1 ASBESTOS POLICY AND MANAGEMENT PLAN 1. INTRODUCTION 1.1. The Control of Asbestos at Work Regulations 2006 requires employers to prevent the exposure of their employees to asbestos, or where this is not practicable, to reduce the exposure to the lowest possible level. Control of Asbestos at Work includes a regulation placing a duty on those who have repair and maintenance responsibilities for premises, because of a contract or tenancy, to manage the risk from asbestos in those premises Edinburgh Leisure are responsible for the repair and maintenance of the properties in the estate which are leased from the City of Edinburgh Council This new duty requires Duty Holders to:- a. assess whether premises contain asbestos; b. assess the risk from asbestos; and c. take action to manage the risk from asbestos This document sets out Edinburgh Leisure s policy and procedures for managing asbestos; it is intended to be an effective organisational means for controlling the risk to health from asbestos within properties owned by the City of Edinburgh Council but managed by Edinburgh Leisure The majority of the larger centres which Edinburgh Leisure manage are asbestos free as they were built or refurbished after asbestos stopped being used in the building industry. Asbestos surveys (Type 2) which have been carried out confirm this. Edinburgh Leisure however recognises that asbestos is present in areas of the properties under its control in various forms, condition and types and that an effective asbestos management strategy and associated procedures need to be in place in order to manage the risks to operatives, staff and customers The presence of an Asbestos Containing Material (ACM) is not in itself dangerous but becomes hazardous when disturbed or damaged. Anyone who visits Edinburgh Leisure s premises and disturbs asbestos so that it releases fibres, e.g. work involving drilling, sawing, breaking, cutting or machining asbestos products, can be at risk Staff and Contractors are not expected to be exposed to asbestos within the buildings. Some staff members (e.g. maintenance staff) may be brought into contact with existing ACMs as part of their daily duties but they have been trained to recognise the possibility of its presence and the appropriate actions to be taken Every effort will be made to minimise the risk to staff, operatives, customers and contractors by effectively managing and controlling work where asbestos materials are
2 present. The following policy, objectives and management systems include a rigorous control of any work activity where asbestos may be present. The intention of this document is to present a clearly defined and detailed system of control. 2. WHAT IS ASBESTOS 2.1. Asbestos Asbestos is naturally occurring fibrous silicate minerals found throughout the world, including Canada, Russia, USA, China and South Africa. Asbestos minerals fall into two groups: serpentine and amphibole. Chrysotile (white) asbestos is in the serpentine group whilst the amphibole group consists of amosite (brown), crocidolite (blue), tremolite, anthophyllite and actinolite Chrysotile Chrysotile fibres are curly and flexible which are resistant to alkalis. Chrysotile is the most widely used asbestos type, currently accounting for at least 95% of the asbestos mined Amosite Amosite fibres are spiky, needle-like and have good tensile strength Crocidolite Crocidolite fibres are needle-like and have a high tensile strength and are resistant to acids All asbestos mineral products have:- High tensile strength Flexibility Resistance to chemical and thermal degradation High electrical resistance Can be woven 2.3. Properties Asbestos minerals have the ability to split into long, thin fibres due, mainly, to its composition. The fibrous nature of the minerals allows asbestos, to be spun and woven into yarns. The straight needle-like fibres have been widely used to reinforce cement, plastics and other products. Asbestos is durable and stable, with high resistance to heat and, as a result, was widely used in the construction industry.
