1 WISHAW AND DISTRICT HOUSING ASSOCIATION Policy on the Management of Asbestos As with all the Association s policies and procedures, this document, where required, may be able to be translated into other languages and can be produced in other formats such as larger print. Further information on the implementation of this policy is available at the office. Leaflets\Policies and Procedures\Asbestos Management Policy.doc
2 CONTENTS PAGE NO 1.0 INTRODUCTION ASBESTOS POLICY MANAGEMENT OF ASBESTOS Responsibilities Information, Instruction and Training Information Instruction and Training Dissemination of Information to Contractors Assessment of Asbestos Containing Materials Assessment of Property Portfolio Assessment of ACMs Review Assessment of Risk MANAGEMENT PLAN Introduction The Plan Management of ACMs in Association Owned Properties Risk Assessment Scores Specific Materials Work not covered by CDM, but involving Destructive Access to Properties with ACMs Emergency Procedures The Use of Licensed Contractors Procedure for Work with Asbestos Containing Materials Leaflets\Policies and Procedures\Asbestos Management Policy.doc
3 WISHAW AND DISTRICT HOUSING ASSOCIATION ASBESTOS MANAGEMENT POLICY 1.0 INTRODUCTION This document represents Wishaw & District Housing Association s commitment, in line with the Control of Asbestos Regulations 2012, to the management of asbestos in its premises. It sets out the Association s overall policy relating to asbestos in its premises and describes the management plan required by Part 4 of the Regulations. 2.0 ASBESTOS POLICY It is the policy of Wishaw & District Housing Association Ltd to take all necessary measures to ensure full compliance with the Control of Asbestos Regulations (CAR). This includes the duty to manage any asbestos-containing materials (ACM) in such a manner as to prevent the exposure of employees to asbestos, or where this is not practicable, to reduce exposure to the lowest possible level. This will be achieved by: Procedures for assessment of property stock for the risk of containing asbestos Survey and assessment of those buildings deemed as presenting a risk of containing asbestos Dissemination of information and details of training procedures Overarching Management Plan for managing the risk of exposure to asbestos fibres The production of Plans of Work / Method Statements prior to any work involving the management of asbestos in Association owned properties The methods for prevention or reduction of exposure to asbestos fibres during such work 3.0 MANAGEMENT OF ASBESTOS 3.1 Responsibilities Regulation 4 of the Control of Asbestos Regulations discusses and defines the role of the Dutyholder in relation to the management of asbestos. The Association s Dutyholder is the Technical Services Manager who is responsible for the management of all asbestos within Association owned properties. Under the regulations this legal responsibility to manage asbestos relates to non-domestic premises and common areas within residential buildings only. However, the Association recognises that it also has a duty of care to manage the control of asbestos within its tenanted properties and will apply the policy equally across all properties.
4 The Technical Services Manager holds the legal responsibility for Wishaw & District Housing Association to ensure regulatory requirements are met. However, the management of day-to-day aspects of the requirements can be delegated to other staff. The Association s Maintenance Manager is the delegated responsible person who will oversee the routine tasks associated with the management of asbestos. Persons holding any responsibility, either as Dutyholder or nominated responsible persons must know the extent of their duties and have suitable competence and training. The ACoP L127 also states that the Dutyholder must ensure that anyone working within premises knows the chain of responsibility in relation to asbestos management. It is, therefore, necessary to have a clearly defined organisational structure giving details of the Dutyholder and their full responsibility, depending on the terms of occupation of the property. Details of Wishaw & District Housing Association s chain of responsibility are set down in Appendix 1. The Dutyholder will ensure that all staff and Board members within the Association are aware of their responsibilities and the responsibilities of others under the terms of the CAR. A record of training requirements and provision will be maintained for appropriate members of staff. It should be noted that all Technical Services staff members have a duty to follow approved policy and procedures and individuals within the Association may face prosecution if they put themselves, another staff member or a contractor at risk by disregarding training, advice and /or procedures. 3.2 Information, Instruction and Training CAR 2012 requires that all employers must ensure that employees who are or who are liable to be exposed to asbestos containing materials are provided with appropriate information, instruction and training. To enable compliance with this Regulation, Wishaw & District Housing Association has undertaken to follow the procedures below: Information The primary method of dissemination of information employed by the Association is through its own internal database system, access to which can be granted to any employee (including contractors and external consultants). This system contains the results of all ACM surveys and assessments carried out on the Association s property portfolio and allows for regular review, for instance when any remedial or removal work is carried out. F:\working files\technical Services\Asbestos Management The information contained in the management system will also be made freely available to the emergency services and the Association s out of hours contractor.
