Plymouth City Council Asbestos Policy
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1 Plymouth City Council Asbestos Policy Policy, Arrangements and Procedures for Asbestos Management in Buildings, Structures and Assets Owned or Occupied by Plymouth City Council. May 2008: Version
2 EXECUTIVE SUMMARY Asbestos is the most serious occupational health problem in terms of fatal diseases that this country faces (Source: HM Government). The majority of the buildings, structures and assets owned or occupied by Plymouth City Council were built or refurbished at a time when asbestos containing materials (ACMs) may have been utilised during construction. Contemporary work that interferes or disturbs the fabric of a building may lead to personnel encountering asbestos. The presence of an ACM in itself does not constitute a danger. However, there is a potential risk to health if an ACM is damaged or disturbed. As well as people employed in traditional building/maintenance trades, exposure (and consequent risk) can occur in other groups of people e.g. installers of cabling systems, caretakers, cleaners, building occupiers etc. Regulation 4 of the Control of Asbestos Regulations 2006 places a legal duty on persons in control of maintenance functions and/or non-domestic premises to ensure the safety of building occupiers by the management of asbestos. The Regulations also provide legal duties to those who work with any ACMs. The Health & Safety Executive (HSE) has produced approved codes of practice (ACOPs) that provide practical advice on how to comply with the law related to these duties. This Policy details Plymouth City Councils asbestos policy statement (Part 1), asbestos management responsibilities/arrangements for asbestos management (Part 2) and procedures recommended for asbestos management (Part 3). It applies to all buildings, structures and assets and all individuals employed and/or engaged by the Authority without exception. The Policy allows individuals who have asbestos responsibilities related to Plymouth City Council s buildings, structures and assets to obtain guidance, advice and assistance to ensure their actions fully take account of legal requirements and recommended best practice. Contact details related to the support network (departments who are able to assist with technical advice and support) is also indicated within the Policy: As Chart 1 overpage. AMENDMENT HISTORY Version Number Changes Made Issue Date 1 Initial draft of Policy issued for comment to PCC Asset Management and Corporate Health & Safety Team. 1.1 Draft policy issued for comment to wider PCC stakeholders for comment. Policy agreed at Corp. H&S Committee 1 st Sept April 2008 Sept 2008 Policy and enclosures compiled and written by David Pollock BSc (Hons) MRICS, Building Surveying Team Manager, Asset Management, Plymouth City Council, Floor 13, Civic Centre, Plymouth. PL1 2EW. Telephone Number: (01752) , Fax Number: (01752) [email protected]. This individual shall be responsible for version control and review of any amendment suggestions to this Policy. March
3 Chart 1: Indicating Plymouth City Council s Asbestos Policy Responsibilities, Organisational Arrangements, Procedures and Advice & Support. Chief Executive [3.3.2], Directors [3.3.3], Heads of Service/Headteachers [3.3.4], RESPONSIBILITIES Line Managers/Supervisors/Team Leaders [3.3.5], Head of Asset Management/Director of Community Services (Housing) [3.3.6], Head of Human Resources [3.3.7], Corporate Health & Safety Committee [3.3.8], Occupational Health [3.3.9], Person in Control of Premises (Headteahers, building managers, responsible persons) [3.3.10] General Contractors & Sub-contractors [3.3.13], Asbestos Removal Contractors & Sub-contractors [3.3.14, Asbestos Consultants [3.3.14] Officers responsible for property acquisition and disposal [3.3.16] ORGANISATIONAL ARRANGEMENTS Project or Building works (ie cable installation, maintenance, refurbishment, and demolition, etc) Emergency Contingency Plan for suspected damage of ACMs in premises (accident, vandalism, etc) Premises Occupational Management by PIC: Reg. 4 Control of Asbestos Regs 2006 Duty to manage ACMs Property Acquisition & Disposal (leased/rented installation, maintenance, refurbishment, and demolition, etc.) PROCEDURES P7: Minor Works P8: Flow Diag Organisation and control of Contractors/ Works P9:Checklist HSE licensed Contractor Selection P5: Contingency Plan P6: Report of Suspected Exposure to Airborne Asbestos Fibres of Change P10: Asbestos Surveys S P1: Asbestos Warning Notice P2: Asbestos Label Policy P3: Permit to Work P4: Notification of Change P10: Asbestos Surveys P1: Asbestos Warning Notice P2: Asbestos Label Policy P3: Permit to Work P4: Notification of Change P10: Asbestos Surveys ADVICE & SUPPORT Asset Managemetn Building Surveying Team: (30)7773 and (30)4023 Community Services (Housing): (30)7558 and (30)4657 Health, Safety & Wellbeing Team: (30)4917 PIC Support Website: Appendix G: Bibliography & Guidance to Further Information March
4 Part 1 Plymouth City Council Asbestos Policy Statement P6 Part 2 Plymouth City Council Asbestos Management Responsibilities and P7 Arrangements 1.0 Introduction P7 2.0 Asbestos Policy Objectives P8 3.0 Context: Physical and Financial Resources 3.1 Implemented & Future Tactics to Achieve Asbestos Policy Objectives P9 3.2 Scope of Plymouth City Council s Asset Portfolio P Responsibilities for Asbestos Management P12 General P13 Chief Executive P13 Directors P14 Heads of Service and Headteachers P14 Line Managers, Supervisors and Team Leaders P15 Head of Asset Management / Head of Housing P15 Head of Human Resources (Health, Safety & Wellbeing) P16 Corporate Health & Safety Committee P17 Occupational Health (Health, Safety & Wellbeing) P17 Person in Control of Premises (Headteachers, building managers, P17 responsible persons) Employees P19 Client/Project Managers/Contract Administrators/Designers P20 General Contractors and Sub-Contractors P21 Asbestos Removal Contractors & Sub-Contractors P22 Asbestos Consultant P23 Officers responsible for Property Acquisition and Disposal. P Asbestos Budget P Asbestos Training P26 Part 3 Plymouth City Council Asbestos Policy Procedures P28 Procedure 1: PCC Asbestos Warning Notice. P29 Procedure 2: PCC Asbestos Labelling Policy and Label Examples. P30 Procedure 3: PCC Permit to Work and Asbestos Register Acknowledgement Form. P32 Procedure 4: Asbestos: Notifications of Change of Status. P34 Procedure 5: Contingency Plan Required in the Event of a P35 Suspected Asbestos Incident. Procedure 6: Report of Suspected Accidental Exposure to Airborne P36 Asbestos Fibres (including Form ASB001). Procedure 7: Minor Works: Reactive & Preventative maintenance works. P39 March
5 Procedure 8: Flow Diagram Aide Memoir: Organisation & Control P40 of contractors or Works to Plymouth City Council s Buildings, Structures or Assets. Procedure 9: Checklist Aide Memoir: HSE Licensed Asbestos P41 Contractor Selection. Procedure 10: Asbestos Surveys. P41 APPENDICES A: PCC Corporate Asbestos Management Implementation Programme. P43 B: Maintenance Spend Matrix: Ratings for the Determination of (Asbestos) Works Priorities (property, condition, priority & reason ratings). P45 C: Management Action Summary Options P47 D: Asbestos Management Responsibility Examples P48 E: Summary Information related to Asbestos and its Health Effects. P49 F: Bibliography and Guidance to Further Information & Organisations Providing P53 Asbestos Related Advice. March
6 Part 1: Plymouth City Council - Asbestos Policy Statement. 1.1 Plymouth City Council acknowledges and accepts its responsibilities under the Health & Safety at Work etc Act 1974, the Control of Asbestos Regulations 2006 and any further existing and future asbestos related legislation. 1.2 The Council will align resources and establish the necessary function/responsibility structure to allow effective asbestos management of its assets to comply with Health & Safety Executive Approved Codes of Practice (ACOPs), Regulations and Guidance in respect of Asbestos Management and the contents of Plymouth City Council s Asbestos Policy. 1.3 The Council aims to ensure, so far as reasonably practicable, the protection of employees and others from risks to health from potential exposure to asbestos from the activities or undertakings of the Authority. Barry Keel Chief Executive Carole Burgoyne Assistant Chief Executive Bronwen Lacey Director of Children s Services Adam Broome Director of Corporate Resources Clive Turner Director of Community Services Nigel Pitt Director of Development Dated Dated Dated Dated Dated Dated March
7 Part 2: Plymouth City Council Asbestos Management Responsibilities and Arrangements 1.0 Introduction 1.1 Plymouth City Council aims to ensure compliance with the asbestos policy statement (as Part 1 of this document). 1.2 The policy explains the implementation of asbestos management within Plymouth City Council by effective planning, organisation, control, monitoring and review: refer to Appendix A: Corporate Asbestos Management Implementation Programme. 1.3 The policy applies to all Plymouth City Council buildings, structures and assets (including the Housing Revenue Account residential housing 1 and school premises portfolio) and all individuals employed and/or engaged by the Authority without exception. 1.4 The Asbestos policy has been written to compliment and reinforce the contents and responsibilities contained within Plymouth City Council s Corporate Health & Safety Policy The Asbestos Policy has been previously circulated for consultation to allow comments to be received from officers and appropriate stakeholders 3. The Asbestos Policy will be updated annually, as and when applicable Asbestos Policy Objectives 2.1 The Asbestos Policy provides a clear statement of the objectives and methods to be employed to ensure the safety of building occupiers by the effective asbestos management in Plymouth City Council s non-domestic premises. It defines the framework by which the Council s Asbestos management needs are identified, managed, monitored and reported. The policy lays down the scope of the asset portfolio, responsibilities concerning asbestos management, the implemented & future tactics related to asbestos management, asbestos budget and works prioritisation, training, and support network communication details. 2.2 Asbestos Policy objectives: - Provide a PCC Corporate Asbestos Management Implementation Programme clearly identifying strategic and operational responsibilities for asbestos management in PCC and timescales. To ensure the prevention of exposure to risks associated with asbestos containing materials (ACMs). To promote awareness of the risks from ACMs and PCC s Asbestos Management Procedures through training and induction of relevant staff. 1 Non-domestic locations only: refer to Section 3.2: Housing Revenue Account Portfolio. 2 The Corporate Health & Safety Policy is available from PCC s staff room document library under Health, Safety & Wellbeing, or a copy may be supplied by contacting the H&S Team on Ext This includes consultation with Union appointed safety representatives, the Corporate Health, Safety & Welfare Committee, Directors and individuals who provide services for the support network. 4 Plymouth City Council will regularly monitor changes to Asbestos-related legislation to facilitate amendments to the Asbestos Policy. March
8 To ensure that any ACMs that may be present in any Plymouth City Council (PCC) buildings are maintained in a condition so as to prevent the possibility of any harm to health occurring. Provide adequate resources and commitment to comply with all relevant asbestos legislation, Health and Safety Executive approved codes of practice, guidance notes etc Ensure that all properties built before 2000 are surveyed to identify any ACMs that may be present therein and to prepare and maintain Asbestos Registers (corporate and premises-based) for all buildings. The registers will undergo regular reviews and will be updated when treatment/removal works are undertaken or when the ACM s condition/priority rating has changed. Maintain, implement and monitor a suitable asbestos management plan of each PCC building and undertake appropriate management control measures to ACMs within each PCC buildings such as encapsulation, labelling, inspection, removal etc. Effectively target asbestos related maintenance expenditure avoiding expenditure on non-priority maintenance requests and on assets planned for disposal. Provide procedures for the premises occupational management of asbestos containing materials (ACMs), duties related to building works, emergency contingency plan and property acquisition & disposal. Ensure that all contractors and sub-contractors engaged to carry out work on any of the PCC buildings are aware of the presence or suspected presence of ACMs by highlighting this on works orders or scheme/tender documentation and providing signed access to the premises-based asbestos register, and advised of the appropriate precautions and procedures to be followed. Ensure that only competent HSE Licensed and UKAS accredited external Asbestos Consultants are employed by PCC to carry out surveys and sampling and to supervise asbestos works strictly in accordance with Approved Code of Practice (ACOP) L143 and industry best practice. Ensure that only competent HSE Licensed Asbestos Contractors are employed by PCC to carry out encapsulation, removal or any other works to ACM s strictly in accordance with ACOP L143 and industry best practice. 3.0 CONTEXT: PHYSICAL AND FINANCIAL RESOURCES Foreword Asbestos has been the main cause of occupational ill health from about 1950 onwards and is still the greatest single work-related cause of death from ill health. Past exposure is now responsible for about 4000 people dying from asbestos-related cancers every year. This figure is expected to rise over the next ten years and then decline. (Source: HSE/TUC Publication The Control of Asbestos Regulations 2006: A Guide for Safety Representatives). Health & Safety Executive key messages related to asbestos containing materials (ACMs) in premises: asbestos materials which are in good condition and not releasing dust should not be March
