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Asbestos Policy This document brings the Council’s existing policy on work with asbestos into line with the requirements of the control of asbestos at work regulations which were revised in 2002. All previous policy documents on asbestos are now replaced by this document. Staff involved with working with asbestos, supervising such work, or issuing contracts should fully familiarise themselves with the contents of this document. Comhairle Nan Eilean Siar’s policy on asbestos intends to ensure so far as it is reasonably practicable, the health, safety and welfare at work of its employees and others who may encounter or be exposed to asbestos. Comhairle Nan Eilean Siar’s policy on asbestos shall ensure that known and identified locations of asbestos are recorded and that any such asbestos information is made available to those persons who require it. Procedures for risk assessment of works involving a likelihood of encountering Asbestos are to be established together with arrangements and measures to ensure the management and control of existing asbestos is carried out in accordance with the Control of Asbestos at Work Regulations 2002. Directors and Heads of Service are responsible, so far as is reasonably practicable, for ensuring the health, safety and welfare at work of all employees in their respective departments. In particular they will:
Asbestos is a general name applied to a group of related, naturally occurring fibrous minerals, which have been commonly used in a range of building and equipment materials. There are three main types of asbestos:
In addition legal provision also covers the following:
And any mixture containing any of those minerals. Asbestos containing products have been widely used in buildings as construction materials, fireproofing, thermal insulation, electrical insulation, sound insulation, decorative plasters, roofing products, flooring products, heat resistant materials, gaskets, friction products etc. Since 1985 the new use of any material containing blue or brown asbestos has been banned. By 1999 the new use of any building materials containing white asbestos had been banned. All asbestos fibres, blue, brown and white are dangerous although the control limit for exposure to blue and brown fibres is lower than for white. There is no safe form of asbestos although products where the fibres are tightly bonded (e.g. asbestos cement) are less likely to shed fibres than products where the fibres are more loosely bonded (e.g. asbestos insulating board). The main route of entry to the body for asbestos is by inhalation of fibres. There is no safe exposure level known for asbestos and once asbestos related diseases occur there is no known cure. There are three main types of serious health risks associated with exposure to asbestos fibres: Asbestosis – chronic obstructive lung disease Lung cancer – a fatal lung disease Mesothelioma – a fatal cancer of the outer lining of the lung specific to asbestos exposure. Statistics indicate that despite legislative controls, deaths due directly to asbestos are at an all time high of approximately 3000 deaths per year and are predicted to peak at 10000 cases by 2020. It is recognised that the largest group of workers at risk from asbestos exposure are building workers, particularly those involved in repair and maintenance, refurbishment and demolition, including electricians, plumbers, joiners, computer and telecommunication engineers – people who may encounter asbestos during their normal day to day work activities. This policy is based on the following legislation and shall be amended in line with any changes.
6. The Control of Asbestos at Work Regulations These are substantial regulations incorporating an Approved Code of Practice and were last updated in 2002. They apply to everyone at risk from work with asbestos and extend statutory protection to all those who encounter asbestos at work or are affected by work activities involving it. Key features of the regulations are:
Other provisions include providing protective equipment, face fitting of respirators, keeping plant and equipment clean, providing information, training and necessary labelling. 7. The Asbestos Licensing Regulations These regulations prohibit anyone from carrying out work with asbestos insulation, asbestos coating or asbestos insulating board unless they hold a licence granted by the HSE (Health & Safety Executive). However there are three exceptions to the requirement to hold a licence. These are:
