1 HS028 HAVEBURY HOUSING PARTNERSHIP POLICY ASBESTOS MANAGEMENT Controlling Authority Director of Resources Policy No. HS028 Issue No. 3 Status Final Date November 2013 Review Date: November 2016 Equality & Diversity Impact Assessment carried out 2011 Impact - Low
2 Asbestos Management Policy Index Introduction... 3 Statement of Intent... 3 In Summary:... 4 Strategy for Asbestos Management - Havebury Housing Partnership... 7 The Management of Asbestos... 8 Asbestos surveys... 9 Documentation... 9 Communication... 9 Training... 9 Asbestos Surveys Removal and Reinspection Programme Emergency Procedures Appendix A = Non-Licensable Work Tasks Appendix B = Sample of Asbestos Register Appendix C = Asbestos Decision Flow Chart Appendix D = Asbestos Survey No Access Protocol Appendix E = Waste Collection Protocol
3 Introduction The purpose of this Policy is to ensure that no employees of Havebury Housing Partnership, tenants, contractors or visitors are exposed to injurious airborne asbestos fibres, and in doing so, to comply with current Statutory Regulations and Guidance. Statement of Intent Havebury Housing Partnership recognises its duties under the Health and Safety at Work etc. Act 1974 and will responsibly manage and control asbestos and asbestos containing materials within its buildings so that they do not present a risk to employees, residents, visitors, service users, contractors or members of the public. In order to make appropriate arrangements for safeguarding health arising from the potential of asbestos exposure on Havebury Housing Partnership premises, Directors of Havebury Housing Partnership must take all reasonably practicable measures to prevent undue exposure to asbestos-containing materials. Havebury Housing Partnership will achieve this in the following ways: Implement, monitor and audit the operation of the asbestos management policy at regular intervals, making such changes as necessary to meet the needs of the service and to ensure continuing compliance with regulations. The Health & Safety at Work etc. Act 1974 places duties on employers to ensure as far as reasonably practicable, the health, safety and welfare of employees, and of others that may be affected by the employer s undertaking. These duties are extended with regard to asbestos management with the following legislation which Havebury Housing Partnership will comply with: The Control of Asbestos Regulations 2012 (and supporting codes of practice) HSG264 Hazardous Waste (England and Wales) Regulations 2005 Compliance is also required with the Construction (Design and Management) Regulations 2007 (CDM). Construction (Health, Safety and Welfare) Regulations 1996.
4 Havebury Housing Partnership will also: Survey all buildings under their control to identify and locate asbestos and asbestos containing materials as far as is reasonably practicable. Compile, maintain and make available suitable asbestos registers including building specific site plans (if available) or clear locational references and risk assessments. Train employees on asbestos awareness and where appropriate un-licensed works with asbestos containing materials (ACM s) to HSG210 and provide employees with advice on asbestos to a level expected for their role. Provide information to contractors about Havebury Housing Partnership s asbestos management policy, and seek their sign up and compliance confirmation. Use only suitably qualified surveyors, contractors and consultants. Request proof of training on asbestos awareness and where appropriate unlicensed works with asbestos containing materials (ACM s) to HSG210. Endeavour to collect data to identify, assess and locate asbestos in domestic units and their external areas, communal areas and garage blocks through a programme of surveys Provide information to tenants about asbestos including its health effects, where it may be located in the home and Havebury Housing Partnerships management of ACM s To reinspect the condition of identified asbestos containing materials within a five year rolling programme and update the risk assessments accordingly. In Summary: This policy applies to all premises which are owned or occupied by the Havebury Housing Partnership (HHP) and includes residential establishments. HHP recognises its duty under the Health and Safety at Work etc., Act 1974 to its tenants, employees, visitors, customers, contractors and members of the public. HHP recognises its responsibility to manage all asbestos containing materials and will manage the treatment, removal and disposal according to its legislative responsibilities. HHP will not differentiate between the health risks presented by the three most common types of asbestos used in materials and construction being Crocidolite (blue), Amosite (brown), and Chrysotile (white).
