SAFETY RESPONSIBILITIES AND ARRANGEMENTS IN RESPECT OF ASBESTOS MANAGEMENT (ASBESTOS MANAGEMENT PLAN)

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1 KING S COLLEGE LONDON Health, Safety & Environmental Protection Office SAFETY RESPONSIBILITIES AND ARRANGEMENTS IN RESPECT OF ASBESTOS MANAGEMENT (ASBESTOS MANAGEMENT PLAN) Issue Date: May 2012 Issue Number: 3 Procedure No: SPR020 Author: HSEPO and Estates & Facilities Approved By: Health & Safety Management Group CONTENTS 1 INTRODUCTION OBJECTIVE SCOPE REFERENCES/RELATED DOCUMENTS DEFINITIONS ROLES AND RESPONSIBILITIES GENERAL FIGURE 1 ORGANISATION/RESPONSIBILITY CHART ASBESTOS ASSESSMENT SURVEYS SURVEYING AND BULK SAMPLING COMPETENCE ASBESTOS REGISTER AUDITING OF THE ASBESTOS REGISTER MATERIAL ASSESSMENT PRIORITY ASSESSMENT COMBINED RISK ASSESSMENT ASBESTOS MANAGEMENT INTRODUCTION MANAGEMENT ACTIONS CONTROL ACTIONS IMPLEMENTATION TIMETABLE ASBESTOS MANAGEMENT PROCEDURES PROJECT MANAGEMENT FOR ALL CONSTRUCTION WORKS INCLUDING EMBEDDED SPACES PERMIT TO WORK TABLE 1: DETERMINATION OF APPROPRIATE CONTROL METHOD FOR ASBESTOS MONITORING AND REVIEW RE-INSPECTIONS RECORD KEEPING REVIEW INFORMATION, INSTRUCTION AND TRAINING INTRODUCTION WORK PERFORMED BY OUTSIDE CONTRACTORS/CONSULTANTS SPR HSEPO Page 1 of 33

2 8 ACQUISITION, DEMOLITION AND DISPOSAL OF PREMISES ACQUISITION DISPOSAL DEMOLITION WASTE DISPOSAL PROCEDURE IN THE EVENT OF EXPOSURE TO UNIDENTIFIED SUSPECT MATERIAL OR DAMAGED ASBESTOS GENERAL PROCEDURE IN THE EVENT OF EXPOSURE TO UNIDENTIFIED SUSPECT MATERIAL OR DAMAGED ASBESTOS CRITERIA FOR SELECTION OF LICENSED ASBESTOS REMOVAL CONTRACTORS (LARC) QUALIFICATIONS KEYS FOR APPENDICES FLOW CHARTS APPENDIX A ASBESTOS MANAGEMENT PROCEDURES FLOW CHART EMERGENCY RESPONSE STAGE APPENDIX A ASBESTOS MANAGEMENT PROCEDURES FLOW CHART EMERGENCY RESPONSE STAGE APPENDIX B ASBESTOS MANAGEMENT PROCEDURES FLOW CHART PROJECT WORKS STAGE APPENDIX B ASBESTOS MANAGEMENT PROCEDURES FLOW CHART PROJECT WORKS STAGE 2 (ACM IDENTIFIED) APPENDIX C ASBESTOS MANAGEMENT PROCEDURES FLOW CHART MAINTENANCE AND REACTIVE WORKS APPENDIX D DEFINITION OF CONSTRUCTION WORK CHANGES FROM LAST ISSUE = highlighted SPR HSEPO Page 2 of 33

3 1 INTRODUCTION 1.1 OBJECTIVE King s College London, as a responsible employer, owner and controller of premises, is aware of its legal duties owed to staff, students, building occupiers, contractors and others with regards to the provision of safety related information on asbestos and its duty to manage asbestos within its premises It is the ultimate long term aim of the College to have a fully asbestos safe working environment. In the interim, the College has a structured, risk based approach to the management and control of asbestos containing materials (ACMs) within its property portfolio to reduce the risk to its lowest practical level. This includes the use of licensed and accredited specialists, planned surveys and reinspections and maintenance of comprehensive records The College recognizes the hazard of asbestos and the risks to health that it poses. Therefore to fulfil its moral, social and legal obligations this plan has been developed. Its effective implementation will minimize the risk of exposure to asbestos Asbestos is assessed for condition status on a regular basis. Asbestos that is identified as being in a poor condition or in a high risk area e.g. exposed boards within high activity public access and/or circulation spaces will also be give immediate priority for treatment. 1.2 SCOPE This document provides information, procedures and guidance relevant to the management and control of asbestos containing materials known or presumed to be present with the buildings for which the College is the Dutyholder. It has been developed, in part, to fulfil the requirements and obligations under current legislation and to provide the means from which exposures to asbestos may be prevented through the combined efforts of all parties (i.e. management, staff, maintenance, contractors, consultants etc). This management plan applies to all parts of King s College London without exception, including embedded spaces in relation to refurbishment projects The College has, by survey, identified various asbestos-containing materials as being present throughout many of the buildings owned, leased and/or otherwise occupied by the College. The plan must be read in conjunction with the asbestos survey reports for each building or structure (the asbestos register) which records any asbestos containing or suspected asbestos material known to be present. Refer to the on-line asbestos register (EAR); access may be gained through certain authorized personnel such as Local Estates Managers This asbestos management plan is designed to be a dynamic document that will require updating as the College s procedures change, or as regulatory requirements change. It takes into account all existing regulations and guidelines pursuant to work with the removal or management of asbestos To enable the dutyholder to discharge this responsibility this document describes the requirements and procedures for dealing with asbestos. These procedures cover: The development of a written plan The appointment of a Compliance Co-ordinator (acting as an Asbestos Co-ordinator) The establishment of parameters for the evaluation and assessment of all suspect or confirmed ACMs The requirement to maintain an asbestos register in which a record is kept of the location and condition of ACMs at each site and including details of where asbestos has been removed. The prevention of exposure to asbestos The provision of the periodic re-inspection and review of all ACMs The actions to be taken when there is a risk that asbestos fibres have been released into the atmosphere The promotion of asbestos awareness and the Asbestos Management Plan through training and induction of staff, maintenance and contractors etc. The review and update of the Asbestos Management Plan and procedures. SPR HSEPO Page 3 of 33

