Managing Asbestos Policy

Managing Asbestos Policy Liverpool Mutual Homes Page 1 of 16

Table of Contents 1. MANAGEMENT INFORMATION 2. POLICY STATEMENT 3. POLICY AIMS AND KEY OBJECTIVES 4. INTRODUCTION 5. DETAIL 6. LINKS TO LMH CORPORATE PLAN 7. IMPACT ON LMH FOCUSES 8. CUSTOMER SERVICE STANDARDS 9. PERFORMANCE MANAGEMENT 10. CUSTOMER SATISFACTION 11. CUSTOMER INVOLVEMENT 12. EQUALITY ANALYSIS 13. RISK MANAGEMENT 14. VALUE FOR MONEY 15. POLICY REVIEW AND IMPROVEMENT FRAMEWORK Liverpool Mutual Homes Page 2 of 16

1. MANAGEMENT INFORMATION Date Policy approved by LMH Board Replacing / Updating Updating Next Review Date August 2015 Drafted By: Responsible Executive Director and Board Champion Circulation list Michael Vickers Maggi Howard Available to all LMH staff electronically Available on LMH web site Liverpool Mutual Homes Page 3 of 16

2. POLICY STATEMENT LMH are committed to providing excellent customer services that represent value for money to our customers and partners. This policy is designed to provide a clear acknowledgement of the responsibilities that LMH has in relation to the management of asbestos and its approach to the management of asbestos within the properties it manages. 3. POLICY AIMS AND KEY OBJECTIVES The aims and objectives of this policy are summarised as follows: provides clear lines of responsibility within LMH for the management of asbestos specifies individual responsibilities in the management of asbestos provides a commitment to communication with customers regarding asbestos clarifies the LMH approach to surveying properties provides clear timetable and process for the review of the AMP, Policy and procedures establishes the Compliance Review Group which will review and monitor all areas of compliance within the directorate 4. INTRODUCTION LMH acknowledges and accepts its responsibilities under the Health and Safety at Work Etc. Act 1974, and the Control of Asbestos Regulations (CAR) 2012 to identify and to safely manage Asbestos Containing Materials (ACMs) on its premises. Approved Codes of Practice and guidance information published by the Health and Safety Commission and Executive shall be taken as the adopted standard. It is not a requirement of regulations for employers or persons responsible for health and welfare (of workers, employees, contractors, visitors, third parties likely to become affected by his undertakings), to remove all asbestos when identified. However, by the use of risk management they must manage ACMs via reasonable practicable means to prevent exposure to asbestos fibres and thus comply with the regulations. It is therefore NOT always essential to remove all asbestos-containing materials but to manage them safely, unless it becomes a risk for them to remain in-situ. In order to manage and control the risks from ACMs to employees, occupants, contractors and others, the measures within this policy will be adopted. Liverpool Mutual Homes Page 4 of 16

5. DETAIL 5.1. Introduction. Asbestos fibres have many properties which made them useful: good tensile strength, flexibility, chemical resistance, heat resistance, thermal and electrical insulation. Consequently asbestos has been widely used in many building materials especially between the period of 1930 s 1980 s. The main types of asbestos employed in building products in the U.K. were: Crocidolite, Amosite and Chrysotile. Crocidolite and Amosite were legally banned from use in the U.K. in 1985 with the last, Chrysotile, being banned in 1999. Therefore, all properties built before the year 2000 which have not undergone recent major refurbishment may hold Asbestos-Containing Materials (ACMs) of some description. (Further information on uses and applications of ACMs is contained in Appendix 1). The presence of ACMs in a building does not in itself present a risk as long as they remain in good condition and undisturbed. The UK Heath & Safety Executive (HSE) guidance is that ACMs in good condition are best left and managed in-situ rather than removed. The risk posed to health from asbestos occurs when the fibres are released into the air and breathed-in. Therefore, provided that ACMs are intact, and in a position where they will not be damaged they will not pose a risk to health. This policy document lays down the procedures to be employed by LMH, including its managers at all levels, maintenance staff, internal works operatives (HMS and resident caretakers/handy persons), staff and contractors, by which ACMs may remain in-situ within its properties by effectively managing the risks associated with them. 5.2. Management and Hierarchy of Control. To ensure that the asbestos Policy, Management Plan and Procedures are adhered to, suitably experienced and senior personnel within LMH will be nominated to act as a Responsible Person to oversee their effective implementation and review on behalf of the individual Duty Holder. 5.3. Management of Asbestos in Buildings. 5.3.1. Management Responsibilities. The duties as set out in Regulation 4 of The CAR 2012 Regulations will rest with the person in control of the premises and maintenance activities in the non-domestic premises and to those common areas (non-domestic areas) of properties providing rented or leased accommodation. Liverpool Mutual Homes Page 5 of 16