3 The use of amosite and crocidolite asbestos in products was banned in 1986, with chrysotile used until its prohibition (except for use in a few special circumstances) in Man made mineral fibre Man made mineral fibre (MMMF) is a term given to synthetic mineral fibres. MMMF are generally coarser than asbestos fibres, although some factories produce 'super fine' fibres of the same length and width as asbestos. MMMF includes glasswool, rockwool and ceramic fibres Asbestos Related Diseases Asbestos-related diseases are caused by the ingestion of the fibres and include asbestosis, lung cancer and mesothelioma. 3. CURRENT LEGISLATION There are many regulations that place a duty on an employer with regard to asbestos, the key factors of these regulations are set out below:- The Health & Safety at Work etc. Act 1974 (HSW) requires an employer to conduct their work in such a way that their employees will not be exposed to health and safety risks, and to provide information to other people about their workplace which might affect their health and safety. In the context of asbestos, property owners and occupiers are required to identify areas where asbestos is present and give advice to their (in house and external) contractors accordingly. The Management of Health & Safety at Work Regulations 1999 (Amendment 2003, Amendment 2006) requires employers and self-employed people to make an assessment of the risk to the health and safety of themselves, employees and people not in their employment arising out of or in connection with the conduct of their business - and to make appropriate arrangements for protecting these people's health and safety. The Workplace (Health, Safety and Welfare) Regulations 1992 (Amendment 2002) sets out duties to maintain workplace buildings/premises to protect occupants and workers. The Construction (Design and Management) Regulations 2007 requires the client to pass on information about the state or condition of any premises (including the presence of hazardous materials such as asbestos) to the CDM Co ordinator before any work begins and to ensure that the health and safety file is available for inspection by any person who needs the information. The Control of Asbestos at Work Regulations 2006 see 1.1 above
4 4. ASBESTOS POLICY STATEMENT 4.1. Edinburgh Leisure's policy is to: 1. Produce and maintain an asbestos register that is accessible to all in-house and outsourced staff who may be brought into contact with asbestos as part of their work activities. 2. Promote awareness of the hazards of asbestos and Edinburgh Leisure's management procedures to all relevant staff within Edinburgh Leisure through development of this policy and induction and periodic training. 3. Prevent exposure to hazards associated with asbestos other than by properly trained and protected personnel. 4. Produce an asbestos management policy and procedures plan. 5. Periodically review the plan stating which areas, if any, require asbestos to be sealed, encapsulated, inspected, monitored, labelled, or removed, etc. 6. Ensure that Edinburgh Leisure s policy conforms to Regulation 4 of the Control of Asbestos at Work Regulations Regulation 4 Take reasonable steps to find materials containing, or likely to contain, asbestos (ACM's), Presume materials contain asbestos unless strong evidence to suppose that they do not, Assess the risk of the likelihood of anyone being exposed to asbestos from these materials, Make a written record of the location and the condition of the ACM's and keep the record up to date, Carry out remedial action based on the assessment of risk of exposure, including factors such as location, condition, likelihood of disturbance,etc., Prepare an action plan to manage the risk and implement it, Provide the necessary information, instruction and training for all staff, contractors and anyone else who needs it, Monitor the ACM's and maintain them, Review and monitor the action plan and associated procedures and systems.
5 5. THE ASBESTOS REGISTER 5.1. Recording the location and condition of ACMs (known and presumed) Type 2 asbestos surveys have been completed for 100% of the properties managed by Edinburgh Leisure. The surveys record the location, form, type and condition of any asbestos which has been identified within buildings occupied by Edinburgh Leisure The survey reports, records of removal and analysis reports have been collated to produce a bespoke Asbestos Register. Copies of the Register are held in each large centre and at Edinburgh Leisure s Property and Facilities Management Office at Carron Place. The pavilion copies are held at Jack Kane Centre for pitch pavilions, Craiglockhart Tennis Centre for Tennis Pavilions and Portobello Indoor Bowls Centre for bowling pavilions The Asbestos Register records the location of all known and presumed ACMs identified in the survey reports. Where ACMs have subsequently been removed the record is marked 'removed', it was decided not to delete removed items from the data base as historic knowledge may be required in the future. Where details of the removal are known this has also been recorded on the register The Carron Place Register is available to all Property & Facilities Management staff New and updating of information The Head of Property and Facilities Management (or their designated representative) will be responsible for ensuring that the register is kept up to date with information regarding remedial works, removals and any newly located ACMs It is the responsibility of all staff to report / provide the Head of Property and Facilities Management (or their designated representative)with any information relating