Summary of the main steps in managing asbestos (from HSG264) Find out if ACMs present: Check plans/ drawings. Carry out survey (2)

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1 Asbestos The University s asbestos management procedure follows the stages set out in guidance provided by the HSE (HSG64), as follows. (The numbers in the boxes below refer to the subsequent sections of the procedure.) Summary of the main steps in managing asbestos (from HSG64) Appoint person to manage asbestos () Record No Find out if ACMs present: Check plans/ drawings. Carry out survey () Record: Asbestos register plan/ drawing. Yes No further action RECORD: Prepare asbestos register () Carry out risk assessment () Are ACMs liable to be disturbed? Who can be exposed? Prioritise Monitor (5) ACMs in good condition Prepare management plan (4) Damaged ACMs Repair/remove (4) Maintenance work Manage (5-8) Train staff Manage contractors Check all work against plan/register Control of work itself: - Asbestos essentials - Compliance with CAR. Appointment of Person to Manage The University has nominated the role of Appointed Person Asbestos to carry out this function, as detailed in Section 4 of the accompanying Roles and Responsibilities document.. Identification of Asbestos Containing Materials in Buildings As asbestos was not completely banned until 999, where a property was built before it must be presumed that ACM s are present unless an asbestos survey Page of 7

2 confirms otherwise. Where a property was built post then it can be assumed that there are no ACMs in a building.. Asbestos Surveys Asbestos surveys are one of two types; management surveys or refurbishment or demolition surveys. Surveys at SSU are carried out by UKAS accredited asbestos survey contractors with appropriate qualifications and experience. Current surveys and re-inspections are carried out to standards set by HSE s guidance document HSG64 Asbestos: The Survey Guide. The University Asbestos Register is largely based on surveys conducted to the standards previously recommended by the HSE Types, and (see definitions section). Management surveys In buildings where SSU is the duty holder, SSU takes reasonable steps to establish if there are materials containing asbestos in its buildings by undertaking asbestos management surveys (previously referred to as Type Surveys) of those buildings. The purpose of the survey is to identify the location of ACMs, the amounts present and its condition. This information is then used to carry out a risk assessment to evaluate the likelihood of asbestos release and the likelihood of human exposure. The risk assessment forms the basis on the. Refurbishment or Demolition Survey Refurbishment or demolition surveys (previously referred to as Type Surveys) are undertaken prior to demolition works or refurbishment works that are likely to penetrate the fabric of a building or its services. This type of survey is used to locate as far as is reasonably practicable, all ACMs in a building and will involve intrusive/destructive inspection where necessary to gain access to all areas. A full sampling programme is undertaken to identify the type and proportion of asbestos present in the building materials being surveyed. For a refurbishment or demolition survey to be carried out an area must be unoccupied and fully accessible to the surveyor, with furnishings and equipment removed. Areas where SSU is not the primary duty holder In buildings where SSU is not the primary duty holder, the Appointed Person Asbestos will confirm that any ACMs left in place present no risk to building users. This will be achieved by confirming that the building duty holder has undertaken appropriate asbestos surveys to identify the presence and condition of ACMs, has compiled this information into an asbestos register, and has a programme of reinspection to monitor the condition of any ACMs left in place.. Recording the presence of Asbestos Containing Materials in Buildings the Asbestos Register & Associated Risk Assessment of ACMs Page of 7