Effectively managing the risks from ACMs identified within properties in the LMH portfolio necessitates specific responsibilities being placed on a number of people. LMH has identified a specific manager, the Senior Maintenance Manager, who is most appropriate to act as the Duty Holder regarding the properties for which they hold responsibility. Effectively, the ultimate responsibility for the compliance regime will be held by the person retaining this post. Appropriate resources and systems will be required to execute this task robustly. In terms of the individual Duty Holders and their property portfolio, the responsibility for the implementation of this Policy, the associated Asbestos Management Plan and the supporting Procedures, will rest with selected members of the senior management team to act as appointed Responsible Persons in the management of ACMs. Those personnel within the LMH senior management structure, and their associated responsibilities in managing ACMs are given below: 5.3.1.1. The Chief Executive of Liverpool Mutual Homes. Although the registered provider has an appointed Duty Holder, the LMH Chief Executive shall be ultimately responsible for ensuring compliance with current legislation and to ensure that LMH fulfils their duties and responsibilities as laid out in this document (and the Asbestos Management Plan). Associated tasks are as follows: (i) Reviewing and endorsing the Policies, Procedures and Guidance document produced for Liverpool Mutual Homes. (ii) Ensure that the Duty Holder understands and has the necessary training and resources to fulfil their duties in this role. (iii) At reasonable intervals, review with the individual Duty Holders and the appointed Responsible Persons, the implementation, observance and performance of this document and of the LMH Asbestos Management Plan. This task may in part be practically implemented via the Compliance Steering Group (CSG). 5.3.1.2. The Appointed Duty Holder for LMH. Liverpool Mutual Homes Page 6 of 16

The named manager, acting as the nominated Duty Holder, shall hold responsibility for the implementation of this Poly, the Management Plan, and detailed Procedures for LMH. In addition they shall ensure suitable resources and arrangements are in place for: (i) Setting and endorsing the policy for ACM management and developing procedures for effective implementation. (ii) Ensuring that asbestos surveys are undertaken for all noncommercial properties, the common areas to properties providing rented or leased accommodation and other buildings in which LMH employees, managers and staff work (including HMS and resident caretakers/handy persons). This information must be accessible to the relevant persons, i.e. senior managers and staff of LMH and HMS. (iii) Ensuring that asbestos surveys are undertaken for properties providing domestic accommodation on a priority basis e.g. those timetabled for remedial work shall be scheduled first, together with priority 1 properties, until such time that all properties have been surveyed. (iv) Ensuring the maintenance of the LMH asbestos survey register database. (v) Ensuring that appropriate staff are available, and have been suitably trained, to provide advice and information on ACMs to persons who have an appropriate interest or connection. This shall also include ensuring that suitably trained staff are available to conduct specific inspections on site, whether these staff are employed directly by LMH or from the appointed asbestos consultant. (vi) Providing sufficient resources for staff and management in order for them to execute their duties and responsibilities in accordance with the CAR 2012. (vii) Appointing a Responsible Person(s) to undertake local management of ACMs on their behalf, if this duty is not to be personally undertaken. (viii) Ensuring that the Responsible Person(s) understand and have the necessary training and resources to fulfil their duties in this role; (viii) At reasonable intervals, review the implementation of the both this document and of the corporate Asbestos Management Plan Liverpool Mutual Homes Page 7 of 16