to the presence of asbestos within Edinburgh Leisure's portfolio Where new buildings or parts thereof are acquired by Edinburgh Leisure, the Head of Property and Facilities Management (or their designated representative) will ascertain the need to include the new acquisition in the management plan and commission the necessary surveys/inspections to be included in the register Continued monitoring of ACMs 5.4. Although some of the surveys undertaken are now almost four years old the current condition of known ACMs is accurate. The Head of Property and Facilities Management (or their designated representative) will ensure that the annual inspections are carried out and the results recorded in the corresponding Asbestos Register. A risk assessment is undertaken during each inspection using the following criteria and these are then used to form the basis for prioritising Edinburgh Leisure s management plan:-
6 ensure that all relevant risks or hazards are addressed ensure that all groups of employees and others who might be affected are considered identify groups of workers who may be particularly at risk take into account existing preventive or precautionary measures 6. PROCEDURES 6.1. An uncontrolled escape of asbestos fibres Severe damage (significant dust visible) 6.2. In the event that damage occurs to a highly fibrous material (such as lagging) that contains asbestos, all personnel within the area must leave and the Head of Property and Facilities Management (or their designated representative) notified immediately The Head of Property and Facilities Management (or their designated representative) will assess the situation and arrange for the affected areas to be secured and sealed off using asbestos hazard tape and polythene sheeting to minimise spread of asbestos fibres into adjoining areas At no time should any person enter or re-enter the contaminated area The Head of Property and Facilities Management (or their designated representative) will then contact an approved Asbestos Removal Contractor (ARC) for attendance on site to decontaminate the affected area/s and remove ACM as deemed necessary The Head of Property and Facilities Management (or their designated representative) will also arrange for an analyst to undertake air tests and visual inspections The area/s will remain closed until a certificate of reoccupation is issued by the analyst The Head of Property and Facilities Management (or their designated representative) will investigate the circumstances of the uncontrolled release of asbestos fibres to ascertain that the Asbestos Policy has been adhered to Slight Damage (no visible cloud of dust) In the event that damage occurs to fibre board or plastic material (such as insulation board, thermoplastic floor tile, WC cistern) that contains asbestos, the Head of Property and Facilities Management (or their designated representative) and Facility Manager must be notified immediately The Head of Property and Facilities Management (or their designated representative) will assess the situation and arrange for the appropriate action to be taken. Record of exposure and health checks
7 Should it become necessary, Edinburgh Leisure s Health & Safety Manager will maintain a health record and medical surveillance/screening programme in the event that person/s are exposed to asbestos fibres due to an uncontrolled escape where exposure to asbestos exceeds the action levels Newly identified asbestos It is the responsibility of all staff to report any suspected or damaged asbestos containing material In the first instance to their line manager/supervisor and thereafter to the Head of Property and Facilities Management (or their designated representative). 7. INTERNAL AND EXTERNAL CONTRACTORS & DESIGN TEAMS 7.1. Building Refurbishment Works, Alteration Works including Services or Demolition A copy of the asbestos survey report (Type 2) will be provided by the Head of Property & Facilities Management ( or their designated representative) for external projects with recommendations for any remedial action that should be incorporated into the project. The report will form an integral part of the risk assessment arrangements for compliance with The Construction (Design & Management) Regulations This must be addressed at project inception as failure to do so could cause substantial delays in commencement The most significant responsibility is the requirement to establish the presence of any known asbestos and to request a type 3 asbestos survey (if appropriate) of the area prior to the project starting Where the Head of Property & Facilities Management (or their designated representative) recommends the removal of the asbestos material a licensed contractor will be used. The asbestos removal works should be carefully programmed into the project so as to prevent any risk of damage to the asbestos and exposure. Should air testing be required a competent analyst should be used Maintenance & Repair Works Edinburgh Leisure s Planet Enterprise computer generated work orders will carry a warning of asbestos presence in or close to the area the work is to be carried out. In addition permits to work will be required in areas where asbestos is known to be present. (see 9.2 below) In order to meet the requirements of the Regulations, before any work is undertaken on the premises, the Maintenance or Project Supervisor must first consult the asbestos register. They must then carry out an assessment of the proposed work to determine if there is asbestos involved. Where asbestos materials are involved or in close proximity to the work, a plan of work (method statement) must be prepared.