3 The current SSU Asbestos Register was formulated in. It is not a single document, but is made up of the following, on a building by building basis, and associated documentation (e.g. survey reports, clean air certificates etc); an Excel Spread sheet recording survey findings on a room by room basis. The spread sheet also includes the risk assessment for any ACMs identified, together with the surveyor s recommendation actions, marked up floor plans showing locations and types of asbestos present. The information is stored electronically on the Campus Service S Drive. The ACM risk assessments in the Register are based on a material/priority score and algorithm which is compatible with, but not the same as, that recommended in HSE Guidance document HSG7 A comprehensive guide to managing asbestos in premises. The risk assessment protocol for ACMs is explained in detail in Annex. The Asbestos Register will be reviewed regularly, in line with the risk assessment in the asbestos register, and updated by the Appointed Person Asbestos as soon as possible in the event of any of the following; physical alterations of the University Estate, as advised by Project Managers etc, asbestos removal, asbestos encapsulation and environmental cleaning works. The Asbestos Register will also be updated by the Appointed Person Asbestos following routine monitoring/re-inspection checks, see Section 5. When asbestos removal or encapsulation works take place, the Appointed Person Asbestos will be provided with documentation from the asbestos removal/treatment company to confirm the removal has taken place; this may include a waste consignment note, area clearance notification and air monitoring records. 4. Management of Asbestos The risks identified as a result of asbestos surveys and subsequent risk assessment must be managed. In order for effective management of the risk, there must be central control or oversight of all work that has the potential to affect the fabric of any University building and/or a building s utilities and services, including the IT and telecommunications infrastructures. This will be achieved by requiring all such works to be carried out either under the direction of, or with the prior approval of, the Estates and Facilities Service. The scope of works includes running of cables etc, as well as drilling into building structures, e.g. to fix shelving. This requirement for central control or oversight applies even where it is known that there are no ACMs present (e.g. in buildings constructed post ) as there are other associated risks, e.g. to fire compartmentation. Page of 7

4 Schools or Services wishing to have works carried out that have the potential to affect a building s fabric and/or service infrastructures, thereby potentially disturbing any ACMs present, must consult Estates and Facilities in advance (see Sections 5 & 6 of Roles and Responsibilities ). The Appointed Person Asbestos must be consulted prior to any proposed work by, or on behalf of, Schools and Services in order that the Asbestos Register can be checked and appropriate working practices agreed and put in place. Works involving the treatment, encapsulation or removal of ACMs will be undertaken by University approved HSE licensed contractors. All work with ACMs will be carried out in accordance with HSE advice on best practice, see and associated web pages. SSU has the following management options; 4. Removal In accordance with the specific requirement under the Control of Asbestos Regulations,, Regulation 7, all ACMs will be removed, as far as reasonably practicable, before major refurbishment or final demolition (see HSG 64, para 5). SSU has the right to restrict access to an area should ACMs be identified that are high risk. The area will be restricted until remedial works can be undertaken to make the area safe. Arrangements for the removal of ACMs must be agreed by the Appointed Person Asbestos and the Project Manager with responsibility for the works involved. The Appointed Person Asbestos must review and approve the Safe System of Work before work commences on site. The removal of ACMs must be considered a high risk operation that can only be carried out by a licensed and UKAS accredited asbestos contractor. The ACM removal works must be managed by the Appointed Person Asbestos or an appointed competent person. Time must be allowed for the planning and removal stages of the works and must take account of: Agreement on the scope of the works; Contractors quotation, agreement of costing, production of a Plan of Work and assessment of method statement; Statutory HSE notification period (4 days ); Vacation of the work area (departmental staff, furniture and equipment); Isolation of services as required for safe working; Arrangements and services for the contractor: parking, area for decontamination unit, supply of water and power, security arrangements, method of waste removal etc; Liaison and provision of information for departments affected by the works. 4. Encapsulation or seal Page 4 of 7

5 Where a management survey identifies asbestos in Categories C & D (see Annex ) or Low or Very Low (in accordance with HSG64), ACMs can be left in place but must be sealed or encapsulated to contain and reduce the risk of airborne asbestos fibres being generated. Arrangements for the encapsulation of ACM must be agreed with the Appointed Person Asbestos or an appointed competent person, who will make the arrangements for the work and liaise with the departments involved. 4. Labelling of ACMs ACMs will not be labelled in public areas such as corridors, classrooms and offices. Where it is reasonable to label ACMs in other areas such as plant rooms, standard HSE warning labels or their equivalent will be used to identify ACMs that are at risk of being disturbed. 4.4 Control of Waste Asbestos During and on completion of asbestos removal and environmental cleaning works, ACMs shall be double bagged/wrapped as the waste is produced. Bags shall be sealed, labelled and cleaned prior to removal from the asbestos enclosure. Bags containing asbestos waste shall be transported along an agreed route for immediate removal from site, or safe storage within a lockable container located in an agreed position on site. Asbestos waste material such as asbestos cement and bitumen products generated from non-licensed works shall be double bagged/wrapped and stored in a secure lockable location where damage cannot occur. Final removal and disposal of these items shall be arranged via licensed asbestos removal contractor. All asbestos waste shall be disposed of strictly at a site licensed to receive it all in accordance with the Hazardous Waste (England and Wales) Regulations 5. The Contractor responsible for disposal of asbestos waste shall provide the University with documentary evidence of safe disposal via copies of consignment notes. 4.5 Non-Removal of Asbestos during Building Work Where a decision is taken by the University not to remove known ACMs during building work that might affect adjacent AMCs, the Appointed Person Asbestos must be consulted and appropriate precautionary measures put in place. These will include: Information regarding ACMs shall be made available to the Contractor prior to the commencement of works. The Contractor shall provide details of the measures to be taken in order to protect ACMs from damage/disturbance during the works. Page 5 of 7