5 Removal of asbestos containing material will be carried out by contractors on the HHP approved list of licensed contractors for asbestos removal. Where minor works on non-licensable materials are required, as detailed in Appendix A, an appropriate contractor will be used. Works will be carried out in accordance with the Control of Asbestos Regulations 2012 and Asbestos Essentials Task Manual. HHP will not contract out or undertake any planned or maintenance work to any buildings without adequate information on the nature, condition and extent of, any asbestos containing material likely to be disturbed being available. The asbestos database will be consulted on each occasion and works orders will indicate this procedure has been carried out. All HHP properties will be subject to a Management Survey. All void properties requiring capital works will be subject to a Full Refurbishment Survey. In the event of refurbishment works under HHP s Capital Programmes, a Targeted Refurbishment survey shall be carried out by a suitably qualified surveyor accredited by UKAS to ISO In the event of major refurbishment or demolition works a Refurbishment and Demolition survey shall be carried out by a suitably qualified surveyor. HHP will not carry out any planned or maintenance work that will expose or is liable to expose any person to asbestos without first ensuring an assessment of that exposure has been carried out. Where the assessment indicates likelihood that asbestos will be disturbed by the work then removal shall be undertaken by an approved contractor. HHP aims to prevent the exposure of employees to asbestos. Where this is not reasonably practicable, HHP will reduce to the lowest reasonably practical level, any exposure of employees to asbestos. HHP undertakes not to purchase or install any asbestos containing product or material. HHP will provide instruction and training for all employees who are involved in the management and maintenance of its properties or who may come into contact with asbestos during their normal course of employment. HHP will provide information from Management Surveys to occupiers of its premises, giving the possible locations of asbestos, based on identified places within a survey sample. HHP will maintain and update as necessary the asbestos database of all identified locations of asbestos containing material to premises it owns or occupies, in accordance with the proposed Asbestos Strategy which forms part of this document.
6 HHP aims to undertake a survey of all its housing, sheltered housing, communal areas and garage blocks to establish the presence of asbestos containing material and apply the asbestos risk classification all in accordance with the asbestos management strategy
7 Strategy for Asbestos Management - Havebury Housing Partnership The purpose of this document is to detail the way in which asbestos within the partnership s housing stock will be identified, managed and then notified to staff, contractors and tenants. Background To increase its knowledge of asbestos occurrence within the housing stock, Havebury Housing Partnership was committed to conduct a survey on all of its properties to identify the location and check the condition of asbestos containing materials. In order to meet this commitment Havebury Housing Partnership developed a strategy for the long term management of asbestos containing materials. The asbestos management strategy was aimed at conducting Type 2 surveys (based on MDHS100) on 100% of the property portfolio. In order that a programme of Capital projects could be met the surveys would also facilitate the specification and management of any required asbestos removal works. In January 2010 the HSE produced HSG264 Asbestos The Survey Guide, which replaced MDHS100 and was aimed at helping people carrying out asbestos surveys and those with specific responsibilities for managing the risks from asbestos. The guide is also designed to provide assistance in managing asbestos in domestic premises under wider health and safety legislation and for meeting the requirements of the Construction (Design and Management) Regulations HSG264 details a change in the survey process from the Type 1, 2 & 3 in MDHS100 to Management Surveys and Refurbishment and Demolition Surveys that Havebury Housing Partnership will employ as its standard.
8 The Management of Asbestos The duty to manage asbestos requirements of regulation 4 of CAR 2012 do not normally apply to domestic premises. However, the requirements do apply to common parts of premises, including housing developments and blocks of flats, but do not place any direct duties on landlords for individual houses or flats. Examples of common parts would include foyers, corridors, lifts and lift shafts, staircases, boiler houses, vertical risers, gardens, yards and outhouses. The requirements do not apply to rooms within a private residence which are shared by more than one household, such as bathrooms, kitchens etc. in shared houses and communal dining rooms and lounges in sheltered accommodation. The Health and Safety at Work etc. Act 1974, 7 section 2, requires all employers to conduct their work so 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. Section 3 places duties on employers and the self-employed towards people not in their employment and section 4 contains general duties for anyone who has control, to any extent, over a workplace. In addition, the Management of Health and Safety at Work Regulations 1999 require employers to assess the health and safety risks to third parties, such as tenants who may be affected by their activities, and to make appropriate arrangements to protect them. These requirements mean that organisations such as local authorities, housing associations, social housing management companies and others who own, or are responsible for, domestic properties, have legal duties to ensure the health and safety of their staff (and others) in domestic premises used as a place of work. As employers, the organisations also have duties under the general requirements of CAR 2012 to identify asbestos, carry out a risk assessment of work liable to expose employees to asbestos and prepare a suitable written plan of work.