5 3.2.2 Instruction and Training Wishaw & District Housing Association Ltd will source an approved supplier of asbestos training and provide this training to all employees who require it. There will be regular reviews and refresher training as required. Appendix 2 gives a record of training needs and provision and this document will be regularly updated. All work to be carried out on licensable asbestos material will involve the use of an HSE licensed contractor and they will be required to provide the Association with full method statements as set down in section 4.5. Where permitted under the CAR, minor works on un-licensed materials such as asbestos cement, floor tiles or roofing felt, may be carried out by the Association s approved contractors but only where these contractors have provided evidence that they are fully trained in asbestos awareness and in the use of PPE and RPE as appropriate and hold the relevant insurance cover. (refer to section 4.4). In order to ensure work is undertaken by the appropriate contractor before staff instruct a repair they will assess whether the work is likely to disturb any known ACMs by checking the database and from their own knowledge of the material s make-up, age (where a property has been built or refurbished after 2000 asbestos will not be present) and location. Following reasonable assessment if doubt remains over the content of the materials that will be disturbed then staff will work on the principle that asbestos may be present and instruct sampling of the material prior to issuing a repair order. Where the sampling shows the presence of ACMs then a licensed contractor will be appointed to undertake the repair. The results of any sampling undertaken will be added to the database and, where appropriate, extrapolated across property records for units of the same type and age Dissemination of Information to Contractors The Association recognises its duty to inform all contractors who will be undertaking repairs within its properties of the locations of all known or suspected ACMs. To this end we will invite all our maintenance contractors to examine the Association s internal database of ACMs so that they can familiarise themselves with the locations and types of materials involved refer Appendix 3. This policy stipulates that, in general, all works on ACMs will be carried out by specialist licensed contractors. However, there may be occasions where a nonlicensed contractor discovers an ACM, or suspects a material contains asbestos, during the course of a repair. In these cases the contractor must stop work immediately and inform the Dutyholder who will have the material assessed and tested before work can recommence. The Association s Procedures for the Management of Asbestos set down the steps that will be taken under these circumstances and all maintenance contractors will be issued with a copy of these procedures and be required to follow them.
6 3.3 Assessment of Asbestos Containing Materials Regulations 4(3) to 4(5) of the CAR set down the requirements for assessment of the properties under the Association s control. These require that: the dutyholder shall ensure that a suitable and sufficient assessment is carried out as to whether asbestos is or is liable to be present in the premises Assessment of Property Portfolio The first step of this assessment process was an initial examination of the property stock, taking into account such factors as building age, type and use, together with an assessment of any existing records that may be pertinent. The initial assessment enabled the Association to prioritise further, more detailed, surveys of those properties deemed to be likely to contain asbestos. The Association has worked on the principle that any reasonably suspect materials do contain asbestos, until they are proved not to through sampling. The presumption was also made that for properties within the same block or development (ie refurbished or constructed at the same time and by the same contractor) if ACMs are found in one property they will be present in all. Conversely if a property is found to be asbestos free then it is assumed all similar properties are likewise. The Association has undertaken Type 2 sampling surveys of a representative sample of its stock that was constructed prior to 2000 to ascertain whether ACMs are present. (Note: Type 2 survey is now termed Asbestos Management Survey under CAR 2012.) All further acquisitions (for example, through Mortgage to Rent) will be subject to this initial assessment process. This will enable prioritisation of further, more detailed surveys of those properties deemed to be likely to contain asbestos. Any such assessments will be completed as required, upon acquisition of further properties. In addition, the Association s full property records will be assessed on an annual basis to ensure all information is current. The full list of properties containing, or suspected of containing, ACMs is stored on the Association s internal database:..\..\..\technical Services\Asbestos Management\Property Database\Property database - Asbestos Register.xlsx