4 1.3 REFERENCES/RELATED DOCUMENTS Legislation governing the control of asbestos has been introduced via a series of regulations made under the enabling act, The Health and Safety at Work etc. Act The principle of these regulations is to assess hazard and risk and then take precautions to minimize this risk. The College has a duty to employees engaged in works that expose them to any form of asbestos. These duties extend to any persons who may be affected by the work activity Any asbestos-related issues associated with King s College London owned/leased property, including the removal, encapsulation, transport, and disposal or otherwise potential disturbance of asbestos materials, shall be performed in accordance with all relevant Acts, Regulations, advisory standards, Approved Codes of Practice and industry standards, including, but not limited to, the following: The Health and Safety at Work etc Act 1974 The Control of Asbestos Regulations 2012 The Management of Health and Safety at Work Regulations 1999 (as amended) The Hazardous Waste Regulations 2005 The Site Waste Management Regulations 2008 The Construction (Design and Management) Regulations The following are guidance designed to assist dutyholders in fulfilling their statutory duties: Work with materials containing asbestos. Control of Asbestos Regulations, ACOP L143 The management of asbestos in non-domestic premises, (Regulation 4 of the Control of Asbestos Regulations) ACOP L127 HSE Control of asbestos regulations guidance e.g., HSG227, 247 and 248 Asbestos essentials publications; introduction and task manual, HSE. Asbestos: The Survey Guide, HSG264 Asbestos related HSE web pages - Asbestos Liaison Group memos: : Forms: F061 Emergency notification of suspected asbestos containing material F062 Project Review F063 Employee Training & Acknowledgement F064 Contractor s Notification and Acknowledgement F065 - Asbestos - Visual Re-inspection summary sheet SPR HSEPO Page 4 of 33

5 2 DEFINITIONS In this policy statement and Advisory Note the following definitions apply: King s or the College means King s College, London. Contractor means anyone the College employs to do work of any kind who is not an employee and may in the course of their business carry out or manage construction work. CAR means Control of Asbestos Regulations 2012 AMP means the Asbestos Management Plan ACMs means Asbestos Containing Materials EAR means the Electronic Asbestos Register LARC means Licensed Asbestos Removal Contractor HSE means the Health and Safety Executive EA means the Environment Agency Project includes all preparation, design, planning, construction work and clearance of the site for occupation or use at the end of the construction phase and handover. Chrysotile is White Asbestos Crocidolite is Blue Asbestos Amosite is Brown Asbestos Dutyholder means a) every person who has, by virtue of a contract or tenancy, an obligation of any extent in relation to the maintenance or repair of non-domestic premises or any means of access thereto or egress therefrom; or (b) in relation to any part of non-domestic premises where there is no such contract or tenancy, every person who has, to any extent, control of that part of those non-domestic premises or any means of access thereto or egress therefrom, and where there is more than one such dutyholder, the relative contribution to be made by each such person in complying with the requirements of this regulation will be determined by the nature and extent of the maintenance and repair obligation owed by that person. CAR 2012 regulation 4 ACOP means Approved Code of Practice. An ACOP issued by the Health and Safety Executive gives guidance on how to comply with the regulations to which it applies. Following an ACOP is not mandatory, but in a court of law failure to adopt the advice in an ACOP will be regarded as having failed to comply with the law. CDM or CDM 2007 means the Construction (Design & Management) Regulations 2007 Construction Work means the carrying out of any building, civil engineering or engineering construction works and includes works defined in the CDM 2007 ACOP see appendix D. Client means anyone who accepts the services of another, in the context of this document the Client will be the College and those employees that represent the client s interests will be the Client Representative Designer means any person, including the client or contractor, who in the course of the works prepares or modifies a design or arranges for or instructs anyone under his control to do so. SPR HSEPO Page 5 of 33

6 3 ROLES AND RESPONSIBILITIES 3.1 GENERAL King s College London will appoint suitably qualified and competent staff to discharge its responsibilities regarding asbestos. The following identifies the responsibilities for asbestos management throughout the College This AMP is designed in such a way to integrate into the existing King s College London construction and maintenance & operations programmes. The following key personnel are, under Regulation 4 of the Control of Asbestos Regulations 2012 (Duty to Manage Asbestos in nondomestic premises), responsible for the implementation of the control measures discussed in this document: DUTYHOLDER RESPONSIBILITY College Council The College commitment to promoting a healthy and safe working environment. Approval of the AMP Principal Ensure College wide compliance with and implementation of, the AMP Director of Finance Allocate funding for AMP Director of Estates & Facilities Overall responsibility for the Directorate and is responsible for the overall strategic asbestos management including procedures and practices Ensuring development and implementation of the AMP Deputy Director Estates & Facilities Acts on behalf of the Director of Estates and Facilities in respect of this AMP Commissioning and implementing the AMP and action plan. Conduct and/or otherwise allocate to the approved consultant or other competent persons, the task of providing detailed technical specifications and management services (including the provision of site inspection and air monitoring services) for scheduled or emergency abatement works. Evaluate on an annual basis, or more frequently as required, the need to hold refresher training for any recently employed College staff (including agency and contract staff under direct control) whose job requires them to manage and/or work near known or suspect ACMs Commission or otherwise provide awareness and/or procedural training for all College staff (including agency and contract staff under direct control) whose job requires them to manage and/or work near known or suspect ACMs Commission or otherwise complete a detailed and comprehensive asbestos register for all buildings suspected of containing ACMs. Include within this scope any future acquisitions. Commission or otherwise complete a regular review and evaluation of all ACMs once per year or more frequently as circumstances and assessments warrant. Provide final approval for all asbestos work requisitions forwarded for his/her attention. Monitor the implementation of the AMP SPR HSEPO Page 6 of 33