(minimum 12 monthly). This may be practically undertaken via the Compliance Steering Group (CSG). 5.3.1.3. Senior managers acting as appointed Responsible Persons. The senior managers identified shall ensure suitable arrangements are in place for implementing the procedures contained within this document and the Management Plan. In particular this shall include: (i) Acting as a Responsible Person to undertake local management of ACMs on behalf of the Duty Holder as required. (ii) Ensuring any person undertaking work which may disturb ACMs has first examined and understood the LMH asbestos register system entry and is aware of their responsibility to avoid disturbing the material and, that they have undergone training in accordance with CAR 2012: Regulation 10 Information, Instruction and Training. (iii) Ensuring regular and routine re-inspections of ACMs identified in the LMH asbestos register system are undertaken at a frequency commensurate with the level of risk that these materials present (LMH re-inspection protocol). (iv) Informing and/or seeking advice from the appointed asbestos consultants regarding any amendments considered necessary to the LMH asbestos register system or survey information. (v) Seeking advice from appointed asbestos consultants in situations where the asbestos survey information is not sufficiently detailed or further advice/reassurance is required. (vi) Ensuring that the area adjacent to any ACMs or suspected ACMs is not contaminated, if they have been disturbed or damaged and seeking advice from the appointed asbestos consultants. (vii) Appointing Licensed Contractors (ARCA) for the removal of ACMs as found necessary to individual properties. (viii) To directly oversee, or appoint a competent body to audit asbestos removal works to ensure that they are completed to a satisfactory standard. (ix) To appoint a suitably accredited independent analyst (laboratory) to undertake visual inspections and air testing to ensure that an area is safe for re-occupation upon completion of the works. Air testing may be undertaken during removal works, but it will most likely to be required at Liverpool Mutual Homes Page 8 of 16

the end of any such works. Preferably, this role is to be conducted by the appointed/retained asbestos consultants. (x) To ensure that all relevant parties are informed as to the presence of any identified or presumed ACMs within the property for which they are responsible so that they may act accordingly. (xi) To act as contact in the case of any emergency in relation to asbestos for the property for which they are responsible. 5.3.1.4. Project Managers, Housing Officers, Housing and Property Staff. Project Managers, Housing Officers, Housing and Property Staff, or any others responsible for organising works in buildings which may affect the fabric of the structure, or equipment within it, and having regard to the possibility of disturbing ACMs. In particular they should: (i) Consider at the initial outset of the project the possibility of disturbing ACMs. (ii) Pass on information in regards to ACMs that are relevant to a property to a person in residence in conjunction with the associated level of risk that they pose (and associated dos and dont s ). 5.3.1.5. Staff, internal works operatives, and Visiting Contractors. (i) Observe and implement the requirements of this Policy, the Asbestos Management Plan and related Procedures, and to assist in their implementation and maintenance. (ii) Co-operate with the Duty Holders and Responsible Persons in fulfilling their duties to manage asbestos. (iii) Visiting contractors, or internal works operatives (HMS), to fully observe their own obligations under current legislation and prevailing guidance. 5.4. Asbestos Surveys and Re-inspections. The first step in managing the risk from ACMs is to undertake a suitable and sufficient assessment as to the presence of ACMs, their location, asbestos fibre content, product type, and condition (i.e. a Material Assessment) together with an assessment of the risk of that material to cause harm based Liverpool Mutual Homes Page 9 of 16

on accessibility and the activities carried out in the area around the ACM (i.e. a Priority Assessment). All non-domestic properties (such as shops and offices etc.) and common areas to properties providing rented or leased accommodation inclusive of risers, storage areas etc. are the responsibility of the property Duty Holder and thus any ACMs present must be identified and appropriately managed under CAR 2012. The assessment for the presence of ACMs shall typically be in the form of an asbestos survey. The results from these surveys are currently held upon the LMH asbestos register remotely hosted by the retained surveying consultancy undertaking the surveys. The asbestos register/database system shall be accessed by ALL maintenance staff, and contractors prior to the commencement of any maintenance works on a property in order to check for, and to identify the presence of ACMs. The results of any such check shall be taken into consideration when planning and carrying out their works. This will be appropriately recorded for review. Re-inspections of identified ACMs will be carried out at regular intervals as directed by the relevant Responsible Person and in compliance with the LMH re-inspection protocol (as set out in the LMH Management Plan). The frequency of re-inspections shall be determined from the potential risk that a material may pose, represented by the Risk Code assigned to that material which shall be the combined scores from both the Material & Priority assessments. Irrespective, all materials within communal (non-domestic) areas will be reinspected annually. For domestic areas, materials which are assigned the Risk Code of A shall be inspected every 3 months (until removed/encapsulated). Materials which are assigned the Risk Code of B or C shall be inspected annually. Those materials assigned the Risk Codes of D & E shall be re-inspected at least every 5 years. Asbestos surveys and re-inspections shall address the following possible management recommendations: Leave In-Situ (in good condition) and Manage, Seal, Encapsulate (minor damage) Repair and Manage, and Remove (higher risk and in poor condition) and Dispose. Liverpool Mutual Homes Page 10 of 16