9 disturbed...materials which are damaged, deteriorating, releasing dust or which are likely to do so should be sealed, enclosed or removed as appropriate following official guidance materials which are left in place should be managed and their condition periodically reassessed the risk to the health of the public from asbestos materials which are in sound condition and which are undisturbed is very low indeed Refer to Appendix E: Summary information related to asbestos and its health effects. 3.1 Implemented & Future Tactics to Achieve Asbestos Policy Objectives 2008 Asbestos Policy [this document]: Contains Plymouth City Councils asbestos policy statement (Part 1), asbestos management responsibilities/arrangements for asbestos management (Part 2) and procedures recommended for asbestos management (Part 3). The Policy requires individuals who have asbestos responsibilities related to Plymouth City Council s buildings, structures and assets to obtain guidance, advice and assistance to ensure their actions fully take account of legal requirements and recommended best practice. The responsibilities/procedures cover occupational asbestos management, building works procurement, emergency contingency plan implementation and property acquisition and disposal. Contact details related to the support network (Health & Safety team, Asset Management and Community Services [Housing] are also indicated within the Policy. The policy is accessible from Asset Management s Web-Site: Buildings, structures and assets yet to be asbestos surveyed: It shall be assumed that all unidentified materials within such a premise contain asbestos. A works specific risk assessment shall be undertaken (i.e. Type 3 asbestos survey) prior to any disruptive works being undertaken. These buildings are to be included in the future type 2 asbestos survey programme to ensure asbestos register provision [as below]. Refer to Procedure 10: Asbestos Surveys. Buildings, structures and assets that have been surveyed and provided an asbestos register: The Head of Asset Management/Director of Community Services [Housing] is responsible for the administration of the planned Type 2 asbestos survey programmes undertaken in compliance with Health & Safety Executive guidance MDHS100 and HSG227. The survey programmes shall include all properties constructed prior to To date the corporate operational, schools and the HRA portfolio have been completed. Additional Type 2 Asbestos surveys and register production will be undertaken of the non-operational estate (once contractual and lease repair obligations have been determined), non-building assets (i.e. structures) and additional premises acquired or ones found as a result of the corporate property review. Refer to Procedure 10: Asbestos Surveys. Premises-based asbestos register and management action plan: A paper premisesbased asbestos register has been issued by the Head of Asset Management/ Director of Community Services [Housing] to each premise to allow day-to-day occupational management by the designated Person in Control. The Person in Control is responsible for ensuring that the contents of the asbestos register are made available to employees and contractors who enter and work within each premises. The register contains a management action plan detailing the methods that needs to be implemented, developed, maintained and updated by each premise Person in Control, in conjunction, if applicable, with the maintenance budget holder. This provides the basis to ensure the March
10 safety of building occupiers by the management of asbestos in non-domestic premises: Regulation 4 of the Control of Asbestos Regulations If asbestos containing materials (ACMs) are in good condition and unlikely to be disturbed, the ACM should be left in place, labelled and monitored in accordance with current best practice. Removal or encapsulation works by HSE licensed asbestos contractors should be considered, in liaison with the Head of Asset Management/Housing, if the ACM is found to be in poor condition or if the risk assessment indicates vulnerability to damage due to location or occupational activities. Refer to Appendix C: Management Action Summary Options and Procedures 1 to 3. The exact status related to implementation of each premises management action plan is not known (as at 2008) and will require future audit. For example, the corporate portfolio shall require review following policy reversal in 2008/09 allowing maintenance budget centralisation. To allow for the corporate asbestos register to be updated and maintained the Person in Control needs to inform the Head of Asset Management/Director of Community Services [Housing] of any alterations, removal or modifications of ACMs within their premises: refer to Procedure 4: notifications of change of status. This process has largely not occurred to date, but a procedure has now been included in the 2008 Corporate Asbestos Policy and will be rolled out during Policy implementation. Corporate Asbestos Register: A duplicate paper copy of the register is held and managed by the Head of Asset Management/Director of Community Services [Housing]. A technical re-inspection of the existing corporate asbestos register will be undertaken over a five year period commencing 2008 (20% of the portfolio each year), which will allow the re-issue of updated registers to each premise Person in Control. It had been previously proposed that the corporate asbestos register would be integrated into Evolution (Plymouth City Council s Asset Management information technology program) to allow a single point updatable property information system. Although this aim has been technically illusive, a method of electronic storage is still considered a priority as it would improve information accessibility (remote accessibility by Persons in Control, project managers, contractors etc) and improve the compilation, maintenance and updating of records (i.e. after treatment, removal works or changes to any ACM). Building Works: It is the legal responsibility of the client/project manager/contract administrator/designer to ensure that a Type 3 asbestos survey is commissioned prior to any works that could disrupt the fabric of a building (i.e. cable installation, maintenance, refurbishment, or demolition). All work with asbestos containing materials legally needs to comply with the Control of Asbestos Regulations 2006 and Health & Safety Executive Approved Code of Practice work with materials containing asbestos. Refer to Procedures 7, 8 & 9. Only competent HSE licensed/ukas accredited external asbestos consultants and HSE licensed Asbestos contractors shall be utilised for survey, sampling, asbestos works, supervision and encapsulation, removal or other works to ACMs. Asbestos Emergency Contingency Plan: Indicates the actions that shall be undertaken in the event of an asbestos or suspected asbestos incident: refer to Procedure 5: Contingency plan required in the event of a suspected incident. Person in Control (PIC) Support Initiative: PIC Support is a framework for managing corporate and educational premises in accordance with legislation. Training, guidance and information is provided for those with PIC responsibilties. Asbestos Training: The appropriate level asbestos training allows each individual to acquire knowledge/skills to comply with asbestos legislation (i.e. compliance with Regulation 4 of the Control of Asbestos Regulations 2006), ensuring effective asbestos March
11 management within the Council in compliance with Plymouth City Council s Asbestos Policy. Refer to Section Scope of Plymouth City Council s Asset Portfolio The Authority s property portfolio includes a variety of land and property assets including industrial, retail and commercial land and property, amenity land, cemeteries, car parks, leisure centres, public conveniences, derelict and under-used land in miscellaneous areas. Plymouth City Council is a significant property owner, with assets valued at 1,331,456,176 (as at February 2008). The assets and related responsibilities are categorised as follows: Corporate Operational Assets These are assets that are held and used or consumed by the Authority for the direct delivery of services for which it has either a statutory or discretionary responsibility. Examples include: Offices and depots [not Housing Revenue Account]. Museum, libraries, guildhalls and historic buildings. Social Services residential accommodation homes. Sports centres, pools and other leisure facilities. Adult education, community & youth centres. Crematoria, registry offices. Car parks & transport facilities [responsibility of PCC Transport, Infrastructure and Engineering]. Park shelters, park lodges and pavilions [responsibility of PCC Parks Services]. Public toilets and changing rooms. Storage buildings. The Head of Asset Management (refer to Section 3.3.6) is responsible for strategic asbestos management, unless indicated otherwise above, or if legal, contractual or lease repair obligations indicate otherwise. Operational asbestos management has been delegated by Directors to the Person in Control (building managers, responsible persons) of the operational/occupational management of each premise. This duty will be shared with Asset Management for those properties funded from the Centralised maintenance budget. Corporate Non-Operational Assets These are assets that are held by the Authority but not directly occupied, used or consumed in the delivery of services. Examples include: Business premises and investment properties let by the Authority (commercial, retail and industrial property). Land acquired and held in advance of development. Property surplus to requirements. The Head of Asset Management (refer to Section 3.3.6) is responsible for strategic asbestos management and operational asbestos management unless legal, contractual or lease repair obligations indicate otherwise, or is such responsibilities have been delegated to a Person in Control located at the premises and responsible for occupational operational management/budget expenditure (i.e. leaseholders). Corporate Community Assets Community assets are assets that the Authority intends to hold in perpetuity, they have no determinable useful life and they may have restrictions on their disposal. Such assets are usually procured for, dedicated or March
12 donated to public use and placed with the Authority s custodian to provide care and maintenance and access for the public. The test for a community asset is considered to be whether it is alienable or could be sold and the proceeds of sale used for some other purpose without the consent of some outside body, trust owner or beneficiary. Examples of community assets include: Parks and open spaces [responsibility of PCC Parks Services]. Land used for cemeteries. Allotments. The Head of Asset Management (refer to Section 3.3.6) is responsible for strategic asbestos management, unless indicated otherwise above or if legal, contractual or lease repair obligations indicate otherwise. Operational asbestos management has been delegated by Directors to the Person in Control (building managers, responsible persons) of the operational/occupational management of the premises/land. Housing Revenue Account Portfolio These are assets held & used by the Authority for the delivery of Council Residential Housing. Residential Housing. Offices, Depots, and parks/open spaces (HRA only). The Director of Community Services [Housing] is responsible for strategic asbestos management (refer to Section 3.3.6). The Director retains operational asbestos management unless legal, contractual or lease repair obligations indicate otherwise, or if such responsibilities have been delegated to a person in control located at the premises and responsible for occupational operational management/budget expenditure. The duty to manage asbestos does not apply to domestic premises (i.e. a private dwelling where a person lives). However, common parts in housing developments and blocks of flats (i.e. entrance halls, stairs, lifts, plant rooms, shared corridors etc) are nondomestic and subject to Regulation 4 Control of Asbestos Regulations Schools Portfolio These are assets held & used by the Authority for the provision of education (Children s) services. Primary Schools (including special schools) Secondary Schools The Head of Asset Management (refer to Section 3.3.6) is responsible for strategic asbestos management (on behalf of the Local Education Authority), unless the school s legal status indicates otherwise. Operational asbestos management has been delegated by the Director of Children s Services to the headteacher (Person in Control) of the operational/occupational management of the premises, unless legal, contractual or lease repair obligations indicate otherwise. 3.3 Responsibilities for Asbestos Management General Plymouth City Council has responsibility for compliance with the Health and Safety at Work etc. Act 1974 and all associated legislation. This includes specific legislation relating to asbestos containing materials (ACMs): refer March