7 3.3.2 Assessment of ACMs The Association has carried out a comprehensive sample survey of materials within its buildings and is aware of the exact location, extent and condition of all ACMs in the properties surveyed. The Type 2 surveys were carried out by UKAS accredited asbestos management consultants. Further, the Association will also undertake to ensure that a Demolition / Refurbishment Asbestos survey will be carried out prior to any demolition work or major refurbishment within properties with ACMs. For the purposes of definition, major refurbishment will be determined as that work covered by the Construction (Design and Management) Regulations In all cases, surveys of premises for the purposes of identification and assessment of ACMs will be carried out in full accordance with relevant HSE guidance The surveys will include numerical assessment of the condition of any identified ACMs. This Material Assessment Score (MAS) will depend on the material in question, its condition, any surface treatment and the type of asbestos it contains. The findings of all such surveys will be used for management purposes, to be defined in subsequent sections of this document. In addition, in compliance with the Regulations governing dissemination of information, the Association will share information with all relevant parties as outlined in Section 3.2 of this document. Existing survey reports include photographic evidence, laboratory analysis certificates and marked-up building plans and these are available for viewing in the Association s Asbestos Database Review Regulation 4(6) of the CAR requires review of the assessments resulting from such surveys if there is any reason to suspect that assessment is no longer valid or if there have been significant changes to the property. To this end, the Association will undertake to ensure that there will be annual reinspections of the ACMs within its properties, where appropriate (artex within homes, for example, will not be inspected) and any changes will be recorded in the database. Additionally, there will be annual reviews by management personnel for the purposes of ensuring the management plan and survey records remain up to date and valid. The Dutyholder will ensure the conclusions of any reviews are recorded as described previously.
8 3.4 Assessment of Risk Regulation 4(8), part(a) carries the requirement to undertake an assessment of the risk of exposure of persons to asbestos fibres. The assessment of risk will utilise the results of the Material Assessment Score (MAS) for the identified ACM. The priority for management of ACMs will be determined by assessing the likelihood of those materials being disturbed. This priority assessment will take into account such factors as maintenance activities, likelihood of disturbance, human exposure potential and occupant activity. This will enable the production of a Priority Assessment Score (PAS) for management. This scoring will be developed in conjunction with the site Health and Safety Coordinator and an approved asbestos consultant where appropriate, to ensure a suitable allocation of score for normal occupant activities, likelihood of disturbance and human exposure potential. The full assessment of risk of exposure will include both the MAS and PAS for each ACM identified. Further, for surveys and assessments on any subsequent acquisitions, both the PAS and the full risk assessment on each ACM will be completed at the time of receipt of the sampling survey results, in conjunction with the approved asbestos consultant. Both the PAS and the results of the risk assessment will be recorded and made fully available as necessary in the Association s internal database. All risk assessment scoring will be periodically reviewed to ensure it remains valid. For instance, ACMs in an unoccupied area may have a low risk assessment score. However, this area may subsequently become occupied and a re-assessment of both the PAS and full risk assessment will be required. This re-assessment will be undertaken as part of the annual review. 4.0 MANAGEMENT PLAN 4.1 Introduction In accordance with Regulation 4(8), part(c) to 4(10), the Association has undertaken to implement a suitable plan for the management of all asbestos-containing materials within its properties. As each identified ACM in these properties is likely to have unique characteristics in terms of type of material, occupancy of area and so forth, it is not feasible to set out the management plan for each material in this document. Rather, the Association will utilise its internal database system. This system allows for any updating of the records relating to specific ACMs, and allows notification of the completion of any planned works. The principles of the Association s over-arching management plan for the control of asbestos containing materials within its properties are set down below.