Licensed contractors must ensure that any staff working with asbestos are under medical surveillance, and that they give 14 days notice to HSE of any work that they intend to carry out. 8. The Asbestos Prohibition Regulations These regulations prohibit the supply and use of all forms of asbestos and asbestos containing products. The arrangements detailed consist of a series of procedures which are intended to safeguard persons who may encounter the possibility of discovering asbestos in the course of their work and to ensure the safety of any premises occupants who may be affected by any associated works which may involve the disturbance of asbestos containing materials. All reasonable practicable steps will be taken to ensure that Comhairle employees, tenants and contractors working on behalf of the Comhairle will not be exposed to hazards associated with materials containing materials. The Health and Safety Executive (HSE) publication MDHS 100 (surveying, sampling and assessment of asbestos containing materials) sets out how to survey workplace premises for asbestos containing materials and how to record the results in a usable form. There are three types of survey referred to in MDHS 100: Type 1 survey: Location and assessment survey (presumptive survey) The purpose of this survey is to locate, as far as is reasonably practicable, the presence and extent of any suspect asbestos containing materials and assess their condition. Type 2 survey: Standard sampling, identification and assessment survey (sampling survey). The purpose and procedures used in this survey are the same as for type 1 except that representative samples are taken and analysed for the presence of asbestos. Samples from each type of suspect Asbestos Containing Material found are collected and analysed to confirm or refute the surveyor’s judgement. If the material sampled is found to contain asbestos, other similar homogenous materials used in the same way in the building can be strongly presumed to contain asbestos. Type 3 survey: Full access sampling and identification survey (pre demolition/major refurbishment survey). This type of survey is used to locate as far as is reasonably practicable, all ACM in the building and may involve destructive inspection, as necessary to gain access to all areas, including those that may be difficult to reach. A full sampling programme is undertaken to identify possible ACM’s and estimates of the volume and surface area of ACM made. The survey is designed to be used as a basis for tendering the removal of ACM’s prior to demolition or major refurbishment, so the survey does not assess the condition of the asbestos, other than to note areas of damage or where additional asbestos debris may be expected to be present. A systematic programme of surveying all Comhairle owned non domestic properties will be undertaken by the Department of Technical Services. Surveys will be conducted strictly in accordance with a type 2 survey as defined in the HSE publication MDHS 100, by a trained and competent surveyor and will inspect all areas of the building. If any areas are not accessible they must be presumed to contain Asbestos. Data will be recorded on site by the surveyor onto an asbestos inspection pro forma sheet. 11. Bulk Sampling and Analysis Representative bulk samples shall be taken to confirm or refute the presence of asbestos containing materials. Samples shall be taken when no occupants are present in the area or when the building is empty. Sampling will not be carried out where there is an electrical hazard or if it will damage the critical integrity of a roof, gutter pipe etc. After sampling any friable or broken material will be sealed whilst the samples shall be double sealed in polythene bags. Analysis for the identification of asbestos fibres in bulk samples will be undertaken by a laboratory in accordance with the HSE publication MDHS 77. In addition the laboratory shall be accredited by the United Kingdom Accreditation Service (UKAS). Data collected on site will be input by the Technical Services Building Maintenance Clerk into the Asbestos Management Suite database. Data will include:
The condition of each asbestos element identified on site is assessed using the material assessment algorithm as defined in the HSE publication MDHS 100. The assessment will depend on four different parameters:
Each parameter is scored as high (3), medium (2), low (1) or very low (0). Presumed asbestos containing materials are scored as crocidolite (3) unless there is a reasonable argument that another type of asbestos was almost always used in that type of application. The priority assessment establishes the possible threat caused by human asbestos related activity. The assessment is based on four different headings: A) Occupant activity. B) Maintenance activity
C) Likelihood of disturbance
D) Human exposure potential
As with the material assessment each parameter is scored high (3), medium (2) low (1) or very low (0) The assessment score is calculated using the following formula Score = sum of material assessment. + Total of average priority assessment ( average of occupant activity )
( average of maintenance activity )
( average of likelihood of disturbance )
( average of human exposure potential ) The total score of material assessment and priority assessment gives the risk rating which is high , medium , low , or very low. This is used to determine the management actions necessary for ensuring safety.