7 Compliance Manager Compliance Coordinator King s College Project Officers/Project Managers Construction Managers Estates Managers Contractors/ Directly Employed Labour (DEL)/All Employees of the College. Carry out an annual review of the AMP to critically review all management processes and their effectiveness as well as the overall progress made against the implementation action plan. Assists the Deputy Director of Estates and Facilities in respect of their duties under the AMP Day-to-day management of the Compliance Co-ordinator The day-to-day administration and maintenance of the Asbestos Management programme Maintenance of the Asbestos Register and all other relevant information pertaining to the control and management of asbestos. Co-ordinate the response to any report of suspect asbestoscontaining building materials, asbestos debris, damage or disturbance. This will include evaluation of circumstances under which it has been encountered and initiating the necessary sampling, clean-up, removal or repair as appropriate liaising with the Assistant Director (and/or their appointed asbestos specialist) who will be responsible for final approval. Advise managers or project managers on the retrieval and evaluation of EAR information connected to any maintenance, renovation or construction activities that they are planning to undertake. Monitor asbestos work instructions/method statements to ensure the individual manager or project manager in charge of the work has followed the AMP and allow for update of the EAR. Monitor and make adjustments, within the scope of the AMP, to the labelling that identifies the presence of all known or suspect ACMs within College property. Ensure a copy of all site inspection reports and corresponding air monitoring data is made available to whosoever wishes to inspect such reports. Arrange for all original survey data/information and any subsequent asbestos survey data/information or updates to be loaded onto the EAR and make them available upon request for viewing by whosoever wishes to inspect them. Project management Assist, by the provision of information, individual designers, or consultant project managers in the evaluation of any maintenance, renovation or construction activities in respect of the presence of asbestos containing materials. Identification and bringing to the attention of appropriate staff any suspect material Ensure all contractors working on asbestos are aware of and meet the requirements of the AMP Ensure project personnel (including contractors) are inducted Instruction of works (King s College Project Manager not to be delegated to a consultant Project Manager) Ensuring that any works that may disturb or damage ACMs are avoided. Reporting to the Compliance Co-ordinator (either directly or via Project Manager) any material suspected to contain asbestos where the material has been damaged or disturbed or where SPR HSEPO Page 7 of 33

8 staff/contractors are likely to undertake work that may affect such materials. Refer to the AMP for procedures to follow with regard to the management or removal of ACMs. Removal of asbestos containing pipework gaskets in emergency situations by nominated trained DEL only. Asbestos Consultant or other competent person Licensed Asbestos Removal Contractor (LARC) As and when required: Providing a management consultancy service in the areas of asbestos management and abatement Undertaking surveys and sampling, where requested, in accordance with current legislation Reviewing and commenting on projects where asbestos works may be necessary including the provision of information for any building projects and on contractors method statements Supervision of asbestos removal works including, but not restricted to, attending pre-start, progress and completion meetings Reporting to the Compliance Co-ordinator any defects or noncompliances relating to the Asbestos Removal Contractor s performance, including suitability of work areas, adherence to method statement and compliance with College policy. Checking areas on completion of works to ensure that the ARC has completed his scope of works and all affected areas have been left in a satisfactory condition. Issuing completion reports, including all clearance documentation to include a minimum of analysis confirmation or applicable survey reference, technical specification or scope of works, method statement, clearance certification and consignment notes. Updating and issuing asbestos surveys, including update of plans where applicable, following the removal or reduction of risk of asbestos containing materials. Providing training programmes for College staff. Bringing to the attention of the Compliance Co-ordinator and/or the HSEPO any concerns regarding the management of ACMs on College premises. Complying with current legislation and ACOPs and guidance Removal and/or encapsulation of ACMs in a safe and controlled manner without increasing risk of exposure to asbestos fibre to staff, students and visitors etc. Attend site, as directed by the Asbestos Consultant, or other competent persons, for the making safe of any uncontrolled disturbances of ACMs Providing assistance to the Asbestos Consultant or other competent persons, in the undertaking of refurbishment/demolition asbestos surveys as necessary. College Health, Safety and Environmental Protection Office Liaise with College Dutyholders above as necessary Monitor/audit the effectiveness of the AMP SPR HSEPO Page 8 of 33

9 3.2 FIGURE 1 ORGANISATION/RESPONSIBILITY CHART Key Information/ Consultation Management Instruction/ Management College Health, Safety and Environmental Protection Office Monitor/audit the effectiveness of the Asbestos Management plan College Council and Principal Responsible for approval and overall implementation of the Asbestos Management Plan Director of Estates & Facilities Responsible for the overall strategic asbestos management and the Asbestos Management plan Deputy Director of Estates & Facilities Acts on behalf of the Director of Estates and Facilities in respect of the Asbestos Management plan Trade Union & Safety Representatives Consultation through agreed channels on matters affecting employees they represent Maintenance Staff, Contractors, Building Managers, Heads of School/Dept and Employees Ensuring that any works that may disturb or damage ACMs are avoided. Reporting any suspect/suspected asbestos to the Compliance Co-ordinator Compliance Co-ordinator Day-to-day administration and maintenance of the Asbestos Management programme Managed by Compliance Manager Local Estates Managers, Project Managers, Project Leaders Following College asbestos management procedures for planned maintenance, projects and emergency/out-of hours discovery Analytical and Air monitoring Contractor Analysis and air monitoring as required (UKAS accredited) Asbestos Removal Contractor Controlled licensed removal of asbestos Asbestos Consultant Management consultancy, surveys and sampling SPR HSEPO Page 9 of 33