6 Routine airborne monitoring of the working area may be requested as reassurance that the work is not disturbing ACMs. Limitation of access controls must be put in place. Limitation of extent of works controls must be put in place. 4.6 Airborne Monitoring An independent analytical company UKAS accredited to ISO75 (or equivalent) shall be employed to carry out all airborne monitoring work on behalf of the University. For maximum transparency, independent analysts should be appointed directly by the University and not by a contractor appointed to carry out other asbestos work, e.g. removal. Clearance Testing All available information from the University s Asbestos Register (applicable to areas concerned) shall be made available to the independent analyst prior to commencing these works. Clearance testing involving disturbance of the relevant areas must be carried out on the satisfactory completion of all work affecting ACMs. Surface swabs may also be taken. The analyst will produce a report for the Appointed Person Asbestos to will allow the University s Asbestos Register to be updated. Reassurance Monitoring Airborne monitoring shall be carried out in areas considered sensitive, or in situations where it is considered there is a need to reassure staff or students, to provide independent documentary evidence that no leakage of asbestos has occurred. Reassurance monitoring shall be carried out at the discretion of the Appointed Person Asbestos. 5. Routine Monitoring of ACMs ACMs that are in good condition can safely be left in-situ and monitored. The Asbestos Register specifies the time interval for re-inspection, which should be no greater than years. The Appointed Person Asbestos is responsible for ensuring that there is a published programme of re-inspection based on the Asbestos Register, and that re-inspections are carried out by a competent person in accordance with this programme. The Register will be updated within 4 weeks of re-inspection, with all necessary alterations made to drawings, data and risk assessment. 6. Information, Instruction & Training SSU has a duty to provide information on the location and condition of ACMs to anyone who is liable to work on or disturb them. This duty is discharged primarily by the central control or oversight of any work with the potential to affect ACMs (Section 4). In addition to this, the following steps are taken to inform, instruct and train staff in asbestos awareness; Page 6 of 7

7 The electronic Register is available to SSU members of staff with appropriate access rights. The Register and all other associated information and drawings are available to Estates & Facilities team members via the Appointed Person Asbestos and the Campus Service S Drive. Asbestos Training Courses The Appointed Person Asbestos will arrange a suitable training course for staff with responsibilities for projects or works that may disturb ACMs within the building fabric. All Estates project officers and others who may undertake works which disturb asbestos must attend the course and attend a refresher course once a year, as recommended by the HSE ( Asbestos Essentials, EM ). Controlling building maintenance activities all IJOs issued to building maintenance contractors have a reminder to check the Asbestos Register before commencing work. The Appointed Person Asbestos will supply information from the Asbestos Register to contractors and consultants with the agreement of the appropriate Estates and Facilities Project Officer. For large refurbishment projects information about ACMs must be supplied as part of the pre-tender information pack and to the Principal Contractor as part of the pre-contract health and safety information. General enquiries about asbestos in the University should be directed in the first instance to the Estates Services Help Desk on ext Emergency Procedure Where there has been unintended damage to known ACMs, or where damaged materials that could contain asbestos are discovered, the following action should be taken.. STOP THE WORK IMMEDIATELY.. Windows and doors should be closed if it is possible to do so without further disturbance to the damaged material and additional risk of inhalation of fibres.. ALL PERSONS SHOULD LEAVE THE AREA. 4. POST AN OUT OF BOUNDS NOTICE, SEAL UP DOORWAYS USING TAPE. 5. REPORT TO ONE OF THE FOLLOWING: a. Estates Helpdesk, extn. 7 b. Estates Appointed Person Asbestos c. Estates Project Officer d. Estates Facilities Team Page 7 of 7