16. Major Refurbishment / Pre Demolition Any officer with responsibility for issuing tenders for major refurbishment or demolition works will ensure that a type 3 survey as defined in the HSE publication MDHS 100 will be undertaken prior to any major refurbishment or demolition works. The survey results will be included in the pre design health and safety plan as required by the Construction Design Management Regulations 1994. All the information collected during the asbestos surveys will be recorded in the asbestos management database suite. This will be known as the Asbestos Register. The Asbestos Register will be maintained in the Technical Services repairs and maintenance offices in Stornoway and Balivanich. It is the responsibility of the Asbestos Manager to update the register as changes occur. A hard copy of the register will be issued to the responsible officer of each property on the register. Access to the Register will also be made available to head teachers, property managers, and contractors working on the property, via the Council’s intranet. The public utility services, the fire brigade and others whose presence may expose them to possible risk from asbestos will have access to the council asbestos register as appropriate. 18. Information for Contractors All officers with the responsibility for issuing works orders will ensure that prior to the works commencing the asbestos register is consulted and the existence of asbestos is brought to the attention of the contractors in writing, clearly identifying areas which are known/presumed to have asbestos containing materials. Where contractors arrive on site, they are under instructions to report their presence and identify the tasks that they are to carry out to the responsible property officer. At this point the Asbestos Register located on the premises must be checked to confirm or refute the information previously issued by the ordering officer. Should the contractors discover any variances to the information contained in the asbestos register, this must be reported to the Asbestos Manager to enable him to update the Register. 19. Asbestos Licensed Contractors A system of vetting and appointing suitable applicants for inclusion on the Council’s standing list of asbestos contractors is operated. Contractors carrying out work on behalf of the Council are subject to performance monitoring and recording. Only contractors who have been vetted and approved by Comhairle nan Eilean Siar shall be eligible to tender for asbestos work. Contractors shall be reviewed by the Technical Services Department every five years. The Technical Services Department shall ensure that prior to any asbestos removal works being undertaken, the appointed contractors provide all relevant documentation required for works with asbestos. This shall include:
Documentation required on completion of the removal works shall include:
20. Disposal of Asbestos Waste The Scottish Environmental Protection Agency require a minimum of three days notification prior to the disposal of asbestos containing materials. All asbestos containing material shall be disposed of by double wrapping in labelled 1000 gauge polythene sheeting or bags, and transported by a registered carrier to a landfill site licensed to receive asbestos waste - all in accordance with the Special Waste Regulations 1996. The disposal of asbestos material shall be the responsibility of the appointed contractor. As such, evidence of appropriate documentation for the consignment and disposal of asbestos waste shall be required prior to award of contract. All staff who may encounter asbestos during the course of their work shall be given the necessary training to be able to identify the situations in which asbestos may be present, to be able to recognise asbestos or similar suspect materials and to set out safe working practice to minimise risks to health and safety. Supplementary information will be provided on a periodic basis using information supplied from HSE publications and Croner or other proprietary information service. Persons in charge of buildings will be provided with appropriate training and information regarding accessing information from the Asbestos register. Induction training will be provided to all new staff The Comhairle Asbestos Manager or Health and Safety officer can be contacted for advice relative to materials thought to contain Asbestos. If during the course of normal work practice Asbestos containing material is encountered, the following procedures should be followed Stop any work, remove and keep all persons out of the area. Where practicable close or seal or lock off the area. Do not remove any equipment or material. Prepare and display a potential Asbestos hazard keep out sign to prevent persons from gaining access to the area. Inform the line manager who will report the discovery to the Asbestos Manager. The Asbestos Manager will notify the premises management and the Comhairle Health and Safety section. The Asbestos Manager will arrange for the property to be inspected and for any samples or air tests to be taken if required and will keep the premises management and the Health and Safety section advised. Following laboratory analysis the Asbestos Manager will advise the premises management and the Health and Safety section of the outcome and the proposed action. On completion of any repair or removal work the Asbestos Manager will advise the premises management and the Health and Safety section when the area has been made safe. The Asbestos Manager will ensure that all actions including areas where asbestos has been removed and analytical reports are included in the Asbestos register and copies forwarded to premises management and the Health and Safety section. List Of Relevant Statutes, Statutory Instruments, Approved Codes of Practice and Other Official Guidance
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