10 4 ASBESTOS ASSESSMENT 4.1 SURVEYS An asbestos survey has four main elements: i. Firstly, it must locate and record, as far as is reasonably practicable, the location, extent, asbestos and product type of any presumed or confirmed ACMs; ii. Secondly, it must inspect and record information on the accessibility, condition and surface treatment of any presumed or confirmed ACMs; iii. Thirdly, it must determine and record the asbestos type, either by laboratory analysis following sampling or by making a presumption based on product type, appearance, location and a knowledge of the history of the usage of asbestos; iv. Fourthly, it must also indicate locations of materials that have been identified as not containing asbestos i.e. as a result of sampling and analysis The information must be held in a suitable form that is easily understood and readily accessible by all relevant personnel and can be updated as required There are three types of surveys for identification of Asbestos Containing Material (ACM) detailed within the HSE guidance HSG264, Asbestos-the Survey Guide for the surveying, sampling and assessment of asbestos containing materials. These are the management survey, the Refurbishment survey and the Demolition survey. For all College premises a competent qualified surveyor will be employed to carry out these surveys A Management Survey is for the purpose of managing asbestos-containing materials during the normal occupation and use of premises A Management Survey aims to ensure that: Nobody is harmed by the continuing presence of asbestos containing materials in the premises or equipment; That the asbestos containing materials remain in good condition; and That nobody disturbs it accidentally The Survey must locate ACM that could be damaged or disturbed by normal activities, by foreseeable maintenance, or by installing new equipment. It involves minor intrusion and minor asbestos disturbance to make a Materials Assessment (which shows the ability of ACM, if disturbed, to release fibres into the air). It guides the client, for example in prioritising any remedial work The dutyholder must provide the surveyor with the site layout, building plans, building specifications or architect's drawings, and any history of asbestos work; point out site hazards, including means of safe access to heights and provide keys, etc The area should be vacated during the survey A Refurbishment Survey is required where the premises, or part of it, need upgrading or, refurbishment (See CAR reg 5) In addition to normally accessible ACM, there is likely to be ACM that are concealed in the fabric of the building and would not have been identified in a management survey. CAR Regulation 5 requires that an employer shall not undertake work in [demolition,] maintenance, or any other work which exposes or is liable to expose his employees to asbestos in respect of any premises unless he has carried out a suitable and sufficient assessment as to whether asbestos, what type of asbestos, contained in what material and in what condition is present or is liable to be present in those premises A refurbishment survey aims to ensure that: Nobody will be harmed by work on asbestos-containing materials in the premises or equipment; Where it is foreseeable that ACM is likely to be disturbed during the refurbishment or installation works, they can be safely removed from the work area as far as reasonably practicable prior to works. Such work will be done by the right contractor in the right way. SPR HSEPO Page 10 of 33

11 The survey must locate and identify all ACM before any work begins at a stated location or on stated equipment at the premises. It often involves destructive inspection and asbestos disturbance The dutyholder must provide the surveyor with the site layout, building plans, building specifications or architect's drawings, and any history of asbestos work; point out any site hazards, including means of safe access to heights and provide keys, etc The dutyholder must ensure that whenever possible there is an on-site pre-start meeting with the asbestos surveyor to agree the exact scope of the refurbishment or installation works and therefore the exact scope of the survey that will be required The area surveyed must be vacated during the survey and certified 'fit for reoccupation' after the survey Although different types of survey can be specified and used depending on the circumstances, it is important that the building owner, employer and the surveyor knows exactly which type of survey is to be carried out, what the specifications for each type are and in which areas they are to be used. The type of survey must conform to HSG264, otherwise interpretation of the survey reports will be difficult and the management plan produced may not adequately minimize the risks involved. It is possible that at larger premises a mixture of survey types will be appropriate e.g. a boiler house due for demolition will require a Refurbishment/demolition survey, while other parts of the premises require a Management Survey. Therefore it is important that there is a clear statement and record of the types of surveys that are to be carried out, including the reasons for the type selected, where they are to be carried out and an estimate of the number of samples to be collected A Demolition Survey is required where the premises, or part of it, are scheduled for demolition (see CAR reg. 5) In addition to normally accessible ACM, there is likely to be ACM that are concealed in the fabric of the building and would not have been identified in a management survey. CAR Regulation 5 requires that an employer shall not undertake work in demolition, [maintenance, or any other work] which exposes or is liable to expose his employees to asbestos in respect of any premises unless he has carried out a suitable and sufficient assessment as to whether asbestos, what type of asbestos, contained in what material and in what condition is present or is liable to be present in those premises A demolition survey aims to ensure that: No-one will be harmed by work on ACMs in the premises or equipment; All ACMs can be safely removed from the building as far as reasonably practicable prior to demolition. Such work will be done by the right contractor in the right way The dutyholder must provide the surveyor with the site layout, building plans, building specifications or architect's drawings, and any history of asbestos work; point out any site hazards, including means of safe access to heights and provide keys, etc The survey must locate and identify all ACM before any work begins at a stated location or on stated equipment at the premises. It often involves destructive inspection and asbestos disturbance The dutyholder must provide the surveyor with all know details of pre-existing structures or buildings previously demolished, underground ducts or shafts etc The dutyholder must ensure that whenever possible there is an on-site pre-start meeting with the asbestos surveyor to agree the exact scope of the demolition works and therefore the exact scope of the survey that will be required The dutyholder must ensure that whenever possible there is an on-site pre-start meeting with the asbestos surveyor to agree the exact scope of the refurbishment works and therefore the exact scope of the survey that will be required The area surveyed must be vacated during the survey and certified 'fit for reoccupation' after the survey Although different types of survey can be specified and used depending on the circumstances, it is important that the building owner, employer and the asbestos surveyor knows exactly which type of survey is to be carried out, what the specifications for each type are and in which areas they are to be used. The type of survey must conform to HSG264, otherwise interpretation of the survey reports will be difficult and the management plan produced may not adequately minimize the risks involved. It is possible that at larger premises a mixture of survey types will be appropriate e.g. a boiler house due for demolition will require a demolition survey, while other parts of the premises require a Management Survey. Therefore it is important that there is a clear statement and record of the types SPR HSEPO Page 11 of 33