8 6. THE AREA MUST REMAIN UNOCCUPIED UNTIL INVESTIGATION BY THE APPOINTED PERSON ASBESTOS OR A COMPETENT PERSON. 7. The Appointed Person Asbestos or the competent person attending will assess the situation and make suitable arrangements. This may involve air monitoring, sampling and analysis of the suspect material or arrangements for the removal of the material and a clean of the area. Suspect contaminated areas must remain out of bounds until cleared by the Appointed Person Asbestos or the competent person attending. In a situation where a SSU competent person is unavailable a licensed asbestos contractor should be contacted to attend and manage the situation. A more detailed version of the Emergency Procedure is provided in Annex, taken from the HSE s Asbestos Essentials, EM. 8. Incident Reporting If it is found or suspected that persons have been exposed to airborne asbestos fibre (normally taken to mean a level that exceeds. fibres per ml of air) the Appointed Person Asbestos should be notified immediately. The Appointed Person Asbestos will conduct an investigation of the incident, and review the asbestos management plan. The normal University Accident, Near Miss and first aid report form must be completed and sent to the Health and Safety Team. Where exposure occurs in an area under the control of a Principal Contractor the reporting will be the contractor s responsibility. Following the investigation the Appointed Person Asbestos will supply the Health and Safety Team with additional information for the incident report that will include the nature of the exposure, the type of asbestos material/fibre content and copies of any analytical or air test records. The Health and Safety Team will assess the requirements to report under the RIDDOR regulations (see Annex ). Where it is suspected that University staff or students may have been exposed to asbestos fibres they may be referred to Solent Health Services (Occupational Health) for advice about possible health risks and actions that may be required. A report of the possible exposure will be provided by the Health and Safety Team to HR for insertion into the relevant staff personnel files. This record needs to be kept for 4 years. The following guidance, taken from HSE s webpages on Asbestos ( frequently asked questions ), is also provided to individuals who may have been exposed to asbestos. People who believe they may have been exposed to asbestos are understandably anxious and concerned about the possible effects on their health. Many cases of inadvertent, short-term exposure to asbestos will most likely have led to minimal exposure to fibres, with little likelihood of any long-term ill health effects. If you are concerned about possible exposure to asbestos from work activities, you are advised to consult your GP and ask for a note to be made in your personal record about possible exposure, including date(s), duration, type of asbestos and likely exposure levels (if known). In some Page 8 of 7

9 circumstances, your GP may refer you to a specialist in respiratory medicine. HSE does not advocate routine X-rays for people who have had an inadvertent exposure to asbestos. Asbestos-related damage to the lungs takes years to develop and become visible on chest X-rays. X-ray examinations cannot indicate whether or not asbestos fibres have been inhaled. Page 9 of 7

10 Annex Risk Assessment Rating of ACMs Note that this Annex includes, for comparative purposes, the risk rating used in the current University Risk Register, followed by the scheme recommended by the HSE in its guidance HSG7.. Current Risk Rating scheme In the current University Asbestos Register, the risk assessment rating of ACMs in buildings is based on a Material Assessment, which is scored by the surveyor, and a Management Assessment, which is scored by the University as the Duty Holder, as described below. A Material Assessment which has the following 4 components; Product type, Condition, Surface treatment, and Asbestos type; and is scored as shown. Product type: Score: Thermal insulation (e.g. pipe and boiler lagging), sprayed asbestos, loose asbestos, asbestos mattress and packing. Asbestos insulation boards, mill boards, other low density insulation boards, asbestos textiles, gaskets, ropes and woven textiles, asbestos paper and felt. Asbestos cement product. Asbestos reinforced composites (plastics, resins, mastics, roofing felts, vinyl floor tiles, semi-rigid paints, textured coatings, etc). 4 Condition: Score: Delamination of materials, sprays and thermal insulation. Visible asbestos debris. 4 Significant breakage of materials or several small areas where material has been damaged revealing loose asbestos fibres. A few scratches or surface marks, broken edges on boards, tiles, etc. No visible damage. Surface treatment: Score: Unsealed lagging and sprays. 4 Unsealed AIB or encapsulated lagging and sprays. Unsealed asbestos cement. Enclosed sprays and lagging, AIB and cement (with exposed face painted or encapsulated), asbestos cement sheets, etc. Page of 7