Prioritisation of Surveys. Initially a percentage of accommodation and communal areas, sufficient to be representative of the various property types, shall have their ACM content assessed. This shall be done to provide an sufficient level of information so that the Duty Holder has confidence to identify all typical ACMs that maybe present within any given property type within their portfolio. It is the ultimate goal of the LMH to have all appropriate properties (i.e. those constructed prior to 2000) to be surveyed by the end of 2015. To ensure a structured approach is employed in carrying out asbestos surveys LMH shall initially carry out a desk-top review of all currently nonsurveyed properties. Each property shall then be placed in one of three levels of priority for having a survey conducted: Priority 1, Priority 2 and Priority 3. Those properties within the Priority 1 rating being surveyed first. The criteria that shall be used for assigning the level of priority shall be: age of the property, past knowledge/experience in managing the property, planned maintenance works and the best information available at the time in regards to the presence of ACMs to that type of property. 5.5. Accessing and Maintaining Asbestos Survey Information. At the time of issuing this document the asbestos surveys are held for LMH on the Apec Environmental Ltd, Asbestos Survey Database system (access via secure password at: http://www.apecuk.org). Maintenance work will only be awarded to/conducted by those contractors held on the LMH list of Approved Contractors or internal works operatives (HMS and resident caretakers/handy persons). Therefore, these companies shall have experience of the requirements of LMH when working on their properties and full knowledge of the system employed by LMH in managing ACMs and in making such information available for their properties. LMH will contact all contractors employed to confirm their understanding of asbestos related regulation/guidance and application of their associated obligations (and training) annually. In the rare event where works are required to be carried out by specialist contractors not included on the approved contractor list, this work will be subject to control via a issue of the asbestos register of ACMs identified or presumed to be present (extracted from the LMH asbestos register system) and by ensuring that the contractor (and their individual operatives employed) has undergone suitable asbestos awareness training within the last 12 months. Liverpool Mutual Homes Page 11 of 16

The LMH asbestos register database shall be updated following any asbestos removal works and following completion of re-inspections by those qualified/appointed to undertake them. Where building or engineering works are planned or due to be undertaken in properties, sufficient time must be given to the project to ensure any measures necessary as a result of the presence of asbestos in the property are properly allowed for. Thus, the presence of ACMs shall form part of any project meetings as shall the requirement to incorporate any notification period etc. required by the HSE for the removal of licensable materials from the property. Project managers, planners, designers and architects must therefore, have access to and understand the asbestos survey report and ensure that a report is in place prior to commencing their work. Contractors appointed to undertake remedial work or removal of asbestos containing materials shall be competent and listed on LMH s list of Approved Contractors. They shall hold a Licence issued by the Health and Safety Executive and be members of an appropriate trade association such as: ARCA the Asbestos Contractors Removal Association or TICA the Thermal Insulation Contractors Association. LMH currently employs Apec Environmental Limited as its strategic asbestos consultant who can be contacted to answer any questions and give advice to staff regarding asbestos matters as required. 5.6. Communication LMH is committed to communication with its staff, customers and partners about asbestos and how it is managed in the properties managed by LMH. The two key elements of this will be how we communicate with customers and provide support and training to staff. The implementation of this policy will include both communication and training strategies to deliver on this commitment. 5.7. Monitoring and Review. The relevant Responsible Person shall ensure that the LMH asbestos register is maintained in regards to all asbestos survey and removal Information held or commissioned for LMH properties. The relevant Responsible Person will monitor and review arrangements for asbestos management to premises during visits in the course of their work. Liverpool Mutual Homes Page 12 of 16