9 4.2 The Plan The scope of the Management Plan covers all Association owned premises (with the exception of those that have been deemed as presenting no foreseeable risk of containing asbestos, i.e. those where construction commenced after 2000). The Plan will ensure that all necessary measures for controlling the risk of exposure are implemented. These measures will include, but are not limited to: Monitoring of the condition of identified and suspected ACMs (see Section 3.3 of this document) Ensuring information is disseminated as required (Section 3.2) Review of the Management Plan on a regular, planned basis and with additional reviews if there is reason to believe it is no longer valid (Section 3.4) Ensuring that measures specified in the Plan are implemented according to the Plan, and recorded in the Plan. 4.3 Management of ACMs in Association Owned Properties Risk Assessment Scores An assessment of the risk of exposure of persons to asbestos fibres for each location identified as containing or presumed to contain asbestos has been undertaken, following the survey carried out by approved asbestos consultants (as per Section 3.4 of this document). The results of this Assessment are contained in the Association s internal database. The production of these risk assessment scores has enabled the formulation of a structured plan for the management of ACMs at each property and these are stored on the Association s database at F:\working files\technical Services\Asbestos Management\Risk Assessments. The banding for these risk assessment scores has been reached after consultation with specialist asbestos consultants: Score Rating Action 16+ High -Immediate Action Required Medium -Action Required within Short-term Low -Action required within Medium-term <10 Very Low -Action required within Long-term Individual materials require a specific written management scheme providing specific actions and proposals. This is recorded, along with risk assessment scores, in the Association s internal database and can be reviewed and amended as required.
10 4.3.2 Specific Materials While the risk assessment has enabled a prioritisation of the work required on Association owned properties, each type of identified ACM needs specific methods of management, depending on the material. The general policies of managing each type of ACM identified are outlined as follows: Asbestos Cement The following procedures will apply: Annual condition inspections of all asbestos cement materials. Clear asbestos labels will be placed on all cement sheets at low level, or in areas that may easily be disturbed. Cement flues will not be labelled other than in those areas indoors where disturbance is possible. Where asbestos containing roofing is present, suitable signage will be placed externally and in strategic positions internally to warn occupants of the presence of asbestos. The Association will endeavour to ensure all staff and site occupants are aware of the materials and how their presence could impact on their activities. Composite Materials The following procedures will apply: Annual condition inspections of all asbestos composite materials. The Association will endeavour to ensure all staff and site occupants are aware of the materials and how their presence could impact on their activities. Asbestos Insulation Board The following procedures will apply where material condition and RAS scores allow. Where scores do not allow it will be the Association s policy to remove the material. The Association will manage all AIB that is in a suitable condition (as determined by the Risk Assessment Scores). Annual condition inspections of all asbestos insulating board materials. Clear asbestos labels will be placed on all exposed areas of insulating board, or in areas that may easily be disturbed. The Association will endeavour to ensure all staff and site occupants are aware of the materials and how their presence could impact on their activities.
11 Textured Coatings (Artex) The following procedures will apply: The Association will endeavour to ensure all staff and site occupants are aware of the materials and how their presence could impact on their activities. Vinyl Products The following procedures will apply: Annual condition inspections of all asbestos composite materials. Clear asbestos labels will be placed on all vinyl products containing asbestos. The Association will endeavour to ensure staff and site occupants are aware of the materials and how their presence could impact on their activities Work not Covered by CDM, but Involving Destructive Access to Properties with ACM s While the Association will identify, as far as possible, all locations of ACMs within its property portfolio there may be areas within the structure of the buildings that are not accessible under the constraints of the Asbestos Maintenance survey undertaken. As discussed in Section 3.3 of this document, the Association will undertake to perform a Demolition / Refurbishment Asbestos survey prior to any work covered by the CDM Regulations It must also be recognised that there may be instances where work is due to be undertaken that may involve some form of minor destructive access, such as drilling through cavity walls to install cabling etc. and this may reveal the presence of ACMs not previously identified. In these circumstances the Association will undertake an assessment of the risk of disturbing concealed ACMs prior to instructing the work. If any suspected ACMs are revealed during the course of the repair work will immediately cease and staff will inform the Dutyholder who, together with an external asbestos consultant, will undertake a thorough assessment of the area (including any required sampling) prior to agreeing how work will be completed. To facilitate this process the Association will ensure all maintenance contractors are fully conversant with the procedures for notifying the Dutyholder if they come across any material they suspect may contain asbestos. These procedures, together with appropriate asbestos awareness training for staff, will minimise, as far as is reasonably practicable, any risk of exposure to asbestos fibres as required by the Control of Asbestos Regulations:..\Technical Services Procedures\Asbestos Management Procedures.doc