9 Asbestos surveys Purpose The purpose of the survey is to help manage asbestos in the duty holder s premises. The survey has to provide sufficient information for an asbestos register and plan to be prepared, a suitable risk assessment to be carried out and a written plan to manage the risks to be produced. Documentation The results of the surveys will be recorded in a clear, comprehensible, readily accessible and useable format and kept up to date on the property record. All sites where asbestos is discovered will be part of the risk classification scheme which will indicate how the risk was calculated (i.e. how the scores were arrived at) and also specifying actions required in relation to the scores recorded. Communication Information on the location of asbestos (where known) will be communicated to contractors and employees prior to any work activities, this information is designed to reduce the risk of contact with any asbestos containing material during the course of their works. All new tenants will be notified of the risks associated with asbestos. Neighbourhood Officers will provide a copy of the asbestos survey to new tenants when signing up for a property. Training Training appropriate to role will be given to Havebury employees in order that they are equipped with the necessary skills, knowledge and understanding about asbestos and issues surrounding ACM s to be dealt with safely and in full accordance with this policy. Employees will be given relevant training based on an assessment of their needs. Training requirements will be regularly reviewed with further training provided where a shortfall is identified. Key Targets/Actions 1. The Responsible Person will review the training needs of relevant employees annually. 2. The Responsible Person will prepare management reports at various intervals agreed by the Directors, and these will provide indicators on the status of asbestos management within Havebury Housing Partnership. 3. CDM coordinator and /or Contract Administrators and Repairs Team to ensure that all contractors and technicians are advised of up to date information relating to asbestos locations and conditions, prior to the
10 commencement of any work. Information will also indicate the risk band of the asbestos. 4. The Health and Safety Team will ensure that all tenants receive appropriate information on asbestos, and new tenants in particular, who are moving into properties where asbestos is present, are given appropriate information and advice by the Neighbourhood Team.
11 Asbestos Surveys Prior to the introduction of HSG264 asbestos surveys were carried out in accordance with MDHS100, these surveys were commenced in April 2007 and are predominately Type 2 and Type 3 surveys. Following the introduction of HSG264 Havebury Housing Partnership will conduct Management, Targeted Refurbishment and Refurbishment and Demolition surveys as its standard. Management surveys (previously known as Type 2) Management surveys should be carried out on properties which contain or possibly contain ACMs. Management surveys should be used as the primary means of managing routine maintenance work in domestic premises, communal areas and garage blocks. However duty holders must recognise that these surveys are limited in their scope and extent of intrusion and therefore do not provide sufficient information on the presence of ACMs for larger scale refurbishment and other improvement projects. Information from the Management Surveys can be enhanced with data from Targeted Refurbishment surveys and Full Refurbishment Surveys when the circumstances allow, e.g. when properties are vacant. Properties built after 1 st January 2000 will be considered free of asbestos therefore will not require any type of asbestos survey. However workers in such premises should always be vigilant. Targeted Refurbishment Surveys Targeted Refurbishment surveys will be required where refurbishment work or other work involving disturbing the fabric of the building is carried out. The survey strategy for refurbishment works is similar to that for Management surveys. Prior to Capital improvement work or major repairs, a Targeted Refurbishment survey will only be necessary in the specific area/location where the works will take place, e.g. cupboard, part of a room, kitchen/bathroom. However further Targeted Refurbishment surveys will be necessary in other locations when new improvement schemes are proposed. These Targeted Refurbishment surveys should have the specific purpose of identifying ACMs for removal, control or avoidance during the refurbishment works. Refurbishment Surveys (previously known as Type 3) Refurbishment and Demolition surveys will be required where refurbishment work or other work involving disturbing the fabric of the building is carried out. The survey strategy for refurbishment works is similar to that for Management surveys.
12 For improvement schemes and other project work, Refurbishment and Demolition surveys should be incorporated into the planning phase of such work as far as possible. This will avoid delays and disruption etc. where the work is urgent (e.g. essential or emergency maintenance, repair and installation), the Refurbishment surveys may have to be carried out just before the work itself. Surveys should be performed with due diligence. The above strategy requires management arrangements which reflect the circumstances and uncertainty of ACMs in domestic premises. There will always be the potential for ACMs not to have been identified before maintenance and refurbishment work is carried out. In these situations the management arrangements must include the following: Adequate asbestos training of trades people (e.g. to cover awareness, including identification) and work procedures; Arrangements must be in place to ensure that asbestos registers or records are checked before work commencing and there are procedures for dealing with any suspect/suspicious/unknown material, i.e. stop work, check material etc; Adequate supervision of employees and contractors to ensure procedures are implemented and followed. Referencing of Surveys All surveys carried out following the introduction of HSG264 will be referenced Management surveys, Targeted Refurbishment surveys and Refurbishment and Demolition surveys. Surveys carried out before the introduction of HSG264 will be referenced as Type 2 and Type 3. Completeness of Surveys It is intended that every readily accessible asbestos containing component within each room and externally will be individually scored and the type of survey recorded. Material Risk Assessment The material risk assessment algorithm is a requirement for identifying areas of concern in order to develop an Asbestos Management Plan as required by the Control of Asbestos Regulations 2012.