13 to Appendix F. This Asbestos Policy shall be read in liaison with Plymouth City Council s Corporate Health & Safety Policy All Directors, School Headteachers, Managers and any other Authority employee responsible directly or indirectly for asbestos management (i.e. those who control, undertake or organise premises management, maintenance, any work process likely to interfere with the fabric of any of the Authorities premises, or property acquisition & disposal shall be responsible for ensuring compliance with the Corporate Asbestos Policy Directors, Heads of Service and School Headteachers shall ensure that all of their staff familiarise themselves with the contents of the Asbestos Policy, insofar as it is relevant to their roles and responsibilities. Additionally, Directors, Heads of Service and School headteachers are responsible for ensuring that employees under their control and management have the relevant level of competency to deal effectively and legally with asbestos related issues. All work with asbestos containing materials in any buildings, structures and assets owned or occupied by Plymouth City Council is to be carried out by a Health & Safety Executive licensed asbestos contractor in full compliance with the Control of Asbestos Regulations 2006 and related HSE Approved Codes of Practice, Regulations and guidance. The Head of Asset Management/Director of Community Services [Housing] may provide formal dispensation to allow the use of competent general contractors to undertake works to non-notifiable materials, upon the provision of conclusive evidence, prior to works commencement, to indicate that such works are to be undertaken in full compliance with the Control of Asbestos Regulations 2006 and related HSE Approved Codes of Practice, Regulations and guidance Responsibility for the implementation, review and monitoring of this Policy document, along with the Authorities strategic asbestos management framework is delegated to the Director responsible for health & safety implementation (Assistant Chief Executive). Resource responsibilities related to the strategic asbestos management framework [advice & support network] shall be delegated, depending on function and premises portfolio, to the Head of Asset Management, Director of Community Services [Housing] and Head of Human Resources (Health, Safety and Wellbeing). Responsibilities for occupational/operational asbestos management shall be delegated by each Director to Persons in Control (headteachers, building managers, responsible persons) of each premises and, if applicable, to those responsible for building maintenance Chief Executive Will be responsible for: Refer to Appendix A: PCC corporate asbestos management implementation programme, Chart 1 (Executive Summary) indicating PCC asbestos policy responsibilities, organisational arrangements, procedures and advice & support network and Appendix E: Examples of asbestos management responsibilities Specifying and ensuring that the structure of the Council facilitates itself to March
14 the successful implementation of the Asbestos Policy Ensuring the objectives of the Asbestos Policy are fully understood by all Directors and that the appropriate management arrangements are in place Directors Will be responsible for: Specifying and ensuring that the structure of their own Departments facilitates itself to the successful implementation of the Asbestos Policy i.e. the identification of Persons in Control (headteachers, building managers, responsible persons) Ensuring the objectives and contents of the Asbestos Policy are fully understood by all their own Departmental Heads of Service, Headteachers and employees Managing their responsibility through Departmental Management Team meetings and membership of the Authorities Corporate Health & Safety Committee Ensuring that individuals responsible for asbestos management are identified, competent and have sufficient and suitable initial and update training with respect to asbestos issues where appropriate Heads of Service and Headteachers Will be responsible for: Ensuring the identification, registration and training of Persons in Control (headteachers, building managers, responsible persons) Specifying and ensuring that the structure of their service area or school facilitates itself to the successful implementation of the Asbestos Policy Ensuring the objectives of the Asbestos Policy are fully understood by all their own Departmental Managers Ensuring that all Managers under their control are made aware of their duties and responsibilities in line with the Asbestos Policy Ensuring Managers are adequately trained and suitably competent to manage asbestos with their own service area or school department Ensuring their service area or school employees recognise asbestos management as an integral element of their business and is given equal status alongside other management functions Co-operating and working in close liaison with all officers to achieve effective asbestos management and Policy compliance Ensuring that all asbestos incidents that occur in workplaces and premises under their control are properly recorded and notified in compliance with the emergency contingency plan: refer to Procedure 5. March
15 Headteachers will bring to the attention of the governing body any significant asbestos management issues. Will involve the governors in any policy matters and bring to the attention health & safety guidance received from the Children s Services or Corporate Health & Safety Team and liaise with and involve, as appropriate, the Health & Safety Lead Governor Line Managers, Supervisors and Team Leaders Will be responsible for: Ensuring the objectives of the Asbestos Policy and Procedures are fully understood, implemented and observed by employees directly under their control Ensuring that all employees under their control are made aware of their duties and responsibilities in line with the Asbestos Policy Ensuring that all asbestos incidents that occur in workplaces and premises under their control are properly recorded and notified in compliance with the emergency contingency plan: refer to Procedure Ensuring safe systems of work pertaining to asbestos work activities (if applicable) are developed, implemented, controlled and monitored Ensure all procurement decisions fully take into account asbestos considerations Head of Asset Management/Director of Community Services [Housing] Will be responsible for: Developing asbestos related policy, arrangements, procedures and guidance in compliance with legislative requirements Devolving the principal functions of asbestos management to the relevant Maintenance Team Managers (shared duty holders 1 under Regulation 4 1 Regulation 4 Control of asbestos Regulations 2006 defines the duty holder (responsible to manage asbestos in non-domestic premises as: (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 duty holder, the relative contribution to be made by each 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. Duties under Regulation 4 Control of Asbestos Regulations 2006:- (a) take reasonable steps to find materials in premises likely to contain asbestos and to check their condition: (b) presume that materials contain asbestos unless there is strong evidence to suppose they do not: (c) make a written record of the location and condition of asbestos and presumed asbestos-containing materials (ACMs) and keep the record up to date: (d) assess the risk of the likelihood of anyone being exposed to these materials; (e) prepare a plan to manage that risk and put it into effect to ensure that: (i) any material known or presumed to contain asbestos is kept in a good state of repair (ii) any material that contains or is presumed to contain asbestos is, because of the risks associated with its location or condition, repaired, or if necessary removed (iii) information on the location and condition of the material is given to anyone potentially at risk The Type 2 Asbestos Survey (undertaken to Health & safety Executive Guidance MDHS100 and HSG227) shall provide a written regulation compliant asbestos register for each premises in the Asset Management/Housing portfolios. The register shall complete all of the Regulation 4 duties, except those underlined above. The underlined duties shall be the responsibility of the Person in Control responsible for occupational/operational and access/egress related to their building. March
16 the control of Asbestos Regulations 2006) and Officers responsible for the Project Management of Projects (including feasibility and design) or functions related to property acquisition or disposal Managing this responsibility through the Departmental Management Team meetings and the Corporate Health & Safety Committee Ensuring that employees under his direct control are trained, qualified and competent to deal with asbestos issues. BIOH P402/P405 qualifications shall be required by employees commissioning/maintaining asbestos registers, undertaking asbestos surveys (type 2 and 3 asbestos surveys), assisting with duties under legislation/pcc Asbestos Policy (i.e. emergency contingency plan required in the event of a suspected asbestos incident) and the provision of specialist asbestos management advice Ensuring that the overall strategy for the safe operation and execution of Asset Management/Community Services [Housing] activities includes consideration of asbestos issues within their particular property portfolios or areas of work Ensuring the adequate provision of resources for strategic and operational asbestos purposes (in compliance with the Asbestos Policy and implementation programme) Ensuring that asbestos surveys are undertaken/commissioned in full compliance with Health & Safety Executive Guidance MDHS100 and HSG227 to allow the compilation of a corporate and premises-based legislation compliant Asbestos Registers. The Corporate Asbestos Register shall remain with the Head of Asset Management/Head of Housing. The premises-based register shall be forwarded to the Person in Control based at each property to aid compliance with the duties 1 under Regulation 4 Control of Asbestos Regulations The asbestos registers shall include the initial management action plan to allow use and future development by the Person in Control Ensuring that the Corporate Asbestos Register is regularly updated and maintained Ensuring that technical re-inspections of Type 2 asbestos registers over a 5 year duration are undertaken to allow asbestos records to be kept up to date. Undertake duties related to updates, as above Ensuring an effective response is provided for emergency situations and to ensure compliance with the emergency contingency plan: refer to Procedure Providing information on ACMs as may be required Providing the Health and Safety Executive with details of asbestos management procedures if/when requested. Completion of the duties allows full development of the management action plan (contained within the asbestos register) and enables compliance with Regulation 4 of the Control of Asbestos Regulations The Head of Asset Management or/director of Community Services [Housing] shall need to commission asbestos remedial works (repair or removal) if responsible for the maintenance repair obligations of the subject building as (e) (ii) above, in compliance with asbestos related legislation: See 3.13 Asbestos Removal Contractors and Sub-contractors. March
17 Assisting with auditing the compliance of asbestos management action plans implemented by Persons in Control (headteachers, building managers, responsible persons) Head of Human Resources (Health, Safety & Wellbeing) Will be responsible for: Investigating and reporting to the Corporate Health and Safety Committee on any alleged incident of accidental asbestos exposure and for ensuring reporting of incidents under Reporting of Injuries, Diseases and Dangerous Occurrences Regulations 1995 (RIDDOR) where appropriate Advising line managers on notification to the Occupational Health Service should any member of staff be involved in an incident of accidental asbestos exposure in order that medical advice can be given Providing general health & safety information on ACMs as may be required Assisting and ensuring compliance with the contents of the emergency asbestos contingency plan arrangements: Refer to Procedure Assisting with auditing the compliance of asbestos management action plans implemented by Persons in Control (headteachers, building managers, responsible persons) Ensuring liaison with department and Trade Union safety representatives related to Health & Safety (including asbestos) Corporate Health & Safety Committee Will be responsible for: Ensuring the Asbestos Policy is reviewed annually, or when significant changes occur to the Authorities business or structures Reporting annually via Corporate Management Team on the effectiveness of the Policy, Procedures and actual working practices Reporting immediately to the Corporate Management Team if any serious deficiencies are identified in the Authorities management of asbestos Occupational Health (Health, Safety & Wellbeing) Will be responsible for: Providing occupational health advice to management and staff on issues relating to asbestos on referral Ensuring that any exposure is recorded on the employee s Personal File and retaining the medical notes for a period of forty years after the date of final exposure. March
18 Person in Control 2 of Premises (headteachers, building managers, responsible persons) Will be responsible for: Ensuring that all staff (permanent and temporary), service users, visitors, contractors and others who are likely to interfere with the fabric of the building are provided appropriate asbestos awareness training and are aware/implement their responsibilities under PCC Asbestos Policy Ensuring that the asbestos register and management action plan 3 (fully developed by the Person in Control) stays on site at all times, that all staff know where it is kept (and can use it), and that anyone likely to disturb asbestos containing materials are able to access the register s information contents (as above). This will ensure that such parties/individuals are not put at risk of exposure to asbestos containing materials (ACMs) Ensuring the asbestos management plan recommendations are developed and implemented (kept up to date and regularly reviewed to identify any changes i.e. change of room use/activity, or where further asbestos is located etc) ensuring the effective operational/occupational management of known or assumed ACMs identified by the Type 2 survey and contained within the premises based Asbestos Register: Refer to Procedures 1, 2 & Regularly carry out visual checks of all ACMs, to ensure that asbestos containing materials remain in a good state of repair, and record such 2 Person in Control relates to premises managers, responsible persons or headteachers previously nominated by their Directorate as being responsible for the occupational or operational control of Plymouth City Council premises. This role will be the Duty Holder under Regulation 4 of the Control of Asbestos Regulations 2006 and, if applicable, may share this legislative responsibility with the department or individual responsible for the remote provision and allocation of the premises maintenance budget 3 Regulation 4 of the Control of Asbestos Regulations 2006 requires Duty Holders to undertake 5 Steps. The Type 2 Asbestos Survey organised by the Head of Asset Management or Director of Community Services [Housing] has enabled the production of a legislation compliant written register for each premises, including your own. The register shall complete all of the Regulation 4 duties, except those underlined. Refer to Footnote 1 under Policy section However, as the person in control responsible for occupational/operational and access/egress related to your building you will need to develop the premises management action plan by: 1) ensuring that the register is kept up-to-date and made available to all occupiers/visitors: 2) ensuring that the premises management action plan is implemented: 3) undertaking regular monitoring of presumed or known asbestos containing materials to ensure they remain in good condition. The Person in Control will need to review the contents of Step (d), the likelihood of risk, for completeness/ suitability if completed by the external asbestos surveyor: Refer to Footnote 1 under Policy section Persons in Control may obtain assistance or advice from the Support Network. Refer to Appendix B The HSE Approved Code of Practice L127 entitled The Management of Asbestos in Non-Domestic Premises Regulation 4 of the Control of Asbestos Regulations 2006 provides detailed advice on how to comply with the duty in Regulation 4 of the Control of Asbestos Regulations 2006 and explains the duties of building owners, tenants and anyone else with legal responsibilities for non-domestic premises. These duties are those summarised in (a)-(e) detailed in Section The HSE have also produced two guides to managing asbestos in premises. 1) A short guide to managing asbestos in premises INDG223 and 2) A comprehensive guide to managing asbestos in premises HSG227. To enable the management of asbestos in non-domestic premises Asset Management has undertaken Type 2 asbestos surveys of the Corporate operational premises portfolio and schools. Community Services [Housing] have undertaken Type 2 asbestos surveys of non-domestic locations of residential housing. The surveys have enabled the provision of asbestos registers for each premises. Each asbestos register has been previously forwarded to the nominated person in control to enable effective management of asbestos containing materials in each premise allowing compliance with Regulation 4 of the Control of Asbestos Regulations March