12 4.4 Emergency Procedures In the event that work undertaken on Association owned properties is believed to have disturbed an ACM, either identified in the register, or previously unidentified, the following emergency procedures will be followed: Work will immediately cease. If there is dust / debris on clothing, clothes will be removed and placed in a plastic bag. Operatives will shower (if possible) or wash thoroughly and clean and tidy the wash area. The Dutyholder will be informed immediately of the possible exposure and a sample of the suspect material will be taken for analysis by a UKAS registered surveyor. If no asbestos is identified in the sample, no action need be taken. If, however, the sample is found to contain asbestos the Dutyholder will determine actions to be taken, in accordance with this policy and a licensed contractor will be employed to undertake any clearance / remedial work required. (Refer to Sections and 4.4). 4.5 The Use of Licensed Contractors There are three categories of asbestos works: Licensed Notifiable non-licensed Non-notifiable non-licensed Licensed works All high risk asbestos work must be undertaken by a licensed contractor and notified to the HSE a minimum of 14 days prior to work commencing. High risk work includes all work to asbestos coatings and work to asbestos insulation board where the work is not sporadic (short duration) and not low intensity (SALI). Low intensity means that the risk assessment has shown that the airborne fibre concentration will be below the control limit of 0.1fibre/cubic centimetre. Notifiable non-licensed works Where asbestos related work is of short duration all work (including ancillary works) is less than two hours or no individual works for more than 1 hour in any seven day period - and low intensity (SALI) then it can be undertaken by a suitably trained and appropriately insured non-licensed contractor. If the ACM is friable or degraded or where the main purpose of the work is the removal of the ACM then the contractor must notify the HSE prior to commencement.
13 Non-notifiable non-licensed works Where asbestos related work is SALI (as defined above) and the ACM is non-friable and not degraded and where the work to the ACM is ancillary to the main repair then it can be undertaken by a suitably trained and appropriately insured non-licensed contractor and does not need to be notified to the HSE. At present none of the Association s maintenance contractors is insured to undertake works on ACMs and none have appropriately trained staff. Therefore, it is current policy that the Association will employ a licensed asbestos contractor to undertake any works involving the disturbance of ACMs. However, if this situation changes the Association may instruct a non-licensed, approved contractor for those works which are categorised by the HSE as lower risk and can be undertaken by a non-licensed contractor. It should be noted that such contractors will only be permitted to undertake this work if they have provided satisfactory evidence to the Association that relevant training needs have been met and they are adequately insured. They will also be required to submit full method statements prior to undertaking any repair works and notify the HSE as required. 4.6 Procedure for Work with Asbestos Containing Materials The requirements covering Plans of Work for asbestos removal are contained in Regulation 7 of the CAR, with additional coverage in Regulation 6. In summary, these require, but are not limited to, the following: The employer of workers involved with the remedial or removal work (ie the licensed contractor) will draw up a written plan of work or method statement. Employers will ensure their workers follow this plan so far as is reasonably practicable. If work cannot follow the plan, work will cease and the risks will be reappraised. Work will not re-commence until a new plan is written, or the existing one amended. The plan will be site-specific and detail the following: Findings of the assessment of the work required, including: description of the work required (e.g. removal, encapsulation etc.); type of asbestos and analysis results; quantity and extent of material; and scale and duration of works. Address and location of work. Provision of relevant documentation including, but not limited to: HSE licence; staff training and medical certificates; equipment test certificates; site log records; maintenance records; and sketch of work area.
14 Methods to be used, including: Steps taken to prevent or control exposure (e.g. type of wetting, shadowvacuuming, glove bags, wrap and cut), together with the reasons why these methods have been chosen Procedures for removal of waste and contaminated tools and equipment from the work area and site Type of equipment, including PPE and procedures used for protection of workers (e.g. type of vacuum cleaners, PPE / RPE details, methods of communication across enclosure barrier, transit routes) Type of equipment and procedures used for protection of other people in the wider environment (e.g. use and location of barriers, warning signs, disposal skips, enclosures, use of air monitoring, clearance certification and emergency procedures). Document History Approved by the Board of Management - 17 January 2006 First revision by Board of Management - 4 July 2006 Second revision by Technical Services Manager - 18 January 2010 Third revision by Technical Services Manager - 18 November 2010 Fourth revision by Technical Services Manager - 22 July 2011 Fifth revision by Technical Services Manager - October 2012
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