12 of surveys that are to be carried out, including the reasons for the type selected, where they are to be carried out and an estimate of the number of samples to be collected. 4.2 SURVEYING AND BULK SAMPLING COMPETENCE Both management and refurbishment/demolition surveys require the removal of samples to identify whether asbestos is present in a material or not. The bulk sampling strategy should be agreed before the survey commences. HSG264 and HSG248 provide details on a suitable sampling strategy. The Health and Safety Executive strongly recommends the use of accredited or certificated surveyors for asbestos surveys which includes the collection of bulk samples Any laboratory to which bulk samples are sent for testing must be accredited by UKAS for the relevant testing method Checking whether an organisation has the appropriate training and experience can be done by finding out if it is approved by a recognised accreditation body as complying with the standard ISO plus ISO in order to undertake air monitoring, sampling and four-stage clearance ISO 9001 registration of an organisation gives assurance of quality systems that are managed effectively, although this requirement can also be demonstrated to have been met by ISO and ISO If an individual surveyor is to be appointed, checks can be done by finding out whether he or she has personnel certification for asbestos surveys from a certification body which has been approved by a recognised accreditation body under the standard ISO UKAS accredits organisations competent to survey and sample asbestos in buildings. The UKAS website can be used to find such organisations United Kingdom Accreditation Service, UKAS The National Individual Asbestos Certification Scheme (NIACS) also accredited individuals but this scheme is no longer running. A former scheme ABICS (Asbestos Builders Inspection Certification Scheme), was discontinued in October 2010 and is no longer available. However, surveyors who can demonstrate that they have successfully completed all of the three assessment stages of the ABICS scheme can legitimately rely on this as evidence that they are competent to carry out asbestos surveys Analytical laboratories must hold Category 1 laboratory status in the Regular Interlaboratory Counting Exchanges (RICE) scheme and have a satisfactory performance in the Asbestos In Materials Scheme (AIMS) scheme In addition it is vital that dutyholder obtains evidence the inspection body or individual surveyor has satisfactory knowledge and experience of the type of building that is subject to survey HSG264 "Asbestos: The Survey Guide" places a great emphasis on the competence of surveyors and guide Dutyholders to use either a company accredited by UKAS or an ABICS certified surveyor. 4.3 ASBESTOS REGISTER The asbestos register forms an up to date record of all ACMs within any given location or property within the College s Estate. Where ACMs have been removed details of the removal shall be clearly recorded. The register should also contain information about materials that are suspected or presumed to contain asbestos but that have not been accessed or sampled for confirmatory analysis. Any areas or items not accessed must also be recorded and presumed to contain asbestos unless there is strong evidence to prove otherwise The survey results will be transposed onto an electronic database and managed as an Online service. The Compliance Co-ordinator or Approved consultant will update the register based on investigation and remedial works carried out and the production of the associated certificates Unless otherwise stated, the asbestos register only contains those ACM that are reasonably accessible and does not include ACM that may be hidden within the fabric of the building or in inaccessible areas. SPR HSEPO Page 12 of 33

13 4.4 AUDITING OF THE ASBESTOS REGISTER Regular audits will be undertaken to ensure the register is kept up to date. The audit will comprise a walk through visual re-inspection by either the Compliance Co-ordinator, or other nominated, suitably trained, competent personnel on site or by the approved consultant using the form F065, or equivalent. The audit frequency will depend on the type and condition of the ACMs but will not be less than an annual inspection The Compliance Co-ordinator will ensure that the register indicates the audit frequency. The audit frequency will be agreed between the Compliance Co-ordinator, Director of Facilities Management and College Safety Officers of the HSEPO. 4.5 MATERIAL ASSESSMENT The material assessment is an assessment of the condition of the ACM, or the presumed ACM and the likelihood of its releasing fibres in the event of it being disturbed in some way. This material assessment will give a good initial guide to the priority for management, as it will identify the materials that will most readily release airborne fibres if disturbed. However, there are other factors to take into account when prioritising action. These factors are considered in the priority assessment HSG264 (Asbestos: The Survey Guide) recommends the use of an algorithm to carry out the material assessment and contains an example. The algorithm is a numerical way of taking into account several influencing factors, giving each factor considered a score. These scores can then be totalled to give a material assessment score. The use of algorithms is not infallible, but the assessment process is clear for all to see, so if discrepancies arise, it is possible to track back through the assessment process to find the root of the error. Refer to table 2 in HSG PRIORITY ASSESSMENT The material assessment (above) identifies the high-risk materials, i.e. those that will most readily release airborne fibres if disturbed. It does not automatically follow that those materials assigned the highest score in the material assessment will be materials that should be given priority for remedial action. Management priority must be determined by carrying out a risk assessment that will take into account factors such as: Maintenance activity; Occupant activity; Likelihood of disturbance; Human exposure potential; Again these factors can be placed in an algorithm whereby scores are averaged for each factor and then totalled. Refer to table 3 in HSG COMBINED RISK ASSESSMENT The risk assessment for an ACM is the total of the two figures determined by the material assessment and the priority assessment. The algorithm score leading to a possible maximum score of The material assessment looks at the type and condition of the ACM and the ease with which it will release fibres The priority assessment looks at the likelihood of someone disturbing the ACM The risk assessment can only be carried out with detailed knowledge of the above. Although a surveyor may have some of the information which will contribute to the risk assessment and may be part of an assessment team the dutyholders under CAR are required to make the risk assessment, using the information given in the survey report and their detailed knowledge of the activities carried out within the premises. The risk assessment will form the basis of the management plan, so it is important that it is accurate Decisions on the actions deemed necessary will be assisted by the results from the risk assessment that is the combination of the material assessment and the priority assessment as outlined above. These scores can be broken down into categories with actions appropriate to each category detailed. The College scoring is as follows: SPR HSEPO Page 13 of 33