19 inspections between the 5 yearly technical re-inspections by Head of Asset Management/Director of Community Services [Housing]. Asset Management/Housing must be advised of any significant changes to the condition of the ACM that may require repair or removal operations: refer to Procedure Ensuring that ACMs and associated labelling is maintained in good condition in conjunction, if applicable, with the maintenance budget holder: refer to Procedure Ensuring that Management Action Plans are to be made available to the external enforcing authorities (HSE), the occupiers of the premises, Head of Asset Management/Director of Community Services [Housing] and Trade Union Safety representatives Assisting and ensuring compliance with the contents of the emergency asbestos contingency plan arrangements: refer to Procedure Ensuring that any works activities undertaken to their premises by staff, service users and third parties is undertaken in a safe manner fully considering ACMs: refer to Suitable and sufficient risk assessments (i.e. Type 3 asbestos survey) and safe systems of work are required prior to activity commencement: refer to Alerting the Head of Asset Management or Director of Community Services [Housing] when any previously unknown asbestos is found, or suspected, during works activities, in order that an assessment can be made and appropriate action taken: refer to above Ensuring that the Head of Asset Management/Director of Community Services [Housing] is to be notified of any changes to the asbestos content of your premises (i.e. the condition of asbestos containing materials or after treatment/removal works). This will enable the updating of the Corporate Asbestos Register held by the Head of Asset Management/Director of Community Services [Housing]: Refer to Procedure Ensuring that new materials, components, equipment or apparatus erected, installed, purchased or gifted is free of asbestos material Employees All persons employed by Plymouth City Council will be responsible for: Ensuring that any work that may disturb or damage ACMs is avoided Reporting to the premises Person in Control (headteachers, building managers, responsible persons) or alternatively their line manager any materials suspected of containing ACMs where the material has become disturbed and/or damaged or where staff, contractors and/or sub contractors are likely to undertake work, which may affect that material. March
20 Client/Project Managers/Contract Administrators/Designers: Refer to Procedures 7, 8, 9 & 10. Will be responsible for: Ensuring that the Plymouth City Council Asbestos Policy and any associated guidance is adhered to Ensuring that, before feasibility/design work is started on a project, the Asbestos Register is consulted and sufficient information is obtained on any ACMs within the working area to safely carry out the works. Where disruptive works are planned, a competent and qualified Asbestos Consultant must be commissioned during feasibility/design to undertake a Type 3 asbestos survey (including CAD drawings) to identify concealed ACMs. A minimum of 6 weeks should be allowed to enable surveys, sampling, analysis and reporting to take place Ensuring that the extent of the survey requirements are clearly communicated to the preferred Asbestos Consultant and to include satellite areas where service connections may be made Ensuring that the outcomes of any survey are made available to the premises-based and corporate asbestos registers: Ensuring that unsurveyed areas and areas of no access are mapped against proposed works to ensure that the extent of the works does not impinge on these areas of no access and, if so, these areas are surveyed before the start of the works Ensuring that before any work is started on any PCC premises that adequate risk assessments/method statements are completed, the Asbestos Register has been consulted and, where disruptive works are being undertaken, a Type 3 survey (refer to Procedure 10) has been completed by the preferred Asbestos Consultant. If no asbestos is identified then the works can proceed with caution, bearing in mind the possibility that the Asbestos Register and/or any additional surveys might not have identified all ACMs Stopping any works and informing staff if suspected materials are discovered during the course of the works and immediately complying with the emergency contingency plan: Refer to Procedure Ensuring that if asbestos is identified, which will be disturbed during the works, that an Asbestos Consultant is commissioned to prepare a scope and specification including a schedule of all ACMs to be removed as a set of separate tender documents Ensuring that only HSE licensed asbestos contractors and UKAS accredited HSE licensed consultants are used Ensuring that separate contracts are issued for asbestos remediation works and subsequent asbestos testing/monitoring (ensuring conflict of interest situation are avoided). March
21 Informing all relevant staff, contractors and sub contractors of the presence of any known asbestos, which may affect the works. Additionally, contractors are to be instructed to consult the Asbestos Register in order to familiarise themselves with the location of any known asbestos, non-accessible areas or restricted areas in the premises Ensuring that all Risk Assessments, Method Statements and Notices (as may be required under the Control of Asbestos Regulations 2006) are in place, before any work is allowed to start on site. Copies of all such documentation must be available for inspection on site at all times for the duration of the project Only permitting the works to start if the project manager/designer is satisfied with the quality of the documentation: indicated in above Ensuring that the Asbestos Registers (Corporate & Premises-Based) are updated as soon as new or revised information is available, which may be near the beginning, during or at the end of a project and signing off the fact that the updated Asbestos register reflects the position at a specified date: refer to Procedure 4. Updates shall include details of all newly identified asbestos-based materials and details of where any previously identified materials have been encapsulated, modified or removed. All new and amended records must include an MDHS100 and HSG227 risk assessment General Contractors 4 and Sub Contractors Will be required to: Ensure that they are fully familiar with current legislation, approved codes of practice 5 and guidance relating to the management of asbestos containing materials (ACMs) Ensure that they have a clear understanding of Plymouth City Council s Asbestos Policy Ensure that all staff employed by them have received an appropriate level of asbestos awareness training Consult the PCC asbestos registers for the premises before works start. 4 The term Contractors will be used in the wide sense ie. any individuals or organisations undertaking activities within Plymouth City Council s buildings, structures or assets including direct labour organisations or external companies ie. contractors, caretakers, cleaners, catering staff etc. 5 HSE approved code of practice L143 entitled work with materials containing asbestos applies to all work with asbestos and explains the requirements of the Control of Asbestos Regulations The ACOP applies in particular to work on, or which disturbs or is liable to disturb materials containing asbestos, asbestos sampling and laboratory analysis. It is particularly relevant to those who are responsible for maintenance and repair of non-domestic premises where asbestos containing materials are or are likely to be present. The ACOP has a special legal status: If you are prosecuted for a breach of Health & safety law and it is proved that you did not follow the relevant provisions of the ACOP you will need to show you have complied with the law in some other way or a court may find you at fault. The HSE has also produced asbestos essentials guidance (refer to Items 8 & 9 in Appendix F) that provides specific work activities related to minor works undertaken on asbestos materials. March
22 Ensure that where work may be affected by, or involves, ACMs that a HSE licensed contractor is engaged to carry out the work Ensure that any relevant risk assessments, method statements and statutory notices are in place before work commences Progress all works diligently but, if any suspect materials are encountered, to immediately suspend operations, isolate the area, and to contact the client/project manager/contract administrator/designer or Person in Control of the building to instigate the Emergency Contingency Plan: refer to Procedure Provide copies of all test certificates, Certificates of Reoccupation and evidence of correct waste disposal to the Project Manager within ten working days of the completion of the work. Practical completion and the final release of retention monies or the authorisation for payment of a contractors invoice can only be achieved after copies of the test certificates, certificates of reoccupation and evidence of correct waste disposal have been delivered by the Contractor to the Authority Asbestos Removal Contractors & Sub Contractors Will be responsible for: Ensuring that they have a current license from the HSE to work with the type of asbestos indicated Ensuring that they have current and adequate insurance cover for the asbestos works to be undertaken Ensuring working practices are in compliance with current legislation and all associated Approved Codes of Practice and Guidance Notes Attending site to assess and prepare quotations against asbestos work specifications. The contractor or sub contractor must raise any issues relating to health and safety or potential additional costs, on the project to the instructing officer/project manager Attending site meetings as may be required Providing a written Method Statement and Risk Assessments to the Project Manager and the Statutory Authority. The Risk Assessments and Method Statement must indicate the resources and timetable allocated to the project. Emergency procedures must be discussed, and agreed, with the Project Manager/Contract Administrator/Designer and Person in Control, as appropriate before work commences Providing statutory notice to the Health and Safety Executive as may be required prior to the commencement of any asbestos related works or, by agreement with the Project Manager, applying for a waiver against the minimum notice period. Copies of all such notices must be submitted to the Project Manager before work commences Carrying out their obligations under the contract, including maintaining March
23 high standards of safety and hygiene in asbestos works and all related work areas and supplying labour, materials and equipment of the highest standard, complete with all supporting documentation as may be required Arranging transport and disposal of asbestos waste materials in accordance with legislative requirements and providing copies of all Consignment Notes to the Project Manager Carrying out regular inspections of the work environment. Any defects found, or any reported by the Authorities representatives, must be rectified immediately Identifying any additional elements of work which are to be agreed. The Method Statement must be updated accordingly Liaising with the appointed Asbestos Consultant to ensure the satisfactory progress of the works Providing copies of all test certificates, Certificates of Reoccupation, evidence of correct waste disposal to the Project Manager within ten working days. Practical completion and the final release of retention monies or the authorisation for payment of a contractors invoice can only be achieved after copies of the test certificates, certificates of reoccupation and evidence of correct waste disposal have been delivered by the Contractor to the Authority Taking appropriate steps as may be required to maintain safe access and egress where existing means of access and egress are temporarily affected by asbestos working enclosures Asbestos Consultant Will be responsible for: Maintaining and demonstrating UKAS accreditation to ISO and 17025, and an HSE supervisory license Maintaining adequate insurance cover for the tasks to be undertaken Providing support to the Project Manager as may be required Reviewing and commenting, when requested by the Project Manager on asbestos works such as: specifications, Contractor s and/or sub contractors Method Statement, work procedures etc Carrying out analytical works and inspections as agreed with the Project Manager. Where site conditions alter, the Asbestos Consultant will be required to amend the level of testing and inspections to ensure that all information relevant to the continued health and safety of the Contractor and building occupants is obtained Reporting to the Project Manager or his representative, any defect or non-compliance relating to the Contractor s and/or Sub Contractor s March