11 Composite materials containing asbestos: reinforced plastics, resins, vinyl tiles, text. coatings, etc. Asbestos type: Score: Crocidilite Amphibole asbestos excluding Crocidilite Chrysotile. None. A Management Assessment (referred to in HSG7 as the priority assessment ) which consists of the following components; Location, Likelihood of disturbance, and Exposure Potential ; and is scored as shown. Location: Score: Heating and ventilation units. Confined Space. Internal. External. Likelihood of disturbance: Score: Routinely disturbed e.g. door lining panels, hatches accessed daily, etc. Easily disturbed e.g. wall panels, access panels, etc. Occasionally likely to be disturbed e.g. maintenance activity (ceilings, gaskets, fuses, etc). Unlikely to be disturbed. Usually inaccessible e.g. roof soffits, floor voids (shuttering), partition wall inner panels, etc. Exposure potential: Score: High Constant or daily use. Medium Frequent or brief use (wc, stores etc). Low Periodic use (restricted use area e.g. archive store or maintenance use e.g. riser, boiler room, etc). Very low No use of area (locked or sealed area). Page of 7

12 Risk Category The above factors are scored, added together, and the resulting score used to rate the risk in a Category from A E, as follows. Category A: 7+ Materials within this category warrant urgent consideration. Materials with such a high rating indicate that persons may currently be exposed to significant asbestos fibre contamination. This exposure will vary according to local conditions e.g. the intensity of use of a heating system (which refers mainly to air handling ducts) or the nature of air flow & movement around a damaged ceiling. Due to potential for exposure, materials, which fall into this category, should be treated as a matter of urgency. In most circumstances, immediate plans for removal of the asbestos concerned should be implemented or at least rapid sealing of the affected areas. Category B: 4-6 (inclusive) Situations within this category warrant urgent consideration in that any change in one of a number of contributory factors may result in an unacceptable risk to health. It is therefore necessary for the asbestos to be treated as recommended within a specified timescale. It is recommended that the maximum period for action should be 6 months and that in the meantime emergency repair and sealing operations should be undertaken where any deterioration or damage occurs. Category C: - (inclusive) Situations within this category do not pose an imminent risk and the likelihood of exposure was perceived to be low at the time of the survey. It would be appropriate for materials within this category to be monitored as deterioration may occur over time. It is recommended that the maximum period for action should be months and the material subsequently inspected periodically if appropriate. Category D: - (inclusive) Situations within this category are low priority. It is recommended that the maximum period for action should be 4 months and the material subsequently inspected periodically if appropriate. Category E: No asbestos was identified in materials within this category. No further action is considered necessary. Page of 7

13 . HSE Risk Rating scheme (from HSG7) The following methodology for risk rating recommended by the HSE in its guidance HSG7 is provided for information and as a comparator against the scheme used at the University. Material assessment algorithm. Sample variable Score Examples of scores Product type (or debris from product) Asbestos reinforced composites (plastics, resins, mastics, roofing felts, vinyl floor tiles, semi-rigid paints or decorative finishes, asbestos cement etc) Extent of damage/deterioration Asbestos insulating board, mill boards, other low density insulation boards, asbestos textiles, gaskets, ropes and woven textiles, asbestos paper and felt Thermal insulation (e.g. pipe and boiler lagging, sprayed asbestos, loose asbestos, asbestos mattresses and packing Good condition: no visible damage Low damage: a few scratches or surface marks; broken edges on boards, tiles etc Medium damage: significant breakage of materials or several small areas where material has been damaged revealing loose asbestos fibres Surface treatment Asbestos type High damage or delamination of materials, sprays and thermal insulation. Visible asbestos debris Composite materials containing asbestos: reinforced plastics, resins, vinyl tiles Enclosed sprays and lagging, asbestos insulating board (with exposed face painted or encapsulated), asbestos cement sheets etc Unsealed asbestos insulating board, or encapsulated lagging and sprays Unsealed laggings and sprays Chrysotile Amphibole asbestos excluding crocidolite Total score Crocidolite Score Potential to release asbestos fibres or more High 7 9 Medium 5 6 Low 4 or less Very low Page of 7