14 Scale of Risk High High Medium Low Very Low HIGH RISK MATERIAL REQUIRING URGENT ATTENTION = Score 18 or more The potential hazard arising from this category warrants urgent attention. Immediate plans for consultation with the Asbestos Consultant and the Compliance Team should be made for the remediation of the asbestos containing material, appropriate action to be agreed according to location and condition. The option chosen for remediation will follow the hierarchy of control. In most cases it shall be necessary to prevent access or occupation until remediation has been agreed and completed. MEDIUM RISK MATERIAL REQUIRING PROGRAMMED REMOVAL WITHIN A SPECIFIED TIMESCALE/INSPECTION = Score 14 to 17 This category indicates that deterioration in any of the contributory factors may result in asbestos fibre release. Therefore all asbestos, within this category, would typically warrant remediation on a programmed basis usually within a specified time scale, appropriate action to be agreed with the Compliance Team according to location and condition. The option chosen for remediation will follow the hierarchy of control. LOW RISK MATERIAL REQUIRING REGULAR INSPECTION/REMOVAL AS PART OF REFURBISHMENT AND DEMOLITION PROJECTS = Score 9 to 13 This category indicates the need for regular monitoring as situations within this category do not pose an imminent risk to health and likelihood of fibre release is low under existing conditions but, this risk may rapidly alter should any number of factors contribute to the materials deterioration. It is recommended that ACMs falling into this category is visually inspected on an annual basis to ascertain any change in condition and if any does, it can be promptly subject to control actions to prevent and increase in exposure and uncontrolled fibre release and a reclassification to the above category. Approved warning labels (A Labels) should be positioned to help to prevent accidental damage to the material. Any remedial action identified through reclassification to a higher category is to be agreed with the Compliance Team according to location and condition. The option chosen for remediation will follow the hierarchy of control. VERY LOW RISK MATERIAL REQUIRING ANNUAL INSPECTION/REMOVAL AS PART OF REFURBISHMENT AND DEMOLITION PROJECTS = Score less than or equal to 8 This category indicates low priority. ACMs within this category should be subject to annual visual inspection to ascertain any change in condition or when usage of the area changes. Where such a change occurs, prioritisation to a higher risk category may be necessary. Approved warning labels (A Labels) should be positioned to help to prevent accidental damage to the material. NONE 0 points No action necessary SPR HSEPO Page 14 of 33

15 5 ASBESTOS MANAGEMENT 5.1 INTRODUCTION This asbestos management plan for ACMs within the College Estate will identify steps needed to be taken to ensure the continued safe occupation and operation of premises The general principles of the asbestos management strategy at King s are as follows: SPR HSEPO Page 15 of 33

16 5.1.3 For all ACMs identified there will need to be a series of Management Actions to be undertaken, it may also be necessary to subject some of the ACMs to Control Actions to restrict the spread of and exposure t o, asbestos fibres. 5.2 MANAGEMENT ACTIONS The management of existing asbestos is important to ensure asbestos materials are not damaged or deteriorate to such an extent that College staff and students, external contractors or visitors are unnecessarily exposed to airborne asbestos fibres. The requirements of the contractor site induction and permit to work system (refer section) will aid in the management of existing asbestos materials. It is also the policy of the King s College London to incorporate asbestos issues into building works contracts, designed to ensure any asbestos on, or in, King s College London premises is dealt with in the appropriate manner. Asbestos removal may not be immediately necessary or possible, but must be completed before a structure or part of a structure is demolished Monitor the condition of ACMs: ACMs that are in good condition, sealed and/or repaired and are likely to be undisturbed will initially be left in place until such time as its long term future is decided. Leaving such ACMs in place and provided the matrix remains stable and no airborne dust is produced, presents a very low health risk. The condition of these ACMs will be monitored regularly and the results recorded. When the condition of the ACM starts to deteriorate, remedial action will be taken. The time period between monitoring will vary depending on the type of ACM and the risk assessment, its location and the activities in the area concerned. HSE recommends that even low risk ACM are monitored at least annually. Monitoring involves a visual inspection, looking for signs of disturbance or deterioration, scratches, broken edges, cracked or peeling paint and debris. Where deterioration has occurred, a recommendation on the remedial action to be taken will be made. This may be a case of resealing the surface of the ACM, but if there is evidence that the ACM is vulnerable to disturbance on a frequent basis a decision will be made on whether to remove it or at least protect it by putting up a suitable barrier after clearance of any visible debris Labelling and colour coding of ACMs The College has implemented a system of labelling throughout King s College London premises, to clearly identify and provide warning of the presence of asbestos containing materials. Labels must comply with CAR 2012 (note particular reference to Schedule 2) and/or BS5378 and Health and Safety (Safety Signs and Signals) Regulations Labels for internal usage must be waterproof and self-adhesive. Weatherproof signage constructed from rigid, hardwearing materials, such as sheet metal, may be required for outdoor applications (e.g. warning signage fixed on, or near, brittle corrugated asbestos cement roof cladding). Alternatively, a spray paint template, including black text on an orange background, may be used where appropriate King s College London will install self-adhesive labels, or other clear signage, in prominent positions on, or near, asbestos containing materials located in non-public areas, where maintenance personnel may operate from time to time. Such areas would typically include plant rooms, ceiling spaces, service ducts and the like. The purpose of such labelling is to immediately bring to the attention of such personnel the presence of asbestos, to avoid the inadvertent mechanical disturbance of the material In the public areas of College premises, frequented by academic and administrative staff, students and visitors, it is not intended to install labels with cautionary text. Such areas would include administrative and academic offices, teaching areas and public thoroughfares Asbestos materials installed and accessible in public areas may be highlighted at the College's discretion, using a colour coded labelling system with no cautionary text. The reasoning behind such a system is to alert relevant personnel (e.g. Maintenance staff and contractors) to the presence of asbestos in public places, while avoiding the emotive issues that may arise by installing labels with an asbestos warning text. The College may also require the clear labelling of asbestos materials present in public areas prior to the commencement of refurbishment or demolition work in these areas. This is to ensure such materials are immediately recognised and not damaged during the works, or are removed under appropriate controlled conditions in accordance with all legislative requirements. (Refer to Estates Standard Operating Procedure for Asbestos Management) Labelling and colour coding alone will not be relied on as control measures in themselves. They may become dirty, obscured or fall off and therefore will only be used as a back-up measure. Good lines of communication between managers of the asbestos management system, workers and contractors must be maintained so that they have good, accurate information about ACMs on the premises Once labelling is undertaken the labels themselves will be managed, which will include re-inspection and re-labelling as necessary where labels are removed, obscured or painted over etc. This can be managed during monitoring or re-inspection of ACMs. SPR HSEPO Page 16 of 33