24 performance, including suitability of the work area, adherence to the Method Statement, Statutory Instruments and the Authorities Asbestos Policy and Procedures. Where the Project Manager is not immediately available the surveyor/analyst will be expected to take such measures as may be deemed necessary to ensure the continuing health and safety of Contractors and Sub Contractors and building occupants. These actions must be reported to the Project Manager as soon as reasonably practicable Checking areas on completion of asbestos remedial works to ensure that the contractor has completed his scope of works and all affected areas have been left in a satisfactory condition Carrying out air monitoring tests as may be required by the Project Manager or his representative, or as identified in the Risk Assessment Reporting to the Project Manager and others as may be appropriate, any aspects of asbestos management encountered on site which could give rise to health risks e.g. breaches of the Asbestos Policy and Procedures, suspect or damaged asbestos Issuing formal reports, including Certificates of Re-occupation, to the Project Manager on completion of any site works Taking appropriate steps as may be required to maintain site access and egress where existing means of access and egress are temporarily affected by asbestos working enclosures Officers Responsible for Property Acquisition and Disposal All officers 6 responsible for property acquisitions and disposal will be responsible for: Ensuring compliance with Plymouth City Council s Asbestos Policy during all activities associated with property acquisitions and disposal Ensuring that Plymouth City Council owned assets will be referred to the Head of Asset Management or Director of Community Services [Housing] 7 to ensure asbestos surveys are undertaken to identify the location/condition of asbestos containing materials (ACMs) assisting compliance with the asbestos management duties under Regulation 4 Control of Asbestos Regulations Ensuring that assets acquired by PCC on a full repairing lease are treated as Plymouth City Council owned property: as above Ensuring that assets acquired by PCC where repair obligations in the lease dictate PCC s legal/contractual responsibility for identified building elements/components are treated as Plymouth City Council owned property: as above. 6 The Property Surveying Team in Asset management (Ext 5567) and PCC Legal shall need to be involved with all property acquisitions and disposal activities from initial inception. PCC shall need to ensure where reasonably practicable that newly acquired assets do not have unacceptable risks associated with ACMs or unmitigated risks associated with ACMs awaiting asset disposal. 7 Refer to Responsibilities of Head of Asset Management/ Director of Community Services [Housing] in March
25 Ensuring that no new property (either freehold/leasehold or rented) may be acquired or occupied by PCC until the presence and condition of asbestos containing materials is confirmed by the provision by the landlord or the property seller of detailed existing asbestos records (Type 2 asbestos register in compliance with HSE guidance MDHS100 and HSG227). If this information is not available ensuring prior to the formulation of any legal acquisition or occupation agreement that a Type 2 asbestos survey report is completed Ensuring that no new property (either freehold, leasehold or rented) may be acquired or occupied by PCC until the effects of the existence of ACMs on any future building, refurbishment, improvement or remodelling works have been fully considered Ensuring that no new property (either freehold, leasehold or rented) may be acquired or occupied until the effects of the existence of ACMs on the future operational management of the property have been fully considered Ensuring that where applicable and possible all Plymouth City Council property is let on a full repairing lease making the tenant wholly responsible for asbestos management, building repair and statutory compliance obligations Ensuring that where Plymouth City Council owned property is either sold (disposal to a third party) or let on a full repairing lease (where all maintenance repairs etc are the tenants responsibility) that PCC complies with the legal duty to co-operate by providing the new owner or tenants any existing asbestos records. If such records are not available PCC shall advise the future tenants of the need to comply with the asbestos management duties under Regulation 4 Control of Asbestos Regulations Ensuring that derelict/abandoned PCC premises which are sound and being held for future re-use are effectively secured against vandals and unauthorised third party access. ACMs should be labelled (refer to Procedure 2) and monitored to ensure they remain in good condition Ensuring that derelict/abandoned PCC premises which are in poor condition or have been identified for disposal are effectively secured with ACMs labelled (as ) or ACMs in poor condition are removed before the building is sealed by a HSE licensed asbestos contractor to allow for disposal or demolition of the asset Ensuring that any plant, equipment, fixture or fitting not forming part of the premises is disposed of by a competent HSE licensed asbestos contractor. 3.4 Asbestos Budget Occupational Management of Asbestos: Costs associated with administering occupational management of Asbestos shall need to be covered by existing establishment budgets. Prioritisation of asbestos works related to the Corporate Portfolio March
26 and financed from the central maintenance budget shall comply with the contents of Plymouth City Council s Corporate Building Maintenance Strategy (available on Asset Management s website: ). The Corporate Building Maintenance Strategy provides detailed procedural guidance for planned and reactive maintenance works prioritisation. A copy of the works prioritisation matrix is contained in Appendix B 8. The Corporate Building Maintenance Strategy maintenance spend matrix, although not mandatory, is recommended for both the School and Housing portfolios Project or maintenance related asbestos costs: The costs of asbestos works (including the commissioning of a type 3 asbestos survey prior to works commencement or repair, encapsulation or removal works related to ACMs) shall need to included within the overall allocated project budget. The works shall fully comply with the Control of Asbestos Regulations Personal injury claim settlements, property damage and emergency rectification works: In October 2005 the Council s Public Liability issuers withdrew cover in respect of public liability claims relating to the presence of/exposure to asbestos. This standard practice in the insurance market means that the Council will have to assume the risk where it negligently exposes third parties to an asbestos related injury or negligently damages property. Although Plymouth City Council s Risk & Insurance Team (contact ext 4967 or 4921) continue to handle any future claims, the final costs related to personal injury or property damage have to be met by individual departments, due to the withdrawal of cover for asbestos-related claims. The overall costs of any personal injury claim settlements or rectification works following property damage will be charged to the relevant departmental revenue budget Property acquisition & disposal - Project related asbestos costs: Any property acquisition & disposal activities (leased/rented property, owned property, derelict or abandoned premises) will need to include the costs of asbestos within the overall project costs and allocated revenue or capital budget. The costs of asbestos works (including the commissioning of a type 2 asbestos survey prior to acquisition & disposal) shall need to included within the overall allocated project budget. Newly acquired property should not pose unacceptable cost/asbestos management liabilities. 3.5 Asbestos Training The appropriate level of asbestos training is a prerequisite of ensuring effective asbestos management within the Council. Asbestos training will allow:- 1) Each individual to acquire the appropriate level of knowledge and skills to comply with asbestos legislation, ensuring effective asbestos management within the Council in compliance with the Control of Asbestos Regulations 2006 and Plymouth City Council s Asbestos Policy. 2) To ensure the appointment of a sufficient number of competent persons to assist with Asbestos Policy implementation and legislation compliant asbestos management activities. 8 An emergency or prioritised asbestos maintenance request will lead to generation of a high priority related to any property type. March
27 Plymouth City Council s asbestos training needs and the associated budget and commissioning arrangements can be summarised as follows:- Person in control asbestos awareness training (PIC network): Corporately funded training to aid persons in control with asbestos management duties in the premises they control or work within, including the implementation of management action plans, in compliance with Regulation 4 of the Control of Asbestos Regulations Attendees would include Persons in Control (headteachers, building manager and responsible persons), kitchen managers, caretakers, cleaners, DLO operatives and clients, project managers, contract, administrators, designers. BIOH P402 Asbestos Surveying and P405 Asbestos Management: to enable technical Officers [Asset Management/Community Services (Housing)] manage the corporate asbestos registers, undertake asbestos surveying support (type 2 and type 3 asbestos surveys), assist with the duties under legislation/plymouth City Council s Asbestos Policy (i.e. emergency contingency plan in the event of a suspected asbestos incident) and allow the provision of specialist asbestos management advice as part of the PIC support network. Provided by a competent accredited external training organisation. The Costs are to be met by individual departmental budgets. General Contractor Awareness Training: Adequate training must be provided as part of the Contractor s general Health & Safety training arrangements and quality assurance procedures (evidenced by CHAS registering). Costs met by Contactors themselves. Asbestos Removal Training: to enable asbestos removal operations as part of Community Service s [Housing] Asbestos Team): Provided by a competent qualified accredited external training organisation: Costs to be met by individual departmental budgets. Generally, managers have the responsibility to identify individuals they manage who require competency training to ensure the effective implementation of activities directly or indirectly related to asbestos management. Additionally, other training (i.e. Person in Control workshops) shall be operated by the Authority to ensure that persons responsible for operational management of premises/maintenance of premises are provided the opportunity to attend training. Evidence of asbestos training will need to be placed by managers on employee s personal files to enable review processes to be undertaken. March
28 PART 3: Plymouth City Council - Asbestos Policy Procedures. Procedure 1: Plymouth City Council Asbestos Warning Notice Procedure 2: Plymouth City Council Asbestos Labelling Policy & Label Examples Procedure 3: Plymouth City Council Permit to Work AND Asbestos Register Acknowledgement Form Procedure 4: Asbestos: Notification of Change of Status Procedure 5: Contingency Plan Required in the Event of Suspected Asbestos Incident Procedure 6: Report of Suspected Accidental Exposure to Airborne Asbestos Fibres (including Form ASB001) Procedure 7: Minor Works: Reactive & Preventative Maintenance Works. Procedure 8: Flow Diagram Aide Memoire: Organisation & Control of Contractors or Works to Plymouth City Council s Buildings, Structures or Assets Procedure 9: Checklist Aide Memoir: HSE Licensed Asbestos Contractor Selection Procedure 10: Asbestos Surveys March
29 PART 3: Plymouth City Council - Asbestos Policy Procedures. Procedure 1: Plymouth City Council Asbestos Warning Notice Persons in Control (headteachers, building managers or responsible persons) or others responsible for the management of asbestos in Plymouth City Council buildings, structures or assets may find the adoption and use of asbestos warning notices a useful asbestos management tool, as part of their implemented management action plan. PLYMOUTH CITY COUNCIL ASBESTOS WARNING NOTICE WARNING ASBESTOS MAY BE PRESENT IN THIS BUILDING Please ask to see the Asbestos Register held by the Person in Control of the premises before you carry out any work Do not cut, drill or abrade any material that contains asbestos or that you suspect may contain asbestos. The Asbestos Register, if appropriate, shows the known locations of suspected asbestos compiled from a visual inspection only. It is possible that asbestos exists in areas hidden from view. Do not assume there is no asbestos present if there is no entry on the Register or if there is no Register. If you suspect the presence of asbestos, do not disturb the material and seek advice from your Manager AND the Person In Control (headteacher, building manager or responsible person) of the premises. If you discover any material which you suspect may contain asbestos and is not on the Asbestos Register or you notice that any asbestos material is damaged, please notify the Person In Control of the premises. March
