CONSULTANCY SERVICES

Auditing of Asbestos Removal/Surveying Projects

All companies engaged to carry out asbestos removal and/or remediation projects should be assessed for competency. Holding a license granted by the HSE is not necessarily a guarantee of top quality performance. A fairly straight forward audit of the company engaged can be carried out at the head office of said company to assess initial managerial competency. This should then be followed up by on-site practical audits of the asbestos operatives as the project progresses.

Choosing contractors working with any asbestos product should follow the same principles as choosing contractors generally. A contractor provisionally chosen may be discussed with HSE. A thorough check should be made on the competence of contractors including those licensed by the HSE before an order/contract is placed with them. The fact that a contractor is licensed by HSE for asbestos work is never by itself a guarantee of their competence.

ARL also offer a tender vetting service for all asbestos remediation projects where tender documents are reviewed with the clients purchase team prior to contract being let. After contractor selection a pre-work site meeting should be held between contractor, ARL and the client to discuss and agree all aspects of asbestos management and associated supervision and air/personal monitoring. The outline of clients’ requirements plus the supply of asbestos survey report shall have been part of documentation supplied at pre-tender stage.

It is recommended that any company selected to carry out asbestos surveys or simple sampling exercises holds UKAS accreditation for such undertakings. To gain UKAS accreditation, companies are obliged to carry out mandatory in-house audits (including re-visits) of surveys and surveying staff, however, confidence in the performance of the surveying company can be improved by having occasional independent audits carried out.

Guidance on Current Asbestos Regulations

The myriad of legislation, regulations, approved codes of practices and guidance notes covering all aspects of asbestos related matters can sometimes lead to confusion as to which government publication applies to which situation. Matters are often further complicated by the publication of updates, revisions and new documentation and the withdrawal of others.

ARL are pleased to offer guidance on these issues.

Auditing Performance of Air Monitoring Labs

It is obligatory that all companies that carry out air monitoring services hold UKAS accreditation for the services offered. As with UKAS accreditation for asbestos surveying, such companies are obliged to carry out in-house audits. Again, confidence in the performance of the company can be improved by having occasional independent audits carried out.

Such audits will ensure that the selected on-site analyst performs to acceptable standards and to his companies UKAS procedures.

Generation of Corporate Asbestos Policies

Many companies have adopted documented corporate asbestos policies.

The objective of such a policy is to prevent exposure to asbestos, or to reduce such exposure to asbestos to a level which is the lowest that is reasonably practicable. 
Generically these policies provide:

• Guidance on a system of management to identify and record the location of asbestos, audit its condition annually and decide what action to take.

• Guidance on the employment of licensed competent contractors for work on asbestos insulation, sprayed coatings and asbestos insulation board.

• Guidance on control standards required for permitted work.

• Guidance on Decision Making for Asbestos Management.

ASBESTOS SURVEYS, PRIORITY ASSESSMENTS & SAMPLING          

SURVEYS

ARL hold UKAS accreditation for Type 1, Type 2 and Type 3 Asbestos Surveys.

A building survey should identify the type and location of asbestos materials. It should also reveal the condition of the asbestos and therefore allow a decision to be made as to whether further treatment is required.

One of the most important considerations has to be that asbestos can occur almost anywhere in a building and the survey must look at the building as a whole, as opposed to just those areas where asbestos is likely to occur.

Surveys can vary widely in their size and complexity, for example from a small boiler house which contains asbestos lagging, to a hospital or school which may contain a number of different types of asbestos in different locations (probably all in different conditions).

In general there are three types of survey that can be undertaken. The purpose of the survey is to locate any suspect material, and assess the risk.  Where there is doubt about any material, it should be presumed to be asbestos until proved otherwise.

The success and usefulness of a survey will depend on the specification and planning carried out beforehand, and the training, experience and diligence of the surveyor.  When an area is not or cannot be inspected, this must be recorded and presumed to contain asbestos until it can be proven otherwise.