The relevant Responsible Person shall investigate and review the cause of any incidence (or near-miss ) involving the accidental damage of ACMs. The investigation shall identify the cause, review work procedures and those procedures set out in this document and the Management Plan to prevent a reoccurrence of that, or a similar incident. Such incidents will also be reported to the Asbestos Steering Group for strategic review across all activity within LMH. 5.7.1. Policy Monitoring and Review. The Policydocument will be reviewed and amended as and when Legislation is revised, or as a minimum every 12 months to ensure that this document and the associated Management Plan and Procedures remain up to date. This review should also appropriately reflect any additional changes required as a result of actual experience, or case studies. Any review of this document shall be undertaken by the Group Chief Executive, the individual Duty Holders, the appointed Responsible Persons and the Asbestos Steering Group in conjunction with the appointed asbestos consultant where appropriate. 5.8. Reference Legislation, Approved Codes of Practice (ACoPs) and Guidance Documentation. The following documents have been identified as being significantly relevant to managing risks from asbestos containing materials, and further information on any document below can be obtained from directly from the HSE. 5.8.1. Legislation. o The Health and Safety at Work Act 1974. o Control of Asbestos Regulations (CAR) 2012. o The Management of Health & Safety at Work Regulations 1999. o Workplace (Health, Safety and Welfare) Regulations 1992. o Hazardous Waste Regulations 2005. o Construction (Design and Management) Regulations 2007. 5.8.2. Approved Codes of Practice (ACoP) (Health & Safety Commission). Liverpool Mutual Homes Page 13 of 16

o ACoP L127 Management of asbestos in non-domestic premises. o ACoP L143 - Work with materials containing asbestos. o MDHS100 Surveying, sampling and assessment of asbestos containing materials, holds ACoP status and was superseded in January 2010 by the following document, o HSG 264 Asbestos: The survey guide, holds ACoP status. 5.8.3. Guidance Documents (Health & Safety Executive). o HSG247 Asbestos: The licensed contractors guide. o HSG248 Asbestos: The analysts guide. o HSG189/2 Working with asbestos cement. o HSG213 Introduction to asbestos essentials (First Edition). o HSG210 Asbestos essentials task manual (Second Edition). o HSG33 Health and safety in roof work (First Edition). (Covers asbestos cement roof demolition). o HSG227 Comprehensive guide to managing asbestos in buildings. o EH51 Respiratory equipment for use in removing asbestos. 6. LINKS TO LMH CORPORATE PLAN This policy links to our Corporate Plan by aiming to: o Operate within an open and accountable environment; o Deliver excellent customer service; o Develop a full knowledge and awareness of customer needs. 7. IMPACT ON LMH FOCUSES Focus on Viability and Strength Maintain high standards of governance and compliance with legal and regulatory requirements; Control and manage all key risks through embedded and effective risk management approaches; Liverpool Mutual Homes Page 14 of 16

8. CUSTOMER SERVICE STANDARDS On approvals of the policy, a series of customer service standards will be developed and implemented in line with the detailed procedures and the policy will be updated with this during the initial 6 month review. 9. PERFORMANCE MANAGEMENT On approvals of the policy, the performance management standards and measures will be fully developed and implemented in line with the detailed procedures and the policy will be updated with this during the initial 6 month review. 10. CUSTOMER SATISFACTION Satisfaction with the delivery of any asbestos related works would be measured as part of the overall delivery of works and not directly with the policy. 11. CUSTOMER INVOLVEMENT The policy has been consulted on with customers through the Service Review Group, who were very supportive of the positive approach been taken in the management of asbestos. Following approval of the policy further consultation will be carried out on the related procedures, including our communication strategy. 12. EQUALITY ANALYSIS An equality analysis has been completed and no significant impacts have been identified that would be impacted by this policy. 13. RISK MANAGEMENT A risk assessment has been completed for the policy which highlights the risks associated with not effectively managing asbestos. The implementation of this policy will significantly reduce any asbestos associated risks to the organisation. 14. VALUE FOR MONEY A VFM assessment has been completed for the policy and the approach taken within the policy will ensure a positive external Liverpool Mutual Homes Page 15 of 16

assessment. 15. POLICY REVIEW AND IMPROVEMENT FRAMEWORK This policy has been reviewed in line with LMH Policy Review Framework. The next review will be completed in August 2015. In line with LMH continuous improvement strategy the policy review will incorporate an assessment of key internal and external influencers to ensure the policy reflects best practice together with all legal and statutory requirements. Liverpool Mutual Homes Page 16 of 16