30 Procedure 2: Plymouth City Council Asbestos Labelling Policy & Label Examples Persons in Control or those responsible for maintenance or the management of asbestos in Plymouth City Council buildings, structures or assets may find the adoption and use of asbestos labelling a useful asbestos management tool, as part of their implemented management action plan to prevent inadvertent disturbance of asbestos containing materials (ACMs). 1. All known Asbestos Containing Materials (ACM s) confirmed by an asbestos survey are to be labelled with standard asbestos warning stickers: see example over page. However, during implementation of the management action plan a Person in Control (headteacher, building manager or responsible person) may identify that the provision of asbestos labels to ACMs may be inappropriate to certain locations 1 (i.e. it may create adverse public relations or occupation problems). In such locations 1 red colour coded markers may be used as an alternative to labelling to ensure the prevention of inadvertent disturbance of ACMs as long as the colour coded scheme is clearly identified within the asbestos register and implemented management action plan and that suitable & sufficient instruction, communication and supervision is given to both occupiers and visitors to the premises (i.e. contractors etc). 2. The Person in Control (headteacher, building manager, responsible person, Asset Management, Community Services [Housing] etc) who is the maintenance budget holder will be responsible for the initial labelling of ACMs. 3. The Person in Control (headteacher, building manager or responsible person) who is located at the premises and responsible for operational management will be responsible for the continued presence and attachment of the labels after the initial installation (as 2 above). 4. As part of the management action plan the Person in Control (headteacher, building manager or responsible person) shall undertake, at regular intervals, a procedure to check that the labels are still present and legible and any damaged or missing labels are replaced. 5. The Person in Control shall ensure that suitable communication and consultation occurs with building occupiers to ensure that such persons are informed of the reasons for the labelling and asked to report any damage to the ACMs or the labels to the person in control. 6. All Asbestos labels shall comply with the Health & Safety (Safety Signs and Signals) Regulations, Label fixing shall comply with HSE Guidance. 7. In unoccupied areas with restricted access such as boiler rooms, service ducts and other plant and equipment rooms, it may be appropriate for the Person in Control (headteacher, building manager or responsible person) to affix a sign to 1 Locations may include public amenable areas (i.e. reception or waiting rooms in corporate premises etc), school classrooms or halls, social services residential locations (rest rooms, bedrooms etc) and Housing Communal areas (staircases, corridors, lifts etc) March
31 the outside of the access door to give warning to anyone liable to work in the area or the Emergency Services: see example over page. Example of Standard Asbestos, Label Warning Example of Sign Fixed to Unoccupied Area (i.e. boiler room Door). Note: Alternative signage from the examples indicated above may be applicable depending on the particular circumstances (all signage to comply with the Health & Safety, Safety Signs and Signals Regulations, 1996). Advice can be obtained from your health and safety advisor. March
32 Managing Asbestos in Buildings Policy Procedure 3: Plymouth City Council Permit to Work AND Asbestos Register Acknowledgement Form Persons in control (headteacher, building manager or responsible person) or others responsible for the management of asbestos in Plymouth City Council buildings, structures or assets may find the adoption and use of an asbestos permit to work and/or an asbestos register acknowledgement form a useful asbestos management tool, as part of their implemented management action plan to prevent inadvertent disturbance of asbestos containing materials (ACMs). ASBESTOS POLICY PERMIT TO WORK 1. Permit Number: 2. Contractor s Name: 3. Valid From: Time To: Time Date: 4. Property: 5. Job Location: 6. Description of Works: 7. Authorisation: The Asbestos Register for the premises has been consulted and any areas which contain Asbestos have been pointed out to the contractor named above. The procedure to be followed on discovering asbestos/suspected asbestos containing materials has been indicated to the contractor. Person in Control s Signature: 8. Acceptance: Date: I have read and understand this permit and will undertake to work within the conditions in it* and inform all persons under my supervision of its contents. Contractor s Signature: Date: *Delete if not applicable 9. Completion of Work: The work has been completed and all persons under my supervision, materials and equipment have been withdrawn. Contractor s Signature: 10. Cancellation: Date: I hereby declare this permit to work cancelled. Person in Control Signature: Date: March
33 ASBESTOS POLICY ASBESTOS REGISTER ACKNOWLEDGEMENT FORM Asbestos Register For To be signed by all persons who could disturb asbestos [no matter how trivial the work] before commencing any maintenance/refurbishment/repair on these premises I acknowledge that I have seen and made myself familiar with the premises Asbestos Register for this site. I understand that works of a destructive nature require a pre-assessment to ensure possible hidden asbestos is identified before works commence. If I should uncover a suspicious material or accidentally damage an asbestos containing material, I will stop work, isolate the area and report the matter to the Person in Control of the premises. Company Nature of Work Date Name Signature March
34 Procedure 4: Asbestos: Notification of Change of Status Persons in Control (headteachers, building managers or responsible persons) or others responsible for the management of asbestos in Plymouth City Council buildings, structural & assets need to review and update their premises-based asbestos register with any changes (i.e. inclusion of project information, the results of additional asbestos surveys, or changes in the condition of asbestos containing materials). A copy of the update information, by completing the notification of change of status form to allow the corporate asbestos registers held by the Head of Asset Management/Director of Community Services [Housing], to also be updated. ASBESTOS: NOTIFICATION OF CHANGE OF STATUS (to enable the Updating of the Corporate Asbestos Register) TO: The Head of Asset Management, Civic Centre, Floor 13 or The Director of Community Services [Housing], Floor 3, Windsor House FROM: Name: Department/Company: Property Details: Property ID: Property Name/Number: Address:.... Post Code: Work Details: It is recommended that a plan is attached indicating the location of the recent works or affected ACM and/or detail the asbestos sample number (as contained in the site based Asbestos Register, if applicable). Please give precise }. details of all works }. carried out involving }. asbestos }. Was all asbestos removed? Yes No If no state quantity remaining.m 2 Was remaining asbestos encapsulated? Asbestos warning label in place? Yes Yes No No Order number for work:.. Approx. Value:. Name of Contractor:. Address: Asbestos License No: Any other relevant information:. Signed:.. Position: Date:. March
35 Database amended and revised register details issued. Procedure 5: Contingency Plan Required in the Event of an Asbestos or Suspected Asbestos Incident Plymouth City Council s Contingency Plan Procedures shall be followed in the event of an unexpected exposure or suspected danger of exposure to asbestos containing materials (ACMs) and applies to all buildings, structures or assets owned, managed or utilised by Plymouth City Council. 1. If asbestos is disturbed the degree of risk to health will depend on factors such as the type and amount of airborne asbestos fibres and type, ventilation of the area and location and condition of the asbestos containing material. 2. All unexpected asbestos disturbance must be reported immediately to enable a thorough evaluation, including analysis of airborne fibres and materials concerned, to be carried out and for emergency and remedial measures to be implemented including, if necessary, notification to the Health & Safety Executive by the Plymouth City Council s Corporate Health and Safety Team. 3. The action being taken on unexpected disturbance of asbestos containing materials is:- i. Cease work ii. Do not vacuum clean iii. Close the area (doors and windows) and withdraw all persons 4. The incident shall be reported immediately to the following: Contract Supervisor (if appropriate) Person in Control (headteacher, building manager, responsible person) of the area or building in which the problem occurred Plymouth City Council Corporate Health & Safety Team Asset Management Building Surveyors or Community Services [Housing] Refer to Chart 1 (Executive Summary) for telephone numbers/communication links. 5. There should be an immediate site meeting to decide on measures required which may include one or more of the following:- evacuation, closure and sealing-off of the area concerned, sampling/analysis of the material concerned, air sampling in the area concerned, survey/assessment of the extent of the problem, notification of the incident to the Health & Safety Executive, report of suspected accidental exposure to airborne asbestos fibres (Refer to Procedure 6), consultation with an appropriate Plymouth City Council Technical Officer (Asset Management Building Surveyors or Community Services [Housing] and an HSE Licensed Asbestos Contractor over remedial works required, notification to Council s Press Officer, notification to Chief Executive and appropriate Director, arrangements for any remedial works required including funding, arrangements for clearance and re-occupation of the area, arrangements for temporary relocation of activities normally carried out in the area concerned, March
36 reporting of the incident to appropriate Members and Committees. 6. A further meeting should be held and chaired by the Corporate Health & Safety Team, after the matter has been fully dealt with, to review the incident, determine what measures, if any, could be taken to prevent a recurrence, draw up and circulate an appropriate advisory notice and make recommendations for inclusion in the Asbestos Policy at the next review. Procedure 6: Report of Suspected Accidental Exposure to Airborne Asbestos Fibres (including Form ASB001) Plymouth City Council s Reporting Procedures shall be followed if a suspected accidental exposure to airborne asbestos fibres is believed to have occurred and applies to all buildings, structures or assets owned, managed or utilised by Plymouth City Council. 1. Plymouth City Council employees are not normally involved in work with asbestos or with any product containing asbestos to which the Control of Asbestos Regulations are principally directed (except Community Services [Housing] Asbestos Team). The usual circumstances in which asbestos may be encountered is related to building materials, which contain asbestos. Asbestos fibres may be released into the atmosphere when: a. Contractors are disturbing such materials, or b. Asbestos containing materials have been damaged. 2. If any employee comes into contact with airborne asbestos fibre in the course of their employment they should report the circumstances on the form entitled REPORT OF SUSPECTED ACCIDENTAL EXPOSURE TO AIRBORNE ASBESTOS FIBRES FORM ASB001 (overleaf). 3. Sections A & B of the form are to be completed by the employee, the incident confirmed by their line manager s signature, Section C is to be completed by the Person In Control (headteacher, building manager, responsible person) for the premises, and returned to the Corporate Health & Safety Team in the Civic Centre. 4. Once the form is completed by the Corporate Health & Safety Team it will be held on the H&S record system and a copy returned to the employing department to be filed on the individual s personal file. March
37 PLYMOUTH CITY COUNCIL REPORT OF SUSPECTED ACCIDENTAL EXPOSURE TO AIRBORNE ASBESTOS FIBRES SECTIONS A AND B TO BE COMPLETED BY EMPLOYEE AND LINE MANAGER, SECTION C TO BE COMPLETED BY THE PERSON IN CONTROL FOR THE PREMISES, AND SENT TO THE HEALTH & SAFETY TEAM, CIVIC CENTRE, PL1 2AA SECTION A PERSONAL DETAILS Surname: Date: Employee Reference Number: Forenames: Department: Job Title: SECTION B DETAILS OF INCIDENT LEADING TO SUSPECTED EXPOSURE TO ASBESTOS FIBRE I believe I have been exposed to airborne asbestos fibre in the course of my employment with this Authority. (i) (ii) (iii) (iv) (v) (vi) Description of incident which led to suspected exposure: Date incident occurred. Time of suspected exposure from to. Activity at time of suspected exposure.. Building and exact location where suspected exposure occurred.. Source of asbestos. To whom was incident reported.... Signature: Name:.. Date:. Signature (Manager): Name:.. Date: March
38 SECTION C THIS SECTION TO BE COMPLETED BY THE PERSON IN CONTROL* AND RETURNED TO THE HEALTH & SAFETY TEAM Reference Number:.. Item Number (i) Composition of material.. (ii) Was the material painted/sealed and/or protected in any other way? (iii) Asbestos type and % content. (iv) Result of air sample taken Date:. (v) Action taken by Person in control or Manager responsible: NONE/REPAIRED/RESEALED/REMOVED (vi) Date Asbestos Register updated.. (vii) Incident recorded on Asbestos Register YES/NO (viii) Has the Person in Control of the premises revised the management action plan? YES/NO Signature:.. Name:. Date:.. Job Title:. SECTION D TO BE COMPLETED BY EMPLOYEES LINE MANAGER Appointment with Date... Attended/Not attended Statement/Comments:.... Date completed copy despatched to Department for Medical File and copy to employee Signed:. Date. Job Title: SECTION E TO BE COMPLETED BY HEALTH & SAFETY TEAM Date received from employee: Date passed to Health & Safety Team: Occupational health referral recommended?.. Accepted/Refused THIS RECORD TO BE RETAINED WITHIN EMPLOYEES MEDICAL FILE FOR FORTY (40) YEARS FROM DATE EMPLOYEE CEASED EMPLOYMENT WITH THE AUTHORITY *In liaison, if applicable, with Asset Management Building Surveyors or Community Services [Housing] March
