe condition for re-occupation. Any other relevant comments: Signed (Operative)..Date Signed (Greenfields)..Date. 13

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