14 Priority assessment algorithm. Assessment factor Score Examples of score variables Normal occupant activity Main type of activity in area Secondary activities for area Likelihood of disturbance Location Accessibility Extent/amount Human exposure potential Number of occupants Frequency of use of area Average time area in use Maintenance activity Type of maintenance activity Frequency of maintenance activity As above Rare disturbance activity (e.g. little used store room) Low disturbance activities (e.g. office type activity) Periodic disturbance (e.g. industrial or vehicular activity which may contact ACMs) High levels of disturbance (e.g. fire door with asbestos insulating boards sheet in constant use) As above Outdoors Large rooms or well-ventilated areas Rooms up to m Confined spaces Usually inaccessible or unlikely to be disturbed Occasionally likely to be disturbed Easily disturbed Routinely disturbed Small amounts or items (e.g. strings, gaskets) m or m pipe run. >m to 5m or > m to 5 m pipe run >5m or >5m pipe run None to 4 to > Infrequent Monthly Weekly Daily < hour > to < hours > to <6 hours >6 hours Minor disturbance (e.g. possibility of contact when gaining access) Low disturbance (e.g. changing light bulbs in asbestos insulating board ceiling) Medium disturbance (e.g. lifting one or two asbestos insulating board ceiling tiles to access a valve) High levels of disturbance (e.g. removing a number of asbestos insulating board ceiling tiles to replace a valve or for recabling ACM unlikely to be disturbed for maintenance per year > per year > per month Page 4 of 7

15 Note that the scores in the Priority Assessment are not summed, but averaged. The Priority Assessment average scores are added together, and summed with the Material Assessment score to give the final total score. Further advice is given in HSG7. Page 5 of 7

16 Annex - Asbestos Emergency Procedure Flowchart Source: HSE Asbestos Essentials EM Discovered or damaged materials that could contain asbestos? Stop work immediately Keep everyone else out of the area Is there dust or debris on clothing? Report the problem to the person in charge as soon as possible Put up a warning sign possible asbestos contamination Give client a sample to send for analysis Does it contain asbestos? NO No action required A little, e.g. dust on sleeve, on shoes Get help All put on RPE Wipe down with damp rags A lot, eg contaminated clothes, hair, footwear Stay put Call for help. All put on RPE, helper put on PPE Wipe down with damp rags Undress. Shower, wash hair YES The client must make an Asbestos Management Plan and decide if the task needs an HSE-licensed contractor Put contaminated clothes, towels etc in a plastic bag for a specialist laundry. Leave washing facilities clean Dispose of rags as asbestos waste Keep a record of the event Page 6 of 7

17 Annex HSE Guidance on Reporting Exposures to Asbestos Exposure to asbestos is reportable under RIDDOR when a work activity causes the accidental release or escape of asbestos fibres into the air in a quantity sufficient to cause damage to the health of any person. Such situations are likely to arise when work is carried out without suitable controls, or where those controls fail they often involve: Use of power tools (to drill, cut etc) on most ACMs; Work that leads to physical disturbance (knocking, breaking, smashing) of an ACM that should only be handled by a licensed contractor e.g. sprayed coating, lagging, asbestos insulating board (AIB); Manually cutting or drilling AIB; Work involving aggressive physical disturbance of asbestos cement e.g. breaking or smashing. If these activities are carried out without suitable controls, or the precautions fail to control exposure, these would be classed as a dangerous occurrence under RIDDOR and should be reported. Page 7 of 7

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