39 Managing Asbestos in Buildings Policy Procedure 7: Minor Works: Reactive & Preventative Maintenance Works. 1. Minor works are those which are normally actioned by the issuing of a works order or instruction, do not normally require pre-assessment and may include emergency, reactive, routine, day-to-day or other small jobs which do not normally require preparation of specifications, schedules, drawings or other contract documents. 2. It would not be practicable or reasonable for this type of work to be pre-surveyed for asbestos due to the vast number of orders raised, and the effect this would have on response times, service delivery and costs. 3. Minor works and reactive & preventative maintenance work is carried out by external contractors and by in-house staff. 4. When an order number is received which involves work that will interfere with the fabric of a PCC building, it is the Maintenance Operative s responsibility to view the premises based Asbestos Register (normally kept at the reception or held by the Person in Control) to determine whether asbestos is present. If no asbestos is identified then the works can proceed with caution bearing in mind the possible presence of ACMs not identified in the Asbestos Register The following procedures shall be observed: Comply with the responsibilities under Asbestos Policy Section 3.3 In particular (general contractors and sub-contractors), (asbestos removal contractors & sub-contractors) and (asbestos consultant). People carrying out these works should receive training and instructions on asbestos awareness, recognition and procedures for reporting its discovery. If unexpected potential asbestos containing materials are discovered during the works they must not be disturbed but the incident reported to the originator of the works request (Client) who will arrange for an asbestos inspection and priority assessment. If the material has been inadvertently disturbed then the incident shall need to be reported immediately to enable the instigation of the Emergency Contingency Plan: refer to Procedure 5. If the works or their locations are significantly different from the works order or if the resultant repairs are likely to involve or affect other elements of the building (i.e. awkward working conditions or areas with restricted access in close proximity to assumed ACMs) refer back to the originator before proceeding. 6. Works Orders/Site Instructions must contain, where possible, the following standard message in bold print:- WARNING: THIS LOCATION MAY NOT HAVE BEEN ASSESSED FOR THE PRESENCE OF ASBESTOS BE VIGILANT REPORT SUSPECT MATERIALS TO YOUR SUPERVISOR. 1 The premises based asbestos register is not destructive and does not, therefore, show details of any concealed asbestos-based materials. Should you have reason to believe that materials encountered whilst carrying out the work might contain asbestos they should be presumed to do so until proven otherwise. All work should cease and the emergency contingency plan commenced immediately: refer to Procedure 5. March
40 Procedure 8: Flow Diagram Aide Memoire: Organisation & Control of Contractors or Works to Plymouth City Council s Buildings, Structures or Assets The following actions are an outline guide which may need to be undertaken related to any demolition, maintenance or any other work liable to expose employees to asbestos or affect the services and/or fabric of a building: You want to arrange for some building work to be carried out to Plymouth City Council building, structure or asset Compliance with Regulation 5, Control of Asbestos Regulations 2006: Identification of the presence of asbestos Ensure you have read and understood Plymouth City Council s Asbestos Policy and the HSE Approved Code of Practice and related guidance. Consult the existing type 2 premises asbestos register to check if there is any asbestos in the area where the works are to be undertaken Preparation of suitable and sufficient assessment prior to commencement of the works: Initiate a Type 3 asbestos survey and written report in compliance with the HSE guide MDHS100 and HSG227. If the proposed works will disturb the fabric and/or services of the building (CAR2006 Regulation 5(a) and ACOP L143 Para 51 and 52(a)) or Assume existence of ambibole (blue/brown) asbestos and apply in full the provisions of the Asbestos Regulations 2006 (Regulation 5(b) and ACOP L143 Para 52(b)) Inform any person liable to disturb the ACM s, make the Type 2 and Type 3 information available prior to works commencement (ACOP L143 Para 49) Information to be included in project health & safety plan (larger project subject to the Construction, Design & Management Regulations), plan of work/method statement and risk assessments (ACOP L143 Para 50) Consider the use of a permit to work system on asbestos and warning notice. Ensure that the contractor/person carrying out the work is competent (refer to contractor selection over page), has the relevant level of experience/training and has produced a work specific and written plan of work (method statements) and risk assessments in full compliance with the Control of Asbestos Regulations 2006 and HSE ACOP L143: Regulation 1 to 37. Work need to be properly planned with a safe method of working established and recorded to ensure the safety of workers, building occupiers, etc. PCC Asbestos Policy directs that only HSE licensed can work on ACMs. Work in close proximity to ACMs may require a HSE licensed contractor. Undertake works on site. Ensure a suitable monitoring regime has been put in place by the client/project manager/contract administrator/designer. If any damaged or suspect material is discovered cease work immediately. Do not vacuum clean. Clear people from area and invoke the emergency contingency plan contained in Plymouth City Council Asbestos Policy: Procedure 5 Update the premises asbestos register with the Type 3 asbestos written report and any other information or circumstances that have changed the asbestos register during the works. Provide a copy of the update information by completing the notification of change of status form (contained in PCC Asbestos Policy: Procedure 4) and send to Head of Asset Management/ Director of Community Services [Housing] March
41 Procedure 9: Checklist Aide Memoir: HSE Licensed Asbestos Contractor Selection Contractor Selection: This means assessing the competence of the contractor prior to works commencement (i.e. during the pre-works planning stage). The extent of the assessment will depend on the nature of the work involved and whether the contract is simple (e.g. minor repairs) or more substantial. Helpful indicators are: Adequate insurance cover Inclusion on Plymouth City Council s approved list of asbestos contractors (CHAS registration) Past performance Work undertaken for others Membership of trade bodies Health & Safety policy Organisation for Health & Safety Commitment to recognised Health & Safety Executive Approved Codes of Practice (ACOPs) Is the contractor HSE licensed if undertaking asbestos works? Is the licence valid? Work method statement/plans of Work acceptable? Asbestos awareness and training Is the analyst UKAS approved? Has the Contractor notified the HSE of the works? Works compliance with associated HSE ACOPs, Regulations and Guides Compliance with PCC Control of Contractors Health & Safety Performance Standard (HSPS09) Procedure 10: Asbestos Surveys Health & Safety Executive Guidance MDHS100 refers to three types of asbestos survey:- Type 1: Location and Assessment Survey ( presumptive survey ): A Type 1 survey locates, as far as reasonably practicable, any materials suspected of containing asbestos to allow assessment of risk of all accessible parts of a building. However, the survey is limited to presumption and defers the need to sample and analyse presumed asbestos containing materials (ACMs) to a later time. A Type 1 asbestos survey is a detailed visual examination of accessible parts of a building (it will not identify hidden or enclosed materials contained in a building s structure refer to Type 3 below) and provides the basis of the establishment of an Asbestos Register which is used by the Person in Control (headteacher, building manager, responsible person) for the development of management action plans to effectively manage the building s day-to-day occupational activities. Type 2: Standard Sampling, Identification and Assessment Survey ( sampling survey ): The purpose and procedures used are the same as Type 1 (as above) except that this type includes representative sampling and analysis by a UKAS accredited laboratory to confirm or refute the surveyor s judgement and presumptions. Type 3: Full Access, Sampling and Identification Survey ( destructive inspection ): Survey used where major refurbishment or demolition is planned and includes destructive inspection to all concealed parts of a building to establish the presence of ACMs. The installation of services where cabling operations will be required (i.e. data cabling) or the fitting of components or equipment into the fabric of a building will also necessitate a Type 3 asbestos survey. A type 3 survey should also review adjoining areas that may be affected during the works (i.e. inadvertent disturbance of ACMs by operatives, materials or plant). March
42 APPENDICES Appendix A: PCC Corporate Asbestos Management Implementation Programme [The programme dates associated with each task will be completed following consultation of the Asbestos Policy by the Corporate Health & Safety Committee]. Appendix B: Maintenance Spend Matrix: Ratings for the determination of (Asbestos) works priority (Taken from the Corporate Maintenance Strategy: available on Asset Management s website: Appendix C: Management Action Summary Options. Appendix D: Asbestos Management Examples Appendix E: Summary information related to Asbestos and its Health Effects Appendix F: Bibliography and Guidance to Further Information & Organisations Providing Asbestos Related Advice. March
43 Managing Asbestos in Buildings Policy Appendix 1 March
44 March
45 Managing Asbestos in Buildings Policy Appendix B: Maintenance Spend Matrix: Ratings for the determination of maintenance works priority (Corporate Plymouth City Council Properties, subject of the Centralised Maintenance Budget). Property: Condition: Rating Rating Description Rating Rating Description S1 S2 S3 S4 S5 Core service, critical or high profile asset to be in best possible condition. Core Service, asset to be in good condition operationally and aesthetically. Core service, asset to be reasonable condition to meet operational and statutory requirements. Non-core service, operational property condition needs to meet minimum operational and statutory requirements. Non-core service, non-operational property maintained to meet statutory requirements only. Grade A Grade B Grade C Grade D Good. Performing as intended and operating efficiently. Satisfactory. Performing as intended but exhibiting minor deterioration. Poor Exhibiting major defects and/or not operating as intended.. Bad. Life expired and/or serious risk of imminent failure. Priority: Reason Ratings: Rating Rating Description Rating Rating Description Priority 1 Urgent work that will prevent immediate closure of premises and/or address an immediate high risk to the health and safety of occupants and/or remedy a serious breach of legislation. R1 R2 Health & Safety Breach. Breach of Legislation. Priority 2 Essential work required within two years that will prevent serious deterioration of the fabric or service and/or address medium risk to the health and safety of occupants and/or remedy a less serious breach of legislation. R3 R4 R5 Deterioration of Fabric. Revenue Implications. Council Objectives/ Priorities. Priority 3 Desirable work required within three to five years that will prevent deterioration of the fabric or services and or address a low risk to the health and safety of occupants and/or remedy a minor breach of legislation. March
46 Managing Asbestos in Buildings Policy Maintenance Spend Matrix Example: Asbestos Containing Material (ACM) Example1: Therefore: Core Service high profile asset: ACM in poor condition and a major health & safety risk. Property = S1, Condition = C, Priority = P2, Reason = R3 Property & Condition Priority & Reason Condition Property D C B A S1 R S2 S3 S4 S5 Priority Reason R1 R R2 R3 R4 R5 Total Score Property & Condition Priority & Reason Red Amber Green Red R R Amber Green RR = Immediate action. March
47 Managing Asbestos in Buildings Policy Appendix C: Management Action Summary Options HSE ACOPs and Guidance 1 provides detailed examples of management action options. However, the following table provides basic summary management action options concerning asbestos containing materials: Minor Damage The material should be repaired and/or encapsulated. The condition of the materials should be monitored at regular intervals. Where practical the material should be labelled. Inform the contractor and any other worker likely to work on or disturb the material. Poor Condition Asbestos in poor condition should be removed. Good Condition The condition of the materials should be monitored at regular intervals. Where practical the material should be labelled. Inform the contractor and any other worker likely to work on or disturb the material. Asbestos Disturbed Asbestos likely to be disturbed should be removed. Use of the General Control Hierarchy may also provide assistance to determine the correct management action in a particular circumstance:- 1. Eliminate 2. Reduce 3. Isolate 4. Control 5. Personal protective equipment 6. Discipline 1. Refer to ACOP L143 work with materials containing asbestos: Control of asbestos Regulations 2006, HSG 213 Introduction to asbestos essentials: comprehensive guidance on working with asbestos in the building maintenance & allied trades, HSG 210 Asbestos essentials and Contruction Design & Management Regulations 2007: Refer to Appendix F. March