An experienced surveyor should have a good understanding of which materials are likely to contain asbestos and where they may be located.  He / she may be able to discriminate between potential asbestos and non-asbestos materials in situ, by a combination of visual and other senses.  This initial judgement will be tested by sampling and analysis in a type 2 survey but previous experience is used to make a presumption in a type 1 survey (see below).

There are three types of survey referred to in HSE’s MDHS 100 document.

Type 1: Location and Assessment Survey (Presumptive Survey)

The purpose of this type of survey is to inspect any likely locations where suspect material may be.  Depending on the age of the building, general condition, records and previous refurbishment work, it is possible to gain an idea of places where asbestos may be located.

All areas should be inspected and the findings assessed for likely risk. Even inaccessible areas such as ducts, lift shafts, above false ceilings, and so on, should be inspected. Where materials cannot be inspected, then these should be presumed to contain asbestos. This thorough inspection defers the need to sample and analyse until a later date.

Once the survey is completed a management plan can be developed. A notable drawback with Type 1 surveys is the probability that non-asbestos containing materials will have to be included in the asbestos management plan. This will increase the time spent and cost in the management of such materials and can be a false economy.

Type 2: Standard Sampling, Identification and Assessment Survey (Sampling Survey)

The purpose and procedures used in this survey are the same as for Type 1 above, but this goes further in that representative samples are gathered, analysed, and the findings risk assessed. Sampling may take place simultaneously with the survey, or as in the case of some larger surveys, sampling can be carried out as a separate exercise once the Type 1 survey has been completed.

This type of survey is the one most often conducted as suspect materials are definitively identified and non-asbestos containing materials are not included on the asbestos register or incorporated into the asbestos management plan.

Type 3: Full Access Sampling and Identification Survey
(Pre-demolition/Major Refurbishment Surveys)

This type of survey is used to locate and describe, as far as reasonably practicable, all asbestos containing materials in the building and involves destructive techniques to gain access to all areas. The purpose of this survey is to locate any asbestos in areas that may be uncovered / disturbed during refurbishment or demolition. The type of action that could be necessary is the removing of wall panels, taking up floorboards, etc.

This survey is designed to be used as a basis for tendering for the removal of asbestos from the building prior to demolition or major refurbishment. The survey does not assess the condition of the asbestos other than note areas of damage or where additional asbestos debris may be present.

Combination Surveys

A survey could be a combination of all the three types, e.g. in a series of similar properties, one or two could be subjected to a type 3 survey, 20% say to a type 2 survey, and on the basis of the findings, the remaining properties may only require a type 1 survey.

PRIORITY ASSESSMENTS:

ARL hold UKAS accreditation for Priority Assessments.

Under Regulation 4 of the Control of Asbestos Regulations 2006, the duty holder has to prepare a plan which not only details where the asbestos containing materials are located, but also specifies the measures to be taken to manage and control the risk (management plan). This requires a risk assessment to determine the priority and appropriate course of action for any asbestos containing materials that require control or remedial work.

Priority assessments in accordance with Methods for the Determination of Hazardous Substances (MDHS) 100 are routinely carried out by ARL.

SAMPLING EXERCISES:

ARLs UKAS accreditation for Asbestos Surveys covers the sampling of suspected asbestos containing materials.

Due to the extensive use of asbestos containing materials, sampling is usually the only effective way to identify the type of any asbestos present. Decisions on how a suspected asbestos containing material can treated should not be taken without knowing exactly what the suspect material contains. ARL use fully trained demonstrably competent personnel to safely sample the material. The sample is then analysed by an independent UKAS accredited laboratory. A short letter report giving the findings of the exercise (including photographs) and recommendations is then generated along with the independent analysis report.

ASBESTOS MANAGEMENT

GENERATION OF ASBESTOS MANAGEMENT PLANS

Regulation 4 of the Control of Asbestos Regulations 2006, the duty holder etc still to be modified, the duty holder has to prepare a plan which not only details where the asbestos containing materials are located, but also specifies the measures to be taken to manage and control the risk (management plan). This requires a risk assessment to determine the priority and appropriate course of action for any asbestos containing materials that require control or remedial work.