8 In those circumstances where asbestos is involved it is advised that it be removed before the work commences. Where work is in close proximity to asbestos materials, the plan of work should include details of the method(s) to be adopted to ensure the asbestos is not disturbed Sporadic / Low intensity Work Section 8 of the Control of Asbestos Regulations (CAR) 2006 identified certain works which can be carried out without a licence. These fall into the following groups:- Rubber, plastic, resin, bitumen products containing asbestos Gaskets, washers, ropes and seals (used at high temperatures with no insulation purpose) Asbestos cement Textured/decorative coatings Edinburgh Leisure intends to make provision for such work to be carried out in the estate but operatives will be suitably trained and protected, the work will be risk assessed and method statement provided. Arrangements for the disposal of the ACM will be by licensed contractor, approved by the HSE, thereby, ensuring the ACM is disposed of in a controlled manner External Contractors All contractors working for Edinburgh Leisure have responsibilities as follows:- adherence to Edinburgh Leisure's asbestos management policy; ensuring that any work that may disturb or damage material containing asbestos is avoided; halting work and seeking advice from Edinburgh Leisure s Maintenance or Project Supervisor if suspected asbestos material is discovered during the course of the works; reporting immediately to Edinburgh Leisure s Maintenance or Project Supervisor any materials suspected to contain asbestos where the materials have been disturbed or damaged, or where works are likely to be undertaken that may affect such materials General Maintenance and Project Work All employees, including contractors, involved in any maintenance or project work should be made aware by the Maintenance or Project Supervisor that asbestos materials could be present on site. Permits to work will be required in areas where asbestos is known to be present. (see 9.2 below). As it is not always practicable for them to consult with the asbestos register, they should also be informed by the Maintenance or Project Supervisor
9 that the asbestos materials have been identified by hazard warning notices. They should also be informed that, if they are in any doubt as to the nature of the material they are working with, they should inform their Supervisor Asbestos Remedial Works On completion of any asbestos remedial works the Head of Property and Facilities Management (or their designated representative)must be provided with a completion document a copy of which should be retained with the project file / Health & Safety File. The completion document must comprise of the following:- Air Clearance/Monitoring certificates produced by the analyst if necessary Waste consignment note Asbestos Removal Contractor's method statement Plans clearly illustrating all asbestos that has been removed and all asbestos that has been retained Manual update of removed asbestos on printed asbestos register 8. SURVEYS AND TYPES 8.1. Edinburgh Leisure as a standard undertakes two types of survey: Management Survey: Standard sampling, identification and assessment survey (sample survey) Edinburgh Leisure undertakes this type of survey for all buildings where we have a Duty to Manage Asbestos (CAR 2006). The purpose of the survey is to identify, as far as is reasonably practicable, the presence, extent, location and condition of ACMs. Representative samples are collected by the surveyor and analysed for the presence of asbestos. This information is then used to create the asbestos register Demolition/Refurbishment Survey: Full access sampling and identification survey (pre-demolition/major refurbishment work/alterations) This type of survey is generally required before refurbishment, alterations or demolition works. The purpose of the survey is to locate and describe, as far as is reasonably practicable, all ACMs (that have not previously been identified) in the building / area where works are to be undertaken, including cable routes. This survey is designed to access all areas and is likely to involve destructive inspection, such as opening up of the structure, to view inside cavities, floor voids, risers and services ducts etc.