13 Friability Low = 1 Medium = 2 High = 3 Condition Good = 0 Fair = 1 Poor = 2 Debris = 3 Surface Treatment Sealed =1 Poor = 2 Bare = 3 Fibre Type No Asbestos Detected = 0 Chrysotile = 1 Amosite = 2 Crocidolite =3 The algorithm score is based on the following criteria and points: Once the score from each set of criteria is totalled a material assessment score is provided. Generally the higher the score the higher associated risk posed by a particular ACM. The hazard assessment criterion examines the risk posed by an asbestos material to release fibres that may be inhaled. This factor is the most significant when assessing asbestos. Therefore in order to consider if an asbestos material will release fibres the material assessments considers the type of asbestos, the extent of any damage to the material, whether people will come in contact with the material etc. These assessments are required to establish an asbestos management plan as it identifies areas of risk in order that procedures can be put in place, remedial works can be undertaken etc. The total material assessment algorithm value for each item is compared to Risk Bands in accordance with MDHS100 and HSG264. The risk bands are as follows: Band A Urgent Risk Material - Materials in this category pose an immediate risk to anybody in their vicinity and as such, immediate plans for removal will be made. Until removal can be achieved, access to the location of the material should be restricted and temporary measures to seal or repair the material should be put in place. Affixing asbestos warning labels can provide additional protection prior to removal. Risk Band B High Risk Material Materials in this category require remedial action as soon as reasonably practicable. Action may range from removal to repair, encapsulation and labelling. If left in-situ, the condition of the material should be monitored regularly, ideally as a minimum, at least on a two yearly basis and may require further repair or encapsulation if the condition has deteriorated.
14 Risk Band C Medium Risk Material This category indicates the need for regular monitoring although the current risk of fibre release is low, this material may suffer deterioration through age/accident. It is recommended that asbestos materials in this category be visually inspected on a two yearly basis to ascertain any change in condition. Where such a change occurs, re-prioritisation to Risk Band B will be necessary. Approved warning labels (A Labels) should be positioned to prevent accidental damage to the material. Risk Band D Low Risk Material This category indicates Low priority. Visual inspections should be made on a five yearly basis to ascertain any change in condition. Where such a change occurs, re-prioritisation to Risk Band C or B will be necessary. Approved warning labels (A Labels) should be positioned to prevent accidental damage to the material. Risk Band E No Asbestos Detected No action is required.
15 Removal and Re-inspection Programme High Risk asbestos materials (Risk Band A and B) shall be addressed as soon as practicable and removed or encapsulated so that they can be reassessed in a lower risk band where long term management is appropriate. Following completion of the survey being carried out, a programme for reinspection shall be established. This shall also be supported by the fact that tenants are provided with details of the asbestos materials in their properties and they are made aware of the associated risks and informed that they should report damage to these materials to Havebury. Emergency Procedures These procedures are to be adopted when known or suspected asbestos containing materials are disturbed or identified during works. i) Stop work. ii) Immediately inform your section head or other designated person. iii) Put warning sign up. iv) Arrange for a sample. v) Does it contain asbestos? vi) If yes, arrangements for removal or encapsulation by a licenced contractor will be made. vii) Reduce exposure to as low as reasonable practicable. viii) Do not sweep or vacuum up. Non Licensable Work and Notifiable Non Licensable Work tasks Due to the changes to working with asbestos under the Control of Asbestos Regulations 2012, in the interest of the health and safety of its technicians and tenants, Havebury will pass any asbestos removal work to an approved contractor. Listed in Appendix A are a number of tasks involving working with asbestos containing material which can be carried out by an unlicensed contractor, provided they have appropriate training and PPE in accordance with the HSE Asbestos Essentials and other relevant guidance and legislation which shall include but shall not be limited to: The Control of Asbestos Regulations 2012 (and associated Approved Codes of Practice L143) Management of Health & Safety at Work Regulations 1999 Construction (Design and Management) Regulations 2007 HSE Document HSG 247