48 Appendix D: Asbestos Management Examples: Occupational Management Example 1: A maintenance contractor calls at your community centre to carry out work. As the receptionist you have been told by your manager (Person in Control of the premises) to ensure that all appropriate visitors to the premises (i.e. contractors) use the type 2 asbestos register that you keep at reception. You show the contractor the asbestos register and signs the asbestos register acknowledgment form, or permit to work form (Procedure 3). This allows compliance with the legal duty to pass asbestos information to those who may be at risk. Project/Works Example 2: A school caretaker puts up white boards and uses an electric drill to fix the new boards to the old blackboards, some of which contain white asbestos. The caretaker (and the other building occupiers) would be exposed to asbestos dust unless either disturbance of the building fabric is avoided or controlled conditions are used following a risk assessment (i.e. type 3 destructive asbestos survey). You are his line manager and are responsible for preventing unsafe work. Example 3: An architect is working directly for a school and correctly understands that it will be his responsibility to obtain a project specific asbestos investigation (type 3 asbestos survey). To allow this to happen he will need to decide on the extent and level of asbestos information needed to inform her particular project. If applicable she will design out any asbestos issues, or alternatively ensure that any future works concerning asbestos containing materials are managed in compliance with the Control of Asbestos Regulations Emergency Contingency Example 4: As Person in Control of an operational depot you are informed by an employee that a forklift truck has just collided and damaged a material within a warehouse known from the premises-based asbestos register as being an asbestos containing material. You immediately invoke the asbestos emergency contingency plan by ensuring that all works in the warehouse stop, personnel are withdrawn and the area is isolated. You also contact your health and safety advisor, who in turn contacts the Asset Management Building Surveyors or Community Services (Housing) to allow the rest of the contingency plan to be implemented. You later review your original risk assessments/method statements etc related to forklift truck operations to ensure that a safe system of work is maintained and the condition of ACMs is safeguarded. Property acquisition Example 5: As Head of Service you have identified a new building that you would like to lease to allow the delivery to the Plymouth public of your departmental service. You decide to gain authorisation from Committee, but do not ask either Asset Management or Legal for assistance or input, as you consider that additional involvement will increase the time line related to final occupation. After lease completion the recently appointed architect has indicated that the proposed alteration works will be costly as the building fails to meet statutory requirements: it contains blue asbestos lagging in poor condition to the plant room and heating distribution pipe work. To make things worse your Director has asked why you failed to instigate a feasibility study as part of your business case and also why you have not met your responsibilities for property acquisition under the asbestos policy. March
49 Appendix E: Summary Information related to Asbestos, its Health Effects 1. What is Asbestos? Asbestos is a name given to several mineral silicates found naturally within rock and mined to facilitate various commercial uses including the production of building materials. There are two main groups of asbestos (serpentines and amphiboles) and three main asbestos types from within the two groups used in material production (chrysotile or white, amosite or brown and crocidolite or blue). The type of asbestos cannot be identified just by its colour. All types of asbestos can be dangerous if disturbed. 2. Why was asbestos used? The physical & chemical properties of asbestos have determined its use and commercial value. These may be summarised as follows: Flexibility and acoustic insulation properties; High tensile strength; Incombustibility (fire resistance); Low thermal conductivity (insulation material & friction product) Resistance to chemical attack. 3. When was asbestos containing materials used in the UK? Asbestos imports into the United Kingdom commenced at the end of the 19 th Century, with peak demand occurring circa The asbestos prohibitions regulations banned the use of asbestos containing materials (ACMs) in 1985, 1992 (blue and brown), and 1999 (white). It is possible that ACMs could exist within any property built or refurbished up to implementation of the asbestos prohibition regulations (this is thought to be up to 500,000 commercial, industrial and public buildings in the UK). Materials containing asbestos include loose insulation, sprayed coatings, thermal insulation, asbestos boards, paper, felt & cardboard, textiles (ropes, cloth and gaskets etc), friction products (machinery, lifts etc), cement products (profiled sheets etc), textured coatings (ceiling artex etc, bitumen products, flooring and reinforced plastics (toilet cisterns/seats, windowsills etc). In fact thousands of building materials are known to contain asbestos. 4. What are the health effects related to asbestos dust exposure? Generally, asbestos if well maintained and managed is not a risk to health. However, if disturbed by maintenance/refurbishment activities (i.e. involving sawing, grinding or drilling operations) or damaged by day-to-day operational functions undertaken by a premises occupier the dust or airborne asbestos fibres can lead to potential irreversible damage to health. The main illnesses caused by asbestos may be summarised as follows: Asbestosis Scaring of the lung tissue making breathing difficult. Mesothelioma Cancer of the lining of the chest, abdominal wall or heart lining. Lung cancer Risk increased for smokers. Pleural Plaques Bands of scar tissue on lungs. Skin complaints Asbestos fibres can penetrate the skin creating asbestos warts. Other cancers Research suggests asbestos exposure can cause other cancers. March
50 All the types of asbestos can cause illnesses. The largest group of workers at risk are building orientated (particularly people involved in maintenance activities). According to the British Journal of Cancer there will be 500,000 asbestos related deaths in Western Europe over the next 35 years ( people are currently dying from asbestos-related diseases). The HM Government Minister responsible for Health & Safety has indicated the asbestos is the most serious occupational health problem in terms of fatal diseases that this country faces. 5. Why is it dangerous? Asbestos is made up of thin fibres. These can break down into much smaller and thinner fibres. The smallest fibres cannot be seen with the naked eye but they can be breathed in. Asbestos fibres are only dangerous if they are made airborne and breathed in, but ALL types of asbestos fibres are potentially fatal if breathed in. The fibres that are breathed in can become stuck in the lungs and damage them. This can cause scars that stop the lungs working properly (asbestosis), or it can cause cancer. The main types of cancer caused by asbestos are cancer of the lung and cancer of the lining of the lung (mesothelioma). These diseases can take from 15 to 60 years to develop and there is no cure for any of them. 6. Where do you find asbestos? You are most likely to find it in buildings built or refurbished before Many thousands of tonnes of asbestos products were used in buildings. Much of it is still there and you cannot easily identify these products from their appearance. The most common asbestos in buildings were: loose packing between floors and in partition walls; sprayed ( limpet ) fire insulation on structural beams and girders; lagging, e.g. on pipework, boilers, calorifiers, heat exchangers, insulating jackets for cold water tanks, around ducts; asbestos insulation board (AIB), e.g. ceiling tiles, partition walls, soffits, service duct covers, fire breaks, heater cupboards, door panels, lift shaft linings, fire surrounds; asbestos cement (AC), e.g. roof sheeting, wall cladding, walls and ceilings, bath panels, boiler and incinerator flues, fire surrounds, gutters, rainwater pipes, water tanks; other products, e.g. floor tiles, mastics, sealants, textured decorative coatings (such as artex), rope seals, gaskets (e.g. pipework), millboards, paper products, fire doors, cloth (e.g. fire blankets), bituminous products (roofing felt). Remember how dangerous the asbestos is depends on the type of asbestos and the type of material it is in, the condition of the material, and how likely the material is to be disturbed. 7. Who is likely to be exposed to asbestos fibres? Anyone who disturbs asbestos-containing materials, for example, by working on them or near them. Research has suggested that the groups most at risk are those who carry out building maintenance and refurbishment work, for example (this is not a complete list, nor in any March
51 particular order): demolition contractors; electricians; roofing contractors; painters and decorators; construction contractors; joiners; heating and ventilation engineers; plumbers; telecommunications engineers; gas fitters; fire and burglar alarm installers; plasterers; general maintenance staff; builders; computer installers; shop fitters; building surveyors. March
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53 Managing Asbestos in Buildings Policy APPENDIX F: BIBLIOGRAPHY AND GUIDANCE TO FURTHER INFORMATION ITEM TITLE TYPE HSE Ref ISBN CONTENT/AUDIENCE 1 Control of Asbestos Regulations 2006 Reg. - - For anyone involved with ACMs in the workplace or in connection with their work 2 A Short Guide to Managing Asbestos in Premises ( 5 for pack of 10) INDG 223 (rev 3) Free booklet for potential duty holders 3 A Comprehensive Guide to Managing Asbestos in Premises Guide HSG HSE guidance for those who have a duty to manage the risks from ACMs in premises ( 12.50) Designed for complex organisations or those responsible for older buildings likely to contain substantial quantities of asbestos and who need more guidance than that contained in A Short Guide to Managing Asbestos in Premises. 4 The Management of asbestos in non-domestic premises (Regulation 4 of the Control of Asbestos Regulations 2006) ( 9.50) 5 MDHS100: Surveying, sampling and assessment of asbestos containing materials. ( 18.00) ACOP L Guide MDHS X The guide addresses the main factors that determine the risk presented by ACMs; notes the immediate steps to be taken to prevent exposure and indicates how to develop a longer-term strategy and management plan. In addition, there are appendices on planning surveys, survey reports, material assessment and algorithms, worked examples of priority assessments, management options and the selection and management of asbestos contractors and analytical laboratories. Publication provides advice on how to comply with the duty in Regulation 4 of the Control of Asbestos Regulations 2006 to manage asbestos in non-domestic premises. It contains the duties of building owners, tenants and anyone else with legal responsibilities for premises. Sets out how to survey workplace premises for ACM s, how to recognise and sample suspected ACMs and how to record the results properly. March
54 ITEM TITLE TYPE HSE Ref ISBN CONTENT/AUDIENCE 6 Workplace (Health & Safety and Welfare) Regulations Work with materials containing asbestos: Control of Asbestos Regulations Introduction to asbestos essentials: Comprehensive guidance on working with asbestos in the building maintenance and allied trades ( 12.50) 9 Asbestos Essentials Task Manual. ( 8.50) Reg S1 1992/30 04 ISBN ACOP L Guide HSG X Guide HSG Indicates the duties to maintain buildings/premises to protect occupants and workers This Approved Code of Practice applies to all work with asbestos and explains the requirements of the Control of Asbestos Regulations The book applies in particular to work on, or which disturbs or is liable to disturb, materials containing asbestos, asbestos sampling and laboratory analysis. It is particularly relevant to those who are responsible for the maintenance and repair of non-domestic premises where asbestos containing materials are or are likely to be present. For anyone who is liable to control or carry out maintenance work with ACMs that does not require an HSE license. Contains information on where you are most likely to find asbestos and on appropriate protection methods. Includes photographs of typical ACMs, a drawing of a building, indicating typical locations for the most common ACMs, decision flow charts and advice on waste-handling and the wearing of correct PPE. (See also Asbestos Essentials Task Manual below) Supplements Introduction to asbestos essentials. Particularly useful for workers who occasionally need to carry out minor works to ACMs. Contains task sheets giving detailed practical advice on 25 specific work activities as well as 8 guidance sheets on sundry associated issues, such as use of equipment and personal protection measures. 10 Construction, Design and Management Regulations 2007 Reg SI 2007/320 - Regulations detailing the requirements to be undertaken during the design, construction, use and demolition of buildings. Legal obligations are placed on clients, designers, planning supervisors, principal contractors, sub-contractors, employers and the selfemployed. March
55 11 Health & Safety at Work etc Act 1974 Act - ISBN Main enabling Act of Health & Safety legislation 12 Management of Health & Safety at Work Regulations 1999 Approved Code of Practice and Guidance L21 Reg HSE Books 2000 ISBN Requires employers and self-employed persons to make an assessment of the risks to the health & safety of themselves, employees or third parties Document prices quoted correct at time of Policy issue. March
56 Managing Asbestos in Buildings Policy ORGANISATIONS PROVIDING ASBESTOS RELATED ADVICE Please refer to Chart 1 (Executive Summary) for contact names and telephone numbers for Plymouth City Council s Officers responsible for the delivery of asbestos related service and/or advice. PIC Support Network Asset Management Web-Site: HSE Asbestos Website Tel: Website: HSE Books HSE priced and free publications are available from: HSE Books PO Box 1999 Sudbury Suffolk CO10 2WA Tel: Fax: Asbestos Control and Abatement Division (ACAD) TICA House Yarm Road Business Park Darlington County Durham DL1 4QB Tel: Asbestos Removal Contractors Association (ARCA) ARCA House 237 Branston Road Burton-On-Trent Staffordshite DE14 3BT Tel: March
57 Asbestos Testing and Consultancy (ATAC) ARCA House 237 Branston Road Burton-On-Trent Staffordshire DE14 3BT Tel: British Institute of Occupational Hygienists (BIOH) Suite 2, Georgian House Great Northern Road Derby DE1 1LT Tel: Institute of Occupational Medicine (IOM) 8 Roxburgh Place Edinburgh Scotland EH8 9SU Tel: United Kingdom Accreditation Service (UKAS) High Street Feltham Middlesex TW13 4UN Tel: Health & Safety Laboratory Broad Lane Sheffield South Yorkshire S3 7HQ Tel: March
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