ARL can assist duty holders to comply with this regulation by offering guidance on what an asbestos management plan should contain, or by generating complete asbestos management plans.

ASBESTOS CONTAINING MATERAL INSPECTION

All asbestos containing materials located during surveys are added to the asbestos management plan for the building surveyed. All inspections are then to be carried out by a demonstrably competent person and all such inspections are to be recorded.

As any change in the condition of an asbestos containing material will mean that the risk presented by the material has increased, the risk and hazard bandings will need reviewing and the management strategy altered accordingly.

ARL surveyors carry out re inspection and condition monitoring visits throughout the UK.

REPAIR AND ENCAPSULATION GUIDANCE

Damaged asbestos contain materials are often deemed to present high risks and require urgent attention to reduce this risk. If such materials are to be left in place they must be repaired by thoroughly competent persons as soon as the risk comes to light (or as soon as is reasonably practicable).

Where asbestos containing materials are bare and/or unsealed, the risk and hazard presented by the material can be reduced by encapsulation or enclosure. This course of action will prevent the casual release of asbestos fibres.

Guidance on the best and most economic methods for the repair and encapsulation can be readily supplied by ARLs Consultancy.

REMEDIATION OF CONTAMINATED LAND

Research by the Institute of Occupational Medicine has shown that there are levels of asbestos contamination in soils which could constitute a potential risk to health in the event of the soils being disturbed.  The same research recommended that an action level of 0.001% by weight of asbestos in soil should be adopted.

It is recommended that soils containing more than 0.001% asbestos is regarded as being capable of generating airborne concentrations in excess of 0.1 f/ml and that precautions to protect the workforce by wetting the soil, providing respiratory protection etc., are taken. 

Further guidance can be found in the ICRCL Document Guidance Note 64/85 (Second Edition). The Interdepartmental Committee on the Redevelopment of Contaminated Land issued this document under the title of “Asbestos on contaminated sites” in October 1990.

ICRCL 64/85 has been superseded by a document entitled “Model Procedures for the Management of Land Contamination” which is over 200 pages long. It can be viewed at www.environment-agency.gov.uk.

ASBESTOS IN DOMESTIC PREMISES

Well over 3000 building products are known to contain asbestos, many of which have been used in the construction of domestic premises.
 
Some of these products are easily recognisable.
Asbestos cement products are often found as corrugated and flat sheet roofing, roof tiles, gutters, rainwater pipes, water tanks in lofts, coal bunker lids, window sills, boiler flue pipes, soffits and fascias.
Lesser known examples of asbestos containing materials which can be found in domestic premises include “artex” type textured coatings, reinforced plastic toilet cisterns, damp proof courses, acoustic pads under metal sinks and draining boards, roofing felts, cavity and loft insulation products, partition walls, bath panels, ceiling tiles, floor tiles and paper backed linoleums.

Although asbestos was essentially banned in November 1999 and many manufacturing companies stopped using asbestos in the early 80s, along with the building products mentioned above there is a bewildering range of domestic consumable products containing asbestos that may well still be in day to day use. Some examples are given below:
Bakelite products, brake pads and clutch linings to motor vehicles, flower pots and planters, GPO distribution pillars, louvre blades, extraction fan blades, wall plugging compounds, coffee pots, toasters, irons and ironing board covers, hair dryers, electric blankets and vermiculite containing garden products.

A surprising fact is that natural Soapstone is sometimes mined in areas where veins of Tremolite exist. Soapstone is used in the manufacture of Talcum Powder. Talcum Powder is used in baby powder, cosmetics and feminine hygiene products. Fibrous Tremolite is an uncommon asbestos type. During mining processes, Soapstone has been known to be contaminated with Tremolite.

In the past, based on epidemiological evidence, the International Agency for Research on Cancer (USA) classified talc contaminated with asbestos as carcinogenic!

If any doubt exists on whether a product or material contains asbestos or not, it must be assumed that it does until proven otherwise. Get professional expert advice from ARL.