17 5.3 CONTROL ACTIONS Leave in place (defer action): The identification of asbestos in a building does not automatically necessitate its immediate removal. Asbestos in a stable condition and not prone to mechanical damage can generally remain in place. The asbestos will need to be inspected on a regular basis (depending on risk and in meeting the requirements of the ACOP) to ensure its integrity is maintained, should be labelled with an appropriate warning, and must be removed under controlled conditions prior to demolition or refurbishment works that may disturb the asbestos Encapsulation or Sealing: Encapsulation refers to the coating of the outer surface of the asbestos material by the application of some form of sealant compound that usually penetrate to the substrate and harden the material. Sealing is the process of covering the surface of the material with a protective coating impermeable to asbestos. Encapsulation or sealing helps protect the asbestos from mechanical damage, and is designed to reduce the risk of exposure by inhibiting the release of asbestos fibres into the airborne environment, and increase the length of serviceability of the product The use of encapsulation or sealing may be of limited application. It is not considered to be an acceptable alternative to repairing or removing severely damaged asbestos materials Enclosure involves installing a barrier between the asbestos material and adjacent areas. This is effective in inhibiting further mechanical damage to the asbestos and friable products such as calcium silicate pipe lagging or sprayed asbestos may be targeted for enclosure where removal is not an option. The type of barrier installed may include plywood or sheet metal products, constructed as an enclosure around the asbestos. If barriers are installed they must be on a monitoring regime and categorised as either permanent or temporary. Temporary barriers must be inspected weekly and must only be installed for a maximum of six months Removal of asbestos must be performed under appropriate controlled conditions, depending on the type of asbestos product to be removed. Removal is considered preferable to the other abatement options such as enclosure or encapsulation, as it eliminates the hazard from the work place. The removal process, however, does pose an increased risk to personnel engaged in the removal, and may result in increased airborne fibre levels in adjacent occupied areas if the removal program is not strictly controlled. Asbestos removal is generally an expensive exercise, and can cause major disruptions to building occupants The removal of asbestos is considered appropriate when the asbestos product is deteriorated, has reached an unserviceable condition, or is at risk of being disturbed, and the other control options are not feasible. Where demolition or refurbishment works are to occur, and this work is likely to impact on asbestos materials, the asbestos must be removed under controlled conditions prior to the commencement of any site works An asbestos project review form (F062) must be completed prior to any planned refurbishment or demolition works taking place. It is the responsibility of the Project Manager for the works to ensure that the form is completed and forwarded to the Compliance Co-ordinator as soon as the works are planned Such works will generally have to be undertaken by licensed asbestos removal contractors, unless the asbestos is firmly linked to the matrix and an assessment by a competent person concludes the Control Limit or Short Term Exposure Limit will not be exceeded and the works are exempt from the licensing requirements of the CAR. An example is asbestos cement sheeting; if this is removed outdoors it is likely to be exempt, but if removed indoors the STEL is likely to be exceeded. All of these works will be subject to other legislation such as the Hazardous Waste Regulations Table 1 provides a summary of the relative advantages and disadvantages of each control method, as well as situations in which each may be considered appropriate Work with asbestos containing materials shall be carried out according to methods described in HSE task guidance sheets (e.g. Asbestos Essentials) or equivalent UKAS protocols carried out by licensed contractors Procedures in the event of exposure to unidentified or damaged asbestos to be adhered to in the event of any asbestos or suspected asbestos materials being disturbed are contained in section 10. SPR HSEPO Page 17 of 33

18 5.4 IMPLEMENTATION TIMETABLE Where materials are identified that require any of the above actions, these will be timetabled for action according to their risk assessment. These actions will be subject to regular review. 5.5 ASBESTOS MANAGEMENT PROCEDURES The flow charts in Appendices A to C outline College Management Procedures for Planned Maintenance, Project works and Out of Hours/Emergency situations. Forms as identified in section 1.3 shall be used as appropriate. 5.6 PROJECT MANAGEMENT FOR ALL CONSTRUCTION WORKS INCLUDING EMBEDDED SPACES All Project Managers involved in construction works must review the works with regard to the possible presence of asbestos; control of the works to ensure appropriate measures are taken to avoid damage or exposure; necessary remedial or removal works (based on the ultimate long term aim of asbestos safe working environment) and the impact of any remedial asbestos works on the project programme. Project Managers must seek assistance from the Compliance Co-ordinator regarding the Asbestos Register and involvement of the Asbestos Consultant, or other competent person at the earliest planning stages of a project. Project Managers must include information on the presence or otherwise of asbestos in pre-construction information as required by CDM All refurbishment projects including those in embedded spaces must undergo the above review which will, unless agreed with the College s competent person and recorded in writing; include a refurbishment or demolition survey (equivalent to the old type 3 survey). The only variation with embedded space will be that the Trust s registers are reviewed instead of the College s register. 5.7 PERMIT TO WORK If it is determined after consulting the asbestos register and the production of Risk Assessments and Method Statements, from a Contractor, that asbestos materials are present in the vicinity of the planned works and are likely to be disturbed in the course of such works a competent asbestos consultant will be required to oversee such works and a Permit to Work will need to be issued Permit to work authorisations will only be issued by King s College London Estates Department, or the person authorised to act on behalf of the King s College London Estates Department Before being issued with a permit to work, individuals will be required to read and understand the AMP as well as copies of relevant asbestos registers Where practicable, project personnel should be made aware of the requirements of the AMP prior to tendering to ensure they allow for such requirements when quoting Workers engaged in the removal or disturbance of ACM where it is reasonably foreseeable that the Control Limit or the Short Term Exposure Limit will be exceeded will only be issued with a Permit to Work if they are an Approved Licensed Asbestos Contractor. The assessment of potential exposure must be carried out and recorded by a competent person The permit to work is designed to ensure appropriate work practices are employed in the vicinity of asbestos containing materials. The permit to work will document what asbestos materials are to be removed, encapsulated or otherwise protected, prior to the contracted maintenance or building works proceeding. The permit to work will also indicate other requirements such as the need for personal protective equipment (PPE), barricading and airborne fibre monitoring When work is completed, or the permit to work expires (whichever occurs first), the permit shall be signed and returned to King s College London Estates Department who will cancel it after ensuring that a safe in situation exists King s College London Estates Department will maintain a register of all permits to work, which have been issued and cancelled. SPR HSEPO Page 18 of 33