10 Samples are taken as with the type 2 survey and the type and size of the ACM is recorded. This type of survey is designed to be used as a basis for tendering the removal of the ACMs from the building prior to the commencement of the planned works. 9. THE MANAGEMENT PLAN 9.1. Priority Assessments As recommended by the Health & Safety Executive (HSE), when an inspection or survey is undertaken by the Head of Property and Facilities Management (or their designated representative) for each of Edinburgh Leisure's known ACM s or presumed ACMs, a risk assessment is carried out to assist in deciding on appropriate action and formulating a management plan. The risk assessments are carried out in two parts: the first is a material assessment which assesses the condition of the material and the likelihood of it releasing fibres if disturbed; the second part is a priority assessment which takes into account maintenance activities, likelihood of disturbance, human exposure potential, occupant activity or visitors Management Options Once an ACM has been risk assessed the condition (Good, Fair, Poor)) is logged against the inspection log and a management plan is formulated. At each inspection the ACM is re-assessed, a new re-inspection date is recorded and the management options are reviewed. Edinburgh Leisure has adopted the following management options for known ACMs:- Monitor Label Periodic inspections at intervals of 12 months or less depending upon the risk priority Where appropriate, Edinburgh Leisure s known asbestos is labelled, and/or included within the Permit to Work scheme, or fixed with an appropriate warning sign. Protection/Enclosure Where appropriate, known asbestos in Edinburgh Leisure s estate is protected by a physical barrier, such as a timber and polythene casing. The casing is sealed and as airtight as possible to prevent the migration of fibres. Sealed/Encapsulate There are two methods of encapsulation: (i) applying a durable layer adhered to the surface of the ACM, such as PVA or (ii) applying a material that penetrates the ACM before hardening which locks the material together.
11 Both methods are reported to have a life of twenty years if undisturbed. Repair Repair will only be undertaken if the damage is slight. There are a number of methods including filling, wrapping and isolated encapsulation. All repairs will be carried out using non-asbestos materials. Permit to Work procedures exist throughout Edinburgh Leisure and will apply to areas that contain asbestos which have been identified as being in Poor condition. Permit to Work Remove A Permit to Work must be obtained prior to any works commencing. All areas that require a permit as a result of the presence of asbestos will be clearly labelled. To obtain a permit to work a method statement and a risk assessment must be prepared by the internal or external contractor for the relevant work. A dedicated supervisor must be appointed with details including their name, contact number and their position in the company. Each method statement and risk assessment must be identifiable by a unique reference number. The HSE recommend against removal of asbestos since if removal is undertaken without due consideration there is a potential to increase the risk of harm. ACMs will be removed where it is found to be in poor condition and repair etc, or it is not possible or it is impossible to undertake maintenance works without disturbing the material, or refurbishment works are due to be undertaken. Edinburgh Leisure s management plan has been set up so that each individual piece of asbestos is managed according to its needs and is reviewed by re-inspection. Each inspection is logged on the asbestos register for the specific ACM. 10. TRAINING ARRANGEMENTS Facilities Management Staff Aim: to train all existing and new facilities management staff in asbestos awareness, asbestos register, asbestos management policy and to review this training on a biennial basis.
12 10.2. Training completed to date Property & Facilities management and maintenance staff have been trained and certified in the following courses: Asbestos Awareness Management by OHSAS half day Asbestos Awareness Training Course for managers and supervisors October 2007 (updated 2010) Asbestos Awareness by OHSAS Two hours Asbestos Awareness Training Course for operatives October 2007 (updated 2010) Follow up operative and management courses for those who missed the first two sessions were held on 10 th January New Property & Facilities Management Staff All new Facilities Management staff will be made aware of the Asbestos Management Policy & Plan by their manager as part of their induction training and will be asked by their managers to provide details of any training that they have previously undertaken. The new post holder will subsequently be included in EL s asbestos awareness training programme and receive the appropriate certification Refresher Training Property & Facilities Management staff will be required to attend refresher training courses in asbestos awareness, asbestos register content and asbestos management policy every two years. D. Ramsay January 2010
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Reviewed by: Approved by: Health & Safety Management Committee Management Board -. R3. Part 1: Introduction Part 2: Policy Part 3: Organisation and Responsibilities Part 4: Procedures Appendices: 1 Management
London School of Economics & Political Science Policy for the Control of Asbestos Final Draft 27.01.2014 Approved by Estates Strategy Committee 00.00.2014 Next Review Date 00.00.2015 London School of Economics