19 TABLE 1: DETERMINATION OF APPROPRIATE CONTROL METHOD FOR ASBESTOS APPROPRIATE WHEN DEFER NOT APPROPRIATE WHEN ADVANTAGES DISADVANTAGES Negligible risk of exposure and Asbestos inaccessible and fully contained or Asbestos stable and not liable to damage Possibility of deterioration or damage Airborne asbestos dust exceeds recommended exposure standard No initial cost Cost of removal deferred Hazard remains Need for continuing assessment Asbestos management programme required ENCAPSULATE OR SEAL Removal difficult or not feasible Firm bond to substrate Damage unlikely Short life of structure Readily visible for regular assessment Asbestos deteriorating Application of sealant may cause damage to material Water damage likely Large areas of damaged asbestos Quick and economical for repairs to damaged areas May be an adequate technique to control release of asbestos dust Hazard remains Cost for large areas may be near removal cost Asbestos management system required Eventual removal may be more difficult and costly ENCLOSURE Removal extremely difficult Fibres can be completely contained within enclosure Most of surface already inaccessible Disturbance to, or entry into, enclosure area not likely Enclosure itself liable to damage Water damage likely Asbestos material cannot be fully enclosed May minimise disturbance to occupants Provides an adequate method of control for some in situations Hazard remains Continuing maintenance of enclosure Asbestos management programme required Need to remove enclosure before eventual removal of asbestos SPR HSEPO Page 19 of 33

20 6 MONITORING AND REVIEW 6.1 RE-INSPECTIONS Monitoring through re-inspections of asbestos materials remaining on site is to be conducted by a suitably qualified and competent person. Such re-inspections will comprise a visual assessment of the condition of the materials to determine whether the material remains in a satisfactory condition, or if deterioration has occurred since the previous inspection. Such re-inspections will determine if any remedial action, such as encapsulation, isolation or removal of the asbestos materials, is required. Re-inspections will be performed depending on risk assessment but no longer than a year Normally, re-sampling of materials would not be required during re-inspections. If, however, previously unidentified or undocumented asbestos, or materials suspected of containing asbestos, are encountered during the re-inspection process, sampling and analysis will need to be performed. The asbestos register, where necessary, will be updated and re-issued at the completion of the reinspection work. 6.2 RECORD KEEPING King s College London Estates Department shall maintain detailed records of all activities and work permits relating to asbestos works, which have been undertaken within and on King s College London premises. The records kept shall include: Records marked with a ( *) must be retained for a minimum of 40 years copies of all asbestos survey reports, including updates and amendments;* copies of all 'permit to work' documents; site induction records pertaining to the informing of contractors about the presence of asbestos on site, and that such contractors have been appropriately trained in safe work procedures and practices; Records pertaining to the informing of King s College London employees about the presence of asbestos on site, and that such employees have been appropriately trained in safe work procedures and practices; Records of any asbestos abatement works performed on site; * Clearance certificates indicating areas are safe to reoccupy after asbestos abatement works;* Asbestos fibre air monitoring results.* Records of management plan reviews. Face-fit test records for Respiratory Protective Equipment.* Accident and near miss records will be maintained by the HSEP Office Occupational Health surveillance for King s College personnel who carry out reinspections and other specifically defined works, through agreement with the Compliance Team, HSEPO and Occupational Health will be maintained for a minimum of 40 years by Occupational Health It is also the policy of the King s College London to incorporate asbestos issues into building works contracts, designed to ensure any asbestos on, or in, King s College London premises is dealt with in the appropriate manner. 6.3 REVIEW It is required that the asbestos register is updated every time control actions undertaken. This will necessitate the use of the Asbestos consultant, or other competent persons and the material assessment or priority assessment may differ following management actions. All the supporting documentation for control actions should be kept with the asbestos register, or at the very least, the location of supporting documentation be cross-referenced within the register An inspection register to complement the asbestos register should also be kept to ensure materials are reinspected at the appropriate frequency (at least annually) Audits of reinspection reports and the maintenance of the asbestos register will be undertaken at random intervals by the Building and Contracts Safety Officer and/or the Health, Safety and Environmental Protection Office. The register and procedures will be subject to an annual review to take into account changes in legislation, codes of practice and also experience within the Estate over the previous twelve months again by the Health, Safety and Environmental Protection Office and/or the Building and Contracts Safety Officer The Asbestos management plan will additionally be subject to review at periods not exceeding twelve months or when there is a change in asbestos management staff, changes in legislation or SPR HSEPO Page 20 of 33

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